I see that Nebraska Public Service Commissioner Chrystal Rhoades used the occasion of FCC Commissioner Brendan Carr's visit to Nebraska to bend his ear regarding the FCC's pending Lifeline rulemaking proposal. According to an ex parte she ubmitted, Commissioner Rhoades told Mr. Carr that: "In some areas of Nebraska, wireless resellers may be the only wireless Lifeline option because many major market carriers no longer provide Lifeline as an ETC. The FCC's proposal will reduce comparable and competitive choices in the Lifeline market, contrary tothe goals of the 1996 Telecommunications Act."
I submitted comments along the same lines to the FCC in February opposing the FCC's proposal to restrict Lifeline support to resellers. While I generally support initiatives to promote facilities-based investment, I said that "in communications policy – as in other areas – sometimes there are reasons justifying 'exceptions to the general rule,' and I submit that this is such a case."
In my comments, I concluded:
"The reality is that, today, almost 70% of Lifeline subscribers are served by resellers. As the Commission has recognized, many of these are minorities who rely primarily or exclusively on wireless services, including wireless broadband services, for access to communications. There is no dispute that wireless resellers, like TracFone, have focused their marketing on reaching Lifeline-eligible low-income consumers, and, this, in turn, has increased awareness of the program. In any event, the reality today is that facilities-based providers currently are serving only a minority of Lifeline subscribers, so that discontinuing support for resellers would be very disruptive to the program."
I often have good faith disagreements with many of the state PUC commissioners. But, on this Lifeline point, I'm with Commissioner Rhoades.