Cox California (Cox) Cox urged the Commission to adopt LifeLine Program guidelines that are technologically and competitively neutral, consistent with the federal universal service program, and simple and straight-forward. Cox argued that the Commission should adopt the service elements required for federal universal service programs because they are competitively and technologically neutral, straight-forward, consistent with the Moore Act and do not contravene Section 710(a). According to Cox, the Commission should adopt minimum service requirements and rules that allow LifeLine subscribers to benefit from the competitive marketplace, just as non-LifeLine subscribers do. Cox argued that the Commission should not pursue “minimal” plans or “non-minimal” or any plans that traditional wireline providers can offer but which other providers, such as wireless and VoIP cannot. Cox characterized the proposals in the Scoping Memo regarding discounts equal to SSAs are discriminatory, not competitively-neutral, and in violation of the Moore Act because they would apply to only one type of provider. According to Cox, the Commission must allow the existing practice of including LifeLine in bundled service offerings; a rule stating otherwise would be discriminatory towards LifeLine consumers and contravene LifeLine’s purpose. The Commission, according to Cox, should adopt a definition of basic service/LifeLine service that allows, but does not require, VoIP providers to participate in the LifeLine Program. Cox argued the Commission should not adopt any proposal that would continue the cap on LifeLine rates, set a statewide rate, or cap the amounts LifeLine providers are reimbursed. Cox asserted that the Commission should not re-litigate issues it has resolved relatively recently, including, but not limited to, the SSA and use of the
Cox California (Cox) Cox urged the Commission to adopt LifeLine Program guidelines that are technologically and competitively neutral, consistent with the federal universal service program, and simple and straight-forward. Cox argued that the Commission should adopt the service elements required for federal universal service programs because they are competitively and technologically neutral, straight-forward, consistent with the Moore Act and do not contravene Section 710(a). According to Cox, the Commission should adopt minimum service requirements and rules that allow LifeLine subscribers to benefit from the competitive marketplace, just as non-LifeLine subscribers do. Cox argued that the Commission should not pursue “minimal” plans or “non-minimal” or any plans that traditional wireline providers can offer but which other providers, such as wireless and VoIP cannot. Cox characterized the proposals in the Scoping Memo regarding discounts equal to SSAs are discriminatory, not competitively-neutral, and in violation of the Moore Act because they would apply to only one type of provider. According to Cox, the Commission must allow the existing practice of including LifeLine in bundled service offerings; a rule stating otherwise would be discriminatory towards LifeLine consumers and contravene LifeLine’s purpose. The Commission, according to Cox, should adopt a definition of basic service/LifeLine service that allows, but does not require, VoIP providers to participate in the LifeLine Program. Cox argued the Commission should not adopt any proposal that would continue the cap on LifeLine rates, set a statewide rate, or cap the amounts LifeLine providers are reimbursed. Cox asserted that the Commission should not re-litigate issues it has resolved relatively recently, including, but not limited to, the SSA and use of the
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