Bringing Broadband to People with Low Incomes

Bringing Broadband to People with low Incomes

For years, the Lifeline program has provided qualified consumers with a discount on monthly charges for their primary home phone line, even if it's a cell phone. And the Link-Up program has lowered the cost eligible consumers pay for setting up new phone service at their home, including cell phone service. Now, with broadband becoming increasing essential to communications, the Federal Communications Commission is asking if these programs should be modernized to subsidize Internet connections and devices. On July 15, Benton Foundation, the Office of Communication, Inc. for the United Church of Christ, Access Humboldt, and Center for Rural Strategies filed comments with the FCC how best to approach this modernization.

Background
Until now, the Lifeline and Link-Up programs have correctly focused on connecting the very hardest to connect in our country. These programs have connected low-income consumers who have limited means. These are the consumers who have the potential to benefit the most from reliable access to communications. These programs help individuals compete for jobs. For example, when an individual applies for a job, a phone number is necessary to complete the application. Lifeline and Link-Up are programs that have given our most vulnerable populations voice access to employment, healthcare providers, emergency services and their community at large.

While a phone line is still a critical component, in today's world, broadband is now an essential piece of the communications puzzle. Broadband-enabled communications are reducing costs for employers, government agencies, universities and healthcare providers, but the unconnected may be left behind.

Cost is Biggest Barrier to Broadband Adoption
In February of 2010, the FCC identified cost as the greatest barrier to adoption of broadband . The Lifeline and Link-Up programs are, at their heart, attacking the barrier of cost for low-income consumers. For some, market efficiencies will never decrease costs enough to pay for the service on their own. These programs should always provide low-income consumers access to the necessary communications mediums of their day. It is for that reason that we strongly support the expansion of the LifeLine and Link-Up programs to allow for the subsidies to apply for both voice and broadband service.

Getting from here to there -- pilot projects
The development of a broadband component to the Lifeline and Link-Up programs is a complex endeavor and the FCC should employ pilot projects to identify the best path forward. As the FCC develops pilot programs, we suggested four principles to consider:

1. Technological Neutrality: While it would be ideal for every Lifeline or Link-Up participant to have access to fiber broadband capacity, it is important to seek out the most efficient medium for broadband connectivity. We urge the FCC to remain technology neutral and consider wireline, wireless, and other technology broadband choices.
2. Flexible Program Offerings: We also urge the FCC to allow for flexibility so that the program can take into consideration the special needs of the community it is trying to serve. For older populations, accessing the Internet through a cell-phone may be too small of a medium to easily use. For consumers in locations where wireline infrastructure development maybe too expensive, a wireless option may be the most efficient method to provide access. For the members of the disability community, the opportunity to choose the device impacts the benefits of the program to participants. For those consumers who choose a smartphone to access broadband and voice service, it is important for a pilot program to flesh out the potential benefits or pitfalls of such a service.
3. Evaluation and Publicly Accessible Data: A plan for the evaluation of every pilot program must be developed as the program itself is developed. Pilot programs developed by the FCC should clearly identify pitfalls and potential best practices. These evaluation plans must include a clear implementation timeline for the pilot program including when an evaluation will be completed. Additionally, it is critical that all evaluations and related data be released to the public so that independent researchers (from the private, public and academic sectors) can evaluate the pilot programs as well. Timely public release of this data and effective public access will help ensure that that the evaluation determinations are dependable and independently certified.

Portable Lifeline and Link-Up Support: While the transition to broadband support is yet to be realized, the FCC should consider making low income support for broadband services portable and less reliant on particular providers. The FCC should also extend universal service support funds to programs designed to support digital literacy, rather than creating a independent program. According to the FCC's own findings people who are not online require multiple types of assistance to get online, including, but not limited to, education, cost support, literacy skills, and relevancy of content.

The states' role in Lifeline and LinkUp
The Lifeline and Link-Up programs must adapt to best serve the low-income community. We fully support the expansion of the program to include group homes and homeless shelters. Consumers who are in domestic violence shelters, group living facilities, or in homeless shelters are among the most vulnerable members of the low-income community. For these persons, access to communications is a necessary tool to move towards self-sufficiency. We urge the FCC to reach out, to nonprofits and other organizations currently serving this community through roundtables or other public forums to explore a range of options and to identify best practices. With this input, the Lifeline and Link-Up programs could be best tailored to meet the needs of this population and designed to thwart fraud, waste and abuse. The FCC might also gain valuable insight and partners for improving outreach to let these consumers know about the benefits they are eligible for.

Conclusion
Ultimately, consumers that are eligible to participate in these programs have a limited capacity for repeat visits to government offices for social services. Access to voice or broadband means that consumers can more effectively communicate with government social services agencies. Considering that the target participants are usually without any communication access when they enter a government office, the Lifeline and Link-Up programs could help streamline administration of other social service programs offered within a given state.

In today's world, access to communications means at the very least, access to and links with health care, public safety, first responders, government, education and employment. As federal, state and local governments seek ways to tighten their budgets, face-to-face and paper services are likely to be replaced with more cost efficient online services. This means that for the unconnected, low-income citizens in our country, accessing government services will be more difficult if they aren't familiar with broadband services and don't have easy access.

To function effectively in today's society, voice access is a given. However, now it is clear that broadband access is also essential. Careful changes to program offerings, expansion to eligibility, the creation of a national eligibility baseline, and enhanced outreach will ensure that these programs are successful in their efforts to serve our most vulnerable citizens.