TracFone and Gila River Telecom disagreed in docket 11-42 filings on whether the FCC can use Lifeline or Link-Up funds to pay for equipment and training. TracFone said universal service cash “may not lawfully be used to subsidize either equipment or training,” while Gila River said the commission “has ample statutory authority to permit Universal Service Funds to be used for equipment and training.” Providing equipment and training “would contribute to greater broadband adoption,” TracFone acknowledged (http://xrl.us/bmbvtf), but Section 254(b) of the Telecom Act is clear that “funding for such equipment and training must come from other sources.” But Gila River said the same section, as well as Sections 151 and 154(i), gives the FCC “broader mandates” to help adoption (http://xrl.us/bmbvth). Section 254(b) says the FCC and the Joint Board “shall base policies for the preservation and advancement of universal service,” which Gila River said “makes clear the primary tenet of universal service” is to provide access to advanced telecom and information services. Several commenters focused on the Lifeline program’s “one per residence” rule. Typical were comments from CompTel’s Mary Albert: “Substituting a single line per qualifying adult rule for the proposed single line per residential address rule would better promote the availability of voice service by ensuring that the neediest of low income consumers are not denied Lifeline/Link Up assistance simply because they do not have a unique fixed residential address recognized by the U.S. Postal Service or because they live in group facilities.” CenturyLink urged the commission to “consider a limited scale pilot program to provide universal service support to promote broadband adoption,” and said the FCC shouldn’t “restrict Link Up discounts solely to service initiations that involve the physical installation of facilities by providers at a consumer’s residence” and should “not adopt a sample-and-census approach for verifying Lifeline eligibility.”
The FCC should consider limiting Lifeline/Link-Up reimbursement to a single line per qualifying adult rather than the proposed single line per residential address, CompTel said in a filing at the FCC (http://xrl.us/bmbmta) on the commission’s further notice of proposed rulemaking. No one should be denied a phone because they live in a group facility, CompTel said. The FCC should also reject arguments that Link-Up reimbursements for non-recurring costs should be limited or eliminated, the group said. “Doing so would recreate a barrier to subscribership for low income consumers,” CompTel said. “The Link-Up program was created to reimburse [eligible telecommunications carriers] for the revenues they forgo in providing low income consumers a discount on service activation fees. Service activation fees are standard in both the wireline and wireless industries and in the absence of Link-Up assistance, consumers will be forced to pay 100 percent of those charges, which very well may discourage consumers from signing up for telephone service.” A beefed up Lifeline/Link-Up program could eventually supplant other Universal Service Fund programs and the FCC should resist “artificially constraining the size of the program, especially now when the nation’s consumers are in the midst of difficult economic times,” the Free State Foundation said Friday in a filing at the FCC (http://xrl.us/bmbk9j). “We support ongoing efforts, such as some the proposals put forward by the Commission, to ensure the programs operate with integrity and efficiency,” the filing said. “For example, we support pro-efficiency and anti-fraud measures to eliminate duplicate enrollment by the same customers with multiple [eligible telecom carriers], to provide Link-Up support to reimburse only costs actually incurred for initiating service, and to improve methods for verifying customers’ eligibility.” The group said the Lifeline program is inherently more efficient than other USF programs. “A primary strength of the Lifeline/Link-Up programs is that their subsidies are targeted to those low-income persons that need them,” the filing said. “Subsidies targeted to individuals are more efficient and can be more reliably monitored for accountability than subsidies targeted more broadly to service providers."
An influx of freshmen in the 112th Congress forced the telecom industry to increase education efforts in 2011, industry lobbyists said in interviews. This year there are 13 freshman senators and 93 new House members. As a result, telecom lobbyists have had to spend more of their time teaching the nuts and bolts of major telecom issues like spectrum and Universal Service Fund reform, lobbyists said.
The FCC should not ignore the broadband needs of community anchor institutions as it addresses the future of the Universal Service Fund, the Schools, Health and Libraries Broadband (SHLB) Coalition said in a filing at the FCC. “Schools, health care providers, libraries, public safety providers, public media, and others … require open, affordable, high-capacity broadband to provide all the essential educational and informational services that their communities demand, especially vulnerable and ‘at-risk’ populations,” the coalition said. “Unfortunately, the National Broadband Map and several other studies show that community anchor institutions often are not able to obtain the affordable, high-capacity bandwidth that they need.” The group said the 4 Mbps standard the FCC cites for residential users is a far too low of throughput rate for anchor institutions. Anchor institutions are “'multi-user environments’ that generally have 10 to 50 or more computers in use simultaneously sharing the same broadband connection,” the group said. “As a rule of thumb, community anchor institutions should have a minimum of 1 Mbps level of service for every computer.”
Free Conferencing Corp. said the FCC should be cautious about imposing a proposed $.0007 rate regime for intercarrier compensation because of the effect it would have on free calling services and consumers. The company responded to the FCC’s request for comments on changes to the Universal Service Fund and intercarrier comp (See related story). “FreeConferenceCall.com would be dramatically affected (negatively) by a $.0007 rate regime, as would our 15-20 million monthly customers,” the company said. “The Commission should not cut off consumers’ choices in telecommunications through this Rulemaking. … FreeConferenceCall.com must stand up for competition in telecommunications, effective regulation and the consumer.”
Satellite broadband providers said in joint comments filed in docket 10-90 they opposed all of the Universal Service Fund changes proposed by incumbent local exchange carriers(http://xrl.us/bmbhwj). The providers include Spacenet, ViaSat and ViaSat’s subsidiary WildBlue, Dish Network, its sister company EchoStar, and EchoStar subsidiary Hughes. The FCC recently asked for comment on separate proposals from the state members of the Federal-State Universal Service Joint Board, ILECs and rural LECs. The ILEC plan is known as the America’s Broadband Connectivity (ABC) plan. Each of the proposals places “the interests of incumbent wireline carriers above those of consumers and the objectives of universal service,” said the satellite broadband companies. “Tellingly,” the proposals don’t make a case that wireline carriers “are in the best position to extend high quality-broadband service to unserved consumers quickly and at a minimal cost,” they said. The proposal “virtually guarantees funding to incumbents” even where another technology could offer a better solution and run “contrary to the principles of competitive and technological neutrality,” said the satellite companies. Subsidizing wireline incumbents gives them an insurmountable price advantage, effectively deterring competitors from entering subsidized markets, said the satellite companies. The proposals also wouldn’t require incumbents to meet evolving broadband speed requirements, thus perpetuating the rural/urban digital divide and entrenching the “already outdated DSL technology that cannot be upgraded easily,” said the satellite providers. If the FCC decides to preclude non-wireline providers from competing, it should do so only for fiber services and only when such services can be “deployed more cost-effectively than other services,” said the satellite companies. Meanwhile, some state and wireless comments were dismissive of the future role of satellite broadband. Any funding for satellite broadband shouldn’t be part of a mobility fund, as proposed in the ILECs plan, said the Rural Telecommunications Group (http://xrl.us/bmbhvk). “Although it is unlikely that satellite service will be able to deliver speeds that are close to the broadband threshold proposed by the ABC Plan, any support for satellite providers should not come out of a funding mechanism that is designated for mobile broadband,” RTG said. “Satellite carriers provide a fixed Internet access service, and should not receive support from a fund purposed for ensuring that consumers enjoy the benefits of mobility.” Satellite will most likely be used where it’s too expensive for ILECs to build out, and the funds should therefore come from funding reserved for incumbent carriers, RTG said. Satellite broadband wouldn’t fit the needs of Vermont and Maine, said the Maine Public Utilities Commission and Vermont Department of Public Service in a joint filing (http://xrl.us/bmbhvz). “The ABC Plan relies upon satellite service to meet the goal of universal broadband, notwithstanding technical, geographic, and capacity limitations that indicate that satellite may not reliably meet the 4/768 threshold in the ABC Plan, nor be comparable to the much higher speeds available in urban and suburban areas,” the states said. “Satellite service is not suited for interactive voice communications, and does not meet the comparability test in the context of a plan that replaces support for rural telephone service with support for satellite service.” Satellite service can be hurt by “atmospheric conditions,” capacity constraints, and topography, said the states.
The FCC should not ignore the broadband needs of community anchor institutions as it addresses the future of the Universal Service Fund, the Schools, Health and Libraries Broadband (SHLB) Coalition said in a filing at the FCC. “Schools, health care providers, libraries, public safety providers, public media, and others … require open, affordable, high-capacity broadband to provide all the essential educational and informational services that their communities demand, especially vulnerable and ‘at-risk’ populations,” the coalition said. “Unfortunately, the National Broadband Map and several other studies show that community anchor institutions often are not able to obtain the affordable, high-capacity bandwidth that they need.” The group said the 4 Mbps standard the FCC cites for residential users is a far too low of throughput rate for anchor institutions. Anchor institutions are “'multi-user environments’ that generally have 10 to 50 or more computers in use simultaneously sharing the same broadband connection,” the group said. “As a rule of thumb, community anchor institutions should have a minimum of 1 Mbps level of service for every computer.”
The Native Telecom Coalition for Broadband urged the FCC to adopt its earlier proposal for a Tribal/Native Broadband Fund as part of changes to the Universal Service Fund. “The proposed ‘Native American’ USF program holds the promise of finally delivering many of the commitments embedded or implied in treaties and acts of Congress that have been languishing for over a century,” the group said in a filing at the commission (http://xrl.us/bmbgs3). “A broadband communications platform will provide the 21st century foundation that is needed to work toward Native American participation in socio-economic advancement, while enhancing their ability to preserve and pass on to future generations longstanding cultural traditions and values."
The Native Telecom Coalition for Broadband urged the FCC to adopt its earlier proposal for a Tribal/Native Broadband Fund as part of changes to the Universal Service Fund. “The proposed ‘Native American’ USF program holds the promise of finally delivering many of the commitments embedded or implied in treaties and acts of Congress that have been languishing for over a century,” the group said in a filing at the commission (http://xrl.us/bmbgs3). “A broadband communications platform will provide the 21st century foundation that is needed to work toward Native American participation in socio-economic advancement, while enhancing their ability to preserve and pass on to future generations longstanding cultural traditions and values."
Small and mid-sized wireless carriers, cable operators and competitive local exchange carriers all criticized parts of the America’s Broadband Connectivity (ABC) plan for making major changes to the Universal Service Fund and intercarrier compensation regimes. The plan, a compromise among major telecom carriers and rural local exchange carriers, is unlikely to be approved without some changes, said industry and FCC officials. The trick for the FCC will be keeping ILECs on board while accommodating other interests (CD Aug 25 p1). The FCC also asked for comment on a “complementary” filing by rural carriers as well as proposals by the Federal-State Joint Board on USF, also discussed in many of the comments.