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Reply Comments on Lifeline and Link Up Reform and Modernization

May 25, 2011 |

New America Foundation (“NAF”) respectfully submits these reply comments in response to the Federal Communication’s Commission’s Notice of Proposed Rulemaking (“NPRM”) in the above-captioned dockets. NAF reiterates the need for the Commission to remain focused on the primary goal of ensuring vital communications access for all Americans as it reforms the Lifeline and Link Up fund. To that end, NAF believes the following reforms are critical to meeting that goal: expanding eligibility requirements to explicitly include Community Networks; permitting consumers to apply Lifeline discounts to whichever services, bundled or unbundled, they determine best meet their needs; redirecting a portion of savings from the High-Cost fund reform to the Lifeline program; and adopting a broader, more inclusive and innovative approach in its development of the broadband pilot program.

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