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Comment Sought on How NLAD Can Accommodate ACP Participant Addresses

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Released: November 21, 2013


Federal Communications Commission

News Media Information 202 / 418-0500

445 12th St., S.W.


Washington, D.C. 20554

TTY: 1-888-835-5322

DA 13-2240

Released: November 21, 2013




WC Docket No. 11-42

Comment Date: December 5, 2013
Reply Comment Date: December 12, 2013

In this Public Notice, the Wireline Competition Bureau (Bureau) seeks comment on waiving
certain Lifeline rules for the benefit of those individuals participating in state-administered Address
Confidentiality Programs (ACPs).1 ACPs allow victims of domestic violence or sexual abuse to keep
their residential address confidential from public records.2 These programs are administered at the state
level and provide victims with alternate, shared mailing addresses for use on public documents, such as
public benefit materials or voter registration.3 The addresses often include a P.O. Box along with an
individualized code tied to each participating consumer.4
In the Lifeline Reform Order, the Commission adopted a rule requiring subscribers to provide
their residential address to Eligible Telecommunications Carriers (ETCs) prior to receiving Lifeline
service.5 ETCs must transmit that residential address to the National Lifeline Accountability Database
(NLAD) when it is ready to accept subscriber information, in order to facilitate a check for duplicative

1 See National Center for Victims of Crime, Stalking Resource Center, Address Confidentiality Programs,
programs (last viewed Nov. 21, 2013) (describes the aims and purposes of the programs).
2 National Network to End Domestic Violence, Technology Safety: Address and Voter Confidentiality Programs, (last viewed Nov. 21, 2013).
3 See id. Many states utilize a single address for enrollees. See, e.g., The Attorney General of Texas, The Address
Confidentiality Program, (last viewed Nov. 21, 2013); Secretary of the
Commonwealth of Massachusetts, Address Confidentiality Program FAQs, (last viewed Nov. 21, 2013); Attorney General of North
Carolina, North Carolina’s Address Confidentiality Program (ACP),
47dd-a653-9ee175ac218e/ACP_Brochure_Eng-(2010).aspx (last viewed Nov. 21, 2013).
4 See, e.g., Colorado Department of Personnel and Administration, About the Colorado Address Confidentiality
ngoBlobs&blobwhere=1251736045538&ssbinary=true (last viewed Nov. 21, 2013); National Center for Victims of
Crime, Stalking Resource Center, Address Confidentiality Programs,
programs/stalking-resource-center/help-for-victims/address-confidentiality-programs (last viewed Nov. 21, 2013).
5 Lifeline and Link Up Reform and Modernization et al., WC Docket Nos. 11-42 et al., Report and Order and Further
Notice of Proposed Rulemaking, 27 FCC Rcd 6656 (2012) (Lifeline Reform Order). See also 47 C.F.R. §

support.6 The current Lifeline rules do not permit subscribers to use P.O. Boxes as their residential
We seek comment on whether the Bureau should waive the rule limiting the use of P.O. Box
residential addresses, to allow qualifying, low-income consumers who participate in state-administered
ACPs to receive Lifeline service. A potential Lifeline subscriber would provide the ETC with proof that
he or she is receiving mail at the address that has been designated by the state as the ACP address. ETCs
would then transmit that address to the NLAD as the residential address for that subscriber.8 We seek
comment on the types of official documents that ETCs should accept as proof of ACP enrollment and the
address formats used for ACP participants. We also seek comment on whether to waive the requirement
for ACP participants to fill out a one per household worksheet, in order to allow for more efficient
Lifeline enrollment for ACP recipients.9 Finally, we seek comment on whether any additional safeguards
might be necessary to ensure that any waiver provided does not increase the likelihood of waste, fraud
and abuse.
Pursuant to sections 1.415 and 1.419 of the Commission’s rules,10 interested parties may file
comments and reply comments on or before the dates indicated on the first page of this document.
Comments should reference

WC Docket No. 11-42

, and may be filed using the Commission’s Electronic
Comment Filing System (ECFS) or by filing paper copies.
Electronic Filers: Comments may be filed electronically using the Internet by accessing the
Paper Filers: Parties who choose to file by paper must file an original and one copy of each
filing. Filings can be sent by hand or messenger delivery, by commercial overnight courier, or by
first-class or overnight U.S. Postal Service mail. All filings must be addressed to the
Commission’s Secretary, Office of the Secretary, Federal Communications Commission.
o All hand-delivered or messenger-delivered paper filings for the Commission’s Secretary
must be delivered to FCC Headquarters at 445 12th St., SW, Room TW-A325,
Washington, DC 20554. The filing hours are 8:00 a.m. to 7:00 p.m. All hand deliveries
must be held together with rubber bands or fasteners. Any envelopes and boxes must be
disposed of before entering the building.
o Commercial overnight mail (other than U.S. Postal Service Express Mail and Priority
Mail) must be sent to 9300 East Hampton Drive, Capitol Heights, MD 20743.

6 See 47 C.F.R. § 54.404(b)(6).
7 See Lifeline Reform Order, 27 FCC Rcd at 6695, para. 87 (stating that P.O. Boxes are not allowed to be used as
residential addresses on Lifeline application and enrollment forms).
8 See 47 C.F.R. § 54.404(b)(6).
9 Because many states’ ACP programs operate through a single address, without such a waiver, many ACP
participants would have to fill out a one-per-household worksheet. See Lifeline Reform Order, 27 FCC Rcd at 6691,
para. 78 n.208. Even with such a waiver, however, pursuant to the Commission’s eligibility certification
requirements, an ACP participant would still need to certify s/he is only receiving one Lifeline benefit per
household. See 47 C.F.R. § 54.410(d)(3)(vi).
10 47 C.F.R. §§ 1.415, 1.419.

o U.S. Postal Service first-class, Express, and Priority mail must be addressed to 445 12th
Street, SW, Washington DC 20554.
People with Disabilities: To request materials in accessible formats for people with disabilities
(Braille, large print, electronic files, audio format), send an e-mail to or call the
Consumer & Governmental Affairs Bureau at 202-418-0530 (voice), 202-418-0432 (tty).
The proceeding this Notice initiates shall be treated as a “permit-but-disclose” proceeding in
accordance with the Commission’s ex parte rules.11 Persons making ex parte presentations must file a
copy of any written presentation or a memorandum summarizing any oral presentation within two
business days after the presentation (unless a different deadline applicable to the Sunshine period applies).
Persons making oral ex parte presentations are reminded that memoranda summarizing the presentation
must (1) list all persons attending or otherwise participating in the meeting at which the ex parte
presentation was made, and (2) summarize all data presented and arguments made during the
presentation. If the presentation consisted in whole or in part of the presentation of data or arguments
already reflected in the presenter’s written comments, memoranda or other filings in the proceeding, the
presenter may provide citations to such data or arguments in his or her prior comments, memoranda, or
other filings (specifying the relevant page and/or paragraph numbers where such data or arguments can be
found) in lieu of summarizing them in the memorandum. Documents shown or given to Commission
staff during ex parte meetings are deemed to be written ex parte presentations and must be filed
consistent with rule 1.1206(b). In proceedings governed by rule 1.49(f) or for which the Commission has
made available a method of electronic filing, written ex parte presentations and memoranda summarizing
oral ex parte presentations, and all attachments thereto, must be filed through the electronic comment
filing system available for that proceeding, and must be filed in their native format (e.g., .doc, .xml, .ppt,
searchable .pdf). Participants in this proceeding should familiarize themselves with the Commission’s ex
For further information, please contact Michelle Schaefer, Telecommunications Access Policy
Division, Wireline Competition Bureau at (202) 418-7400 or TTY (202) 418-0484, or
- FCC -

11 See 47 C.F.R. §§ 1.1200 et seq.

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