NDIA has responded, via letter, to a document released by the FCC titled Bridging the Digital Divide for Low-Income Consumers”.  This document includes the “Fourth Report and Order, Order on Reconsideration, and Memorandum Opinion and Order”, a “Notice of Proposed Rulemaking (NPRM)” and a Notice of Inquiry (NOI). 

NDIA’s letter is available here – NDIA letter to FCC Lifeline 11-11-17. The letter includes the following:

We agree with the specific questions and concerns of the public interest groups who submitted a letter on November 8, 2017. We share these additional three observations which should influence the FCC’s actions on this matter:

  1. The NPRM proposes to limit Lifeline provider eligibility to facilities-based ETCs. This, at a time when AT&T, one of the most important companies qualifying for that role, has recently relinquished its ETC status (other than for Connect America Fund areas) in a dozen states and is asking public service commissions in three additional states for permission to do so. If both AT&T and numerous mobile Lifeline resellers are eliminated as provider options, yet providers of Lifeline broadband service must be ETCs with both broadband and voice service, low-income consumers in the AT&T phone service territories will have few options for Lifeline service.
  2. The FCC should not limit Lifeline to areas in need of infrastructure. In Paragraph 120, the NOI asks “whether the Lifeline program could better reach nonadopters of broadband by focusing Lifeline support in areas where providers need additional incentive to offer high-speed broadband service.” Adoption is certainly not only a problem in areas lacking high speed infrastructure. Pew Research Center tells us that in 2016, only 73% of urban U.S. adults and 64% of rural adults used broadband at home.
  3. The NOI discusses the possibility of targeting enhanced Lifeline subsidies to “digitally redlined” areas: 123. Digital Redlining. We next seek comment on whether and how the Commission should also target Lifeline support to bring digital opportunity to low-income areas where service providers have less incentive to deploy facilities or offer robust broadband offerings compared to other areas.” As NDIA’s research, along with that of Free Press, is a primary source of recent discussion of digital redlining, we are happy to see the FCC acknowledge the importance of the issue. But the NOI’s discussion seems to be based on a misunderstanding of the term. “Digital redlining” refers not to a speculative situation in which “providers have less incentive to deploy facilities or offer robust broadband offerings compared to other areas”, but to actual historical failures (notably by AT&T) to upgrade their fixed networks to provide mainstream broadband speeds in large areas of the cities they serve, leaving all the residents of those areas (not just low-income households) with maximum available speeds below 25/3 mbps, and many with speeds of 3 mbps or less. Even if AT&T intended to continue as an ETC in those cities – which it doesn’t, see point 1 above – why would an extra $10-15 a month from a few hundred or even a few thousand Lifeline customers in the redlined areas of Cleveland or Dayton convince the company to install millions of dollars’ worth of new fiber to neighborhood nodes, when it wasn’t and still isn’t prepared to do so to compete for thousands of their non-poor neighbors?

The following quote can be attributed to Angela Siefer, Director of NDIA.

NDIA can find no evidence of policies or suggested policies in the FCC’s document titled “Bridging the Digital Divide for Low-Income Consumers” that would actually bridge the digital divide – that is, increase access to and use of information communication technologies. In fact, the policies suggested in the document increase bureaucratic hurdles for innovative community-based connectivity solutions to participate as providers of Lifeline broadband service. NDIA encourages the FCC to hear and learn from local digital inclusion practitioners. 

 

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