Saturday, September 12, 2015

FCC Lifeline comments: Cheap broadband is necessary but not sufficient

(I wrote the following for submission to the FCC as part of the National Digital Inclusion Alliance's comments on "Lifeline modernization", which includes FCC Chairman Wheeler's proposal to add a broadband Internet option to the Federal Lifeline telephone program.This was NDIA's response to paragraph 17 of the FCC's Notice of Proposed Rulemaking (NPRM), which says: "The ability to use and participate in the economy increasingly requires broadband for education, health care, public safety, and for persons with disabilities to communicate on par with their peers. As we ensure that Lifeline is restructured for the 21st Century, we want to ensure that any Lifeline offering is sufficient for consumers to participate in the economy.")
The Commission's goals for Lifeline Modernization include not just more access to the Internet for low-income households, but meaningful social and economic outcomes of that access in the areas of education, health care, public safety, and improved opportunities for low-income disabled Americans.

Affordable broadband access is necessary, but not sufficient, to produce those desired outcomes.
In his June 2014 report entitled "Digital Readiness", John Horrigan makes a critical distinction between the traditional "digital divide" -- the number of Americans who lack advanced Internet access -- and the phenomenon of "digital [un]readiness", i.e. the much larger number who do have advanced access but lack the skills to make meaningful use of it. In national survey research conducted for the Joint Center for Political and Economic Studies, Horrigan found that:
  • 29% of adult Americans have low levels of digital readiness, as measured by respondents’ understanding of terms about the Internet and self-reported confidence in using computers or finding information online. 
  • Digital readiness is a bigger problem than the digital divide. Some 18% of Americans lack “advanced Internet access,”  that is, either broadband at home or a smartphone; 15% are not  Internet users at all. Put differently, 70 million Americans are not “digitally ready” for robust online use, nearly twice the number (36 million) of people with no online access.   
  • Lack of digital readiness afflicts one in five Americans  who have advanced online access. Although non-Internet users necessarily lack digital readiness, 18% of people who have broadband or a smartphone register low levels of digital readiness. These Americans – possessing the tools but deficient in skills – exhibit far lower levels of Internet use.
In other words, ready access to broadband services for the vast majority of Americans at all income levels except the poorest has not, by itself, prepared all those connected people to function effectively on line.

Another Horrigan study sheds light on this access vs. skills question from a different angle. Deepening Ties is based on the second of two surveys of Comcast Internet Essentials participants conducted in 2014 by Princeton Survey Research Associates, with funding from the Comcast Research and Development Fund. Horrigan writes:
The most significant finding in Deepening Ties is the very large impact formal training has on digital literacy or the attainment of concrete Internet skills. Those who receive formal training from an IE program, library, or other institution (as opposed to informal assistance from family or friends) were significantly more likely to use the Internet to pursue economic opportunities and cultivate social ties. Those who received formal training were 15 percentage points more likely to use the Internet to look for a job, 14 percentage points more likely to use it to access government services, and 12 percentage points more likely to use it to connect with family and friends.
In other words, giving a low-income family access to cheap Internet service is significantly more likely to result in meaningful use of that service if accompanied by formal training in basic skills to enable that use.

This should not come as news to anyone. Effective community digital inclusion initiatives always combine affordable access (and affordable equipment) for digitally inexperienced residents with basic skills training and support from local, trusted entities.

Affiliates of NDIA have managed or served as major partners in some of the nation's most effective low-income adoption programs, including NTIA BTOP SBA and PCC projects at the multi-state, statewide and local levels; long-running public library digital literacy training and access programs; collaborative efforts led by city governments and universities; and programs maintained by community-based nonprofits large and small. 

Here’s what we know from this experience: For less educated, older and poorer Americans who lack both the resources and the skills to become effective Internet users, getting to digital literacy and meaningful Internet use generally requires...
1. affordable broadband access,    
2. affordable equipment,    
3. friendly hands-on basic skills training, and    
4. ongoing support from community, friends and/or family.

At $9.25 per month per household, the Commission will be hard pressed to provide eligible households the first of these essential ingredients through the Lifeline program, let alone the other three.

Of course the Commission should do what it can to leverage the potential of hundreds of millions of dollars in Lifeline broadband payments to get providers engaged in partnerships that help their new customers get access to training and equipment. After all, the faster they become adept with the technology, the sooner many of these customers are likely to trade up to faster, more expensive broadband services.

But the Commission must also acknowledge that Lifeline-supported broadband access will be just a first step toward the vision of digital inclusion and empowerment outlined in the NPRM. The impact of that first step will be immensely greater if it brings the nation closer to a comprehensive, long-term strategy for digital inclusion, rooted in local communities, that supports all of the ingredients needed to make it happen -- affordable access, affordable equipment, training and support.

Such a strategy doesn't exist now, and it won't be developed or implemented without strong, determined, consistent public leadership. At the national level, that leadership should come from the Commission, which more than any other Federal agency is responsible for pursuing the goal of universal broadband Internet access.

We encourage the Commission to:

1) Make basic digital skills training and support, including collaboration with community providers, a competitive advantage and/or qualification for participation in any Lifeline broadband initiative, either as a traditional ETC or as a non-traditional or innovative provider.

2) Take the lead to convene appropriate U.S. agencies with digital inclusion practitioners and other stakeholders to develop plans (with resources) to leverage Lifeline broadband access with community training and support to advance meaningful uses that are important to the respective agencies, including but not limited to:
  • the Department of Health and Human Services and Centers for Medicare and Medicaid Services with respect to Patient Health Record adoption
  • the Department of Justice with respect to community safety applications
  • the Treasury Department, Consumer Financial Protection Bureau, Federal Trade Commission and Federal Reserve with respect to online financial services, financial literacy and Internet safety
  • the Departments of Labor and Commerce with respect to workforce readiness
  • the Department of Education with respect not only to the K-12 concerns outlined in the NPRM, but also to adult education including GED preparation.

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