This week the American Library Association (ALA) submitted comments with the Federal Communications Commission in its Lifeline modernization proceeding. As it has done with its other universal service programs, including most recently with the E-rate program, the Commission sought input from a wide variety of stakeholders on how best to transition a 20th century program to one that meets the 21st century needs of, in this case, low-income consumers.
Lifeline was established in 1985 to help make phone service more affordable for low-income consumers and has received little attention as to today’s most pressing communication need: access to broadband. ALA’s comments wholeheartedly agree with the Commission that broadband is no longer a “nice-to-have,” but a necessity to fully participate in civic society. We are clearly on record with the Commission describing the myriad of library services (which may be characterized by The E’s of Libraries®) that are not only dependent themselves on access to broadband, but that provide patrons with access to the wealth of digital resources so that libraries may indeed transform communities. We well understand the urgency of making sure everyone, regardless of geographic location or economic circumstances, has access to broadband and the internet as well as the ability to use it.
In addition to making broadband an eligible service in the Lifeline program, the Commission asks questions related to addressing the “homework gap” which refers to those families with school-age children who do not have home internet thus leaving these kids with extra challenges to school success. Other areas the Commission is investigating include whether the program should adopt minimum standards of service (for telephone and internet); if it should be capped at a specific funding level; and how to encourage more service providers to participate in the program.
Our Lifeline comments reiterate the important role libraries have in connecting (and transforming) communities across the country and call on the Commission to:
- Address the homework gap as well as similar hurdles for vulnerable populations, including people with disabilities;
- Consider service standards that are reasonably comparable to the consumer marketplace, are regularly evaluated and updated, and to the extent possible fashioned to anticipate trends in technology;
- Allow libraries that provide WiFi devices to Lifeline-eligible patrons be eligible for financial support for the connectivity of those devices; and
- Address the affordability barrier to broadband access through the Lifeline program, but continue to identify ways it can also promote broadband adoption.
We also reiterate the principles (pdf) outlined by The Leadership Conference on Civil and Human Rights and supported by ALA that call for universality of service for eligible households, program excellence, choice and competition, innovation, and efficiency, transparency and accountability.
Now that the comments are filed, we will mine the public comment system to read through other stakeholder comments and consult with other national groups in preparing reply comments (we get an opportunity to respond to other commenters as well as add details or more information on our own proposals). Reply comments are due to the Commission September 30. So as always with the Commission, there is more to come, which includes in-person meetings if warranted. Also, as always, many thanks to the librarians in the field and those who are also members of ALA committees who provided input and advice.