Comments to the Federal Communications Commission Regarding the Emergency Broadband Benefit Program

The Consolidated Appropriations Act, 2021 establishes an Emergency Broadband Connectivity Fund of $3.2 billion and directs the Federal Communications Commission (FCC or Commission) to develop regulations for an emergency broadband benefit program (“program”) to disburse those funds. The Information Technology and Innovation Foundation (ITIF) appreciates this opportunity to comment on this program.

Despite years of significant gains, the United States still faces real challenges in closing the digital divide, challenges greatly exacerbated and amplified by the ongoing COVID-19 pandemic. ITIF supports quick disbursement of this critical relief—the Commission should focus first and foremost on quickly getting money out the door. However, it should also consider how the emergency broadband benefit program can serve as a bridge to a better, more rational subsidy program than the current Lifeline system. The Commission ideally could provide a voucher that gives flexibility and choice to eligible participants. The Commission should also avoid relying on the outdated Eligible Telecommunications Carrier (ETC) framework and aim to broaden participation by broadband providers. Finally, the Commission should design this program so that it could potentially be made a permanent tool to counter economic downturns, should Congress see fit to authorize and fund it.