FCC Filing: Federal-State Joint Board on Universal Service Lifeline and Link Up Lifeline and Link Up Reform and Modernization

OTHER

WC 11-42 — Federal-State Joint Board on Universal Service Lifeline and Link-Up Lifeline and Link Up Reform and Modernization;

 

COMMENTS

TDI, along with the tagged consumer groups filed comments to the Federal Communications Commission in response to the FCC’s request for comments concerning the state of the Lifeline program.

[see below, under Tags: for a full list of signatories]

TDI advocates equal access to communications including the provision of affordable services and equipment, for the more than 48 million Americans who are hard of hearing, Deaf, or DeafBlind. 

While the Lifeline program has significantly helped eligible participants, we urge the Commission to reduce barriers for eligible people to qualify while increasing the required speed and data standards to allow Lifeline to fulfill its purpose: to help “ensure that low-income consumers can afford 21st-century broadband and the access it provides to jobs, healthcare, and educational resources.”

However, many eligible Deaf and hard-of-hearing participants experienced barriers when trying to access the Lifeline program. Access to services provided by these broadband carriers varies considerably based on geography and infrastructure. We were well aware that there was an eligible Deafblind man who struggled to access broadband accessibility and has no connection at home. 

In fact, according to the latest publicly available data for 2021, only about 26% of eligible people take part in the Lifeline program. In part, this is a result of barriers to participation, including:

  1.  Finding a participating carrier, which may be prohibitive in many locations
  2. Qualifying for the service
  3. Maintaining periodic eligibility verification
  4. Having sufficient income to afford the cost of broadband after the discount.

Voice and broadband service costs continue to increase, making the Lifeline program necessary for millions of eligible Americans.

Costs for broadband services continue to rise every year like clockwork. As prices continue to rise, affordability slips through the grasp of millions of Americans. This situation means that government programs such as Lifeline become even more essential for Americans to maintain connectivity.

The Lifeline program provides exactly that to its participants: a lifeline to essential communications services. However, the Lifeline program’s minimum requirements are insufficient for video calling and other essential communications services.

The Commission should increase minimum speeds under the Lifeline program to reflect what is needed by consumers, including those who are deaf or hard of hearing. The Commission should adopt a minimum speed requirement of 50/50 mbps download/upload speed requirement for home broadband use. Also, the current minimum data cap of 1024 GB per month is also insufficient for some users.

We urge the Commission to spur increases in speed minimums for mobile access, as the current 3G minimum simply is not sufficient for many applications. The current minimum mandate of 4.5 GB per month on a mobile network is far too low to be useful to a person who is deaf or hard of hearing using their mobile device with modern applications for work, take part in school, or connect with friends, family, or essential services.

The FCC should also consider the needs of the different groups of people who are deaf or hard of hearing who have voice-only and data-focused plans. 

For that reason, we recommend the Commission examine such bundling programs to mandate minimums—high speeds, unlimited data, and voice services that are in line with what is commonly offered in the market. Then, the Commission should mandate telecommunications providers provide similar services under the Lifeline program. That is, eligible participants should be able to secure a plan comparable to commonly offered family bundled plans but at the reduced price as mandated by Lifeline.

URL below is linked to the actual filing document on FCC’s Electronic Comment Filing System 

https://ecfsapi.fcc.gov/file/10419942909274/2021.04.19%20Consumer%20Groups%20and%20Accessibility%20Researchers%20Lifeline%20Comments%20final.pdf

Special Thanks to: SAMUELSON-GLUSHKO TECHNOLOGY LAW & POLICY CLINIC