NDIA was first organized in 2015 to provide a needed voice for digital inclusion practitioners in the proceeding which led to the FCC’s Third Report and Order, Further Report and Order, and Order On Reconsideration adopted March 2, 2016 – referred to as the 2016 Lifeline Order, which created a framework for limited but important Lifeline support for broadband Internet access for low-income Americans.

Less than two years after that Order, the FCC now seeks public comment on a new Proposed Rulemaking with the apparent purpose of dismantling most of that framework. Under the perverse title of “Bridging the Digital Divide for Low-Income Consumers”, the proposed rules seem explicitly designed to reduce the Lifeline program’s availability, participation levels, and provider choice and economic value for participants, for voice as well as Internet data service. Of particular concern to digital inclusion advocates and practitioners, the Commission proposes to roll back all of the 2016 Lifeline Order’s movement in the direction of consumer choice, provider diversification and service innovation… thus eliminating the program’s potential to help “Bridge the Digital Divide for Low-Income Consumers” in any meaningful way.

We encourage NDIA Affiliates and others to submit comments to the FCC expressing the necessity for the Lifeline program to effectively be what it was intended to be – a communications subsidy for low-income consumers. To help you submit comments, we have created a template letter. In the template, we offer five statements and suggest you include 1-3 of these:

  • We oppose the proposed outright elimination of the Lifeline Broadband Provider designation created by the 2016 Lifeline Order (paragraph 55).
  • We opposes the elimination of non-facilities based ETCs (paragraphs 62 and 64).
  • We oppose the elimination of the Lifeline program’s “equipment requirement” as discussed in paragraph 76.
  • We oppose the framework of maximum discount levels, mandatory contributions and benefit limits for Lifeline households discussed in paragraphs 111 through 118.
  • We oppose the Commission’s suggestion that the “digital redlining” of low income urban neighborhoods can be remedied by targeting enhanced Lifeline subsidies to encourage ETC infrastructure investment, discussed in paragraph 123.

And then include one or more of the following:

  • Description of a community member’s broadband access barriers and how those barriers were overcome.
  • Statistics of how many people your organization has guided to home broadband.
  • Home broadband service options in your community, including costs and speeds. Also note which of the service offerings have eligibility limits or are limited time offers.
  • Any local statistics you have on broadband adoption barriers or solutions.

You can submit your letter to the FCC via their online system, Electronic Comment Filing System. Public Knowledge created a document titled Navigating the FCC: Comments. This document includes “How Do I File a Comment With the FCC?” For the “Proceedings”, enter each of these docket numbers one at a time, hitting enter after each one – 17-287, 11-42, 09-197. 

The deadline for comments is February 21, 2018.