In NDIA’s Initial Comments of the Second Further Notice of Proposed Rulemaking (NPRM) on reform and modernization of the FCC’s Lifeline program, we state the Commission should take community-based solutions into account as alternative solutions in its proposed modernization of Lifeline. Community-based broadband solutions define their first purpose as broadband access and use by disadvantaged households. They provide a low-cost broadband service while often also providing local training and support.

On September 30, 2015 we submitted Reply Comments focused upon allowing community-based low-cost solutions to be Lifeline broadband providers and not allowing Lifeline broadband providers to institute data caps.

Excerpts of our Reply Comments:

From Page 2:

Barriers to community-based low-cost broadband solutions participating as Lifeline broadband providers:

  • They are not ETCs.
  • They may not be as experienced in regulatory compliance as current Lifeline broadband providers and thus require training and an assigned FCC support staff.

If community-based low-cost broadband solutions were designated as eligible Lifeline broadband providers, changes to their existing services might include the following:

  • Expand backhaul capacity.
  • Expand geographically (to additional buildings or neighborhoods), and/or to new demographic populations (for example, from students to parents).
  • Purchase routers and modems for use in the home by the Lifeline subscribers.
  • Some of the non-profit solutions are currently set up as open networks, not requiring individual sign on. Presumably, they would need to change their sign in process to ensure the service is being used by eligible households.
  • Restructure budgets so that fundraising dollars previously used for low-cost service can be used for training and support. 

From Page 5:

We believe that monthly data allotments of the type currently in effect for Lifeline data plans and other low-cost 3G/4G mobile accounts, e.g. 1 GB, 2 GB or even 6 GB per month, are inappropriate for home broadband access, and will defeat the Commission’s goal of enabling Lifeline-eligible households to engage in a variety of meaningful uses of broadband in such areas as education, employment, healthcare and community safety – especially where such allotments must be shared among multiple household members.  

Community providers like those described in NDIA’s Initial Comments, driven by “bottom lines” of public service or nonprofit mission rather than profit, and focused on the specific needs of low income consumers, are often able to provide superior levels of network access – including unlimited data – to those consumers at much lower cost than commercial providers.

Albemarle Schools LTE network, Connecting For Good wifi mesh, TFA-Wireless, Chattanooga EPB NetBridge (community-based networks described in our Initial Comments as potential Lifeline providers) plus Red Hook WIFI currently provide unlimited data to their users, and would expect to do so for Lifeline-subsidized households.

TFA-Wireless Coverage Map TFA-Wireless Coverage Map

From pages 2-3:

Technology For All-Wireless (TFA-Wireless): A specific example of how a community-based organization’s eligibility as a Lifeline provider could expand their low-cost solution.

The current TFA-Wireless platform is a research network in collaboration with Rice University.[1] The research has been funded by the National Science Foundation and also provides a community resource of wireless Internet service. It is available for free for up to 1.5 mbs and serves the Southeast Houston neighborhood around the TFA office which includes a portion of the Milby High School attendance zone. The current quality of service is limited by the research aims of the current network, but TFA is planning a second layer of service with a higher throughput of 5-10MB. This second layer of service is currently dependent upon fundraising efforts. It could be implemented more quickly if eligible households in the neighborhood could use their Lifeline Program subsidy for TFA-Wireless.

Milby High School in Southeast Houston serves 2012 students, 80.9% of which are economically disadvantaged. 94.6% are Hispanic and 18.7 percent are English Language learners.  There are 1392 at-risk students or approximately 69% of the student body.  In addition to Milby High School, there are also four elementary schools and one junior high school in the current footprint of our TFA-Wireless platform.

To serve the full attendance zone of Milby High School would require an additional 25 antennas and additional bandwidth injected into the network.  Based upon the demographic data, to serve the entire Milby High School attendance zone, TFA would need to increase the footprint of their network from its current coverage of about 20,000 residents (4243 households) to about 59,500 residents (12,812 households).  Of these households, 26.6% or 3411 live below the poverty level.[2] This is twice the poverty level of the state of Texas as a whole. Per capita income in 2015 is estimated at $12,685. Education levels of adults in the proposed area are also low with 33% having less than a 9th grade education and 49.1% (33% + 16.1%) with no high school diploma. Only 5.6% of the adults in the proposed service area have a Bachelor’s Degree and even less (1.9%) have a graduate or professional degree.[3]

Houston Independent School District (HISD), of which Milby High School is part of, has initiated the PowerUP program. PowerUP is a program that provides one laptop for each Milby High School student . Teaching methodologies are being changed to meet 21st century skill requirements and HISD is converting to digital-age instruction and communication in the new PowerUP program. Milby students have adequate bandwidth at school, but many do not have access to the Internet at home or after school. Expanding TFA-Wireless could change that.

Technology For All has created the “TFA-PowerUP+” program as a convergence of opportunities and collaboration to improve student educational success by increasing parent, student, and teacher technical skills and positive interactions with each other through online tools for education and engagement. 

Technology For All has been working in conjunction with HISD’s Milby High School to help students take full advantage of the PowerUP program to succeed and further their education. TFA will fill the homework gap and enhance the success of the PowerUP program by:

  •  Providing students with additional skills, tools and bandwidth (TFA-Wireless) to achieve their educational goals.
  • Training parents to have the skills they need to monitor and encourage their students’ educational progress.
  • Helping teachers gain the basic computer skills necessary to more effectively facilitate instruction, manage curriculum, and engage their digitally proficient students and parents.

If TFA were to become a provider of Lifeline broadband, it could direct its fundraising efforts to covering the training and support needs of the disadvantaged community members it serves.

[1] TFA-Wireless (Last visited September 29, 2015.)

[2] Texas Education Agency.

[3] U.S. Census Bureau through the tool