CPUC Warned Not to Restrict Participation in Low-Income Pilots

The California Public Utilities Commission could shut out many wireless providers from participating in a proposed state LifeLine pilot if it proceeds with proposed rules, the National Lifeline Association (NaLA) warned. The CPUC received comments Tuesday on a proposed decision to approve two pilot programs to stack California LifeLine and federal affordable connectivity program (ACP) benefits (docket R.20-02-008). Verizon cautioned the CPUC to allow “reasonable network management.”

The CPUC may vote June 8 on the draft order to approve wireline and wireless broadband pilots. Participants could get access to up to $57.15 -- or up to $102.15 on tribal lands -- of combined state and federal support for the plans (see 2304260061).

"Rather than heeding the advice of wireless service providers, the Commission has proposed ... a wireless pilot Tier A plan that is an unrealistic platinum-plated unlimited plan that does not exist in the retail marketplace and therefore has no basis,” NaLA commented. That plan would include a free 4G smartphone and unlimited voice, text and mobile data and 50GB of hot spot data at 4G or higher speeds. Meanwhile, the wireless Tier B plan, which includes largely the same requirements except with only 30GB of hot spot data, “is based on a TracFone/Verizon proposal that is a market-leading, ultra-high value offer based on network-owner economics and the purchase power of Walmart, and is unlikely to be offered by other wireless California LifeLine providers,” said NaLA.

Don’t expect any wireless carrier to offer the A plan, or anyone but Verizon to offer the B plan, said NaLA. The association suggested the CPUC review the pilots’ results in 60 to 90 days and consider reassessing its approach then.

The state pilots “will provide critical access to affordable connectivity to California’s disadvantaged communities and households eligible for LifeLine and ACP,” said Verizon's Tracfone. However, it has concerns with the proposed wireless pilots preventing carriers from slowing subscribers’ speeds until they use 150GB on the A plan or 80GB on the B plan. Tracfone, which would likely provide the B plan, "would not intentionally reduce a subscriber’s speed,” Verizon said. “But like all carriers and plans," it could reduce a wireless customer’s data speed "temporarily in times of network congestion.” The carrier may not participate if that isn’t allowed.

It's good that participation is voluntary in the wireline pilots, said the California Broadband and Video Association. "Certain restrictive requirements, including the proposed speed minimum, data caps and reporting requirements, could deter pilot program participation," the cable group said. The CPUC proposed requiring unlimited 100 Mbps download and 20 Mbps upload speeds, or the highest available service in that location.

Use the federal 25/3 Mbps standard instead for the wireline pilot, said CalTel and other small local exchange carriers. Don't require wireline carriers with no data caps to track individual customers' usage, they warned: Tracking is expensive and small LECs might not participate.

Consumer groups supported the proposed pilots. However, The Utility Reform Network and Greenlining Institute suggested not requiring social security numbers. “Some eligible consumers may not remember or do not have access to this information," such as people with unstable housing, they said. Also, TURN and Greenlining suggested the CPUC clarify that participants may choose to use their current phones rather than be forced to get a new device. Center for Accessible Technology said the pilots’ proposed two-year end date “will ensure a responsible use of LifeLine funds.”