On May 18, 2018, National Association of Regulatory Utility Commissioners (NARUC) met separately with Commissioner Carr’s chief of staff and Chairman Pai’s legal advisor. NARUC expressed their support for the Lifeline Notice of Proposed Rulemaking (NPRM) proposal of respecting the state’s role in program administration regarding eliminating ETCs and suggesting cooperative federalism between the Commission and the states.

However, NARUC does not agree with the Lifeline NPRM proposal for eliminating non-facilities-based resellers. Lifeline NPRM said, “To advance our policy of focusing Lifeline support to encourage investment in voice- and broadband-capable networks, we propose limiting Lifeline support to broadband service provided over facilities-based broadband networks that also support voice service.” NARUC commented on Lifeline NPRM’s reasoning behind supporting facilities-based carriers because they feel it “might spur additional investment in infrastructure.”

NARUC’s stance is that non-facilities-based carriers should continue because, not only do they currently serve 75 percent of eligible users, they could also disrupt service to millions of eligible users.