INTRODUCTION

New America Foundation (“NAF”) respectfully submits these comments in response to the Federal Communications Commission’s Notice of Proposed Rulemaking (“NPRM”) in the above-captioned dockets. The NPRM seeks comment on the rules designed to improve delivery of Lifeline and Link Up benefits to low-income consumers and to enhance protections against waste, fraud, and abuse related to the fund.

In response to the Commission’s NPRM, NAF urges the Commission to take the following steps to ensure that the largest number of those eligible to receive benefits are served, that they are served by providers who can effectively meet their needs, and that they are able to choose where to apply their benefits. Therefore, the Commission should: (1) expand the type and number of providers eligible to receive Lifeline support; (2) grant low-income consumers flexibility to apply their benefits to whatever service or package best fits their needs and means; (3) lessen the significant disparities between the High-Cost and low-income programs by redirecting a modest portion of savings from the High-Cost fund to support Lifeline and Link Up programs; and (4) ensure that the proposed pilot program does not, by virtue of its design, foreclose the inclusion of existing, effective models of broadband adoption and the wide range of innovations these models can produce.

As the Commission seeks to reform Lifeline Link Up to meet the needs of the 21st Century, it must move beyond a prescriptive, one-size-fits-all approach for ensuring that low–income communities have the opportunity to utilize and benefit from telecommunications. Technology is changing rapidly and, with it, so do needs. To ensure that the transition to providing broadband connectivity to low-income communities is effective, the Commission should emulate the approach of the BTOP and BIP programs and open doors for innovative new models, thinking, and approaches in making broadband more affordable and accessible for all Americans.