Cincinnati Bell may be a broadband advocate for lower income families, but it says that the FCC should not impose a minimum speed level on the Lifeline support program.
In particular, the service provider said if the regulator applies the 10/1 Mbps speed it set for the second phase of the Connect America Fund (CAF-II) program, it could create negative effects for low-income families.
"While the Commission did not propose a specific minimum speed, by referencing the 10/1 Mbps level of service requirement established in the Connect America Fund proceeding, CBT is concerned that the Commission may be considering imposing a minimum speed requirement such as 10/1 Mbps before customers may use Lifeline support for broadband service," said Cincinnati Bell in an FCC filing. "CBT believes it would be a mistake to do so."
One of the problems with imposing a 10/1 Mbps requirement is that it can't be delivered to every location.
This is because even at service providers like Cincinnati Bell, which has been rolling out FTTH throughout parts of its service area, a large part of its market is still served by copper-based facilities that have inherent distance and speed limitations. Some of these challenges include distance from a Central Office, number of users connected to a node, and simultaneous usage. Many of these challenges can't be overcome in each area until a service provider updates its facilities to fiber.
"CBT believes the Commission should refrain from setting a minimum speed but should instead make any service eligible that qualifies as "broadband" as described in the Commission's Rules," Cincnnati Bell said. "Establishing a minimum service level would automatically leave behind all consumers who live in areas that are not served by broadband at that minimum service level.
Another issue is understanding what consumers are willing to pay for. If the FCC imposed the 10/1 requirement it would mean that it could apply to all Lifeline support customers even if those customers don't want that level of service. Cincinnati Bell itself offers a number of broadband options that range from 2 Mbps to 1 Gbps in areas where it has built out its FTTH network.
The FCC has proposed a Lifeline subscription price of $9.25 a month for 10/1 Mbps, which is close to the same price as unsubsidized 5 Mbps/768 kbps service. Cincinnati Bell said a number of Lifeline customers might think the price is still too expensive.
Instead of imposing a specific service speed level like 10/1 Mbps, Cincinnati Bell said that the best "way to include the maximum number of consumers is to include the broadest possible area of eligible services."
The carrier said that "Although CBT understands the Commission's desire to ensure that consumers have access to the highest speed broadband service possible, a minimum speed requirement also would ignore the fact that many consumers consciously choose to use service at lower speeds. This is due to several reasons: all customers do not need service at that speed, availability and price."
Similar to Cincinnati Bell, a number of service providers including Comcast (NASDAQ: CMCSA) and CenturyLink offer low-cost lower speed broadband under their Internet Essentials and Internet Basics programs. CenturyLink (NYSE: CTL), which provides up to 1.5 Mbps for $9.95 a month, has joined Cox in supporting President Obama's new ConnectHome initiative, a pilot program that is designed to provide broadband to low-income families in 27 cities and one tribal nation.
Not everyone agrees with Cincinnati Bell's assessment.
The Communications Workers of America (CWA) union said the FCC should modernize the Lifeline affordable phone service program by adopting a 10/1 Mbps broadband speed standard, which is below the 25 Mbps threshold the regulator has already set as the minimum speed providers should deliver to consumers.
- see this FCC filing (PDF)
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