NDIA’s comments to the FCC regarding the modernization of the Lifeline Program are built upon our affiliates’ unique positions working directly with non-adopters to increase digital inclusion in the United States. Here are the big points we made in our Comments. We welcome you to read our full Comments.


  1. NDIA agrees that broadband Internet service should be a supported service in the Lifeline program.             
  2. NDIA encourages the Commission to address all three barriers to broadband adoption in this proceeding, and to recognize that local agencies and organizations are on the frontlines of broadband adoption.
  3. NDIA encourages the Commission to recognize that community-based low-cost broadband is an important strategy to address the cost issue.     

Recommendations based upon specific paragraphs in the FCC’s Notice of Public Rule Making:

Paragraph 7… Household Internet access via a wireless provider is most supportive of all members of the household if the service is distributed beyond a singular mobile phone.

Paragraph 17… We recommend the Commission incentivize Lifeline broadband providers to provide training and support through community partnerships while also encouraging other Federal agencies and stakeholders to advance meaningful uses by leveraging Lifeline broadband.              

Paragraph 26… Broadband purchasing awareness programs are most successful when they speak directly to a target population and are created and implemented in partnership with a local trusted organization.

Paragraph 27… Lack of broadband access is a major obstacle to low income households’ adoption of Personal Health Record (PHR) tools. We recommend the Commission work cooperatively with the Department of Health and Human Services and the Centers for Medicare and Medicaid Services to maximize the impact of a Lifeline broadband option on low-income PHR adoption.

Paragraph 29… Local resilient broadband networks can be a valuable public safety tool. We recommend local resilient broadband networks be considered as a Lifeline broadband provider.

Paragraph 33… Due to the necessity of everyone in the household using a Lifeline broadband connection, we recommend the Commission not allow Lifeline support of filtered connections.

Paragraph 44… Requiring multiple Lifeline broadband services from each provider will aid households choosing a Lifeline broadband service that meets their needs.        

Paragraph 52… Locking in the $9.25 subsidy as permanent is premature at this early stage of the modernization of Lifeline.               

Paragraph 54… Because there are multiple costs associated with establishing home Internet service accessible to more than one person in the household, we recommend the Commission cover the broadband connection charge for wireline service.

Paragraph 61… Clearly, we agree broadband should be a supported service in the Lifeline program.

Paragraphs 64-80, 86-89… A National Verifier should work directly with community-based organizations in order to empower those organizations to be strong ambassadors for the Lifeline program.

Paragraphs 129-141… Community-based solutions for low-cost broadband service should be designated as providers of Lifeline broadband.