National Lifeline Association Discusses Lifeline and Emergency Broadband Benefit Programs with Rosenworcel's Staff

On October 4, 2021, the National Lifeline Association (NaLA) met with the Office of Acting Federal Communications Commission Chairwoman Rosenworcel to discuss the Lifeline Program and the Emergency Broadband Benefit (EBB) Program. The discussion focused on the Lifeline minimum service standards (MSS), getting the Lifeline program ready for the end of the EBB and certain Lifeline and EBB process improvements that should be made by the Universal Service Administrative Company (USAC). There is a looming December 1, 2021 deadline for another dramatic increase in the mobile broadband MSS. In her dissent to the 2019 MSS Waiver Order, then Commissioner Rosenworcel called a pause at 2 GB a “smart approach” because another arbitrary increase would do “nothing to provide the certainty we need for this program.” She went on to correctly foresee that “without pausing for review, the FCC will simply be back in the same place, wrestling with the same issues, and more of the same scheduled service adjustments at this time next year.” She was right. Unfortunately, the FCC’s majority did not listen and instead increased the mobile broadband MSS in 2019 to 3 GB, and then the FCC's Wireline Competition Bureau did the same thing in 2020 by increasing the MSS again to 4.5 GB. Acting Chairwoman Rosenworcel’s view that pausing the mobile broadband MSS would be a “smart approach” is as true today as it was in 2019. However, the FCC also needs to address the petitions for reconsideration of the 2016 Lifeline Modernization Order’s mobile broadband MSS formula that have been pending for five years. Further, the FCC should waive reimbursement reductions to restore the Lifeline voice reimbursement to $9.25 per month for which many Lifeline providers will offer unlimited or the equivalent of unlimited voice minutes (e.g., 3,000) to eligible low-income households. The FCC could also address these MSS issues more permanently by taking action on the NaLA Petition for Rulemaking filed on April 19, 2021.