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National Association of Regulatory Utility Commissioners
National Association of State Utility Consumer Advocates
JOINT RESOLUTION
Requesting the Joint Board on Universal Service and the FCC to
Increase Subscription to Lifeline and Linkup by Changing the Eligibility
Standards and Subscription Process
WHEREAS, The National Association of State Utility Consumer Advocates
(NASUCA) and the National Association of Regulatory Utility Commissioners
(NARUC) recognize the national goal of universal telephone service;
WHEREAS, Many low-income families, including the elderly and many
working poor Americans, do not have basic local telephone service
due to such factors as the cost of service, the overall cost of
living, and the availability and level of financial assistance programs
other than Lifeline;
WHEREAS, NASUCA and NARUC strongly support the Lifeline and Link-Up
programs, which are intended to enable low income customers to obtain
telephone service through federal and state subsidies that make
telephone service more affordable;
WHEREAS, the FCC in 1997 in its Universal Service Order ruled that
under the federal regulations a consumer would be eligible for Lifeline
and Linkup benefits only if the customer participated in Medicaid,
food stamps, Supplementary Security Income (SSI), federal public
housing assistance or Section 8, or Low Income Home Energy Assistance
Program (LIHEAP);
WHEREAS, it is commonly accepted that some low income persons,
particularly the elderly, are unwilling to participate in the public
assistance programs that would make them eligible for Lifeline and
Linkup programs;
WHEREAS, the shrinking rolls of public assistance programs due
to welfare reform are reducing the number of consumers eligible
for Lifeline and Linkup;
WHEREAS, consumer participation in Lifeline and Linkup, as well
as overall telephone subscribership rates, would increase by adding
level of income as an independent criterion for eligibility, independent
of participation in other public assistance programs;
WHEREAS, a reasonable level of income standard is 150% of federal
poverty guidelines;
WHEREAS, states that provide state support in addition to the federal
assistance for the Lifeline and Linkup programs may establish their
own eligibility standards;
WHEREAS, existing eligibility standards for this federal program
vary widely among the states and Lifeline subscription is especially
low in some states with narrow eligibility standards;
WHEREAS, a minimum federal eligibility standard applicable to the
federal program support, with a waiver for good cause, would increase
subscription to Lifeline and Linkup as well as overall telephone
subscribership;
WHEREAS, the enrollment in Lifeline and Linkup programs would be
increased by establishing automatic enrollment, whereby customers
are automatically enrolled in Lifeline and Linkup when they participate
in the public assistance programs that make them eligible for Lifeline
and Linkup, with such persons being given the option of declining
such enrollment and while establishing mechanisms for protecting
consumer privacy;
THEREFORE, BE IT RESOLVED that NARUC and NASUCA urge the Joint
Board on Universal Service ("Joint Board") and the Federal
Communications Commission
(AFCC@) to adopt rules for the Lifeline and Linkup programs that
establish a federal minimum income eligibility standard set at 150%
of federal poverty guidelines, which
standard would be the minimum for federal program support and with
temporary waivers for good cause; and,
BE IT FURTHER RESOLVED, that NARUC and NASUCA urge the Joint Board
and the FCC to adopt rules requiring telecommunications providers
to use automatic enrollment, with privacy protections and the option
to decline participation, for Lifeline and Linkup.
Approved by NASUCA: Submitted by:
June 19, 2002 NASUCA Consumer Protection Committee And
NARUC Utility Consumer Affairs Committee
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