As the Commission draws closer to a decision on updates and changes to the Lifeline and Link-Up programs, the Public Interest Commenters encourage the Commission to think broadly and creatively with respect to potential pilot projects. The Broadband Technology Opportunities Program (BTOP) and Broadband Initiatives Program (BIP) have demonstrated that communities that are given the flexibility to design their own broadband deployment and adoption projects will be more engaged in the process which will lead to a better outcome for Lifeline and Link Up reform. There is no doubt that transitioning the program from a voice subsidy to a broadband subsidy will require more than just funds. However, it is important for the Commission to enhance the program so that each community can still utilize the Lifeline and Link-Up support within a program that is specially designed to meet the adoption needs of their community. These federal and state or local partnerships are not new to the Universal Service Fund, and we believe it’s critical that the Commission carefully employ broadband pilot projects to test how federal support can engage with local partners to measure the Fund’s ability to aid in broadband adoption. In addition to fostering federal-community engagement, the pilot projects must be designed in a way that test meaningful adoption hypotheses and permit meaningful examination of pilot data. To that end OTI, drawing on its experience as a BTOP program evaluator and its additional work with BTOP partners, offers an attached proposed Pilot Study Design, which the Commission can use in the design of a Lifeline and Link Up pilot program.

The Public Interest Commenters also agree that if the Commission wants to reach all intended participants of the Lifeline and Link Up programs, the Commission must redefine their “one per household” rule to legitimately encompass consumers that may be living in group homes or who are homeless. Thanks to improvements in technology, we are now able to provide these consumers Lifeline access to communications through mobile telephony. As we transition to broadband, mobile broadband may be one service that can help this vulnerable population gain access to critical information available on the Internet.

The Commission’s notice of inquiry focused on four areas (1) designing, implementing and evaluating broadband pilot programs (2) limiting the availability to one per residence (3) revising the definition of Link Up service, and reducing Link Up support and (4) improving the verification process. The Public Interest Commenters have focused their reply comments on the first two areas noted in the Commission’s notice of inquiry.