Comments to the FCC on Modernizing the Lifeline Program for the Broadband Era

ITIF strongly supports providing subsidies to help low-income Americans afford the communications services that are increasingly essential for modern life. Beyond the equities of ensuring a safety net for those less fortunate, subsidized connectivity for those otherwise unlikely to pay for broadband contributes to network effects, making the Internet a more valuable communications platform and working toward a society that can organize assuming everyone is online. Extensive evidence consistently demonstrates the benefits of broadband on economic growth, employment, and productivity. Lack of broadband can also be a key obstacle for job seekers, making Lifeline a crucial tool to help lift individuals and families out of poverty. Lifeline also plays an important role in helping counter economic downturns, helping those who qualify even if those numbers swell during a recession.

As broadband access continues to be more important to flourishing individuals and communities, bringing Lifeline into the 21st century by refining the support for broadband (wireline or wireless), coupled with common-sense reforms around eligibility administration and program oversight, should be change everyone supports. Unfortunately, the issue of government provided broadband subsidies for low income Americans is becoming increasingly partisan. ITIF urges the Commission to hew to the center and make incremental improvements to the program rather than controversial, disruptive changes.

ITIF believes, as it argued in comments in the 2015 Lifeline proceeding, the ideal program would feature a simple and streamlined voucher system that would allow eligible participants a subsidy they could put toward virtually any communications tool of their choosing: fixed line telephony, cellular telephony, or broadband. Ideally the program’s funds would be disbursed directly to eligible participants and integrated with other subsidy programs, such as the Supplemental Nutrition Assistance Program. Putting the individual at the center of an effective communications subsidy program would help reduce fraud and allow market forces to best serve diverse consumer needs.

The Communications Act restricts the Commission in a number of ways, and there is only so much the Commission can do to work toward this structure. Count Lifeline among the many areas where Congressional action could greatly improve the status quo. Unfortunately, some of the FCC’s proposals would take us further from this vision rather than closer.

ITIF urges the FCC aim to maintain a robust subsidy to help low income Americans gain connectivity. Furthermore, the Commission should maintain the nationwide provider designation; continue to allow resellers to participate in the program; take a targeted approach to minimizing waste, fraud and abuse; and approach a cap to the program with care.