January 18, 2012
EX PARTE
Ms. Marlene Dortch
Secretary
Federal Communications Commission
445 12th Street S.W.
Washington, D.C. 20554
Re: WC Docket No. 11-42, Lifeline and Link Up Reform and Modernization; CC Docket No.
96-45, Federal-State Joint Board on Universal Service; WC Docket No. 03-109, Lifeline
and Link Up
Dear Ms. Dortch:
On January 17, 2012, Dale Schmick, Chief Strategy Officer, YourTel America, Inc., Vice
President of TerraCom and Chairman of the Board of COMPTEL, Jonathan Lee, counsel for
YourTel and TerraCom, and the undersigned met with Zac Katz, Sharon Gillett, Carol Mattey,
Kim Scardino and Garnet Hanley regarding the above-captioned Lifeline/Link Up reform
proceedings.
We discussed the Commission‟s amendment of the definition of voice telephony in
Section 54.101 of the rules and the impact of the change on carriers who had been designated
eligible telecommunications carriers (ETCs) by state commissions under the Commission‟s prior
definition of supported services. We stressed the need for clarity in any guidance the
Commission provides state commissions with respect to interpretation of the new rule in the
context of pending and new applications for ETC designation.
We emphasized the continuing importance of Link Up in providing assistance to low
income consumers to cover the cost of service activation fees. For more than a decade, the
Commission has made clear that both wireline and wireless carriers are eligible for “Link Up
support for the „customary charge for commencing telecommunications services,‟ as defined in
section 54.411 of the Commission‟s rules, including wireless activation fees.”1 Any changes or
revisions to the Link Up rules must be technology neutral.
1 Twenty-Fifth Order on Reconsideration, Report and Order, Order, and Further Notice of
Proposed Rulemaking, CC Docket No. 96-45, FCC 03=115 (rel. May 21, 2003) at ¶18.
Ms. Marlene Dortch
January 18, 2012
Page 2
We noted that the establishment of a National Database to verify consumer eligibility
and to check for duplicate coverage will go a long way toward reducing waste, fraud and abuse
in the Lifeline/Link Up fund.
If you have any questions or need additional information, kindly contact the undersigned.
Respectfully submitted,
/s/
Mary C. Albert
cc: Zac Katz
Sharon Gillett
Carol Mattey
Kim Scardino
Garnet Hanley