In a letter to FCC Chairman Julius Genachowski, Rev. Jesse Jackson made several suggestions to the FCC on reforming its Lifeline and Link Up programs and closing the broadband gap.
The full text of Rev. Jackson’s letter follows:
The Rainbow PUSH Coalition and I, personally, have been active in the discussions on Lifeline and Link-Up reform, filing comments, speaking with commissioners, and following the debate. I commend you for taking on the difficult task of reforming these programs. However, as we approach a vote on the final order, I am concerned that some of the proposed rules will limit the availability of Lifeline to low income Americans.
I support the Commissionʼs universal broadband goal and, clearly, the largest challenge to reaching that goal is finding ways to increase penetration in the low income community. It appears that, in this order, the FCC will begin taking steps to adapt Lifeline to meeting this need. As you are well aware, this will be a long process. Itʼs a big jump from pilot programs to a significant increase in broadband penetration in the low income community.
My concern throughout these proceedings has been two-fold. First, as we begin to explore ways to close this “broadband gap”, we cannot abandon our commitment to providing the poorest Americans with basic voice service. It is a necessity for survival. In your remarks on January 9, you recognized the importance of basic telephone service in todayʼs world: “Lifeline recipients rely on their phones to do everything from finding a job to coordinating child care to calling 9-1-1 during an emergency.” If we fail to address this ongoing need for basic voice service, even as we move toward universal broadband, we will relegate a vast number of citizens to the fringe of society. Low income Americans need cell phones today, as well as broadband tomorrow.
At Rainbow PUSH, we see the effects of lack of phone service on poor people everyday. Churches become answering services–if you have to provide a phone number and donʼt have one, you give out the church number. You struggle to communicate with employers or arrange job interviews, keep track of children, communicate with teachers, arrange child care, obtain basic services, deal with emergencies, and more. Without a phone, actions that middle class Americans take for granted can become insurmountable tasks.
We experience the problems everyday, and we have seen the joy and sense of relief when an individual receives a Lifeline cell phone. Broadband should be supported, but not at the expense of basic telephone service for Americaʼs poor.
Although there has been a lot of media attention lately on free Lifeline wireless phone offerings, there has been little discussion of the benefits such offerings bring. Lifeline provides just the type of basic service mentioned in your January 9 remarks and without it poor Americans would have no viable communication alternative. Moreover, the free cell phone program spares the very poorest from having to pay out-of-pocket costs, costs that may seem minimal to most but are simply out of reach for many Americans.
While fiscal responsibility is necessary in all government programs, I am concerned about your proposal to put Lifeline “on a budget”. You offered no specifics in your talk, but “budget” sounds very much like a cap. Rainbow PUSH and many other groups have opposed capping the Low Income Fund from the beginning. You rightly recognized in your remarks that the program will expand and contract based on economic conditions. As has been pointed out numerous times in this process, even with the increase in Lifeline enrollment due to our current economic downturn, only around 1/3 of qualified households are participating in the program. A cap on the Low Income Fund or a cap targeted to the Lifeline program is incompatible with the mission Congress intended for the program. A cap will keep many poor families from enrolling in and benefitting from Lifeline.
If it is impossible for the 2/3 of qualified households not participating in Lifeline to enroll, then the program, in effect, no longer exists for them.
Second, as you address fraud, waste and abuse in the program, it is inappropriate to create barriers to enrollment that will limit the participation of qualified, low income individuals that Congress created the program to serve.
Any fraud on the part of Lifeline providers or enrollees must be addressed. Any bad actors in the program must be dealt with and eliminated. However, in terms of enrollees, I would suggest that much of what has been labeled overt fraud is the result of a lack of program clarity for applicants that results in unintended fraudulent behavior. Thatʼs why Iʻm encouraged to see that youʼre proposing “new measures to ensure that consumers are informed of program requirements.” If these measures do not result in added restrictions to enrollment, they can be an important step in maintaining the integrity of the program.
The leading Lifeline providers are actively combating fraud, waste and abuse. As you are aware, providers have implemented sixty-day non-usage procedures that will eliminate the problem of subsidies for unused phones. The industry itself has proposed and agreed to fund a non-duplication database, and Iʼm pleased to see that you are mandating that database in your order. Once itʼs implemented, the problem of subscribers having more than one Lifeline phone will be minimized. Also, industry leaders have proposed and are exploring the establishment of an eligibility verification database. Such a database will simplify the enrollment process, remove the burden of documentation from the enrollee, and minimize the possibility that those who are not qualified will receive Lifeline benefits.
The database solution is the best solution for both the duplication problem and verification of program eligibility. In our filings, we have consistently argued against requiring the poor to produce “food stamp letters” or other documentation to enroll for Lifeline. Low-income Americans often have unstable housing conditions that affect their ability to maintain consistent sets of records. Often, records are lost or destroyed. As a result, low income Americans frequently do not have readily available the original documents that prove they are receiving government benefits.
Also, most low-income individuals do not have easy access to the technology that will allow them to get these documents to the phone provider. It is typically a challenge for poor people to access the Internet, send a fax, make a copy or scan a document. Often, they must pay high fees for these services. As studies have shown, many, faced with these barriers, will abandon their efforts to enroll in the program and will be left nonparticipating and unconnected.
We have also consistently argued against requiring a monthly fee. Those who qualify for Lifeline are already facing economic hardship. In most cases, they are surviving on a meager monthly income that leaves them little room for extras, including a cell phone. Requiring a monthly fee will limit participation. Also, 9 million American households–17 million adults–are unbanked. This means that to send in a small monthly payment for phone service, say $1.00, an individual will have to purchase a money order or use a transfer service. Either one is an expensive proposition. Poor Americans would end up paying $5.95, $8.95 or more to simply transfer the fee to the phone company. This would put further financial pressure on struggling households and keep many from enrolling.
Finally, while we recognize modifications to Link-Up may be necessary, we oppose its complete elimination and encourage the FCC to recognize that Link-Up is an important subsidy for those smaller carriers that are most active in reaching the low income community. Without it, many may be forced out of business, leaving large parts of the low income community un-served. Also, as we move toward universal broadband, Link-Up may well be a necessary component in reaching the low income community with broadband service. We advocate a re-envisioning of Link-Up rather than its elimination.
There are now officially over 46 million people living in poverty in the United States, an all time high. The need for poor Americans to be “connected” through telephone service is critical and, while universal broadband is a goal we must strive for, access to a cell phone today creates employment and financial opportunities that would not be there otherwise. Lifeline and Link-Up are needed now more than ever. Now is not the time to create barriers to Lifeline access or limit the ability of carriers to reach out to low income communities.
I appreciate the effort that you, your fellow commissioners, and the FCC staff have put into the reform process. As you shape the final form of the order, I hope you will carefully consider the points I have made here. Lifeline is a program that serves “the least of these” and I hope the reforms you enact allow its benefits to be experienced by more of our fellow citizens in need.
Keep Hope Alive!
Reverend Jesse L. Jackson, Sr.
President and Founder
Rainbow PUSH Coalition