Letter to FCC regarding Lifeline

August 15, 2013

Marlene H. Dortch


Federal Communications Commission

445 12th Street, SW

Washington, DC 20554

Re: Ex Parte disclosure pursuant to 47 CFR � 1.1206(b) in MB Docket No. 09-182, MB Docket No. 07-294, BO Docket No. 12-30; WC Docket Nos. 11-42, 03-109; CC Docket No. 96-45

Dear Ms. Dortch:

On August 13, 2013 the following individuals, who represent members of The Leadership Conference on Civil and Human Rights Media and Telecommunications Task Force, met with Chairwoman Clyburn's chief of staff Michele Ellison, as well as her advisors Dave Grimaldi, Sarah Whitesell, and Rebekah Goodheart. Attending the meeting were: Corrine Yu and Christopher Paredes, Leadership Conference on Civil and Human Rights; Gabe Rottman, American Civil Liberties Union, Task Force Co-Chair; Cheryl Leanza, United Church of Christ, OC Inc., Task Force Co-Chair; Jason Lagria, Asian Americans Advancing Justice | AAJC; Hazeen Ashby, National Urban League; Mike Scurato, National Hispanic Media Coalition; Olivia Wein, National Consumer Law Center; and Todd O'Boyle, Common Cause.

We thanked the Chairwoman for her rapid action to release the framework for the Section 257 studies and encouraged the Commission to quickly incorporate our suggestions and approve the research framework. We encouraged the Commission to fund the studies and complete them in time for use in the 2014 Quadrennial Review. We explained that we did not believe that the form 323 data released at the end of last year was adequate to inform the Commission about the impact of media ownership rules on underserved communities, and that we believed these larger, more comprehensive studies would fulfill the Commission's obligation. We emphasized that the Commission is not in a position to modify the media ownership rules until it compiles a better record, which it does not have at this time. If the Commission is to complete the 2014 Quadrennial Review with adequate data, the time to embark on studies and research is now.

We also discussed the Lifeline program. We emphasized our support for the Commission's reforms and our belief that the Commission should continue implementing those reforms. We praised the Commission for making clear last month that Lifeline carriers must verify eligibility before beginning Lifeline service. We emphasized that enforcement should not unduly harm Lifeline recipients, since many recipients whom are in violation of the rules are in violation because carriers misled them about Lifeline rules and limits. Focusing on carrier compliance will also be more effective because the impact will be more widespread. Finally, we made clear that the new e-rate proposals should not be placed in competition with the Lifeline program, which remains woefully undersubscribed.

Please contact Leadership Conference Media/Telecommunications Task Force Co-Chairs Cheryl Leanza, United Church of Christ, OC Inc., at 202-841-6033, Gabe Rottman, ACLU, at 202-675-2325, or Corrine Yu, Leadership Conference Managing Policy Director at 202-466-5670, if you would like to discuss the above issues or any other issues of importance to The Leadership Conference.


Cheryl A. Leanza

Policy Advisor, United Church of Christ, OC Inc.

Co-Chair, Leadership Conference on Civil and Human Rights,

Media and Telecommunications Task Force

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