Below is NDIA’s response to paragraphs 129-141 of the FCC’s  Second Further Notice of Proposed Rulemaking (NPRM) on reform and modernization of the FCC’s Lifeline program. The full Comments includes supporting details in the appendices.

Community-based solutions for low-cost broadband service should be designated as providers of Lifeline broadband.

In the absence of low-cost commercial broadband service, community anchor institutions, nonprofit organizations and municipalities are creating local Internet access solutions. The Commission should take these community-based solutions into account as alternative solutions in its proposed modernization of Lifeline.

If the Commission were to develop an understanding of community-based broadband service programs, the Commission could develop mechanisms by which these alternatives to commercial service could qualify for support from the Lifeline program’s $9.25 monthly subscriber household subsidy. One possibility would be for the Commission to establish a non-ETC application, implementation and reporting process for community-based solutions of low-cost broadband service participate as providers of Lifeline broadband service. Community anchor institutions, schools, non-profit organizations and municipalities touch the lives of low-income populations every day, and those entities are frequently in the best position not only to educate potential applicants about the program but also to provide them service.

The methods in which community institutions assist low-income population are as diverse as the communities served. The community-based solutions range from direct provision of Internet service to partnering with providers. In between the two extremes is a lot of room for creativity and mixed solutions. The Lifeline Program should encourage local community-based solutions by clearly defining a structure for them to participate regardless of legal construct.  The Lifeline Program should not force community-based solutions (and providers) into one particular model.

We have explored many of these approaches and believe that most programs can fit within five different models:

  1. Direct provision of Internet service through non-ETC commercial provider in partnership with a nonprofit/library/school.
  2. Direct provision of Internet service by schools with EBS spectrum.
  3. Direct provision of Internet service through a higher education network in partnership with a nonprofit/library/school.
  4. Nonprofit/library/school facilitating service through Mobile Beacon or Mobile Citizen.
  5. Internet service via a publicly owned network.

The Lifeline program should facilitate and support all of these various methods of providing broadband service to the low-income population. Of the five community-based low-cost broadband solutions we have identified, three are currently distributed models in which the cost of the broadband service is absorbed by the nonprofit/anchor institutions/public utility.

In order to determine how community-based low-cost broadband service could potentially participate in Lifeline, we must understand the variety of solutions that currently exist. Of the five community-based low-cost broadband solutions we have identified, only the publicly owned networks offer phone service. The Commission should allow the Lifeline subsidy to apply to connectivity purchased by a nonprofit/anchor institutions/public utility who then distribute that connectivity to qualifying individuals. A community organization or library can purchase these devices and connectivity in bulk and distribute them on an as-needed basis to targeted, low-income populations. In the course of a year, one connection could effectively be shared by many low-income individuals for less than $9.25.

In these comments we describe one example for each of the five different solutions.

1. Direct provision of Internet service through non-ETC commercial provider in partnership with a nonprofit/library/school — Connecting for Good.

As of August 2015, Connecting for Good, a 501(c)3 organization in Kansas City, has set-up five mesh wifi networks in low-income housing facilities. Four of those are still operational and they are in process of establishing another. They began setting up these mesh networks in 2012. Connecting for Good provides the ongoing maintenance of the networks and technical support to the users. All the networks have gateway connections to the Internet provided by commercial Internet Service Providers via point to point microwave links. Unlike most Internet Service Providers, Connecting For Good’s ISPs, KC Wireless and Unified Online, do not restrict bandwidth sharing in their terms of service.

Thanks to financial donations, Connecting for Good pays KC Wireless $175/month which provides access to the residents of Glanville Towers and Junipers Gardens. If the networks at Glanville Towers and Juniper Gardens were used to capacity (300 users), the cost per user would be $.58 per user per month. Currently, the networks have an average of 100 users per month which calculates to $1.75 per user per month. Posada del Sol and Amethyst Place receive Internet access donated by United Online. For all facilities the bandwidth is free to users. There are no individual signups or subscriptions involved. These four mesh networks handle over 400 users per day. On average, users on the mesh networks receive speeds of 5 MB down and 2 MB up.

Greater speed can be achieved with larger backhaul capacity, which is more expensive. KC Wireless charges $5.00/month for each additional MB. Connecting for Good’s network equipment could handle up to 150 MB. Connecting for Good fundraises to cover the staff cost of maintaining the networks and providing technical support and digital literacy training to users.

2. Direct provision of Internet service by schools with EBS spectrum — Albemarle County Public Schools.

The Albemarle County Public Schools Board, staff, and community believe that the future of public education lies in the effective use of contemporary technologies. Public education must overcome opportunity gaps by providing all learners a seamless capability to conduct research, access information, and communicate at school and in the home. If only schools are connected, those students with home and community access will continue to push ahead of their un-connected peers. Albemarle County Public Schools is defining school as where our students travel with their learning needs and computing devices, not just within the bricks and mortar walls of school buildings.

Across Albemarle County’s 726 square miles, pockets of poverty exist within unconnected urban ring communities including housing projects and large mobile home parks, as well as within the impoverished rural communities in the foothills of the Blue Ridge Mountains and along the James River where broadband is unavailable through either cable or commercial 4G cellular service.

Albemarle County Public Schools has begun closing learning opportunity gaps by using the 2.5 Gigahertz Educational Broadband Spectrum provided by the Federal Communications Commission to public school districts. The technology department completed a small-scale “research and development” pilot of the project utilizing a building mounted antenna on a school. This pilot provided connectivity across an eight-mile radius with speeds averaging 13 Megabits per second. This pilot test was required by the FCC to prove the Division’s capability to deliver service through its available spectrum. Albemarle County Public Schools has extended their LTE network to students areas of the county with a high percentage of low to medium income households in rural areas of the county. These geographic areas tend to be mountainous and thus more isolated. The school district’s LTE Network is connected to their fiber network which has a POP connection through CenturyLink.

Currently, only select students of Albemarle County Public School have access to the LTE Network through their school issued devices. The LTE Network and the student access is supported by the district’s operational budget. Non-students within range of the LTE Network do not have access. With financial support, the Albemarle County Public School could and would extend access to its LTE Network to non-student low-income households within range of the LTE Network.

3. Direct provision of Internet service through a higher education network in partnership with a nonprofit/library/school — TFA-Wireless.

TFA-Wireless Network is a collaborative wifi project between Rice University’s Department of Electrical and Computer Engineering  and Technology For All (a Houston, Texas 501(c)3 nonprofit organization). TFA-Wireless is both a high-speed, free, secure wireless Internet service and a research network. TFA-Wireless serves 22,000 residents in approximately two square miles of the Pecan Park neighborhood in Houston’s East End where per capita income averages $10,500. The network is funded by the National Science Foundation.

The technology of TFA-Wireless is a mesh network that uses “white space” technology from the Rice/TFA tower to infuse the 802.11 mesh network with broadband connectivity. An upgrade is currently underway to to utilize Rice developed white space technology tools for the entire network.

Because TFA-Wireless is a research network, Technology For All would like to create an overlay that provides a higher quality of service. They would still be using Rice University’s Internet as backhaul and use the same towers and antennas but the technology to households would be a more standard mesh network. Technology For All has calculated the cost of a standard mesh network with backhaul from Rice University to be less than $5 per connection per month.

Technology for All fundraises to provide digital literacy and home computer ownership training to the households using TFA-Wireless and others in the Houston metropolitan area.

4. Nonprofit/library/school facilitating service through Mobile Beacon or Mobile Citizen — PCs for People.

Since September 2012, PCs for People, a Minnesota-based nonprofit 501(c)3 organization, has helped 30,000 households at or below 200% of the poverty rate get online. They provide refurbished computers at little to no cost, help the families choose a low-cost Internet service and provide personal technical support. As needed, PCs for People updates a document of low-cost offers available in the Twin Cities region.

PCs for People is an organizational partner with both Mobile Beacon and Mobile Citizen. PCs for People distributes devices and manages payments for broadband service via Mobile Beacon and Mobile Citizen. At the peak, PCs for People had 14,000 subscriptions via Mobile Beacon and Mobile Citizen. It was the most popular low-cost broadband service in their constituency. Mobile Beacon and Mobile Citizen were charging $10 per month for unlimited 4G service.  PCs for People charges $13.33 for month by month service to cover the administrative costs of managing payments and providing technical support.

  • ISP – Sprint via Mobile Beacon/Mobile Citizen (Sold by PCs for People)
  • Cost/Month – $10.00-13.33
  • Speed – Varies. Average 3-5MB
  • Equipment Cost – $60
  • Eligibility – Set by PCs for People as 200% of Poverty Rate

Mobile Beacon and Mobile Citizen’s low-cost broadband services are a result of an excess capacity agreement with a Clearwire Corporation subsidiary.[1]  Both Mobile Beacon and Mobile Citizen are transitioning their service from Clear’s 4G WiMAX Network to Sprint’s LTE Network.[2] New customers are not being accepted until the transition is complete. As Clear’s 4G towers are decommissioned, customers of PCs for People via Mobile Beacon or Mobile Citizen are losing service. During the transition, customers may go without service for an indeterminate amount of time. PCs for People calculates this situation could cause 24,000 students in the Twin Cities region to go without Internet access.

Comparing the current low-cost offerings in the Twin Cities to the Mobile Beacon and Mobile Citizen service, the popularity of the Mobile Beacon and Mobile Citizen service is immediately clear – low monthly cost, low equipment cost and wide eligibility. One of the other reasons the service via Mobile Beacon and Mobile Citizen is so popular is the mobility of the service. Low-income households tend to move often. With a cellular service, families can take the hotspot with them, avoiding an installation charge when they move.

PCs for People’s experience selling and supporting Internet access via their partnerships with Mobile Beacon and Mobile Citizen have resulted in the following best practices:

  • PCs for People provides 3 months of free service for every new sign up. This offer results in a retention rate of 90%.
  • PCs for People accepts cash payment. Half of their clients are unbanked so it is essential to have store fronts where the clients can pay their Internet bill in cash. (Clients can also choose to pay online, over the phone or in-person.)
  • PCs for People does not require a long-term commitment. If a client does not pay for service, the service is temporarily turned off, not terminated. The client can pay the following month and have the service resumed.
  • PCs for People provides technical support to all clients, troubleshooting their Internet and computer issues when possible.
  • PCs for People holds free computer clean up events quarterly, in addition to providing repairs for $25 regardless of where the computer was purchased.

PCs for People is only one of Mobile Beacon and Mobile Citizen’s partners. With over 100 broadband adoption organizations as affiliates, National Digital Inclusion Alliance can definitively say our affiliates rely heavily upon the $10/month wireless Internet service provided via Mobile Beacon and Mobile Citizen. Because the services of Mobile Beacon and Mobile Citizen are impacting broadband adoption in the United States, we encourage the Commission to fully understand the services provided by Mobile Beacon and Mobile Citizen, the legal arrangements between these entities and Sprint and to take any feasible steps to assist in the transition of their services to LTE on a robust basis.

5. Internet service via a publicly owned network — EPB’s NetBridge Student Discount Program.

The City of Chattanooga is working with EPB to finalize the NetBridge Student Discount Program, a new initiative aimed at increasing Internet access for pre-K through 12th grade students in the City of Chattanooga. Through EPB’s NetBridge Student Discount Program, students who live in the City of Chattanooga and participate in the Free and Reduced Meals program will be eligible for a home connection to America’s first community-wide fiber optic network at a significant discount. NetBridge is an effort to increase educational attainment in the community by helping to bridge the digital divide for young people. When more children in the community can utilize America’s first community-wide fiber optic network as an educational resource, they have better opportunities for succeeding in school. And, when students achieve more it makes the whole community more attractive to business investment and more able to support the growth of homegrown entrepreneurial ventures.

EPB’s NetBridge Student Discount Program offers 100-megabit-per-second Internet service to any household with a student who qualifies for free or reduced-fee lunches for $26.99 a month — less than half EPB’s current rate of $57.99 a month. Approximately 15,200 students will be eligible. EPB launched the program at the beginning of the 2015-2016 school year.  EPB’s August 10, 2015 press release provides the following details: “The Hamilton County Department of Education (HCDE) will provide validation in a two-step process through September 20. Families must be qualified by HCDE to receive meal subsidies and provide written permission for HCDE to release that information to EPB. EPB is providing HCDE with permission forms, which local public schools will distribute along with the Free and Reduced Meals application for parents to fill out. After the validation process is complete, EPB Fiber Optics will offer qualified families 100Mbps Internet service for $26.99 per month with no installation fees, contracts or other conditions.”[3]

In a corresponding effort, The Enterprise Center is creating a game-plan for increasing digital inclusion among all citizens and to offer everyone the benefits of an increasingly computer and web-based world.  A pilot of a digital inclusion program for parents or primary caregivers and their school age children, Tech Goes Home CHA, launched at five public schools and community sites in February, 2015.

In 1935, the City of Chattanooga established EPB as a nonprofit agency to provide electric power to the greater Chattanooga area. Today, EPB serves more than 170,000 homes and businesses in a 600-square-mile area in southeast Tennessee and northwest Georgia. Using a 100% fiber optic network as its backbone, EPB has built a Smart Grid, a next-generation electric system that includes communication capabilities designed to reduce the impact of power outages, improve response time and allow customers greater control of their electric power usage. This same fiber optic backbone is allowing EPB to offer high-speed Internet, TV and phone service to business and residential customers community-wide. In September 2010, EPB became the first company in the United States to offer one gigabit-per-second Internet speed to the entire service territory.

Regarding community-based solutions for low-cost broadband service, we suggest the Commission consider the following:

We recommend the Commission determine how best community-based low-cost solutions can participate as non-ETC providers of Lifeline broadband. The five community-based solutions put forth in these comments are all willing to discuss how they can work collaboratively with the Commission as provider of Lifeline broadband service. We encourage the Commission to include both 1.) a community-based solutions in which the connectivity is purchased by a nonprofit/anchor institutions/public utility who then distributes that connectivity for free to qualifying individuals and 2.) connectivity purchased by a nonprofit/anchor institutions/public utility who then receive payment for that connectivity from qualifying individuals receiving the service.
We recommend the Commission fully understand the national impact on broadband adoption of low-cost broadband services provided via Mobile Beacon and Mobile Citizen.

[1]          Comments of North American Catholic Educational Programming Foundation, Inc. (“NACEPF”) in response to the Notice of Proposed Rulemaking (NPRM) WC Docket No. 13-184 on Modernizing the E-rate Program for Schools and Libraries.

[2]          Sprint LTE Transition. (Last visited August 27. 2015.)

[3]          “Enrollment Underway for EPB NetBridge Student Discount Program”. EPB Press Release. August 10, 2015. (Last visited August 27, 2015.)