Letter from David A. Super, Professor of Law to Marlene H. Dortch, Secretary of the Federal Communications Commission

Abstract

The availability of Lifeline cellular telephone service is extremely important to low income people for many reasons. Today, however, telephone access is clearly insufficient. As more and more governmental, economic, and social actors convert to using the internet as their primary interface with the public, low-income people with only telephone service will be increasingly marginalized. Some services and opportunities will be completely unavailable to them. Others will be available only in inferior forms. And still others will be available to telephone users only late, putting them at a crucial competitive disadvantage with others seeking the same opportunities. In this way, telecommunications will play an important part in ensuring that the poor get poorer. Moreover, even when an entity does provide a telephone alternative to web access, that alternative is commonly inefficient, requiring low-income individuals to spend large amounts of their own scarce time, and quite possibly to exhaust their allotment of Lifeline telephone minutes, to obtain what those with broadband access can obtain in a few clicks.