Federal Communications Commission	"FCC  XX-XXX"


STATEMENT OF
COMMISSIONER JESSICA ROSENWORCEL,
DISSENTING

Re: 	Lifeline and Link Up Reform and Modernization, WC Docket No. 11-42; Telecommunications Carriers Eligible for Universal Service Support; WC Docket No. 09-197; Connect America Fund, WC Docket No. 10-90, Order
Three years ago, the Federal Communications Commission decided to modernize the Lifeline program for the broadband era.  As part of this effort, the agency planned a series of changes to the program’s minimum standards that over time would refocus the program on broadband.  
However, in the intervening years it has become apparent that those who rely on Lifeline still depend deeply on the program for voice services and the formula used to update data minimums may have unintended consequences.  In other words, while the market has evolved, it has not moved in the ways we previously imagined.  As a result, several months ago a coalition including the National Consumers Law Center; National Hispanic Media Coalition; OCA—Asian Pacific American Advocates, United Church of Christ, OC, Inc., and CTIA filed a petition asking the FCC to pause the changes in support set to take place at the start of next month.  They made a compelling case that further study is warranted before making these adjustments because the impact of the changes could be severe.  I think that under the circumstances, this kind of pause is a smart approach.  In fact, I think it would be the best course for the FCC and the program right now.  I regret that my colleagues do not agree.  For this reason, I choose to dissent.
Finally, while I am sympathetic to the increase in minimum data allowances that are part of this decision, I fear this does nothing to provide the certainty we need for this program.  In fact, without pausing for review, the FCC will simply be back in the same place, wrestling with the same issues, and more of the same scheduled service adjustments at this time next year.

2