The National Association of State Utility Consumer Advocates (NASUCA) offered the Federal Communications Commission a number of ideas on Universal Service reform and its impact on the goal of universal broadband. On creating a broadband program for low-income households, NASUCA agrees that universal service support should be made available so low income consumers and their households can obtain broadband service on more affordable terms. The National Broadband Plan, NASUCA argues, should include plans for a Lifeline for Broadband program. However, similar to the goal of universal service for plain old telephone service ("POTS"), the goal of universal service for broadband must necessarily be a long term goal which will take years to accomplish. A Lifeline for Broadband program will assist not only the low income consumers but aid broadband providers by increasing the take rate and return on investments. A baseline understanding of broadband penetration rates and targets for improvement are a necessary part of any regulatory effort that will flow federal USF dollars to broadband service providers. The Commission should recognize this fact and move with deliberation toward development of the baseline information needed to shape an effective and efficient program to promote universal broadband service among low income consumers.
