As readers of this space know, I'm a strong advocate of free market-oriented communications policies, while, at the same time, a long-time advocate of maintenance of a viable, properly-managed Lifeline program. There's no inconsistency, of course. The FCC's Lifeline program, through its provision of subsidies, provides a "safety net" for those qualifying low-income persons who otherwise may not be able to afford a basic level of communications service.
In other words, in the midst of much talk about closing "digital divides," the Lifeline program is directed towards providing support to those low-income persons who might fall on the wrong side of one of those divides.
With this background in mind, I am quite supportive of the Joint Petition to Pause Implementation of the December 2019 Lifeline Minimum Service Standards that was filed with the FCC by CTIA and certain public interest organizations on June 27. Specifically, the Petition asks the Commission to stay implementation of the December 1, 2019 (1) increase in the minimum required broadband data usage allowance, and (2) the phase-down in support for voice services in the Lifeline program. The Petition asks for the postponement until the Commission can consider the Wireline Competition Bureau’s State of the Lifeline Marketplace Report, due to be completed by June 30, 20121.
With this background in mind, I am quite supportive of the Joint Petition to Pause Implementation of the December 2019 Lifeline Minimum Service Standards that was filed with the FCC by CTIA and certain public interest organizations on June 27. Specifically, the Petition asks the Commission to stay implementation of the December 1, 2019 (1) increase in the minimum required broadband data usage allowance, and (2) the phase-down in support for voice services in the Lifeline program. The Petition asks for the postponement until the Commission can consider the Wireline Competition Bureau’s State of the Lifeline Marketplace Report, due to be completed by June 30, 20121.
This is not to say that, at some point, it would not be appropriate to implement the mandates presently targeted by the petition, or at least similar ones. It is rather to say that, given developments since the Commission devised the mandates, implementation on the existing schedule may not be reasonable.
As the Petition points out, under the current schedule, the data usage allowance would jump from 2 GB to 9.5 GB per month on December 1. The petitioners credibly state that such a "flash jump" would also "significantly narrow consumer choice, limiting the variety of service plans available for eligible low-income consumers to choose and requiring eligible low-income consumers to purchase plans that might often include much larger increments of data usage than they need or want."
With regard to the scheduled December 1 phase-down in support for voice service, CTIA and the others state that "a significant number of eligible low-income consumers continue to prefer voice-only services or bundles of services that include more voice usage and less data usage." Indeed, they claim that almost 42% of Lifeline customers presently subscribe to plans that qualify for Lifeline by virtue of meeting minimum standards for voice service. The impending diminishment in support for voice services likely will adversely impact Lifeline customers by constraining the flexibility of service providers to tailor offerings affordability to meet Lifeline customers' demands.
Given the circumstances that exist at present, which the Commission could not have necessarily predicted at the time it devised the existing scheduled mandates, and given the pendency of the State of the Lifeline Marketplace Report, the petitioners' postponement request seems reasonable, and I hope the Commission will consider it such.
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