20100610Comment (Nat'l Consumers League).pdf

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2010 JUN 10 PM 2ft 1 T 10. N A L CONSUME IS LEAl U ENational
ColllImers
LEAGUE
1701 K Street, NW, Suite 1200, Washington, DC 20006
PHONE [phone] FAX (202) 83'-0747 WWW.nclnef.org
June 10,2010
Ms. Jean Jewell
Secretary
Idaho Public Utilties Commission
472 West Washington Stret
Boise, ID 83702
Re: C¡¿se No. TFW-T-09-01-- I'etitionofTraqFQrie Wireless, Inc, for Designatioitas a.n
Eligible . Telecornunications Carrer
Dear Ms. Jewell:
lam writing to you On behalf of the National Consümers League i to express oürsupport for
efforts to help connect thousands of low-inCOme Idaho consumers to WIrele$s telephone service.
Specifcally, we ask that.youallow consumers to use subsidies received via the state Lifeline
program forthc purchase of wireless devices and services and to take other suitable regulatory
actiøns necessaryto !.HoW'lualifying luw..income Idahoans to access $uch services.
As we have stated in previous comments? Jwesupportthe use of state and ftxeral monies to
bring wireless teJephoneservice tolow-incol1econs1.mers, especially in rural communities, via
tèdetal and stte subsidyptogtas sucb as Lifeline.
For mOre thal1 a century, the NationalCol1sumets League bas advocated. on behalfofconsume~s
and workers. In that time, we have consistently supprtedpublìc poUcìes that help consumerS
access essential goods and services at affordable rates. Wireless telephones have been embraced
by more than 285 milion American consumers. More than 22% households have "'cut.hecord,"
choosing totepiace theirlandline telephones with wireless devices fbr all their caIHng needs.4
Among low..income consumers, in. particular, wireless devices and services provide many
advantages over tixed landline phones.
1 The National Consumers League, founded in i 899, is America's pioneer consumer organization. Our mission is to
protect and promote social and econom ic justice for consumers and workers in the United States and abroad. For
more iní'onnation, visit www.nclnet.org.2 Comments OtThe National Consumers League Concerning Federal-State Joint Board On Universal Service. FCC
Docket No. 96-45, January 7, 2009.J NeL Petitions Concerning Eligible Telecommunications Designations And The Lifeline And Link-Up Universal
Service Support Mechanism, FCC Docket 96-45, WC Docket 03- i 09, September 17,2004.4 CTIA-The Wireless Association. "Wireless Quick Facts: Year-End Figures," December 2009. Online:
http://www_ctia.orglmedia!industry info/index.cfm/ A I 0/10323
i(t~O
Jean Jewell
June 10,2010
Re: Case No. TFW-T-09-01
First, low-income consumers oftn do not remain in one residential location for extended peods
of time. Due to eviction, homeiessness, or the need to change residency to find employment,
frequent relocation is an all-too-often fact oflife for low-income consumers.s Wireless devices
can relieve such consumers of the need to frequently have their Lifeline phones service
reconnected after each move.
Second, low-income consumers may not have sufficient credit histories to qualify for traditional
residentiallandline phone. service should their personal tinancial situation improve to such an
extent thatthey 1'10. longer qualify for the state's subsidy programs. Such wireless consumers can
easily maintain uninterrupted service with wireless providers as they transition out of the Lifeline
program.
Third,as.an organization with a special focUS on the needs of workers, wear keenly aware of
the importance øftelephones to them, paicularly those workers who are maintaining multiple
Jobsto try and make ends meet. 6Suçh consumers are rarely at their place oftesîdenceandare
often unable to take advantage of even the limited. beneutsof fixed residential Lifeline phone
service. With thêàbility to keep Lifeline-enabled vvireless devices on.theIr person, low-income
COnSumerS could take advantage of thissetvice to remain in contact with essential government
services, cqrrentand potenti?l1 employers, and family and social SUpport networks regardless of
their geographic location. The mobilty advantage inherent with wireless deviqes isa significant
reason that nealya.quarterofAmericanconsumers have given up theirlandIinephone service.
Thercis no good reason why low-income consumers should iiot also he. able to benefit from the
advantages that such devices bring.
In conclusion, we urge you to allow low-income consumers to access the benefits of wireless
service via state subsidy programs. We believe that such access offers significant potential
beneutsto Idahoanslàcing economic hardship, paricularly in today's difficult environment. We
look forward to working with you as the Idaho Public Utilties Coiiimission moves lòrwardon
this.importait IS$ue.
Thank youfor your consideration.
SBetween 1999and200Q,slìghtlymórethl1l1 16%
of the U.S. population moved. By comparison, 33% of renters
and 28%ofpeopte living iriliouseho1ds below thepove.tt line moved. (Schaff, Kat "Why Do People Move?"
Departmeñt ørRural Sociology, Cornell Univerity. August 2002. Online:
http;!!www.:c.!!Qolbox.Q..:1£9Jll!!D1uil_planning/OOÖi61.html)
(, 1104% of low-wage workers (defil1edas workers ages 16 to 64 whose hourly wage rate is such that even if they
worked fuU~time, fUll-Year theirannualearningli would fall below the povert line for a familyof four) work
multiple Jobs compard with 7.6% ofhìgher..wageworkers.(Loprest,. Pamela et af. "Whoare Low. Wage
Workers?" Offce of the Assistant i:ecreia for Planning and Evaluation, Offce of Human Services Policy. U.S.
DepartmeliiofHealth and HUnil1l1 Services. februar 2009. Online:
htt.:¿laspe.hfis.!!ov/lisplO.9Low WageWorkersrb.pgf)
2
Jean Jewell
June 10, 20 I 0
Re: Case No. TFW-T.09-0J
Sincerely,
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