California Digital Equity Capacity Subgrant Program Draft Guidelines – Submitted Public Comments

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• DE Capacity Subgrant Program Draft Guidelines

The following comments were received in response to the Digital Equity Capacity Subgrant Program Draft Guidelines during the 30-day public comment period between September 30 and October 29, 2024. All public comments submitted through the public comment form were reviewed by the Office of Broadband and Digital Literacy (OBDL). All comments received are a part of the public record and have been posted without change.

Only one set of comments per organization will be accepted/posted.

ID	Date	Name	Title	Type	Organization	City	State	Zip	Comments
6187	October 29, 2024 11:53 pm	Norma Cardona	Founder & CEO	Organization	Cultiva Greatness LLC	Merced	CA	95340	1. Program Background Individuals from the LGBTQ+ community and those who identify as women should be explicitly listed as Covered Populations. Including these groups acknowledges their unique challenges in accessing digital resources and ensures that their needs are prioritized in planning and implementation. 5. Eligible Use of Funds and Program Requirements Define “holistic” in the glossary: The term “holistic” should be clearly defined to ensure consistent understanding and application by applicants. A clear definition will help organizations understand what is expected when planning for comprehensive digital equity strategies. Through an equity lens, holistic might mean removing barriers to accessing digital literacy training, for example. That could entail providing childcare to parents, a meal, and scholarships for the training. Additional clarity is needed about the word “holistic.” Differentiate between “Broadband adoption campaigns” and “Broadband adoption efforts focusing on enrollment in affordable internet service programs”: These two terms are distinct and need clearer definitions. Broadband adoption campaigns should refer to broader awareness-raising and digital literacy efforts, while broadband adoption efforts focusing on enrollment in affordable programs should explicitly focus on connecting people to low-cost or subsidized services. 7. Proposed Allocation & Award Formula Covered Populations (75%) - The top five counties would be allocated almost 41% of the total grant funding. The percentage should be reduced to 50% and counties such as Merced, Tulare, and Madera should receive an additional equity stimulus to offset the limited funds allocated based on their population size. These counties often compete against metropolitan areas for state and federal funding, but their vast geographies, rural corridors, and socioeconomic factors require a more tailored allocation. Rural counties like Merced need greater funding to build sustainable digital equity ecosystems due to limited philanthropic support and fewer community-based organizations (CBOs). By providing these communities with larger allocations, the state can help close the digital divide more effectively in these areas. 8. Funding Restrictions Evaluation Costs: Increase the allocation for evaluation costs from 5% to 10%. Working with institutions like the University of California requires higher baseline costs for evaluations, typically around 35%. Increasing this to 10% would be more reasonable, especially for comprehensive evaluations in smaller counties. Administrative Costs: Increase the allocation for administrative costs from 3% to 10%. In smaller, rural communities, 3% is often insufficient to cover necessary administrative overheads. Raising the limit to 10% would allow smaller counties to manage their programs more effectively. 12. Proposed Schedule of Activities Later Close Date: Extend the application close date to February 28th to account for the December holiday period. A February 28th deadline, which falls on a Friday and is the last day of the month, provides applicants with more time after the holidays to prepare and submit well-developed applications.
6186	October 29, 2024 11:49 pm	Donna Ohr	Deputy Director	Organization	San Diego County Library	San Diego	CA	92123	1. Program Background Thank you for giving us the opportunity to provide comments to the Digital Equity Subgrant Program draft. We trust that ours and others' input will assist the CDT in refining the program, which will in turn enable us to advance digital equity and close the digital divide in our communities. Program Background We need more clarification of The Centralized Services and State Agency Digital Inclusion Efforts components for us to respond effectively to the RFA, avoid unnecessary duplication of services, and to better identify gaps in service delivery to the Covered Populations. 2. Goals of the Capacity Subgrant Program Stakeholder Engagement proposes that stakeholders should be involved in ongoing feedback regarding the effectiveness of the program and to provide input on potential solutions and improvements. If we need to substantially change course because of the input, will we have the ability to change aspects of the grant, including the shifting of the award monies? Track 1 – The ability to develop and refine local digital equity plans is needed by many of our regions, and we are glad to see that there is funding for this important activity. However, we need more guidance for what qualifies as an acceptable digital equity plan, especially as an approval of the plan is a prerequisite for the release of the rest of the award monies. In addition to developing or refining a DEP, the next step for many regions is to form a Digital Inclusion Alliance or Coalition. Does Track 1 cover the costs of such coalition building, as they are key to establishing long-term sustainability, which is one of the requirements of the grant? 3. Definitions In general, align definitions such as those used by NTIA, or recognized national digital equity and inclusion non-profits such as the National Digital Inclusion Alliance or Schools, Health, and Libraries Broadband Coalition. Specifically, expand the definition of Community Anchor Institutions to account for communities that do not have a traditional anchor, therefore including for-profits if they are the only point of gathering in that community. For example, an ethnic grocery store, hair salon, a park, or a kiosk. Provide a definition for Subgroups within a Covered Population. Allow for formerly incarcerated, former foster youth, homeless youth, immigrant communities, and farmworkers to be considered a Subgroup within a Covered Population or as their own Covered Population. Allow for regional/local applicants to define their own Covered Populations, Subgroups, and as determined. Provide a definition for Intersectionality. Address or add AI, and other new and emerging technologies. 5. Eligible Use of Funds and Program Requirements Allow our regions and localities to identify populations that are the most underserved in our areas, such as former foster youth, migrant farmworkers, immigrants awaiting relocation, transient populations, military families, etc. The result is that we can include more smaller and under-resourced non-profit and hyper-localized organizations as subgrantees as they have the specific knowledge of how to work with these populations and have their trust. Consider use of funding for Emergency Preparedness and Services, especially during wildfires, floods, earthquakes, and extreme weather events. This could cover having a stock of devices on hand to use in Local Assistance Centers, strengthening broadband and other infrastructure such as generators, in known evacuation centers, providing digital navigation assistance to evacuees, development of “on the spot” digital literacy programs for school-age children as well as adults in the evacuation centers, as well as digital navigation assistance and device and data needs after the emergency event is over, but residents are still attending to their own personal recovery. 8. Funding Restrictions Eliminate the device cost cap or adjust to the Cost of Living in California. The use of philanthropic organizations and private sector monies is already over-burdened in this area, and it takes time to develop and build a successful and sustainable funding relationship. Include funding for data plans as people need access to a device with a data plan first or simultaneously before other digital inclusion activities can take place and/or be effective. Increase Administrative costs from the 5% or $50,000. We suggest use of the 10% Administrative costs as outlined in NTIA’s Competitive Grant. 11. Post-Award Expectations Provide templates for reporting requirements, especially if not already referenced in the NOFA guidelines by a federal agency or regulation. Refine the DEEM tool or give us the flexibility to expand on it for our own use. After data is collected by the CDT and other State Agencies, provide that data in a format that can be manipulated, such as .csv. Create a real-time dashboard of our digital inclusion activities for use by us and the residents of California. Consider encouraging citizen scientists to use the collected data for innovative analysis, insights, and solutions for use by the State and grant awardees' digital inclusion activities. 12. Proposed Schedule of Activities We appreciate the timeline’s efficiency, especially regarding the administrative and technical reviews and final selection process. However, consider moving the Anticipated RFA Launch to start after January 1, 2025, instead of the proposed December 6, 2024, and move the rest of the schedule to the right one month. From Thanksgiving through the end of December is typically when many organizations, non-profits, cities, counties, and other jurisdictions “slow down” due to holidays, vacations, closures, reduced staffing, and the like. This will also give the CDT time to address and respond to the draft comments, especially further specification of the Centralized Services, which would aid in our Capacity Subgrant applications. 13. General Comment Not Related to Above Sections We appreciate the time and effort that cities, counties, nonprofit organizations, and others have taken to provide comments to the Capacity Subgrant draft. However, many others have not contributed, especially small and/or isolated communities, rural counties, and other historically isolated, under-represented, or underserved communities. Proactively reach out to these communities to seek their input, otherwise we risk perpetuating the inequity we are trying to cure. During the COVID-19 pandemic, the public became aware of the digital divide as it directly affected their lives, especially in the areas of work, health, and education. Now that the pandemic is over, the digital divide has slipped from the public’s awareness. The State, Counties, and Cities need to market the positive inroads into the digital divide that we have made with the federal funding that we received, thusly raising their awareness and support for more and continued federal funding. In comparison to other state awards, we recognize that the NTIA funding allocation of $70.2M for the California’s SDEP is inadequate and ask for more advocacy on the part of our legislators to correct this imbalance.
6185	October 29, 2024 11:04 pm	Paulina Chavez	Director of Programs	Organization	Everyone On	Los Angeles	CA		1. Program Background We recommend that the CDT provide a clear and transparent process for sharing updates and progress reports on the State Digital Equity Plan (SDEP). Regular updates on project milestones, funding allocations, and strategic shifts are crucial to ensure that local initiatives remain aligned with state-level actions. Additionally, given that device funding caps have been set through the competitive grant program, we suggest that CDT clarify how the different grant programs (such as the competitive and capacity subgrants) will be distinguished in future updates, particularly in terms of device-related funding. Ensuring transparency on how these funding streams are applied will help local organizations better understand where opportunities for device funding exist and adjust their strategies accordingly. Regular, accessible updates on the CDT website will further enable community organizations to stay informed and adapt their efforts to support the state’s progress. 2. Goals of the Capacity Subgrant Program CDT's strategy to promote "Long-lasting and Meaningful Change" will need to further elevate the importance of regional and local digital equity plans. It will therefore be important to highlight the importance of and funding for these local planning efforts to help communities identify their needs and chart out a path for sustainability and resource funding beyond NTIA grant dollars. Additionally, CDT should ensure that regional and local digital equity plans have mechanisms in place to move forward with implementation of the approved plans as part of the performance period. "This Program is structured around funding further planning, ecosystem development, and capacity building for statewide and regional/local coalitions" should also include program evaluation activities and data collection to further enhance local and regional knowledge of digital equity conditions. 3. Definitions Digital Equity Ecosystem Definition The current definition of the Digital Equity Ecosystem can be strengthened by highlighting the role of digital equity/digital inclusion practitioners in a regional or local ecosystem. Digital Navigators Definition Based on the current definition, Digital Navigators should be expanded/re-named to "Digital inclusion practitioners"; all digital navigators are digital inclusion practitioners, but not all digital inclusion practitioners are digital navigators. 4. Eligible Applicants Among the experiences outlined in Track 1 regional/Local Ecosystem applicants, CDT should also highlight experiences that have engaged with state-based investments and efforts through the CDT (e.g., development of the SDEP, MMBI) and CPUC (CASF outreach and technical assistance). Though these experiences do not necessarily have to be minimum requirements, they should be enhancing qualifications demonstrating the familiarity of the applicant with the State's Broadband for All programs and activities and thus likelihood for success. 5. Eligible Use of Funds and Program Requirements On "Plans to collaborate with or make second-tier subgrants to key stakeholders in the county/region, especially those that represent the interests of or provide services to Covered Populations," we strongly recommend that the capacity grant leave open the opportunity for lead applicants to add additional Tier 2 partners after submission and during implementation to provide allowances for Tier 2 partner readiness. In the "Development or refinement of regional/local digital equity plans" in addition to CDT-provided tools such as DEEM, CDT needs to also account for other locally-collected data and maps that provide additional insights on digital equity needs. The "Implementation of local digital equity activities" should include community planning engagement activities" that will assess broadband access, affordability, and adoption needs necessary to inform local digital equity plans. CDT should adjust requirement "Track 2 subgrantees must include a plan for regional/local coordination with Track 1 subgrantees". We agree track 2 subgrantees should be required to maintain regional/local coordination, however we believe they should be encouraged to coordinate with many different regional/local stakeholders that extend beyond Track 1 subgrantees. Therefore we recommend altering the requirement to "Track 2 subgrantees must include a plan for coordination with regional/local digital equity stakeholders". The required use of centralized services to support all regions may not work for all regions of the state. We encourage the CDT to consider a more decentralized, localized, flexible approach to uplift local knowledge maintained by local organizations and maintain existing community trust and engagement. Additionally, given that California is the most linguistically diverse state in the country, it's essential that the CDT acknowledges the diverse language needs in different regions of the state, outside of English and Spanish. We recommend the CDT not require the use of state tools such as DEEM and the state DE survey. We suggest the CDT offer the survey as a template tool, but allow communities the flexibility to adapt the survey to different regions, populations, languages, educational levels, etc., and most importantly different purposes. Additionally, some communities may want to adjust the number of questions to increase completion rates. Many digital equity practitioner organizations such as ours have existing digital equity surveys for communities, and it would be ideal to avoid duplication. Should the CDT require the completion of a centralized survey, then we recommend the CDT provide a revised version of the DEEM tool and Statewide Digital Equity Public Survey with recommended changes in consultation with digital equity practitioners across the state. We ask CDT to only require grantees to submit a limited number of state-mandated surveys per the grant period. We also ask the CDT to share the results of the survey, so digital equity advocates can adjust their plans to best fit the needs of the community and to cross-reference data between state and locally collected data. 6. Who This Benefits Focus on Covered Populations In Track 1: Regional/Local Ecosystems, we recommend that the sub grants prioritize local organizations that already have deep relationships with covered populations. By partnering with trusted community organizations, digital equity initiatives will have a better chance of reaching the most marginalized members. Additionally, we urge CDT to partner with expert digital equity practitioners to provide ongoing technical support and capacity building for smaller organizations to ensure their participation in regional ecosystems is meaningful and sustainable. 7. Proposed Allocation & Award Formula CDT should clearly outline how it will provide updates and maintain the SDEP, with a focus on both new and existing projects within the Capacity Grant Program. Publicly available reports on the CDT website will allow local governments and partners in Los Angeles County to coordinate their efforts, ensuring that digital equity is achieved through ongoing infrastructure support and community capacity building. A transparent reporting mechanism, such as regular public meetings or a dedicated dashboard, will ensure state and local efforts remain in sync and responsive to community needs. 8. Funding Restrictions Planning Costs: Please provide more detail on what specifically falls under planning costs. On Pg. 19 of the State Capacity Grant NOFO, there is mention of planning costs, but a clearer definition of what is included would assist subgrantees in budgeting for allowable expenses. Pre-Award Costs: We agree that pre-award costs should be an allowable expense, particularly given the importance of ecosystem building in this funding opportunity. Building capacity within communities is critical to ensuring they can participate fully in these programs. 9. Information Requested from Applicants Information on second tier applicants should not have to be identified before submission to the CDT. This would put a burden on the subgrantee applicant to identify all known beneficiaries in a short time frame, instead of executing a thoughtful process after award of contract requiring a hurried approach that requires a lot of upfront capacity on behalf of the subgrantee applicant. Letters of support should be open to any community leader – not just proposed partners. 10. Selection Information We encourage the State of California to identify and secure additional funding via either the Digital Equity Act, or other State of CA funding mechanisms, that a second round of Capacity Funding may be available for applications submitted that are not awarded grant funds. If more than one application is submitted per region, we recommend that this section be modified so it includes additional points for organizations that have established a large coalition of partners (including digital inclusion organizations) in the grant proposal. 11. Post-Award Expectations Financial Reporting, Technical Reporting: We recommend that the State of California, Department of Technology provide to all grant awardees sample financial reporting templates to ensure organizations are able to efficiently and effectively manage their grant awards. By providing templates and resources, community based organizations can reduce the amount of time spent on these potentially laborious tasks, and increase the amount of time spent completing successful digital inclusion activities post grant award. We also recommend that CDT hold an onboarding webinar for all grantees so that they may be properly prepared to track all activities in the correct technical reporting documents and templates during the grant period. Organizations should be given at least 30 days to complete their reports at the end of each reporting period. Execution and Performance Tracking Subgrant awardees be given at least 90 days for the Close-Out Period: Closeout Period: Final financial and technical reports are due within ninety (90) days after the end of the period of performance. Payment Process As it stands, Track 2's delayed payment processes may discourage small organizations with limited funding from applying for the grant. We recommend altering the guidelines to allow small organizations to be awarded a larger percentage of their grant once the subgrant performance period begins.
6184	October 29, 2024 9:19 pm	Abigail Esquivias	Director of Partnerships and Advocacy	Organization	Social Justice Collaborative	Alameda	CA		5. Eligible Use of Funds and Program Requirements In Track 1: Regional/Local Ecosystems, community-based organizations (CBOs) are seen as valuable “assets” for reaching underserved populations. However, due to program structure, many smaller CBOs, which are well-suited to deliver impactful services, may be excluded from applying. Limited staff, administrative capacity, and resource constraints are common barriers that hinder organizations from accessing funding for work they are already implementing. The program’s focus on county-wide or statewide reach may unintentionally overlook local organizations that are well-positioned to serve specific Covered Populations. These organizations often have strong community relationships, allowing them to provide effective, tailored services. While partnerships are valuable, the current structure may prevent resource-limited CBOs from applying, despite their positive impact. Given the role of CBOs, the program could be strengthened by providing a more accessible pathway for them. Alternatives might include support for partnership-building or a tiered application process that encourages initial participation and allows capacity-building over time. Additionally, adaptable survey tools would help ensure responses accurately reflect community needs, increasing response rates and data quality. 6. Who This Benefits An accessible application process could maximize program impact by enabling local organizations to participate fully. Supporting organizations in this way would help ensure digital equity efforts are responsive to California’s diverse communities. Emphasizing flexibility for applicants to adapt outreach and support based on their community’s unique and often intersecting needs could further increase the program’s effectiveness. 7. Proposed Allocation & Award Formula While the current formula considers various factors, it is critical to continue ensuring that resource distribution aligns with the unique barriers faced across different regions. In areas where existing infrastructure is minimal, high development costs may still limit the ability to meet long-term goals, regardless of population density or enrollment capacity. A nuanced approach that regularly assesses the formula’s effectiveness in addressing both urban and rural challenges would help ensure the program’s impact and sustainability. 8. Funding Restrictions To serve communities effectively, funding flexibility would help organizations respond to changing needs and adjust their approaches. For example, while the plan promotes “supplementing existing solutions in innovative ways,” it’s unclear how flexibility will be granted to address community-specific challenges. Clarifying this could encourage applicants to pursue creative approaches that directly serve their populations. The restrictions on device funding may limit the program’s effectiveness, as access to devices is critical for building digital equity. Allowing more flexibility could broaden reach and impact. The three percent cap on indirect costs might also prevent organizations from applying; adjusting this limit or offering exceptions could make funding accessible to a wider range of capable organizations. 9. Information Requested from Applicants For organizations serving Covered Populations, a demonstrated history of engagement is important. In underserved regions with few providers, community anchor institutions are often well-positioned to support the outlined goals. Accommodating alternative coalition models could better address the needs of high-need, resource-limited areas. 10. Selection Information If additional funding becomes available, and the current structure remains, CDT might consider a separate funding stream for localized projects led by organizations capable of impactful work within specific communities. Additionally, obtaining letters might be difficult in high-need areas where organizations serving Covered Populations are limited. Acknowledging this or allowing flexibility could enable more qualified organizations to apply. With Track 1 allowing only one application per county, will CDT provide facilitation or support to align stakeholders within each county? The single-application approach may not fully capture local nuances, given the diverse needs even within the same county. Facilitation could help align stakeholders and ensure a diverse planning process. 11. Post-Award Expectations The current timekeeping requirements could create an extensive administrative burden. Allowing applicants to track outcomes rather than minute-by-minute tracking would enable them to allocate resources toward program work rather than documentation. 13. General Comment Not Related to Above Sections The requirements appear tailored toward larger organizations with an established capacity for managing complex partnerships. This structure may unintentionally exclude community organizations that bring unique insights and impact. Streamlined processes or support in forming partnerships could better incorporate these organizations and the communities they serve. Focusing on flexibility in both application and implementation could encourage a broader range of organizations to participate effectively in achieving program goals.
6183	October 29, 2024 8:19 pm	Walter Siembab	Research Director	Organization	South Bay Cities Council of Governments	Los Angeles	CA	90056	1. Program Background Sustainability is one of four focal points identified in the draft NOFO. For example, many if not most of the very excellent navigator programs in Los Angeles County are using federal funds that are due to run out, like the ACP did. When asked about funding plans beyond the current grant, the typical response is philanthropy and another grant. The SBCCOG urges the CDT to prioritize projects that include a self-sustaining strategy. The SBCCOG urges the CDT to reduce the funding for state agency digital inclusion efforts and transfer those funds to the Capacity Subgrant Program. Digital equity is best addressed on the ground near the covered populations. For example, the City of Los Angeles Library Department and the Los Angeles County’s Delete the Divide program both offer a successful digital navigator program. It is unclear how the California Connect Corps program would enhance what already exists. State-produced standard tools and resources cannot possibly address the enormous variety of local contexts. Best to invest in the locals. The SBCCOG recommends adding an objective that will link digital inclusion to the challenge of climate change, both in terms of reducing the covered populations’ generation of carbon emissions and of enabling resilience in the face of extreme weather events. This is a form of environmental justice. Objective 2.3 refers to the Affordable Connectivity Program which is now depleted. The SBCCOG’s South Bay Fiber Network is the product of a public-private partnership and, with a modest amount of public subsidy from County transportation Measure M, was able to disrupt the market for broadband internet to cities and other community anchors. That is a better model for producing affordable access as it will not require annual support for large numbers of subscribers. 3. Definitions The SBCCOG recommends adding small businesses to the list of covered populations, especially those located in proximity to concentrations of any of the existing list of covered populations. 4. Eligible Applicants The SBCCOG recommends allowing more than one application from the County of Los Angeles. Large cities like Los Angeles and Long Beach, plus the Councils of Governments, have unique needs and a scale that defies packaging into one application. The SBCCOG recommends re-evaluating the formula used to allocate funds to each county. Under the existing formula, Los Angeles County will receive only $7.2 million. Based on the experience with the NTIA Competitive Grant Program, the State’s Capacity Grant Program should expect 40 or more applications from LA County. If half are funded, $360,000 will be the average award. $1 million is the smallest amount that can produce benefits for large jurisdictions like Long Beach, Los Angeles, or any of the Council of Governments. The SBCCOG consists of 15 incorporated cities. 5. Eligible Use of Funds and Program Requirements The SBCCOG recommends prioritizing projects based on an existing Digital Equity Plan seeking implementation funding. Readiness to implement will produce more benefits faster than funding the development of DEPs. The proliferation of AI tools adds urgency to an already urgent need for digital inclusion.
6181	October 29, 2024 6:50 pm	Sunne McPeak	President and CEO	Organization	California Emerging Technology Fund	Los Angeles	CA	90015-4133	1. Program Background The California Emerging Technology Fund (CETF) submitted detailed Public Comments in January 2024 on the Draft Digital Equity Plan. The CETF Comments were in support of the approach and called for Quantitative Goals to ensure a focus on Outcomes which prioritize reaching the most Digitally-Disadvantaged (Unconnected and Underconnected) Households (HHs). Connecting Digitally-Disadvantaged HHs is a bedrock for closing the Digital Divide, promoting Digital Inclusion, and achieving Digital Equity. Everything that can be done by harnessing the power of technology to transform lives (especially related to Outcome Areas) is built upon this foundation. This should be the primary purpose of the Capacity Grant. Action and accomplishment need to be the focus of the Digital Equity Plan. Investing in more "planning", given all the expenditure of funds to date for planning (more than the total of the Capacity Grant itself), is neither prudent nor productive, unless it relates to immediate action. The availability of data to inform action, and the Outline for a Local Government Strategic Plan to achieve Digital Equity (attached and posted on the CDT website) are excellent resources to spur action and deliver results sooner rather than later. It takes about 40 hours of quality staff time to complete a Local Government Digital Equity Plan, including community engagement. The best way to inform future planning is by "doing"—getting real-time experience by actually reaching Unconnected and Underconnected HHs using known Best Practices and validated templates coupled with a statewide Digital Equity Ecosystem to support implementation. CETF provided in its January 2024 Comments, a projection of the number of Unconnected and Underconnected HHs by Covered Population based on the 2023 Statewide Digital Equity Survey. This included a compelling analysis regarding the common characteristics among the HHs in Covered Populations who are not online to make it easy for the State to set Quantitative Goals. CETF showed, with data analytics, that there is an overwhelming concentrating of poverty. This same data was presented to the California Broadband Council and Statewide Planning Group. However, the Digital Equity Plan did not fully incorporate that input and, therefore, the Draft Guidelines lack Quantitative Goals and Outcomes. While there are criteria for evaluation metrics, they may not be sufficient to drive optimized results. It is incumbent upon the State to set targets for how many households overall will get connected to the Internet and become digitally-proficient as a result of expending $70.2M from the Capacity Grant, including administration and overhead costs, which as currently proposed are very high. Without upfront Quantified Goals there will be insufficient initial focus on obtaining measurable results in closing the Digital Divide from the Capacity Grant. In addition, CETF submitted detailed responses in July 2024 to the CDT Questionnaire with an extensive description of an efficient, cost-effective Digital Equity Ecosystem which must be operated at scale. Although the term "Digital Equity Ecosystem" appears in the Draft Guidelines, the approach indicates a need for a better understanding of the practical implications. The purpose of a Digital Equity Ecosystem is to avoid duplication in each County or Region. It is cost-effective when operated at scale, which, by definition and design, then has the ability to accommodate every CBO that has capacity for and expertise in delivering services in-language and in-culture. This enables the trusted-messenger CBOs to focus all of their efforts on reaching low-income HHs in the Covered Populations without re-inventing wheels and duplicating costs. Feedback on Specific Facets of the Draft Guidelines The primary focus of the Capacity Grant implementation for "building capacity" should be on low-income HHs in Covered Populations, and secondarily on the organizations, communities, and regions that serve them. This approach means that projected and expected Outcomes must be stated in terms of the number of HHs who get connected to the Internet with affordable service and become digitally-proficient so that they have more capacity to get out of poverty. This clarity is missing in the Draft Guidelines. If the funding allocated within each County is used only to support planning or any other activity in the name of "capacity building" without a requirement for Quantified Goals for Covered Populations low-income HHs to be served, then the impact of the $70.2M will not be optimized and much of the funds will end up paying consultants to do plans that sit on shelves. Organizational capacity is best built by "doing" which does require adequate support to achieve success that is enabled and empowered through a Digital Equity Ecosystem. This includes training, coaching, and convening of Learning Communities to facilitate peer learning and accountability among the implementing Grantees. The following summarizes feedback on specific facets of the NOFO. • The Digital Equity Grant Guidelines for Sub-Grants must include Quantified Goals in terms of the projected and the expected target number of low-income Unconnected and Underconnected HHs in each County to be connected to the Internet with affordable service and provided Digital Literacy Training based on the CDT proposed funding allocation. While a Grantee may target a specific Covered Population, given the statistical concentration of poverty, outreach in-language and in-culture must focus on low-income households with an emphasis on Covered Households. And, of course, reporting on HHs reached and served must be by all Covered Populations. • CDT should provide a projection of the number of Unconnected and Underconnected low-income households in each County by Covered Population based on the 2023 Statewide Digital Equity Survey to be reached so that applicants understand the nature of the challenge as well as the expected Quantified Goals. CETF has prepared an analysis of potential target goals by County and Region to close the Digital Divide based on the number of ACP-Eligible HHs enrolled and remaining to be reached, which can be provided to CDT upon request. • If the State decides to allow Capacity Grant funding for planning, then it should be limited to a specific percentage of the Sub-Grants, such as <25%, and should be subject to conditions that will ensure the planning leads to action, such as: (a) the jurisdiction must designate a staff person who will lead both the planning and implementation process; (b) the process must include community engagement and forums; (c) the plan must align to the State Digital Equity Plan; (d) the process must be coordinated with the Regional Broadband Consortium and CPUC through the case workers; and (e) the jurisdiction must participate in 3 convenings of workshops in a statewide Learning Community. CETF strongly urges CDT to encourage Local Governments to review the Digital Equity Strategic Plan Outline before starting a planning process because it will help them drive to action sooner. • The specific nature of the Centralized Services needs to be delineated for transparency with an explanation for the relatively large percentage of funding proposed for this category in contrast to the allocation for the Digital Equity Ecosystem. The Digital Equity Ecosystem is the key to optimizing impact in terms of the number of low-income households reached in each Covered Population. In addition to administration costs, which should be no more than 10% (CETF operates on 7% Support). The most valuable possible Centralized Services as "inputs" to the Digital Equity Ecosystem are Direct Notification to existing public assistance recipients and Public Awareness Advertising through community and ethnic media channels. • The specific definition and function of a Digital Equity Ecosystem needs to be set forth for clarity and transparency, including a delineation of the Essential Components. CETF submitted a detailed description in July 2024. An effective Digital Equity Ecosystem is not a static or passive resource; it must be managed proactively to engage, support, and coach CBO trusted messengers to drive to achieve Quantified Outcomes. • CDT should not purchase commercial products or contract with outside for-profit consultants for Centralized Services or Components of the Digital Equity Ecosystem because there are numerous California non-profit organizations with extensive experience who have developed all the Essential Components of a Digital Equity Ecosystem who are available to submit proposals in an open competitive process. Grants should be awarded based on documented performance and cost-effectiveness for management of the Digital Equity Ecosystem statewide without duplication in Regions and/or Counties. All Capacity Grants within each County should be required to report actual documented Adoptions for low-income Unconnected and Underconnected HHs regardless of whatever other activities on which they may be required to report. Policymakers and the public need to know per Grantee if any Unconnected or Underconnected HHs got connected to the Internet and trained as a result of the Capacity Grant. Planning in isolation of action is not enough. • There must be a standardized rubric for assessment of the results of Digital Literacy Training for all Grantees in all Counties so there can be comparison of performance. Attached is a comprehensive Digital Literacy Overview which includes: Facilitators Guides for both the first and second 3 Elements of the UNESCO (foundation set forth in a Governor's Executive Order in 2009); Digital Proficiency Self-Assessment Tool that is an example of a standardized metric needed for statewide use; and examples of quantified outcome impacts. • The Get Connected Call Center operates @ $65 per Unconnected HH Enrollment + $20 for screening-referrals to CBO synchronous Digital Literacy Training which is compensated at $350 for 6 hours of 3 Courses (Elements) aligned to UNESCO Framework with Digital Proficiency Self-Assessment for standardization and normalization statewide. Thus, a "full Adoption" (exclusive of the cost of a computing device) currently costs <$435 per HH. A rounded-up figure of $450 per Adoption allow for some additional outreach costs. At $450 per Adoption out of $37.91M proposed by CDT, 84,244 HHs can be reached. If $500 per Adoption were allowed to increase flexibility for outreach and coordination at the County and/or Region level, then 75,820 HHs could be reached. Please note that the $65 per enrollment + $20 for screening-referral needs to be paid to a Call Center or CBO doing the work and needs to be a set amount statewide for fairness and leverage of resources • Grantees need to be paid in a timely manner based on performance and not the unnecessary, labor-intense cost-reimbursement approach often used by the State. That kind of expensive overhead and lag time in paying Grantees is totally avoidable if the right structure is used for the Digital Equity Ecosystem, of which Grant Management for Adoptions can be a Component. Recommended Overall Principles and Strategies to Improve the Draft Proposal 1. The Capacity Grant should be used for the most fundamental actions to achieve Digital Internet service and trained to have sufficient digital literacy skills to improve daily living (with documented verification). 2. Outcome Goals should be established for public accountability (such as "Adoptions" per unit of funding) and to ensure fairness and equity across the state. There must be quantified Outcomes for an investment of $70.2M. Outcome Goals are essential to measure success. 3. A Digital Equity Ecosystem provides support for CBOs at scale for cost-effectiveness to minimize duplication of efforts. It should be the heart of "Centralized Services" other than government oversight and administration. Investment in a Digital Equity Ecosystem without unnecessary duplication throughout the state optimizes the ability to reach more Digitally-Disadvantaged HHs. 4. Once all low-income households are online and digitally-proficient, then development of program systems for Outcome Areas can have more impact. However, it is inefficient to invest in Outcome Areas if Grant recipients are not required to achieve Adoptions in the context of the Outcome Area program implementation. 5. Regular convenings of "Learning Communities" and grantee coaching are essential to ensure fidelity of implementation and optimize Outcomes. This sharing of best practices and connecting of communities of interest occurs regularly in many practice domains. 2. Goals of the Capacity Subgrant Program Recommended Overall Principles and Strategies to Improve the Draft Proposal 1. The Capacity Grant should be used for the most fundamental actions to achieve Digital Internet service and trained to have sufficient digital literacy skills to improve daily living (with documented verification). 2. Outcome Goals should be established for public accountability (such as "Adoptions" per unit of funding) and to ensure fairness and equity across the state. There must be quantified Outcomes for an investment of $70.2M. Outcome Goals are essential to measure success. 3. A Digital Equity Ecosystem provides support for CBOs at scale for cost-effectiveness to minimize duplication of efforts. It should be the heart of "Centralized Services" other than government oversight and administration. Investment in a Digital Equity Ecosystem without unnecessary duplication throughout the state optimizes the ability to reach more Digitally-Disadvantaged HHs. 4. Once all low-income households are online and digitally-proficient, then development of program systems for Outcome Areas can have more impact. However, it is inefficient to invest in Outcome Areas if Grant recipients are not required to achieve Adoptions in the context of the Outcome Area program implementation. 5. Regular convenings of "Learning Communities" and grantee coaching are essential to ensure fidelity of implementation and optimize Outcomes. This sharing of best practices and connecting of communities of interest occurs regularly in many practice domains. 6. Who This Benefits CETF strongly recommends that the primary lens for beneficiaries should be low-income Unconnected and Underconnected HHs in each of the Covered Populations as was submitted in January 2024 for the Draft Digital Equity Plan. CETF has submitted documentation of the concentration of poverty in all Covered Populations HHs who are Unconnected and Underconnected. 7. Proposed Allocation & Award Formula Recommendations for Capacity Grant Allocations  Increase funding to Counties and Regions that have higher potential to deliver more outcomes by reallocating proposed funding for Centralized Services. This can be contingent on performance and/or reallocation from Counties and Regions that do not achieve obligated Adoptions--incent a "race to the top" to get as many HHs online and digitally-proficient as soon as possible. Allocation of another $7M from Centralized Services to the under-allocated Counties @ $450 per Adoptions (total $7,090,200) will reach a total of 100,000 HHs. (Please see the attached spreadsheet referenced previously.) Recognizing the value in developing capacity "by doing" for on-the-ground outreach and implementation in each County and Region, with support from a statewide Digital Inclusion Ecosystem, CDT should consider as a basis for "reallocation" or "allocation of additional funds", the relative cost-effectiveness of performance when County Implementation Grants reach peak performance. This means that an approach to reallocation or additional funding would be reaching a performance benchmark of Adoptions that would trigger allocation of additional funds to provide incentives for optimizing the impact of the Capacity Grant. In order to report the budgeted activity to NTIA, this kind of an approach probably would require CDT to identify a specified amount of funds for the purpose of achieving additional Adoptions so that it could be used to compensate Counties for performance or underwrite additional Direct Notification and Public Awareness Advertising to drive enrollments through the Call Center in the Digital Equity Ecosystem.  Support quantified Outcomes (Adoptions) for Counties and Regions by increasing the allocation for statewide Digital Equity Ecosystem funding with higher amount allowed per Grant (>$2M per Grant and $7M for Counties and Regions and add <$6M for Digital Equity Ecosystem), leaving $13M or 18.5% for administration and overhead, which still is a substantial percentage of the Capacity Grant. Overall, there must be user-friendly comprehensive reporting on Quantified Goals: number of low-income HHs by Covered Populations connected to the Internet and trained to digital-proficiency with a standardized verification tool that will generate quantified impact data. The State must provide transparency in performance for all Grantees with an analysis of cost-effectiveness in terms of Adoptions per amount of expenditures: how many low-income HH are connected and trained (1) overall for $70.2M and (2) by Grantee per amount of Grant. There also should be a calculation and public disclosure of the amount and percentage of State administration and overhead costs per Quantified Outcome. CETF has an analysis of the potential for each County to contribute to closing the Digital Divide and can provide upon request because this form doesn't allow attachments. 13. General Comment Not Related to Above Sections This form should allow for attachments of documents that provide information and data to support the Comments.
6180	October 29, 2024 5:25 pm	Joshua Butler	Senior Policy & Advocacy Manager	Organization	Human I-T	Bell	CA	90201	1. Program Background Based on our experience in coordinating digital equity initiatives, Human-I-T suggests that CDT provide more detailed information on the activities and services that will be procured through “Centralized Services” within the Capacity Subgrant. Clarifying the scope of these services will help organizations better align their proposals with CDT’s objectives. 2. Goals of the Capacity Subgrant Program Human-I-T suggests adding a fourth goal. Goal 4: Promote the Sustainability and Resilience of Digital Equity Programs Statement: This goal aims to ensure that digital equity initiatives are built to last by incorporating sustainable practices and responsible e-waste management, while also establishing reliable technical support and community capacity-building to maintain long-term digital inclusion. The focus is on creating programs that adapt over time and continue to meet the evolving needs of Californians. Additionally, this goal reflects California’s commitment to reducing e-waste and promoting sustainability, in line with the Statewide Electronic Waste Recycling Act and climate policies such as the California Climate Action Plan. 8. Funding Restrictions Human-I-T recommends raising the cap on take-home devices from $300 to $400. Our experience providing high-quality refurbished devices indicates that increasing the cap will enable organizations to procure more durable and capable technology, thereby enhancing long-term program impact. Human-I-T supports maintaining the cap on planning costs at 5% to ensure that significant funding is directed toward implementation and direct services. Many regions have conducted extensive planning in recent years and are ready to implement their strategies. Allocating more funding to planning would detract from resources needed for immediate digital equity efforts. Human-I-T recommends increasing the allocation for computing devices to 33% of the budget. This aligns with Goal #2 in the State Digital Equity Plan, which states, "All Californians should have access to affordable broadband and necessary devices." Our analysis of device needs across the state indicates that the current fixed cap would cover only 0.21% of households without computing devices. Increasing the cap would allow for more equitable distribution of devices and ensure that the program’s goals are met. We suggest replacing the fixed-dollar cap with a percentage-based cap for device allocation. Human-I-T’s experience in providing digital equity solutions across diverse regions has shown that a fixed-dollar cap disproportionately limits larger areas with higher needs, while a percentage-based cap ensures that investments are proportionate to the demand. 9. Information Requested from Applicants Human-I-T recommends incorporating specific criteria in the application requirements related to experience in large-scale device distribution, particularly for organizations that have successfully provided affordable devices to underserved populations. Based on our experience, this criterion ensures that applicants with a proven track record are well-positioned to support the program's objectives efficiently and at scale. For Track 2 partners, Human-I-T recommends that applicants be required to provide a description of their experience and capacity working within California. This requirement would ensure that selected organizations possess a strong understanding of the state’s unique digital equity landscape and are better positioned to meet the needs of California's diverse populations effectively. We advise that applicants should not be required to identify all subgrantees before submitting their application. Given the short timeline and the significant administrative burden of coordinating multiple partners, subgrantee identification should be permitted after award selection. This flexibility would enable lead applicants to secure partnerships more effectively and assemble the strongest possible team once the funding is confirmed. 10. Selection Information Human-I-T recommends that experience in digital equity projects, particularly in device distribution and digital navigation, be heavily weighted in the selection criteria. With over a decade of experience operating at scale across California, we have seen the impact that seasoned organizations can make: increased efficiency in reaching Covered Populations, higher retention of digital skills among participants, and improved sustainability of digital equity programs. Experienced organizations bring established partnerships, streamlined processes, and a proven ability to adapt solutions to diverse community needs, all of which contribute to long-term program success and community empowerment. We recommend that CDT establish measures to enhance transparency and coordination among potential applicants. For example, allowing entities to disclose if they plan to apply for the same award could prevent duplication and encourage partnerships that maximize program impact. Human-I-T supports providing a minimum of 25% of grant funding upfront, in alignment with Assembly Bill 590. This measure would ensure that nonprofits do not bear financial burdens when supporting state activities. Our experience has shown that upfront funding reduces risk and allows for more equitable participation by smaller organizations. We recommend extending the upfront funding provision to second-tier subgrantees, requiring awardees to provide a minimum of 25% upfront to their subgrantees. Human-I-T’s work with community-based organizations has highlighted the financial challenges faced by smaller groups when required to cover costs upfront. Providing upfront funding would ensure that the program is accessible and equitable for all participants.
6179	October 29, 2024 5:24 pm	Adria Tinnin	Director of Race Equity and Legislative Policy	Organization	The Utility Reform Network (TURN)	Oakland	CA	94610	1. Program Background TURN joins Digital Equity LA in recommending that CDT create a clear and transparent process for updating the public, particularly members of existing state and local digital equity ecosystems, on progress reports regarding the State Digital Equity Plan (SDEP). This should include regular updates on project milestones, funding allocations, and any strategic shifts that occur. This information sharing is necessary to ensure local and regional initiatives remain aligned with state actions. 2. Goals of the Capacity Subgrant Program The second focal point NTIA requires CDT to consider is whether funded activities create "long-lasting and meaningful change," which TURN agrees is important. However, the description states that activities should "consider the sustainability of initiatives." TURN cautions CDT against thinking of "sustainability" in financial terms. This was a mistake made by the CDT when determining areas to prioritize in their "last mile" grant program. By prioritizing financial sustainability—or profitability—of a project, they inadvertently prioritize those places that would be most profitable, rather than prioritizing places with the greatest need. CDT should consider the sustainability of an initiative's impact on systems change and ensure that public dollars do not replicate the inequitable patterns created by the private sector. As currently written, Track 1 accounts for 54% of the funding allocated from NTIA, and Track 2 accounts for 9% of the funding; however, the allocation of the remaining 37% is unclear. All that is stated is that the remaining money will be used for "Centralized services, State Agency Digital Inclusion Efforts, and costs associated with administering the grant, evaluation, and maintaining and updating the State Digital Equity Plan." There is no explanation of what "centralized services" or "digital inclusion efforts" refers to. Providing transparency of these funds will increase public trust in CDT and help clarify to stakeholders how SDEP goals not covered in Track 1 or Track 2 are being addressed. 4. Eligible Applicants TURN agrees with UNITE–LA that Regional Broadband Consortia should be additionally mentioned among applying entities (such as workforce development programs). RBCs should particularly be highlighted given that the CPUC designated these organizations to build the ecosystems that CDT strives to build and strengthen in each of the state's county regions. RBCs are also well-positioned to leverage investments the state has been making to address digital equity on a regional basis. 7. Proposed Allocation & Award Formula This section is an opportunity to provide greater transparency into the process used to determine each county's allocation. Currently, there is no clear explanation as to why Los Angeles County received more than twice the allocation of the second-highest allocation (San Diego). Although CDT did a good job of providing a description of the evaluation criteria and the weight given to each criterion, it is unclear why counties with large covered populations, such as Alameda and Contra Costa, received much less.
6178	October 29, 2024 5:14 pm	Anna Alvarado	Policy Director	Organization	California EDGE Coalition	Sacramento	CA	95811	3. Definitions Recommendation to expand the definition of covered populations: While we recognize that the term “covered populations” was established in the state’s digital equity plan, we recommend adding opportunity youth (OY) to this category and ensuring regional plans address the needs of this specific group. The current definition of “covered populations” appropriately includes aging individuals (60+), women, veterans, people with disabilities, justice-involved individuals, and English language learners. However, OY—those between the ages of 16 and 24 who are neither in school nor employed—are not included in this initiative and are often overlooked in our systems. This group includes youth and young adults involved with foster care, the juvenile justice system, and those experiencing homelessness. They face unique challenges in accessing employment, education, and training that differ from those typically faced by adults. Opportunity youth are frequently disconnected from educational and workforce training programs due to socio-economic and systemic barriers, which disproportionately affect young people of color. They need reliable high-speed internet and access to technology, such as computers and tablets, to engage in educational and skills training programs, including mental health resources. In recent years, the state has made significant investments in youth apprenticeship programs, and these digital equity subgrants should ensure that OY are re-engaged in our education and workforce systems. Without access to technology, quality internet, or digital literacy skills, this population risks being left behind as the state works to uplift and support them. Additionally, the ongoing Master Plan for Career Education calls for expanding online education and workforce readiness, with recommendations to improve hands-on and work-based learning through state-level standards and tracking systems. This plan emphasizes the need for all learners, including OY, to be informed about work-based learning opportunities through an online resource hub and communications plan. For California to fully realize its economic potential and ensure equitable opportunities for all, it is critical to include OY in digital equity planning. Their access to technology is essential for their well-being and for advancing the state’s economic prosperity. 9. Information Requested from Applicants Recommendation to ensure robust data collection: It is crucial to gather high-quality data that can eventually align with California’s Cradle-to-Career (C2C) Data System. Recently, the Data & Tools Advisory Board voted to conduct a feasibility study exploring digital access to learning. Currently, the C2C system does not capture data on how access to digital tools and broadband impacts learning outcomes, graduation rates, or career readiness. The digital access proposal emphasizes that digital equity is essential for students to achieve key milestones and reach their full potential. A partnership between the Department of Technology and the Digital Equity Plan can align the state’s goals with data elements that C2C could track, such as identifying gaps in access, addressing the digital divide, enhancing digital literacy, and promoting social and educational equity. As regional plans for the subgrant programs are implemented, it will be advantageous to gather data that can eventually be integrated into the C2C system. This will help identify best practices and highlight any gaps or disparities, ensuring that we reach the most underserved Californians. Additionally, the guidelines should ensure that grantees receive the necessary support for data collection and reporting. The C2C system will also be launching a Workforce Data Taskforce to expand its scope to include workforce data elements, providing insights into the outcomes of individuals participating in workforce training programs. This aligns with the objectives of the State Digital Equity Plan. Ensuring quality data collection within the digital subgrant programs can support C2C’s ongoing efforts to expand its digital equity data and we encourage collaboration among state agencies to align goals that benefit Californians. 13. General Comment Not Related to Above Sections As CDT considers public feedback, it is important for future public comment processes to provide other avenues of feedback, such as submitting coalition letters on behalf of organizations that may not have the tools or capacity to engage at the state level. Through an online-only portal and not having the ability to include more than one organization, makes it difficult for communities to engage in the process. Coalition letters led by organizations who are familiar with state processes and have the capacity to do so can engage on behalf of communities who are being directly impacted by these types of state regulations and grant opportunities.
6177	October 29, 2024 5:05 pm	Susanne Sorensen	Owner	Organization	Vinhus	Solvang	CA	93463	5. Eligible Use of Funds and Program Requirements I am not sure what will be needed to follow through with this?
6176	October 29, 2024 5:03 pm	Trish Kelly	Managing Director	Organization	Valley Vision	Sacramento	CA	95817	1. Program Background Valley Vision, a civic leadership organization that serves the Capital region, appreciates the opportunity to comment on the California Department of Technology’s (CDT) State Digital Equity Plan (SDEP) Capacity Subgrant Draft Guidelines. As the Draft Guidelines note, the SDEP has unlocked $70.2 million in federal funding to support implementation of the SDEP. This represents a critical opportunity to support trusted, experienced, on-the-ground organizations that are committed to enhancing digital equity in their communities, but for too long have had insufficient resources to do so. (See page 20 of the SDEP: “Funding and Sustainability: The most cited barrier is the lack of sustainable funding.”) To ensure the most inclusive and effective use of these federal dollars, we offer this general comment rather than section-by-section comments on the Draft Guidelines: The CDT should adapt the Draft Guidelines to address the multiple comments and concerns being raised by stakeholders throughout the state about providing maximum funding and flexibility to local and regional entities that will be stepping up to do this important work at the local and regional levels. California is a state of great diversity. We see it in our varied geographies, populations, cultures, and digital equity needs. We therefore urge CDT to avoid top-down, one-size-fits-all requirements and instead work to ensure that as much funding as possible, along with programmatic flexibility, is provided to potential local and regional grantees who best understand their localized conditions and are closest to those who will be served by these dollars. Many effective digital equity services and resources already exist within our diverse communities. CDT can serve as a hub for highlighting best practices, sharing information, and building on this proven body of work versus duplicating or displacing it. CDT should further take to heart recommendations that the draft guidelines should be amended to provide more clarity around planning requirements, to address concerns about administrative spending limitations, and to be open to multiple grantees within a county when that might make the most sense at the local level.
6175	October 29, 2024 4:54 pm	Shirley Lam	Assistant Director of Policy	Organization	Insure the Uninsured Project (ITUP)	Sacramento	CA	95814	2. Goals of the Capacity Subgrant Program ITUP urges CDT's strategy to promote "Long-lasting and Meaningful Change" to further elevate the importance of regional and local digital ecosystems working in tandem and simultaneously. It will be essential to highlight the importance of and funding for leaders of the regional digital ecosystems to chart out a path for sustainability and resource funding beyond the NTIA grant dollars. ITUP is concerned for the bullet point on "Measurable Implementation Strategies." What is currently reflected in the text is vague and will prove to be slightly, if not more, challenging to execute measurements based off of the mandated timeline for implementing strategies. Not only should the implementation strategies be clear and well-documented, but there should be a component for program evaluation activities and data collection to further enhance local and regional knowledge of digital equity conditions. In the section written as "This Program is structured around funding further planning, ecosystem development, and capacity building for statewide and regional/local coalitions to implement strategies to overcome digital equity barriers," ITUP recommends that CDT also include program evaluation activities and data collection to further enhance local and regional knowledge of digital equity conditions. In the section that written section for "Objective 3.4: Increase the percentage of Californians who possess basic, intermediate, and advanced digital literacy skills," how is CDT defining and measuring whom is considered at basic, intermediate and advanced digital literacy skills? This will be important to define as well as indicate how often this will be re-evaluated to produce the most updated data. In the section that written section for "Objective 3.4: Increase the percentage of Californians who possess basic, intermediate, and advanced digital literacy skills," how is CDT defining and measuring whom is considered at basic, intermediate and advanced digital literacy skills? This will be important to define as well as indicate how often this will be re-evaluated to produce the most updated data. For the section that indicates "Track 1: Regional/Local Digital Equity Ecosystems and Implementation," ITUP urges CDT to consider in addition for Track 1 Funding for local digital equity plans and digital equity capacity building, the Program should additionally focus on the planning of broadband infrastructure development strategies as they align with long-term sustainability of broadband adoption and ecosystem development. For the definition of Digital Navigators: trusted community organizations or community members who conduct the following activities, ITUP recommends that CDT to include the addition of the following to the existing definition so that it reads as - Digital Navigators: trusted community organizations or community members who conduct the following activities, but are not limited to these activities: 3. Definitions For the definition of Digital Equity, what's written is the following, "the condition in which individuals and communities have the information technology capacity that is needed for full participation in the society and economy of the United States." ITUP urges CDT to add some additional language to the existing definition so that it is written as: The condition in which individuals and communities have the information technology capacity and accessibility that reaches and meets Californians where they are that is needed to fully participate in the society and economy of the United States. For the definition of Digital Equity Assets ("Assets"), ITUP urges CDT to consider including the physical assets that are needed to achieve digital equity - the Middle Mile Broadband Network (MMBN), state-owned land/buildings, utility towers, right-of-ways, and the physical locations of all community-anchor institutions across California. For the definition of Digital Equity Ecosystem ("Ecosystem"), ITUP recognizes that the current definition of Digital Equity Ecosystem is a great start, however we believe it could be even stronger with specific details highlighting successful community-driven efforts. Example: A digital equity ecosystem refers to the interconnected network of resources, stakeholders, and practices that work together to ensure equitable access to digital technologies and the internet for all individuals and communities. This ecosystem encompasses various components and entities, including but not limited to: Access: Availability of affordable and reliable internet and devices for everyone, particularly marginalized and underserved populations. Skills Development: Educational initiatives and training programs aimed at improving digital literacy and skills, enabling individuals to effectively use technology. Content and Relevance: Creation of digital content that reflects the diverse needs and cultures of different communities, ensuring that information is accessible and meaningful. Policy and Advocacy: Efforts by governments, organizations, and communities to create policies that promote digital equity and address systemic barriers. Collaboration: Partnerships among public, private, and non-profit sectors to share resources and strategies for improving digital access and literacy. By fostering a digital equity ecosystem, communities can work toward eliminating the digital divide and ensuring that everyone can participate fully in our modern digital age. For the definition of Digital Literacy: the skills associated with using technology to enable users to find, evaluate, organize, create, and communicate information, ITUP recommends that CDT to consider expanding this definition to include language access for cultural and linguistic competency. 4. Eligible Applicants For the section of Eligible Applicants, ITUP suggests that among eligible applicants, Regional Broadband Consortium should be additionally mentioned among entities (such as workforce development programs). RBCs should particularly be highlighted given that the CPUC designated these organizations to build the sort of ecosystems that the CDT strives to build and strengthen in each of the state's county regions. RBCs further are well-positioned to leverage investments the state has been making to address digital equity at a regional basis. For the section on Track 1: Regional/Local Ecosystems, ITUP recommends that among the experiences outlined in Track 1 regional/Local Ecosystem applicants, CDT should also highlight experiences that have supported and leveraged state-based investments and efforts through the CDT (e.g., development of the SDEP, MMBI) and CPUC (CASF outreach and technical assistance). Though these experiences do not necessarily have to be minimum requirements, they should be enhancing qualifications demonstrating the familiarity of the applicant with the State's Broadband for All programs and activities and thus likelihood for success. 5. Eligible Use of Funds and Program Requirements For the section of Development or refinement of regional/local digital equity plans under Track 1: Regional/Local Ecosystems, ITUP urges CDT to consider that the flexibility in the use of grant funds is essential for addressing the specific needs of underserved communities in counties. The guidelines should require the CDT to provide regular updates on SDEP outcomes and broadband access progress to ensure local communities are benefiting from state funding. Furthermore, the CDT should establish a process for ongoing public feedback as the SDEP is implemented, with updates shared through a centralized platform that tracks the impact on local communities, ensuring transparency and accountability. ITUP strongly supports CDT's vision and focus on developing regional and local digital equity ecosystems by utilizing existing partnerships and future collaborations to reach the intended Covered Population. Many Covered Populations face unique barriers to digital inclusion, especially those with language barriers, low digital literacy, and low-income households. To maximize the impact of these funds, it will be essential and crucial that subgrantees are required to work closely with community-based organizations that have deep, trusted relationships and act as trusted messengers serving the Covered Populations. ITUP encourages CDT to emphasize the need for culturally and linguistically appropriate services in digital literacy programs, and broadband adoption campaigns, especially for immigrant and refugee campaigns. In addition, CDT should provide flexibility for local organizations to design implementation strategies that reflect the realities and experiences on-the-ground, such as unincorporated areas, or communities where broadband access and affordability are still significant challenges. By aligning funding with the needs of the community and leveraging trusted partners, CDT can ensure long-term sustainability and success in bridging the digital divide. In addition to the section for the "timeline for implementation of the plan," ITUP suggests that there should be an inclusion of an evaluation of how things will be measured and what steps will be taken if anticipated results are not expected. For the section of "implementation of local digital equity activities," ITUP suggests CDT to consider including community-planning engagement activities and strategies that will assess broadband access, affordability, and adoption needs necessary to inform local digital equity plans. In the section of Additional requirements, ITUP is concerned about the quick turnaround time that CDT expects eligible grantees will be required to follow. Also, the section that lists out that "if a lead applicant is awarded for a multi-county area, a regional/local digital equity plan must be submitted for each county." ITUP is very concerned about the feasibility for local, small community-based organizations to execute this. This is a big ask especially when applicants are encouraged to collaborate and have MOUs in place. 7. Proposed Allocation & Award Formula For this section, ITUP recommends CDT to add additional clarifying language to this section. ITUP recommends that CDT should clearly outline how it will provide updates and maintain the SDEP, with a focus on both new and existing projects within the Capacity Grant Program. Publicly available reports on the CDT website will allow local governments and partners to coordinate their efforts, ensuring that digital equity is achieved through ongoing infrastructure support and community capacity building. A transparent reporting mechanism, such as regular public meetings or a dedicated dashboard, will ensure state and local efforts remain in sync and responsive to community needs. In addition, ITUP supports the state’s decision to limit broadband subsidies to no more than 10% of the subgrant. While subsidies can provide temporary relief, they are not a sustainable solution. These once-in-a-lifetime funds should prioritize long-term strategies that build lasting digital equity solutions. Also, ITUP agrees that pre-award costs should be an allowable expense, particularly given the importance of ecosystem building in this funding opportunity. Building capacity within communities is critical to ensuring they can participate fully in these programs. 9. Information Requested from Applicants ITUP applauds CDT's comprehensive and thorough section on the partnership information. This will prove to be essential in successfully implementing and executing digital equity plans to address the digital divide. However, the section for Track 2: Targeted Statewide Ecosystems second bullet point stating: The expected number of individuals to be served within each Covered Population - ITUP is concerned about how to accurately report this especially for those who are applying for this track of funding for the respective Health Outcome Area Working Group, as this would be applicable for the the entire health of all Californians. 10. Selection Information For the section that is indicated CDT will encourage one application per county, ITUP encourages CDT to consider that after selecting who receives the award, CDT should also connect the awarded grantee with others who were interested to see how they can continue to work together to see if they can braid the work and continue building the digital ecosystems. 11. Post-Award Expectations For the section that indicates the "Advance of Grant Subaward Funds Request," ITUP would like to request for additional information and clarification on the process for this and believes that this would be incredibly helpful for applicants to understand this process. 13. General Comment Not Related to Above Sections Insure the Uninsured Project (ITUP) values the immense amount of work and engagement that went into developing this draft California Digital Equity Capacity Subgrant Program, in particular as a health policy convener and expert in California, ITUP applauds the inclusion of statewide ecosystem and capacity building as an essential component and fundamental to the sustainability and longevity of addressing digital equity for Californians. ITUP appreciates the opportunity to provide feedback on California's draft of the DE Capacity Subgrant program. This initiative represents a comprehensive and inclusive approach to addressing the digital divide, particularly in historically marginalized and vulnerable communities. By leveraging the combined expertise of key partners, this application is uniquely positioned to ensure that the most marginalized populations—such as low-income households, communities of color, and individuals with language barriers—are included in digital equity efforts. The strategic vision, focus on long-term sustainability, capacity building, and collaboration with trusted community-based organizations, will ensure that digital inclusion is not just a short-term fix, but a lasting solution.
6174	October 29, 2024 4:27 pm	Maiten Mowreader	SD Access 4 All Program Coordinator	Organization	City of San Diego	San Diego	CA	92117	5. Eligible Use of Funds and Program Requirements We recommend the California Digital Equity Capacity Subgrant Program explicitly allow and encourage coalition-building efforts and the establishment of a backbone organization for First Tier applicants. These efforts would facilitate partnerships across public, private, and nonprofit sectors, ensuring long-term sustainability of digital equity initiatives. By creating a framework for diversified funding, including private or philanthropic investments, the program can better secure future resources for equitable digital access and infrastructure. This approach would significantly enhance local capacity-building efforts and improve long-term digital inclusion outcomes. We recommend that the California Digital Equity Capacity Subgrant Program allow sub-regional applications under Tier Two, particularly to address the unique needs of regions like San Diego. Centralized, state-wide services may not work for San Diego’s diverse communities, which include veterans, migrants, refugees, tribes, and unhoused populations. A decentralized, localized approach would better leverage local organizations’ expertise and maintain critical community trust. Additionally, San Diego’s linguistic diversity extends beyond English and Spanish, requiring attention to the specific needs of communities. 11. Post-Award Expectations We recommend that the California Digital Equity Capacity Subgrant Program develop clear and standardized templates for reporting, with specific, actionable data points. This would enable meaningful studies and research, maximizing the long-term benefits of the funds. The state must consider, holistically, what insights and outcomes can be gained from this investment. A standardized reporting framework will help ensure transparency and allow stakeholders to measure the true impact of the program on digital equity efforts statewide. Also, offering an onboarding webinar for grantees would ensure proper tracking of activities and use of templates throughout the grant period.
6173	October 29, 2024 4:17 pm	Carolina Mendez	Program Manager	Organization	#OaklandUndivided	Oakland	CA		5. Eligible Use of Funds and Program Requirements #OaklandUndivided recognizes the potential benefits and economies of scale of making proven tools and centralized services available to regional and local projects. However, our organization strongly opposes a top-down approach that requires the adoption of centralized services. Especially in a state as geographically and demographically diverse as California, a one-size-fits-all approach is not responsive to all people, places, and purposes. Decentralized, Localized, Flexible Tools Center Community: Ensuring that these tools are adaptable to the diverse needs and desired outcomes of communities across the state, will help overcome existing survey limitations, encourage higher response rates, and make them accessible to speakers of multiple languages beyond English, as a one-size-fits-all approach is not effective for different populations. We recommend the CDT offer the State Digital Equity Survey as a template tool, allowing local groups to customize questions, language, and format as necessary to reflect community priorities and cultural nuances. Organizations could further adjust the timing and delivery method tailored to their specific community, for example, through digital platforms, texting, or even paper forms where digital access is limited. Allowing this flexibility centers local expertise and protects the experience of covered populations, enhancing response rates and data quality. Local Surveys Combat Survey Fatigue: A top-down approach that requires the adoption of centralized services and assistance with the ongoing collection of responses from state tools will not work in most cities across California, including Oakland, which has unique challenges and differentiating needs. Oakland’s community anchor institutions and digital equity organizations already have tried and true digital equity surveys that reduce the burden on the community by only asking what is necessary to assess needs and deliver benefits. For example, Oakland Unified School District (OUSD) includes home digital access questions in annual back-to-school registration. These questions are tied directly to a community benefit - in this case, the provision of school-loaned Chromebooks and data-enabled hotspots. These targeted surveys combat survey fatigue by serving a specific purpose and providing shortened, strategically designed survey questions, increasing response rates and quality of feedback. Requiring OUSD to administer the State Digital Equity Survey would further exacerbate survey fatigue by including general questions intended to generate a state deliverable, without a clearly defined purpose for identifying and addressing the needs of the community. Centralized Surveys Increase Administrative Burden: We ask the CDT to consider the administrative burden on local organizations, further highlighted by the findings from the DEEM tool responses, which listed “lack of staff/org capacity” as the second most significant barrier impacting organizations. Requiring subgrantees to assist CDT with the ongoing collection of responses for the DEEM tool and Statewide Digital Equity Public Survey will place an undue burden on subgrantee staff. State Tools Require Revisions: If CDT plans to offer these tools to communities as a resource, then the State should provide robust opportunities for community input and revision that are inclusive of the Capacity Grant objectives. Specifically, we want to highlight that there are existing gaps between the DEEM tool and the State Digital Equity Public Survey that limit the effectiveness in capturing the full landscape of digital needs across California. These gaps include: State Digital Equity Survey - The survey responses lacked representation, as key demographic groups were significantly underrepresented. The majority of DE Public survey responses were collected digitally, with roughly 230 out of 36,300 responses submitted on paper, resulting in the most digitally disconnected populations being underrepresented. Similarly, the linguistic diversity in survey respondents lacked comprehensive representation, for example, only 6% of responses were in Spanish, 3% in Chinese, and less than 1% in other prominent languages like Arabic and Vietnamese. This indicates a gap among communities that are often overlooked. DEEM Tool - The DEEM tool results also highlight gaps, some counties lack a response and many have only one response. Additionally, only 68% of surveys were fully completed, indicating that many groups faced challenges finishing despite their intent. Moreover, while DEEM respondents named lack of funding availability as the top barrier impacting organizations, over 60% of the DEEM respondents reported difficulty in accessing these funding sources. The requirement of CDT’s “centralized services” would only further exacerbate this issue by adding unnecessary additional requirements. We recommend that these tools be shared with capacity grant recipients as optional resources, they should not be mandated. Local organizations have established relationships, expertise, and refined strategies to address digital equity in their unique communities. 7. Proposed Allocation & Award Formula The draft guidelines for the California Digital Equity Capacity Subgrant Program state that CDT developed a “formula-based approach to ensure geographic diversity and equity.” Alarmingly, the resulting allocations are anything but equitable. If CDT adopts the proposed allocation formula, Alameda County would have approximately $0.87 per covered person while Alpine would receive $168.29 per covered person (*for calculation methodology see end of comment). We appreciate the importance of capacity funding reaching all communities - urban, rural, and tribal - where covered populations reside; however, any formula that results in such a disparate allocation of funding deserves interrogation and further explanation. The State’s allocation for Alameda County fails to adequately address the concentrated need in the county, which as CETF’s analysis notes, has amongst the State’s highest number of ACP eligible households (209,926 households). What additional context can CDT provide as to how this funding allotment is considered equitable? We implore the CDT to reevaluate these “tentative” allocations, incorporating the following considerations into the revised guidelines: Reduce Allocation for State Activities: CDT must limit the funding it allocates to itself (e.g., administration, evaluation, planning activities, and centralized services). Under current guidelines, the State can claim up to 46% of the total allocation. Claiming nearly half of the total funding is in addition to the $5M the CDT already received to develop the State Digital Equity Plan. We urge CDT to protect as much funding as possible for the communities this one-time benefit is intended to serve. Consider BEAD Funding: The $1.87B in funding for BEAD will almost exclusively benefit rural communities. CDT should factor in this historic digital equity investment - nearly 20 times that of the DE Capacity Grant - into equity analysis and county allocations. Increase Funding for Highest Need Local Ecosystems: CDT should increase the total funding allocated to counties with the highest demonstrated need. At a minimum, CDT should detail plans to allocate surplus funding (e.g., additional tranches of CA funding from NTIA, surplus from counties not applying for or using their full allocation, etc.) to the highest need counties. *Methodology for Per Capita County Investment: Assuming a total award amount of $70.2M and 54% of total funding toward Track 1 (Regional and Local Ecosystem), California’s 58 counties must share approximately $38M. The NTIA requires CDT to prioritize covered population, and NTIA’s Digital Equity Act Population Viewer estimates that Alameda County has 1.4M total covered population while Alpine County, for instance, only has 1,129 total covered population. The current formula would allocate 3.2% of funding for Alameda County and 0.5% for Alpine. 8. Funding Restrictions Device access is one of the core pillars of digital inclusion. According to the Statewide Digital Equity Survey, nearly 1 in 3 California residents without home internet cite lack of device as one of the main reasons. Concurrently, organizations identified “lack of funding availability” as the top barrier impacting their ability to increase their digital equity programming on the DEEM tool survey. Without a computer or the funding needed for organizations to purchase devices, residents cannot fully access the information economy including social services, telehealth, online learning, and more. Additionally, the provision of computers represents one of the most direct benefits to covered populations. Setting a hard cap at $11,250/county for computer labs and $40,000 for take-home devices regardless of the total county allocation disempowers applicants. Community anchor institutions, like the busiest library branches in the most disconnected communities, can serve over dozens patrons a day with a single computer. Therefore, to arbitrarily cap an entire county’s computer benefit at 15 desktops is not responsive to many communities' needs. This cap will prevent subgrantees from achieving goal 2 of the Broadband for All Action Plan and State Digital Equity Plan: All Californians have access to affordable broadband necessary devices, as presented in the program background. Subgrantees demand for computers is evident in CA’s NTIA’s Competitive Grant submission. Given the flexibility to allocate funding for devices, the Oakland subgrantees in the Bay Area Digital Equity Competitive grant requested approximately 25% of total funding be designated for devices. Ideally, the competitive grant would fund most California’s device needs, but the NTIA is going to reject more competitive grant applications than it funds. The program is six times oversubscribed with 700 applications requesting more than $6.5 billion in funding to support digital equity projects across the country. We should trust our local communities to decide if buying computers constitutes a more significant proportion of their project budget. The CDT should encourage applicants to identify alternative funding sources while recognizing the end of COVID-era support from public programs (e.g., Emergency Connectivity Fund) and receding philanthropic interests is making purchasing devices exceedingly difficult. Instead of imposing an arbitrary cap, the CDT should encourage applicants to consider innovative strategies to ensure devices have the greatest possible impact like installing desktops in computer labs accessible to covered populations (e.g., public housing, libraries, juvenile hall, community centers). 9. Information Requested from Applicants Second-Tier Subgrantees: We recommend removing the requirement to identify second-tier subgrantees prior to submission. Requiring second-tier applicants to be named in advance places a burden on the primary applicant to pinpoint and assemble all beneficiary organizations within a very limited timeframe. This approach will force rushed decisions and affect the ability to conduct a thorough and inclusive vetting process. Allowing grantees to identify and formalize relationships post-award would support a strategic selection of subgrantees, further strengthening capacity grant objectives, and project outcomes and better aligning with digital equity plans that best meet community needs. Unique Entity Identifier (UEI): Requiring entities to provide a UEI can present a significant barrier for smaller organizations that are operating under another organization’s umbrella (e.g., through fiscal sponsorship). Many grassroots or community-based organizations (CBO), particularly those housed under a larger entity, may not have a UEI of their own. Without a UEI, these organizations could not directly apply as capacity subgrantees, potentially excluding critical CBOs that play a vital role in advancing digital equity. We ask the CDT to consider removing this requirement for second-tier organizations. 12. Proposed Schedule of Activities We ask the CDT to reconsider its timeline, especially due to the anticipated Digital Equity Competitive Grant announcements. Since the NTIA Competitive Grants will be announced on a rolling basis through April 2025 and the anticipated RFA closes in February 2025, there is a risk of either overlapping project plans or fewer competitive applications. With the Competitive Grant receiving over 700 applications, 20 of them from California, there is a high likelihood that many plans from CA may not be funded despite their merit. Without adequate time to pivot, potential Capacity Grant applicants may be discouraged from participating as they await their Competitive Grant decision. This exceedingly high demand for the Competitive Grant highlights the unmet needs across the state and the importance of strategic funding planning. Adjusting the CDT’s timeline would allow organizations to address unmet needs strategically, filling funding gaps, and ensuring that digital equity efforts are as comprehensive as possible across regions. We recommend the following: Extending the RFA period from 8 weeks to a minimum of 12 weeks to give applicants adequate time to design a robust Capacity Grant application and taking into account the impact of the holiday season. Allowing curing of applications after the February 6, 2025 deadline for regions that are awarded the Competitive Grant. The CDT should encourage NTIA to expedite its Competitive Grant decisions before the anticipated RFA launch on December 6 to avoid overlap. From our experience with the DE Competitive Grant, regional coordination and collaboration for these grants can be complex, especially given the variety of local stakeholders involved, each with unique needs, capacities, and community priorities. The shortened application window further magnified this challenge, requiring organizations to sync efforts in a short amount of time.
6172	October 29, 2024 4:03 pm	Krystal Rawls	Dr.	Organization	California State University, Dominguez Hills	Carson	CA	90745	1. Program Background 1. Program Background California has invested heavily in its Broadband for All initiative. While the CBC provides valuable updates, it can be challenging to track the evolution of various funding programs (DE Programs, BEAD, Middle Mile, Last Mile, etc.) and the implementation activities statewide. A centralized platform to visualize the entire funding ecosystem and its impact on closing the digital divide would be beneficial. Prioritizing DEEM respondents aligned with SDEP goals may optimize the tool’s value and impact. Consider DEEM as the primary resource for identifying Digital Inclusion Practitioners. 2. Goals of the Capacity Subgrant Program As outlined in the SDEP, the Community Advisory Committee (CAC) will be instrumental in guiding trusted organizations. Empowering trusted organizations to engage with the community and build strong relationships is essential for achieving long-term impact. The selection process for the CAC will be critical in ensuring that the true voice of the community is represented and that significant progress is made. Is California Connect Corps designated as a centralized service? Will it be considered the framework for local and regional digital inclusion activities? How will funding allocated to California Connect Corps be distributed, and will it affect the available funds for Track 1 and Track 2 subgrants? 3. Definitions CDT may consider adopting consistent terminology between NTIA and State guidelines, such as using terms like "lead applicant" and "authorized organizational representative/authorized representative.” Native Entities: All native entities, including Indian Tribes, Alaska Native entities, and Native Hawaiian organizations, should be included. 4. Eligible Applicants Ensure equitable distribution of funds when allowing applicants to submit for multi-county versus individual county. If a larger organization submits a multi-county proposal that overlaps with smaller, individual county projects, it's important to weigh the potential impact on creativity, innovation, and the ability to foster strong, localized community relationships. 5. Eligible Use of Funds and Program Requirements Track 1 subgrantees are required to use funds towards local digital equity templates and data collection tools (e.g. surveys). To optimize data collection and analysis, CDT may consider developing a centralized software application for Track 1 subgrantees to utilize. This would streamline the process and enable more effective data-driven decision-making across local and statewide initiatives. To strengthen regional digital equity efforts, consider partnering with organizations that are integrating DEEM into regional priorities to maximize impact. For instance, CSUDH interns put together a data visualization draft to connect DEEM partners with California Jobs 1st (formerly LAHRTC) to explore potential synergies. Digital Equity + California Jobs First Partners in Los Angeles | Tableau Public. 6. Who This Benefits The intersectional nature of identities makes it difficult to accurately count and categorize predefined covered populations. Many individuals belong to multiple marginalized groups, making it difficult to assign them to specific target covered populations. To ensure equitable service delivery, the CDT should consider the multifaceted experiences and needs of Covered Populations through an intersectional lens. 7. Proposed Allocation & Award Formula To optimize the impact of state investments in digital inclusion, prioritize organizations with a proven track record of successful digital equity program implementation, especially those that have previously received broadband funding. A weighted selection process or bridge funding approach that prioritizes organizations that have completed the planning phase and are ready for implementation or expansion will maximize the long-term benefits of these investments. 8. Funding Restrictions 9. Information Requested from Applicants  E. Disclosure of other sources of state or federal funding. Recommend sharing this information or request the state to identify potential partnerships to maximize the impact of funding. 10. Selection Information 11. Post-Award Expectations 12. Proposed Schedule of Activities
6171	October 29, 2024 3:56 pm	Jin Tran	Program Supervisor	Organization	Self-Help for the Elderly	San Francisco	CA	94133	8. Funding Restrictions We urge the State to consider allowing more flexibility in the allocation of funds within Track 1 to enhance the impact of local and regional digital equity efforts. The current cap of 10% on broadband subsidies, along with limits of $11,250 per award for devices in community spaces and $40,000 per award for take-home computing devices, may unintentionally restrict programs focused on providing essential technology and connectivity resources. Programs dedicated to digital literacy and skills training are most effective when paired with adequate access to devices and reliable broadband. Previous state and federal grants have demonstrated the necessity of substantial investments in technology, with up to 36% of their funding allocated to devices and data plans to meet community needs effectively. As the Affordable Connectivity Program ACP winds down and comes to an end, the covered population with limited income will not have access to affordable broadband and not able to keep up with the digital economy. Increasing flexibility in these funding limits will allow communities to better address their specific digital access needs, leading to greater inclusion and long-lasting impact. These crucial supportive services include housing, healthcare, workforce and education. We encourage the state to reconsider these funding caps to support well-rounded digital equity programs that connect underserved communities and provide them with the tools they need to succeed in today’s digital world.
6170	October 29, 2024 2:55 pm	Glenda Nelson	Tribal Chairwoman	Organization	Enterprise Rancheria of Maidu Indians of California	Oroville	CA	95966	13. General Comment Not Related to Above Sections Tribal Sovereignty and Program Flexibility The guidelines should acknowledge the unique governance and autonomy of tribal nations, allowing flexibility for tribes to design digital equity initiatives that are culturally relevant and respect tribal governance structures. In instances where "state" requirements conflict with tribal policies, clarifications should ensure these requirements do not override tribal laws. Inclusion of Tribal Lands in Broadband Development Goals The subgrant's broadband goals should prioritize underserved tribal lands where connectivity is historically limited. The guidelines should consider a dedicated tribal allocation or scoring priority for applications from tribal entities. Broadband availability and adoption metrics used for funding allocation may not accurately capture the needs in remote tribal regions or those with scattered housing or checkerboarded lands. Adjustments in the formula could better reflect the high needs in these areas. Define what the State sees as “Tribal Lands.” Support for Building Tribal Capacity Many tribes may require additional support to build capacity for managing large grants. Track 1 applicants should include funding allowances for capacity-building within tribal communities, including staffing and administrative support for tribal digital equity teams. Consider extending allowable percentages for administrative and planning costs for tribal applicants, acknowledging that the needs for capacity-building in tribal communities may exceed the current caps. Respecting Cultural Privacy in Data Collection While data collection tools such as the DEEM asset inventory tool are crucial, the guidelines should provide tribes the option to protect sensitive cultural data that may not be suitable for broader public databases. Cultural data includes, but is not limited to, sacred sites and culturally important plants and species from misuse or destruction. Tribes should retain control over digital inclusion and literacy data specific to their communities and have the authority to decide what information can be shared with external stakeholders. Centralized Services for Tribal Communities The document encourages using Centralized Services but should explicitly include services designed to address the specific digital literacy and language needs of tribal communities. Since many tribal languages are not widely supported, the guidelines should include provisions to allow tribal governments to seek exemptions or customize services that address these unique linguistic needs. Equity in Funding Distribution The Track 1 funding allocation per county may overlook the unique needs within tribal jurisdictions. A minimum tribal set-aside or additional weighting should be considered for regions with high tribal populations. For example, Butte County has a high population that diminishes funding per tribe. For Track 2, targeted statewide ecosystem funds could allocate a percentage solely for tribal-focused digital equity projects that address connectivity, device access, and digital skills for tribal members. Long-Term Sustainability and Self-Sufficiency The guidelines should outline strategies to ensure the sustainability of digital equity initiatives beyond the grant period, including plans for tribes to maintain digital inclusion programs independently or with reduced dependency on external funding. Tribal programs often require longer timelines due to trust land regulatory requirements, so the guidelines should consider allowing extensions for tribes if needed to ensure compliance and successful project implementation. Consultation and Stakeholder Engagement Stakeholder engagement processes should specifically incorporate tribal consultation protocols, ensuring that tribal representatives can engage in meaningful dialogue with CDT on program requirements and modifications. A formal advisory group comprising tribal representatives could provide ongoing input to CDT on digital equity challenges unique to California’s tribal communities.
6169	October 29, 2024 2:47 pm	Martha Glaser	Founder	Organization	Neighbors for Safe Metering	Sonoma	CA		1. Program Background The goal of Digital Equity for all citizens is of obvious and urgent need. Having taught in Community College and Public School settings, all students, all families in all parts of the state need to have access to affordable Broadband Internet Service. However, many students with Special Needs who require instructional support for documented Disabilities on I.E.P.'s are subjected to wireless radiation in the technology in their schools and homes. At least 10% of the population identifies as sensitive to wireless technology when in close proximity to these devices and antennas, causing physical pain and other symptoms. These devices include cell towers, hot spots, wifi-enabled computers, cell phones, and wifi routers. Use of internet routers without wireless antennas is straightforward and affordable. Using ethernet wired connections, which banks and medical offices often prioritize for cyber safety, also allows EMF-disabled citizens to enjoy broadband access without reliance on wifi devices like hotspots and routers. Wired fiber broadband, along with landline telephone connections, must be available for the EMF-disabled/injured/sensitive population among us. Wired Broadband will not only better serve this increasing population of citizens but will also be far more "Future-Proof." Wired broadband provides greater cyber security, data and privacy protection, and is more cost-effective in the long term. California absolutely needs wired fiber for all regions. 3. Definitions The goal of Digital Equity for all citizens is of obvious and urgent need. Having taught in Community College and Public School settings, all students, all families in all parts of the state need to have access to affordable Broadband Internet Service. However, many students with Special Needs who require instructional support for documented Disabilities on I.E.P.'s are subjected to wireless radiation in the technology in their schools and homes. At least 10% of the population identifies as sensitive to wireless technology when in close proximity to these devices and antennas, causing physical pain and other symptoms. These devices include cell towers, hot spots, wifi-enabled computers, cell phones, and wifi routers. Use of internet routers without wireless antennas is straightforward and affordable. Using ethernet wired connections, which banks and medical offices often prioritize for cyber safety, also allows EMF-disabled citizens to enjoy broadband access without reliance on wifi devices like hotspots and routers. Wired fiber broadband, along with landline telephone connections, must be available for the EMF-disabled/injured/sensitive population among us. Wired Broadband will not only better serve this increasing population of citizens but will also be far more "Future-Proof." Wired broadband provides greater cyber security, data and privacy protection, and is more cost-effective in the long term. California absolutely needs wired fiber for all regions.
6168	October 29, 2024 2:29 pm	Miguel Ange Segura	Director of External Relations	Organization	PIQE	Los Angeles	CA	90026	13. General Comment Not Related to Above Sections We are excited to express our strong support for the application being submitted by UNITE-LA, in collaboration with LAEDC and the DELA coalition, as part of Los Angeles' effort to advance digital equity. This initiative represents a comprehensive and inclusive approach to addressing the digital divide, particularly in underserved communities across LA County. By leveraging the combined expertise of key partners like UNITE-LA, LAEDC, and DELA, this application is uniquely positioned to ensure that the most marginalized populations—such as low-income households, communities of color, and individuals with language barriers—are included in digital equity efforts. Their strategic vision, focused on long-term sustainability, capacity building, and collaboration with trusted community-based organizations, will ensure that digital inclusion is not just a short-term fix, but a lasting solution. We are confident that this partnership will effectively address the barriers to digital access and opportunity for all Angelenos, and we strongly urge CDT to approve and support this vital application.
6165	October 29, 2024 1:59 pm	Katherine Fosburgh	Digital Access Analyst	Organization	Sonoma County Economic Development Collaborative	Santa Rosa	CA	95401	5. Eligible Use of Funds and Program Requirements The 5% or $50,000 cap on spending for a digital equity plan is low, especially for a regional application. The cap percentage should be raised (maybe 20%) or should allow for $50,000 per County for regional applications. Track 1 funding should allow for Counties, or whatever entity applied/is awarded funding, to use the funds for staff to carry out the grant program. The relationship building, organization, and coordination needed to carry out this work requires more capacity than many of these organizations have.
6161	October 29, 2024 1:50 pm	Michael Waring	Dr	Organization	Greater Cement Hill Neighborhood Association	Nevada City	CA	95959	2. Goals of the Capacity Subgrant Program Hello, thank you for your work in this category. I represent a few dozen households of my neighborhood area, and our region is already way behind on these goals. Notably we struggle with usable internet of proper MBPS and latency, delivered to the homes. Nearly all of my neighbors count as the Rural category, and many/most of us qualify for some combination of Aging 60+, below 150% of Federal Poverty income, Women, and Veterans. We are a group with overlapping needs. The largest obstacle remains connectivity. There is middle-mile fiber already underneath our roads, but no residential connections are possible. I've labored for over two years hoping to get some fiber connections made. Very frustrating! We've just learned that County Grant funding has been denied for our zone. FFA funding is unlikely for us, and CASF funding is also unlikely. Kari Sinoff with Sierra Broadband seems to indicate that BEAD funding is our neighborhood's last remaining hope for real infrastructure. Send help! Indian Trails and Eden Ranch, near Nevada City 95959. Help! We qualify! But we keep getting overlooked!
6159	October 29, 2024 1:49 pm	Sidnee Cox	Co-director/Pres	Organization	EMF Safety Network	Sonoma	CA		6. Who This Benefits Our organization supports the needs of the disabled population who are unable to use wireless technology and must rely solely on hardwired connections. An extremely disabling condition, known as Electromagnetic Hypersensitivity, affects at least 1.5% of the population in its acute phase according to scientific research. Our organization hears from many of them, and the numbers are increasing. Access to affordable and reliable broadband must include options for wired and cabled connections such as fiber optics networks. This growing segment of the disabled population needs to be accommodated. 2. Goals of the Capacity Subgrant Program While the goal of bridging the digital divide is noble and building out middle-mile infrastructure is essential, the last mile is most important. Increasingly, the telecommunication industry will be reaching the unserved or underserved via wireless signal with cell towers and small cells antennas. This will increase electromagnetic hypersensitivity in vulnerable populations. We understand that "technology neutral" is now the adopted approach, but we ask the CDT to consider the needs of this disabled population when making your funding decisions.
6147	October 29, 2024 1:04 pm	Liliana Aide Monge	Director of Digital Equity	Organization	UNITE-LA	Los Angeles	CA	90017	1. Program Background Given that the overall goal for NTIA's Digital Equity Capacity grant program is for states to implement the objectives and activities included in their State Digital Equity Plans, for objectives and activities from California's digital equity plan that aren't funded by Track 1 or Track 2 of the draft California Digital Equity Capacity Subgrant Program, it would be helpful for the CDT to explicitly state which objectives and activities will be implemented by the state, so that regional and state ecosystems understand opportunities for alignment. 2. Goals of the Capacity Subgrant Program In order to achieve Goal 1 "All Californians have high-performance broadband available at home, school, libraries and businesses," CDT will need to broaden allowable activities listed in Track 1 Local/Regional Ecosystem Building. The activities, as listed, under Track 1 do not address the "Long-lasting and Meaningful Change: Digital Equity Plans are intended to address the systemic barriers and gaps to digital access" focal point that NTIA requires CDT to consider. We encourage CDT to enable broader activities that enable regions to create plans that address infrastructure gaps in their communities. For most of the cities in L.A., in order to consider addressing access and seeking funding through the Broadband for All, BEAD, or other state broadband deployment grants, they need funding for planning. 3. Definitions The definition of "Digital Assets," per the SDEP and the State's BEAD 5-year Action plan, needs to include mention of "physical assets" that include the MMBN, state-owned land/buildings, utility towers, and rights-of-way. 4. Eligible Applicants Among eligible applicants, Regional Broadband Consortium should be additionally mentioned among applying entities (such as workforce development programs). RBCs should particularly be highlighted given that the CPUC designated these organizations to build the sort of ecosystems that the CDT strives to build and strengthen in each of the state's county regions. RBCs further are well-positioned to leverage investments the state has been making to address digital equity on a regional basis. Among the experiences outlined in Track 1 Regional/Local Ecosystem applicants, CDT should also highlight experiences that have supported and leveraged state-based investments and efforts through the CDT (e.g., development of the SDEP, MMBI) and CPUC (CASF outreach and technical assistance). Though these experiences do not necessarily have to be minimum requirements, they should be enhancing qualifications demonstrating the familiarity of the applicant with the State's Broadband for All programs and activities and thus likelihood for success. 5. Eligible Use of Funds and Program Requirements Under Eligible Use of Fund Additional Requirements, the requirement that "Each regional/local digital equity plan must address the entirety of the county or multi-county area it represents, including municipalities, unincorporated areas, and rural areas," is not responsive to the planning needs of a region like Los Angeles, which has 88 cities that all have very different planning needs. There are already multiple sub-regional plans conducted by councils of government; however, in order to have true impact, individual cities need to have their own plans. There is already momentum for the development of digital equity plans by cities in Los Angeles County, but it is often the cities without resources, and who need digital equity planning most, that don't create them. This is an opportunity to enable those cities to create individual plans. Requiring them to coordinate with one large County plan is not sensitive to their local needs and context. 8. Funding Restrictions Administrative Costs: We seek clarification on whether subgrantees will need to have a negotiated indirect cost rate agreement with a federal agency, or if this requirement will not apply since the grantee is the state. According to Pg. 31 of the Federal Capacity Grant NOFO: 47 USC 1723: State Digital Equity Capacity Grant Program, it would be prohibitive for each subgrantee to individually negotiate an indirect cost rate. Clarification on this matter would be helpful. Planning Costs: Please provide more detail on what specifically falls under planning costs. On Pg. 19 of the State Digital Equity Capacity Subgrant Program, there is mention of planning costs, but a clearer definition of what is included would assist subgrantees in budgeting for allowable expenses. Broadband Subsidies: We support the state’s decision to limit broadband subsidies to no more than 10% of the subgrant. While subsidies can provide temporary relief, they are not a sustainable solution. These once-in-a-lifetime funds should prioritize long-term strategies that build lasting digital equity solutions. Pre-Award Costs: We agree that pre-award costs should be an allowable expense, particularly given the importance of ecosystem building in this funding opportunity. Building capacity within communities is critical to ensuring they can participate fully in these programs. Device Costs: We agree with CDT’s recommendation to cap device funding at $11,250 for community and public spaces and $40,000 for households. These device costs align with Los Angeles County’s recent application to the Competitive Grant Program. We believe this is a reasonable cap and agree that the focus should remain on long-term solutions, such as digital equity planning, to truly close the digital divide. 9. Information Requested from Applicants We do not believe that information on second-tier applicants should have to be identified before submission to the CDT. This would put a burden on the subgrantee applicant to identify all known beneficiaries in a short time frame, instead of executing a thoughtful process after the award of the contract. For example, we would like to develop a localized Local Agency Technical Assistance fund for municipal, public, and community partners to access funding to support their digital equity planning for long-term sustainability. However, under the current proposed State Digital Equity Capacity Subgrant program, we would have to identify which partners would get digital equity planning funds before submitting the full proposal. This would require a hurried approach that requires a lot of upfront capacity on behalf of the subgrantee applicant. Letters of support should be open to any community leader – not just proposed partners. Just because an organization isn’t financially benefitting from the Capacity grant doesn’t mean that they shouldn’t have a say in whether they think the proposal is a benefit to their community. 10. Selection Information UNITE-LA encourages the State of California to work to secure additional funding via either the Digital Equity Act or other State of California funding mechanisms, as the state is in need of additional tools to combat the digital divide, so that a second round of Capacity Funding may be available for applications submitted that are not awarded grant funds. We further recommend that if more than one application is submitted per region, this Section be modified to include additional points for organizations that have established a large coalition of partners in the grant proposal. Large municipal organizations with a large population base should not be favored over community-based organizations that have a large network of collaborators that will ultimately also support the region’s covered population. 11. Post-Award Expectations Furthermore, there is a need to advocate for flexibility in the utilization of funds to accommodate the potential high costs associated with infrastructure deployment. Recognizing the diverse needs and challenges prevailing across communities, the allowance for flexibility in fund allocation will facilitate a more strategic and targeted approach. This adaptability is crucial to effectively address the specific requirements of rural and low-income areas, thereby optimizing the positive impact of the Digital Equity Plan. Financial Reporting, Technical Reporting: UNITE-LA recommends that the State of California Department of Technology provide to all grant awardees sample financial reporting templates to ensure organizations are able to efficiently and effectively manage their grant awards. By providing templates and resources, community-based organizations can reduce the amount of time spent on these potentially laborious tasks and increase the amount of time spent completing successful digital inclusion activities post-grant award. We also recommend that CDT hold an onboarding webinar for all grantees so that they may be properly prepared to track all activities in the correct technical reporting documents and templates during the grant period. Organizations should be given at least 30 days to complete their reports at the end of each reporting period. Execution and Performance Tracking: UNITE-LA recommends that subgrant awardees be given at least 90 days for the Close-Out Period. Closeout Period: Final financial and technical reports are due within ninety (90) days after the end of the period of performance. 12. Proposed Schedule of Activities We agree with the proposed schedule. 13. General Comment Not Related to Above Sections Given the low capacity for many community-based organizations and groups to engage with this comment process, we recommend that the CDT also accept coalition letters that outline comments and feedback as a collective body.
6146	October 29, 2024 12:38 pm	Alexis Snelling	Founder CEO	Organization	WeTransact | SkillVill	San Francisco	CA	94115	11. Post-Award Expectations Given the nature of the ecosystem approach for all grant proposals outlined in this draft, it's vital that more detailed metrics are tracked across all awarded program grants in order to orchestrate greater impact and success derived from each grant. One highly researched standard of metrics that need to be considered has been developed by the Kauffman Foundation specifically around inclusive ecosystems. The relevant 7 e-ship goals should be incorporated into each grant's required ongoing reporting and transparently shared in an open forum between program grantee leaders to continually compare, share, and learn from each quarter. In order to capture this data, a universal skills-based network for all grantees and communities to connect would need to be provided. It is unclear if the allocation of funds includes this specific overarching skills-based learning ecosystem. This is our area of expertise, and I'd be very interested in providing any additional consultation or research to proactively ensure the smooth distribution and sustainable rollout of these grant programs to all succeed better together. Kauffman Foundation e-ship goals
6145	October 29, 2024 12:23 pm	Marina Servantez	Director of DEI & Social Impact Initiatives	Organization	LeadingAge California	Sacramento	CA		2. Goals of the Capacity Subgrant Program LeadingAge California has over 800 members across the state, including providers of affordable senior housing, residential care facilities for the elderly (assisted living), life plan communities, skilled nursing care, home and community-based services, home health, and hospice care. We would like to take this opportunity to ensure that the Capacity Subgrant Program meets the needs of Californians living in affordable housing, particularly those in affordable senior housing. Affordable housing communities are home to a high concentration of individuals who belong to one or more of the covered populations, including those at or below 150% of federal poverty, individuals with language barriers, and members of racial or ethnic minorities. Additionally, affordable senior housing communities house significant numbers of aging individuals and people with disabilities. These communities serve as excellent venues for reaching covered populations where they live. While engaging affordable housing communities would advance many of the grant's objectives, the current draft does not explicitly mention them as target areas for implementation. We recommend that affordable housing communities and organizations serving these communities be considered throughout the goals of the Capacity Subgrant Program. They are ideal locations for service providers to bridge the digital equity gap for covered populations. 4. Eligible Applicants Track 1 currently encourages one lead applicant per county. In its present form, this requirement may hinder collaboration among all organizations that can help reach the covered populations, especially given the short timeline for the grant application process. We recommend introducing a more flexible option for applications or directly connecting organizations to a designated lead per county after the application period. This approach would ensure that valuable contributors can be included in implementation. For instance, affordable housing communities in any given county would be ideal partners on applications to support the program's goals, but the current structure does not encourage these communities to take on a county lead role. 8. Funding Restrictions We recommend considering greater flexibility in existing funding restrictions. The current 5% allocation for planning activities does not provide enough room to ensure that programs are co-designed with the populations they aim to serve. This collaborative approach is vital in program development, as it ensures that initiatives genuinely benefit the communities they are intended to reach. Additionally, the existing limitations on computing devices hinder organizations' ability to equip participants with the necessary tools for engaging in digital equity activities. Digital literacy training programs are most effective when supported by innovative and up-to-date technology, along with a sufficient number of devices to foster collaborative and engaging learning environments. We encourage the State to reassess these funding caps to support comprehensive digital equity initiatives that thoughtfully involve covered populations in the planning process and connect them with the tools they need for success. 11. Post-Award Expectations As currently written, technical reports are due fourteen (14) days after the end of a reporting period. This timeframe may not provide sufficient time for grantees to prepare comprehensive and accurate reports, particularly as many organizations will not have the needed financial reports in such an expedited timeline. To ensure the quality and completeness of all reporting, we recommend extending the deadline to allow for adequate preparation time. This adjustment would enable grantees to present more thorough and accurate reports, ultimately benefiting the overall impact of the grant.
6144	October 29, 2024 11:20 am	Christian Ramos	IT Infrastructure Project/Program Manager	Organization	Los Angeles Unified School District	Los Angeles	CA	90017	8. Funding Restrictions Los Angeles Unified School District would like to request a reconsideration of the current reimbursement cap for take-home computing devices, which is set at $300 per device. Based on our recent experiences, we have found that the actual cost of providing these devices to our students significantly exceeds the current cap. The total cost per device, including additional taxes, fees, and necessary integration costs, is approximately $375. We respectfully request that the CDT increase the reimbursement cap to $375 per device. This adjustment would more accurately reflect the true cost of providing these essential tools to our students and help alleviate the financial burden on our district. We appreciate your attention to this matter. Thank you for your consideration and continued support of our educational initiatives.
6143	October 29, 2024 10:55 am	Arnold Sowell	Executive Director	Organization	NextGen California	Sacramento	CA		13. General Comment Not Related to Above Sections We commend the California Department of Technology (CDT) for prioritizing local and regional planning and implementation within the California Digital Equity Capacity Subgrant Program. Local entities know the needs, resources, and context of their own communities best. However, they also can benefit from the exchange of ideas and approaches taken in other parts of the state. We encourage CDT to create meaningful forums and other opportunities for partners across the state to engage and share ideas, information, and lessons learned — from the application phase through implementation. This engagement should begin as soon as possible so that it may inform the grant applications submitted.
6142	October 29, 2024 10:20 am	Tracy Rhine	Senior Policy Advocate	Organization	Golden State Connect Authority	Sacramento	CA	95814	1. Program Background Under “covered populations,” city and town are referred to, but not county or unincorporated county. 4. Eligible Applicants On page 10 under “eligible applicants” it is unclear what is eligible as an "entity that carries out a Workforce development program.” It does not appear to be a formally defined or described entity within the Guidelines. CDT should consider outlining program eligibility criteria to ensure funding is awarded to legitimate organizations with expertise in providing the necessary services. 5. Eligible Use of Funds and Program Requirements On page 15 under “Track 2” only certain covered populations are listed, though it is unclear why all covered populations are not included for a statewide focus. Furthermore, outcome areas are defined very broadly. GSCA does not have an operational concern with the narrow targets for population; however, the Guidelines should be clarified to account for a targeted implementation under Track 2. 6. Who This Benefits On page 16, under “Who This Benefits,” in the second paragraph it provides that Subgrants awarded under Track 1 (Regional/Local Ecosystems) must develop plans and implement activities to drive towards measurable objectives to benefit members of all Covered Populations within the county/region or multi-county joint application region. This seems unduly limiting to a regional effort that may not include some covered populations, such as incarcerated individuals. Providing some flexibility post-award to adjust/develop a plan that focuses on populations not provided for by Track 2 awardees may lead to more covered populations being more adequately served. 7. Proposed Allocation & Award Formula On pages 16-18 related to allocations, it appears that the proposed Track 1 funding distribution methodology creates potentially negligible funding amounts for the smallest counties in the state. The percentages of Track 1 funding allocated in the Guidelines for the smallest of GSCA counties (Alpine, Colusa, Inyo, Mariposa, Modoc, Mono, Plumas, San Benito, Sierra, Sutter, Trinity, and Yuba) would equate to each of those counties only receiving $189,540 to implement and support activities over a three-year and ten-month period. Unfortunately, this amount may not be enough to meet basic operational needs to implement efforts in those jurisdictions. The CDT should consider a minimum allocation of $250,000 per county and divide the balance on a percentage basis for the remainder of the jurisdictions. This will ensure that residents of even the most remote, geographically challenging, and lowest population areas have an equitable opportunity to receive the benefits of the grant program. Arguably, these may be the most at need and hardest to serve covered populations in the State. Additionally, it is unclear if only one application is allowed per county. For instance, if an application is submitted for a county; must it also incorporate application needs for sub-county entities such as special districts or cities? Lastly, as stated in previous section comments, inclusion or exclusion of covered populations affects allowable efforts. With the previously stated example of incarcerated populations, it seems an award for statewide work with entities supporting the correctional system would more adequately assist serving that population than regional efforts. 8. Funding Restrictions Clarification on Administrative and Evaluation costs is needed in Section 8. With respect to the three percent limit on Administrative Costs and five percent limit on Evaluation Costs, it is unclear if those limitations carry to the sub-recipients. For example, if GSCA receives three percent Administrative Cost on an entire award for numerous counties, do the individual counties have the ability to also charge three percent Administrative Costs on the award they receive from GSCA? Similar questions remain with Evaluation Costs. Additionally, the five percent or $50,000 limit on planning costs may be unduly restrictive for communities that do not have existing resources in place. Lastly, while the Guidelines provide for hardware and software requests to be included (or expected to be included) in the “competitive” applications, it also has an “allowance” in the “capacity” for hardware and software at relatively high numbers. Clarification is needed on how hardware and software costs and needs will be managed through the program.
6141	October 29, 2024 10:01 am	Shelby Arthur	Tri-County Coordinator	Organization	Broadband Consortium Pacific Coast	Santa Barbara	CA	93441	1. Program Background First, we appreciate CDT's and partner agencies' efforts in local engagement for the outreach and analysis of the SDEP planning process that filters into this subgrant design. As revealed through engagement in the Broadband Consortium Pacific Coast region of Ventura, Santa Barbara, and San Luis Obispo Counties, there are already many local organizations engaged in digital inclusion work that have expertise in their fields and direct knowledge of the needs of Covered Populations. In general, we recommend CDT continue to prioritize that local/regional knowledge and practice over requiring use of statewide resources - these resources can be integrated and supplement local efforts rather than direct them. That said, additional information about the timelines, programs to be funded, and Covered Populations to be served by the Centralized Services and State Agency programs would be helpful. 4. Eligible Applicants We support the current draft guidelines allowance for multi-county applications to support regional coordination of resources and existing partnerships with established outreach channels. 5. Eligible Use of Funds and Program Requirements CDT should ensure that Centralized Services do not displace the locally developed digital inclusion services that are already serving a county or region, but rather include opportunities for locally developed digital literacy or other inclusion services to be recognized alongside the Centralized Services. If the digital equity planning period reveals needs unmet by current digital literacy courses, funding should be allowed to develop curriculum targeted to those needs. Centralized Services and State Programs may consider compensating local organizations for the curriculum or design work done at the local level if it can be leveraged and included in a statewide asset database. Please clarify if the “planning” portion of the grant (capped at 5% or $50,000) is expected to be used to draft a Digital Equity Plan for the County, or if there are specific parameters for planning activities. We strongly encourage the state to extend the time period allowed for drafting digital equity plans. Some counties have far more organized and coordinated efforts and will be able to obtain the needed input more efficiently than others; some counties will need more than 6 months to adequately reach Covered Populations and the organizations that serve them to draft an informed Digital Equity Plan. We appreciate the offer of a Digital Equity Plan Template, and recommend it be a reference template rather than a requirement. The State has noted a maximum amount that can be spent on digital devices and referenced in webinars that organizations should leverage funds from NTIA competitive grants for digital devices. There is no guarantee that NTIA competitive grants will be awarded for all regions in our state, nor that the applications contain sufficient funds for digital devices. We do not have a great suggestion for resolving this conflict, but encourage the state to consult digital inclusion experts for advice to ensure digital devices can be distributed as needed to Covered Populations. 6. Who This Benefits Under Covered Populations, we recommend the state expand the definition of Incarcerated individuals to include Formerly Incarcerated individuals. 7. Proposed Allocation & Award Formula The allocation formula seems accurate in the Broadband Consortium Pacific Coast (BCPC) region for Ventura County, but would underfund the counties of San Luis Obispo (SLO) and Santa Barbara (SB) according to analysis conducted by California Emerging Technologies Fund (CETF) using potential households requiring adoption assistance that are eligible for federal assistance programs. Based on the number of households that qualify for federal assistance programs, the County of SLO would fall short of funding to support adoption by 758 households and the County of SB would fall short of funding to support 1179 households in making complete adoptions. We ask that the allocations model be adjusted to ensure adequate funding for all California counties to support households in their efforts to adopt digital technology and improve their access to the digital economy.
6140	October 29, 2024 9:41 am	Bruce Stenslie	CEO/President	Organization	Economic Development Collaborative	Camarillo	CA	93012	1. Program Background First, we commend CDT and partner agencies for the outreach and analysis that went into the SDEP planning process and that filters into this subgrant design. There are already many local organizations engaged in digital inclusion work that have expertise in their fields and direct knowledge of the needs of Covered Populations. In general, we recommend CDT continue to prioritize that local/regional knowledge and practice over requiring use of statewide resources - these resources can be integrated and supplement local efforts rather than direct them. Please provide more information about the CDT timeline for establishing Centralized Services as well as what those services might include, so that applicants can build their proposals around resources expected to be provided. The SDEP lists some potential suggestions, but a list accompanying the RFA would be helpful to applicants. Please provide a list of State Agency Digital Inclusion Programs that will be proposed to be funded so that applicants can draft applications that supplement these programs rather than duplicate them. The SDEP lists Access to Technology, CSL Connected CA, etc., but a list accompanying the RFA would be helpful to applicants. 5. Eligible Use of Funds and Program Requirements If a digital equity plan identifies gaps in currently available digital inclusion resources for digital literacy training tailored to Covered Population needs, funding should be allowed under implementation of digital equity plans to allow for development of additional curriculum if unavailable through other local sources. Clarify how the CDT envisions applicants utilizing the State's "centralized services" and "agency digital inclusion" efforts to maximize subgrantee budgets. For example: will the state offer a no-cost option for digital navigation training to subgrantees? Will the state be engaging with ISPs to compile location-based funding opportunities? CDT should ensure that Centralized Services do not displace the locally developed digital inclusion services that are already serving a county or region, but rather include opportunities for locally developed digital literacy or other inclusion services to be recognized alongside the Centralized Services. Please clarify if the “planning” portion of the grant (capped at 5% or $50,000) is expected to be used to draft a Digital Equity Plan for the County, or if there are specific parameters for planning activities. 6. Who This Benefits Under Covered Populations, we recommend the state expand the definition of Incarcerated individuals to include Formerly Incarcerated individuals. 7. Proposed Allocation & Award Formula The allocation formula seems accurate in the Broadband Consortium Pacific Coast (BCPC) region for Ventura County, but would underfund the counties of San Luis Obispo and Santa Barbara according to analysis conducted by California Emerging Technologies Fund (CETF) using potential households requiring adoption assistance that are eligible for federal assistance programs. Based on the number of households that qualify for federal assistance programs, the County of SLO would fall short of funding to support adoption by 758 households and the County of SB would fall short of funding to support 1179 households in making complete adoptions. We ask that the allocations model be adjusted to ensure adequate funding for all California counties to support households in their efforts to adopt digital technology and improve their access to the digital economy.
6139	October 29, 2024 9:06 am	Chester Williams	Bayview Area Tech Advisor	Organization	URI Resources Inc.	San Francisco	CA	94124	2. Goals of the Capacity Subgrant Program California Digital Equity Capacity Subgrant Program PUBLIC COMMENT on Draft Guidelines POSSIBLE COMMENTS, prepared by SF Tech Council: A. GENERAL: We appreciate the effort and commitment reflected in the Draft Guidelines for the California Digital Equity Capacity Subgrant Program to the goals of advancing digital equity and ensuring all Californians have access to the technology and digital skills they need. We have some feedback on the general design of the Program, and a few suggestions to enhance the Program’s overall effectiveness: Prioritize funding allocation for maximum impact: The Draft Guidelines specify CDT’s investments in statewide, regional and local planning, ecosystem development, and capacity building that address digital equity. But the $70.2M in funding is not enough to support all proposed statewide and local activities across three categories of funding as outlined in the draft guidance, and at a level that can benefit California’s Covered Populations, and support SDEP implementation and further the goals of Broadband for All. To maximize impact, we recommended that the funding be prioritized for activities that can have the broadest reach, especially for communities with the greatest need. Focus on the needs of local communities: Localities have diverse demographics and the size and needs of Covered Populations vary widely across the state. We suggest that applicants be allowed more flexibility to focus on specific, local priorities that are most relevant to their communities. This would allow applicants to target populations that are most underserved in their areas and enable more tailored and impactful interventions. Streamline and simplify grant requirements to maximize impact: The extensive requirements for the capacity grants—encompassing planning, evaluation, administration, and reporting—are burdensome and may consume a substantial portion of the awarded funds and discourage eligible entities from applying. This overhead can significantly reduce the resources available for direct services and program activities that benefit the community. To mitigate this, we suggest simplifying the administrative requirements to allow grantees to fulfill these obligations efficiently. Streamlining these processes will help ensure that the limited funding is used primarily to achieve the program's objectives rather than being absorbed by administrative tasks. Again we strongly support the mission of the California Digital Equity Capacity Subgrant Program and believe that with greater flexibility in these areas, the program can more effectively address the digital divide and serve the diverse needs of Californians. Thank you for considering these comments; we look forward to the successful implementation of this important initiative. B. TARGETED COMMENTS - by section SECTION 4: Eligible Applicants Create flexibility in lead applicant structure: Requiring a single lead applicant per locality poses challenges, particularly given the plan's emphasis on partnerships and collaborative efforts. Local communities often have multiple organizations with unique strengths and outreach capabilities. Allowing for multiple lead applicants or a more flexible lead applicant structure would facilitate stronger partnerships and enable a broader range of organizations to contribute effectively to the program's goals. I recommend revising this requirement to accommodate several lead applicants per locality or to provide a structure that supports consortiums with shared leadership responsibilities. On page 10, for the sake of clarity and to increase the list of eligible applicants we suggest expanding the list of eligible applicants beyond the two types of entities currently emphasized (local educational agencies and workforce development programs). While these two types of entities play crucial roles, the current language could unintentionally limit the diversity of applicants by creating the perception that they are preferred over other potentially impactful organizations. By broadening the scope of eligible applicants, the program can better support a variety of organizations that are working directly with underserved communities, such as nonprofit organizations, public libraries, community health centers, and social service agencies, which also play vital roles in digital equity efforts. SECTION 8: Funding Restrictions We urge the State to consider allowing more flexibility in the allocation of funds within Track 1 to enhance the impact of local and regional digital equity efforts. The current cap of 10% on broadband subsidies, along with limits of $11,250 per award for devices in community spaces and $40,000 per award for take-home computing devices, may unintentionally restrict programs focused on providing essential technology and connectivity resources. Programs dedicated to digital literacy and skills training are most effective when paired with adequate access to devices and reliable broadband. Previous state and federal grants have demonstrated the necessity of substantial investments in technology, with up to 36% of their funding allocated to devices and data plans to meet community needs effectively. Increasing flexibility in these funding limits will allow communities to better address their specific digital access needs, leading to greater inclusion and long-lasting impact. We encourage the state to reconsider these funding caps to support well-rounded digital equity programs that connect underserved communities and provide them with the tools they need to succeed in today’s digital world.
6138	October 29, 2024 8:59 am	Kari Gray	Digital Equity Program Director	Organization	Community Tech Network	San Francisco	CA	94102	1. Program Background CTN recommends that the shared resources allocation also include funding for shared resources and templates for strategic planning and needs assessments for Track 1 and Track 2. If the state provides templates and shared planning resources, more of the Capacity grant resources can be allocated to convening, outreach, and implementation activities. CTN would also like to see: A timeline for confirming and sharing the shared resources so Track 1 and Track 2 applicants can build their proposals around shared resources expected to be provided. The list of potential State Agency Digital Inclusion programs to be funded so that applicants can identify the resources already coming through their counties and draft applications that supplement these programs rather than duplicate them. A clear and transparent process for sharing updates and progress reports on the State Digital Equity Plan (SDEP). Regular updates will further enable community organizations to stay informed and adapt their efforts to support the state’s progress and re-align program delivery strategies. Plans for a transparent, public reporting mechanism, such as a dedicated dashboard, to ensure state and local efforts remain in sync and responsive to community needs. Commitment to an advisory board or other strategy for keeping the DEEM up-to-date and relevant. 2. Goals of the Capacity Subgrant Program CTN recommends that Guidelines include Digital Navigator training as a workforce and economic development strategy. As public and private sector services “digitize,” having trained Digital Navigators in community spaces will ensure all residents can get online to access the help they need. Additionally, Digital Navigator training provides valuable professional development, enhancing job skills of staff in the nonprofit and government sectors. 3. Definitions Covered populations Individuals who are members of a racial or ethnic minority group. CTN recommends that minority ethnic groups not previously or otherwise served in previous programs or statewide initiatives, such as indigenous Mexicans, Hmong, Cambodian, Laotian, etc., be prioritized in this specific covered population. 4. Eligible Applicants To increase the list of eligible applicants, CTN suggests expanding the list of eligible applicants beyond the two types of entities currently emphasized (local educational agencies and workforce development programs). While these two types of entities play crucial roles, the current language could unintentionally limit the diversity of applicants by creating the perception that they are preferred over other potentially high-impact organizations. Every government agency now provides digitized services. To reach the covered populations with these services, CTN recommends including types of organizations that provide services for the covered populations, such as those providing health and human services, aging and adult services, workforce readiness activities, tribal affairs, rehabilitation, veterans affairs, and other agencies supporting covered populations with digitized services in the State. 5. Eligible Use of Funds and Program Requirements CTN requests that CDT clarify how it envisions applicants utilizing the State's "centralized services" and "agency digital inclusion" efforts. CTN expects CDT to ensure that recommended Centralized Services are informed by local organizations and community needs, which may vary by language, region, and other demographics. Centralized services should be customizable to be culturally responsive to the communities they hope to serve. Using the CDT-recommended centralized services can be recommended, but not required. 8. Funding Restrictions Indirect costs of <3% are prohibitive and extremely burdensome on community-based organizations and smaller nonprofits without the resources to even apply for the funding. CTN suggests alignment with the NTIA competitive grant of 15%. 11. Post-Award Expectations Submitting reimbursement quarterly will put a strain on smaller, local organizations’ cash flow and the cash flow of the lead agencies who may be awarding subgrants for the implementation of the Digital Equity Plans. CTN recommends monthly reimbursements or a state commitment to supplementing the Capacity grants with state grants to serve as bridge funding while waiting for reimbursements.
6137	October 29, 2024 7:18 am	Karla Suomala	Co-Director	Organization	SF Tech Council	San Francisco	CA	94103	13. General Comment Not Related to Above Sections We appreciate the effort and commitment reflected in the Draft Guidelines for the California Digital Equity Capacity Subgrant Program to the goals of advancing digital equity and ensuring all Californians have access to the technology and digital skills they need. We have some feedback on the general design of the Program, and a few suggestions to enhance the Program’s overall effectiveness: Prioritize funding allocation for maximum impact: The Draft Guidelines specify CDT’s investments in statewide, regional and local planning, ecosystem development, and capacity building that address digital equity. But the $70.2M in funding is not enough to support all proposed statewide and local activities across three categories of funding as outlined in the draft guidance, and at a level that can benefit California’s Covered Populations, and support SDEP implementation and further the goals of Broadband for All. To maximize impact, we recommended that the funding be prioritized for activities that can have the broadest reach, especially for communities with the greatest need. Focus on the needs of local communities: Localities have diverse demographics and the size and needs of Covered Populations vary widely across the state. We suggest that applicants be allowed more flexibility to focus on specific, local priorities that are most relevant to their communities. This would allow applicants to target populations that are most underserved in their areas and enable more tailored and impactful interventions. Streamline and simplify grant requirements to maximize impact: The extensive requirements for the capacity grants—encompassing planning, evaluation, administration, and reporting—are burdensome and may consume a substantial portion of the awarded funds and discourage eligible entities from applying. This overhead can significantly reduce the resources available for direct services and program activities that benefit the community. To mitigate this, we suggest simplifying the administrative requirements to allow grantees to fulfill these obligations efficiently. Streamlining these processes will help ensure that the limited funding is used primarily to achieve the program's objectives rather than being absorbed by administrative tasks. Again we strongly support the mission of the California Digital Equity Capacity Subgrant Program and believe that with greater flexibility in these areas, the program can more effectively address the digital divide and serve the diverse needs of Californians. Thank you for considering these comments; we look forward to the successful implementation of this important initiative. 4. Eligible Applicants Create flexibility in lead applicant structure: Requiring a single lead applicant per locality poses challenges, particularly given the plan's emphasis on partnerships and collaborative efforts. Local communities often have multiple organizations with unique strengths and outreach capabilities. Allowing for multiple lead applicants or a more flexible lead applicant structure would facilitate stronger partnerships and enable a broader range of organizations to contribute effectively to the program's goals. I recommend revising this requirement to accommodate several lead applicants per locality or to provide a structure that supports consortiums with shared leadership responsibilities. On page 10, for the sake of clarity and to increase the list of eligible applicants we suggest expanding the list of eligible applicants beyond the two types of entities currently emphasized (local educational agencies and workforce development programs). While these two types of entities play crucial roles, the current language could unintentionally limit the diversity of applicants by creating the perception that they are preferred over other potentially impactful organizations. By broadening the scope of eligible applicants, the program can better support a variety of organizations that are working directly with underserved communities, such as nonprofit organizations, public libraries, community health centers, and social service agencies, which also play vital roles in digital equity efforts. 8. Funding Restrictions We urge the State to consider allowing more flexibility in the allocation of funds within Track 1 to enhance the impact of local and regional digital equity efforts. The current cap of 10% on broadband subsidies, along with limits of $11,250 per award for devices in community spaces and $40,000 per award for take-home computing devices, may unintentionally restrict programs focused on providing essential technology and connectivity resources. Programs dedicated to digital literacy and skills training are most effective when paired with adequate access to devices and reliable broadband. Previous state and federal grants have demonstrated the necessity of substantial investments in technology, with up to 36% of their funding allocated to devices and data plans to meet community needs effectively. Increasing flexibility in these funding limits will allow communities to better address their specific digital access needs, leading to greater inclusion and long-lasting impact. We encourage the state to reconsider these funding caps to support well-rounded digital equity programs that connect underserved communities and provide them with the tools they need to succeed in today’s digital world.
6136	October 29, 2024 6:54 am	Karisa Tashjian	Senior Director of Programs and Strategic Partnerships	Organization	Digitunity	North Conway	CA	03860-5267	5. Eligible Use of Funds and Program Requirements Digitunity strongly recommends that the eligible use of funds for Track 2: Targeted Statewide Ecosystems be expanded from two categories—Covered Populations and Outcome Areas—to three, to include Components of Digital Equity: broadband, digital skills, and devices. One of the fund's stated purposes is to support "statewide innovative projects or solutions that can leverage other funding sources to address an unmet need in the digital divide or to enhance an existing solution in a unique, creative manner aligned with an outcome area and/or the specific needs of the Covered Population(s)." Including a distinct category for Components of Digital Equity is essential to fully address strategies and innovations related to computer ownership. When restricted to either Covered Populations or Outcome Areas, the impact of these efforts risks dilution. For example, statewide initiatives focused on sourcing technology donations, improving refurbisher and device preparation capacity, and building a coordinated, well-trained distribution network of trusted community organizations will be far more effective with a dedicated category to support these digital equity components directly.
6135	October 28, 2024 11:11 pm	Tieu Ly	Associate Director of Digital Equity	Organization	Felton Institute	San Francisco	CA	94102	13. General Comment Not Related to Above Sections We appreciate the dedication behind the Draft Guidelines for the California Digital Equity Capacity Subgrant Program. The commitment to advancing digital equity is commendable. We have some feedback and suggestions to enhance the Program's effectiveness: Optimize funding distribution: The $70.2 million allocated may not sufficiently support all proposed activities across the three funding categories. We recommend prioritizing funding for initiatives that can create the most significant impact, particularly in communities facing the greatest challenges. Address local community needs: Different regions have unique demographics and varying needs. We suggest allowing applicants more flexibility to focus on local priorities, enabling them to better serve the most under-served populations. Simplifying grant requirements to improve effectiveness: The complex criteria for capacity grants, involving planning, evaluation, administration, and reporting, can be burdensome and consume a large share of funds, deterring eligible organizations from applying. We recommend simplifying these processes to allow grantees to manage their responsibilities more efficiently, ensuring that limited funding is used to achieve program objectives rather than being tied up in administration. We support the objectives of the California Digital Equity Capacity Subgrant Program and believe that increased flexibility can better address the digital divide and meet the diverse needs of Californians. Thank you for considering our feedback; we look forward to the successful implementation of this initiative. 4. Eligible Applicants Encourage a flexible lead applicant model: Having a single lead applicant per locality can hinder collaboration, as many local organizations offer unique strengths. Allowing multiple lead applicants or a flexible framework can enhance partnerships and broaden organizational contributions. We recommend modifying this requirement to support multiple lead applicants or establish a consortium with shared leadership. To enhance clarity and broaden the pool of eligible applicants, we recommend expanding the criteria beyond the two types of entities currently highlighted (local educational agencies and workforce development programs). While these entities are important, the existing language could unintentionally narrow the diversity of applicants by suggesting they are prioritized over other significant organizations. By broadening the eligibility criteria, the program can better assist a variety of organizations that serve under-served communities, such as nonprofit organizations, public libraries, community health centers, and social service agencies, which are all crucial to promoting digital equity. 8. Funding Restrictions We encourage the State to explore greater flexibility in fund allocation within Track 1 to boost the effectiveness of local and regional digital equity initiatives. The current restrictions, including a 10% cap on broadband subsidies and limits of $11,250 for devices in community spaces and $40,000 for take-home devices, may unintentionally limit programs that aim to provide vital technology and connectivity resources. Programs that focus on digital literacy and skills training are most successful when they are complemented by adequate access to devices and reliable broadband. Historical data from state and federal grants highlight the importance of significant technology investments, with up to 36% of funding often going towards devices and data plans to effectively serve community needs. By allowing more flexibility in these funding limits, communities can better meet their specific digital access requirements, resulting in increased inclusion and a more profound impact. We encourage the state to revisit these funding caps to support comprehensive digital equity initiatives that connect under-served communities and equip them with the tools necessary for success in the digital age.
6133	October 28, 2024 10:25 pm	Walter Larkins	Executive Director	Organization	E O2™ Education Equals Opportunity Too oo	Long Beach	CA	90805	9. Information Requested from Applicants We serve students at State universities, community colleges, and school districts. These organizations have, in the past, provided information to us concerning the student's qualifications as evidence they are qualified. For colleges, Pell grants for school districts students' participation in meal programs. Usually, a superintendent or a senior staff member will provide a list of qualified students, and those students will become the recipients of the technology and training. 11. Post-Award Expectations The process for tracking the technology and/or hotspots can be burdensome. As these devices will belong to the students themselves, and after delivery, the city or organization will have a list of the technology that was in their inventory. The provider delivering the technology should not be responsible for assigning each device to a specific student. It creates a paperwork nightmare if you're providing technology to a group of 20 or more students. The process of scanning the technology to get the serial number and hotspot ID, having students complete the forms transferring ownership, and parents signing off on them (which can be quite challenging), and the demographic information required can be intrusive to certain populations. My suggestion is that the provider creates an Excel sheet that is standardized, with only the names and other required information. Do not require the provider to document the serial numbers and IDs of the technology, as they will have to present the devices to the primary vendor to get service and training anyway. If students aren't on the list, they can't get the training or other services.
6132	October 28, 2024 9:12 pm	Cris Arzate	Resident Services Manager	Organization	Housing Authority of the City of Los Angeles	Los Angeles	CA	90057	5. Eligible Use of Funds and Program Requirements The Housing Authority of the City of Los Angeles (HACLA) recommends the CDT allow for multiple applications from Los Angeles County given the county’s population, square mileage, diversity, urban and rural landscape, and capacity of providers to support the range of digital equity needs. HACLA’s presence in the region as the largest affordable housing provider requires a tailored strategy to respond to the unique needs of the region’s lowest income residents. Additionally, the region’s population of unhoused residents require housing coupled with holistic services that include digital literacy training for residents to re-enter the workforce. HACLA encourages the CDT to provide broad categories for funding that include: Digital Equity Strategic Plan development, capital improvements to computer labs, training services for seniors, funded employment for young adults enrolled in training and work experience programs, and Internet service subsidies for residents of affordable housing.
6131	October 28, 2024 5:36 pm	Steff Saavedra	Manager	Organization	Sylver Consult.ComLLC	San Marcos	CA	92069	13. General Comment Not Related to Above Sections True engagement for tribes means physically meeting with them to discuss challenges, concerns and much more. Emails are not sufficient. Moving forward means holding service providers accountable for easements, previous installations, and maintenance. Some providers only want to move forward if they can install fiber, thus releasing their liability. This is not feasible. And if conduit is being trenched for either electricity or broadband, please add additional empty conduit with a pull string for future installations of broadband/fiber. This will save funds in the future. And per executive order b-10-11 acknowledging: "Whereas the State of California recognizes and reaffirms the inherent right of these tribes to exercise sovereign authority over their members and territory." Not just Tribal Lands. Tribes and rural areas deserve access to be connected.
6129	October 28, 2024 5:30 pm	Estefania Zavala	Digital Equity and Economic Inclusion Officer	Organization	City of Long Beach	Long Beach	CA	90802	2. Goals of the Capacity Subgrant Program The City of Long Beach commends the California Department of Technology (CDT) for allocating no less than 54% of the total State Capacity Grant allocation to the subgrant program. 4. Eligible Applicants Given the size of Los Angeles County, which is more populous than 40 U.S. states, the City asks that the CDT reconsider the recommendation of one application per county representing the partnership of interested eligible entities within each county. LA County is one of the most densely populated regions in the United States, exceeding the populations of states like Arizona, Washington, Massachusetts, Tennessee, and Indiana in size. Therefore, a regional approach to LA County, with an allowance for more than one application, is necessary to ensure that the varied needs and interests of its large population are comprehensively represented and addressed. 7. Proposed Allocation & Award Formula The City appreciates the equitable approach to the funding allocation, with LA County receiving 19.1% of the total funding available, based on the covered population number. 8. Funding Restrictions The City of Long Beach asks the CDT to reconsider this stance on device costs as most organizations will not know if they have received the NTIA Competitive Grant prior to applying for the Capacity Subgrant program. There are few other opportunities for funding device distribution programs. 11. Post-Award Expectations How does the State differentiate contractors and subgrantees? The City recommends CDT to provide training on subgrant awardee reporting requirements to ensure compliance with reporting requirements.
6128	October 28, 2024 3:13 pm	Prishani Satyapal	Executive Director	Organization	Earth Our Common Home	Oakland	CA	94611	5. Eligible Use of Funds and Program Requirements It would be useful if the grants could be used to increase broadband connectivity at Transit Oriented Developments. These are key sites for reducing carbon emissions. Increased broadband at TOD's will support the increased use of transit.
6127	October 28, 2024 2:42 pm	Lindsey Skolnik	Project Manager	Organization	California Alliance for Digital Equity (CADE)	Sacramento	CA		5. Eligible Use of Funds and Program Requirements Comment 1 - Re: Track 2 Subgrantees' Regional/Local Coordination Requirements: CDT should adjust requirement "Track 2 subgrantees must include a plan for regional/local coordination with Track 1 subgrantees". We agree track 2 subgrantees should be required to maintain regional/local coordination, however we believe they should be encouraged to coordinate with many different regional/local stakeholders that extend beyond Track 1 subgrantees. Therefore we recommend altering the requirement to "Track 2 subgrantees must include a plan for coordination with regional/local digital equity stakeholders". Comment 2 - Re: Centralized Services & DEEM Tool Requirements: The required use of centralized services to support all regions may not work for all regions of the state, such as Oakland, which has unique challenges and more diverse needs. We encourage the CDT to consider a more decentralized, localized, flexible approach to uplift local knowledge maintained by local organizations and maintain existing community trust and engagement. Additionally, given that California is the most linguistically diverse state in the country, it is essential that the CDT acknowledges the diverse language needs in different regions of the state, outside of English and Spanish. [For example: Tech Exchange services to Mam speaking community] We recommend the CDT not require the use of state tools such as DEEM and the state DE survey. To date, fewer than 500 Californians have taken the survey and <70% have completed the survey. We suggest the CDT offer the survey as a template tool, but allow communities the flexibility to adapt the survey to different regions, populations, languages, educational levels, etc, and most importantly different purposes. Additionally, some communities may want to adjust the number of questions to increase completion rates. We also want to highlight that digital equity organizations may have existing digital equity surveys for their communities, and we want to avoid duplication. Should the CDT require the completion of a centralized survey, then we recommend the CDT provide a revised version of the DEEM tool and Statewide Digital Equity Public Survey with recommended changes from digital equity leaders across the state. We ask CDT to only require grantees to submit a limited number of state-mandated surveys per the grant period. We also ask the CDT to share the results of the survey, so digital equity advocates can adjust their plans to best fit the needs of the community and to cross-reference data between state and locally collected data. 11. Post-Award Expectations Comment 1 - Re: Payment Process: As it stands, Track 2's delayed payment processes may discourage small organizations with limited funding from applying for the grant. We recommend altering the guidelines to allow small organizations to be awarded a larger percentage of their grant once the Subgrant performance period begins.
6126	October 28, 2024 1:46 pm	Joseph Ramirez	Managing Director Workforce Development	Organization	PRC	San Francisco	CA	94102	1. Program Background We appreciate the effort and commitment reflected in the Draft Guidelines for the California Digital Equity Capacity Subgrant Program to the goals of advancing digital equity and ensuring all Californians have access to the technology and digital skills they need. We have some feedback on the general design of the Program, and a few suggestions to enhance the Program’s overall effectiveness: Prioritize funding allocation for maximum impact: The Draft Guidelines specify CDT’s investments in statewide, regional and local planning, ecosystem development, and capacity building that address digital equity. But the $70.2M in funding is not enough to support all proposed statewide and local activities across three categories of funding as outlined in the draft guidance, and at a level that can benefit California’s Covered Populations, and support SDEP implementation and further the goals of Broadband for All. To maximize impact, we recommended that the funding be prioritized for activities that can have the broadest reach, especially for communities with the greatest need. Focus on the needs of local communities: Localities have diverse demographics and the size and needs of Covered Populations vary widely across the state. We suggest that applicants be allowed more flexibility to focus on specific, local priorities that are most relevant to their communities. This would allow applicants to target populations that are most underserved in their areas and enable more tailored and impactful interventions. Streamline and simplifying grant requirements to maximize impact: The extensive requirements for the capacity grants—encompassing planning, evaluation, administration, and reporting—are burdensome and may consume a substantial portion of the awarded funds and discourage eligible entities from applying. This overhead can significantly reduce the resources available for direct services and program activities that benefit the community. To mitigate this, we suggest simplifying the administrative requirements to allow grantees to fulfill these obligations efficiently. Streamlining these processes will help ensure that the limited funding is used primarily to achieve the program's objectives rather than being absorbed by administrative tasks. Again we strongly support the mission of the California Digital Equity Capacity Subgrant Program and believe that with greater flexibility in these areas, the program can more effectively address the digital divide and serve the diverse needs of Californians. Thank you for considering these comments; we look forward to the successful implementation of this important initiative. 4. Eligible Applicants SECTION 4: Eligible Applicants Create flexibility in lead applicant structure: Requiring a single lead applicant per locality poses challenges, particularly given the plan's emphasis on partnerships and collaborative efforts. Local communities often have multiple organizations with unique strengths and outreach capabilities. Allowing for multiple lead applicants or a more flexible lead applicant structure would facilitate stronger partnerships and enable a broader range of organizations to contribute effectively to the program's goals. I recommend revising this requirement to accommodate several lead applicants per locality or to provide a structure that supports consortiums with shared leadership responsibilities. On page 10, for the sake of clarity and to increase the list of eligible applicants we suggest expanding the list of eligible applicants beyond the two types of entities currently emphasized (local educational agencies and workforce development programs). While these two types of entities play crucial roles, the current language could unintentionally limit the diversity of applicants by creating the perception that they are preferred over other potentially impactful organizations. By broadening the scope of eligible applicants, the program can better support a variety of organizations that are working directly with underserved communities, such as nonprofit organizations, public libraries, community health centers, and social service agencies, which also play vital roles in digital equity efforts. 8. Funding Restrictions 2. SECTION 8: Funding Restrictions We urge the State to consider allowing more flexibility in the allocation of funds within Track 1 to enhance the impact of local and regional digital equity efforts. The current cap of 10% on broadband subsidies, along with limits of $11,250 per award for devices in community spaces and $40,000 per award for take-home computing devices, may unintentionally restrict programs focused on providing essential technology and connectivity resources. Programs dedicated to digital literacy and skills training are most effective when paired with adequate access to devices and reliable broadband. Previous state and federal grants have demonstrated the necessity of substantial investments in technology, with up to 36% of their funding allocated to devices and data plans to meet community needs effectively. Increasing flexibility in these funding limits will allow communities to better address their specific digital access needs, leading to greater inclusion and long-lasting impact. We encourage the state to reconsider these funding caps to support well-rounded digital equity programs that connect underserved communities and provide them with the tools they need to succeed in today’s digital world.
6125	October 28, 2024 1:32 pm	Mark Revis	Broadband Project Manager	Organization	County of Napa	Napa	CA	94559	8. Funding Restrictions My comment is in regard to the cap on Planning Costs: Five percent (5%) or $50,000 is not sufficient for anything other than a single, small county to produce a credible digital equity plan. A large county of a regional consortium of counties would require far more. I recommend a cap of 25% or a minimum of $50,000 per county, whichever is greater. 5. Eligible Use of Funds and Program Requirements Six months is not sufficient time for a local government to complete a credible Digital Equity Plan, especially for a regional partnership, and/or if a consultant is to be hired to assist. I recommend a period of twelve months from the date of award.
6124	October 28, 2024 12:57 pm	Rachelle Chong	Attorney	Organization	Law Office of Rachelle Chong	San Francisco	CA	94127	6. Who This Benefits I am writing to advocate that Covered Individuals include Foster Youth age 21 to Age 26. During the statewide listening sessions, some speakers advocated for foster youth to be included in the program but there is no reference to them. Foster Youth are extremely low income and have no or little funds to purchase a computing device to do homework, distance learn, find a job, or telework. The new CPUC Foster Youth Lifeline Program only provides a device and service until age 21. When a foster youth "ages out" of the foster youth program, it is the time of the greatest need for a computing device (smart phone or tablet) in order to find housing, find food resources, and find a job. As a result, Eligible Individuals should include former Foster Youth age 21 to 26 (not in care), as they are Extremely Low Income with few resources. Thank you. 5. Eligible Use of Funds and Program Requirements For Foster Youth age 21-26, covered funds should include low-cost smartphones, tablets or laptops with Internet capability, and very low-cost Internet access service, e.g. $10/month if the foster youth is ineligible for California LifeLine service. It should also include some basic digital literacy training to set up an email, how to set a password, how to use the Internet for job search, housing, and basic food resources.
6123	October 28, 2024 12:39 pm	Maury Nickelson	Digital Equity & Inclusion Manager	Organization	United Way California Capital Region	Sacramento	CA	95827	8. Funding Restrictions This is a wonderful opportunity. If possible, please reconsider allocating additional funding to purchase equipment such as computers and hotspots (as well as increase the cap on price per device). Over the past few years, we have identified access to free or low-cost devices as the greatest need in our area. In Sacramento, there are limited options for those in need of a computer. Increasing the budget for devices would allow us to provide more computers, which in turn would help families in our community find job opportunities, access telehealth services, and generally improve the quality of life in our region.
6118	October 27, 2024 4:13 pm	Debbie Arthur	Development Director	Organization	Vision y Compromiso	Alameda	CA		8. Funding Restrictions Indirect costs of < 3% are prohibitive and extremely burdensome on community based organizations and non-profits and virtually assure that 1) we are unable to apply, or 2) if we do apply, we will be unable to cover all costs. Administrative Costs: No more than three (3) percent of the amount of the subgrant may be used for administrative costs (exclusive of costs for program evaluation and digital equity planning) in carrying out allowable activities under this Program and described in the Capacity Subgrant award. For this purpose, the three (3) percent limitation on administrative expenses includes the combined total of indirect and direct administrative costs charged to an award.
6114	October 26, 2024 9:17 am	Vickie Ponce	Program Manager	Organization	Community Partners in Caring	Santa Barbara	CA	93454	1. Program Background We recommend the timeline for establishing Centralized Services as well as what those services might include be made public and if possible occur prior to the application deadline, so that applicants can build their proposals around resources expected to be provided. The SDEP lists some potential suggestions, but a list accompanying the RFA would be helpful to applicants. Please provide a list of State Agency Digital Inclusion Programs that will be proposed to be funded so that applicants can identify the resources already coming through their counties and draft applications that supplement these programs rather than duplicate them. The SDEP lists some potential suggestions such as Access to Technology, CSL Connected CA, etc., but a list accompanying the RFA would be helpful to applicants. 5. Eligible Use of Funds and Program Requirements Clarify how the CDT envisions applicants utilizing the State's "centralized services" and "agency digital inclusion" efforts to maximize subgrantee budgets. For example: will the state offer a no-cost option for digital navigation training to subgrantees? Will the state be engaging with ISPs to compile location-based funding opportunities? CDT should ensure that Centralized Services do not displace the locally developed digital inclusion services that are already serving a county or region, but rather include opportunities for locally developed digital literacy or other inclusion services to be recognized alongside the Centralized Services. 6. Who This Benefits Under Covered Populations, we recommend the state expand the definition of Incarcerated individuals to include Formerly Incarcerated individuals. 7. Proposed Allocation & Award Formula The allocation formula underfunds the County of Santa Barbara according to analysis conducted by California Emerging Technologies Fund (CETF) using potential households requiring adoption assistance that are eligible for federal assistance programs. Based on the number of households that qualify for federal assistance programs, the County of Santa Barbara would fall short of funding to support 1179 households in making complete adoptions. We ask that the allocations model be adjusted to ensure adequate funding for all California counties to support households in their efforts to adopt digital technology and improve their access to the digital economy. 8. Funding Restrictions Please clarify if the “planning” portion of the grant (capped at 5% or 50,000) is expected to be used to draft a Digital Equity Plan for the County, or if there are specific parameters for planning activities.
6111	October 25, 2024 3:23 pm	Kim Fogel	Management Analyst	Organization	Alameda County Area Agency on Aging	Oakland	CA	94605	8. Funding Restrictions Please note I am speaking as an individual professional and my comments do not necessarily reflect the views of Alameda County or the Area Agency on Aging. This is a wonderful opportunity but many of us in this field would like to see more resources allotted to purchasing and distributing devices and hotspots. In our area the need is far exceeding the supply. Also a higher device budget would make it easier to procure specialized devices that are designed for use by cognitively impaired clients to help them prolong their independence.
6110	October 25, 2024 3:10 pm	Sery Tatpaporn	President/CEO	Organization	A B L E Community Development Foundation	Sacramento	CA	95828	7. Proposed Allocation & Award Formula In the last 2 years, we have been working with the limited English-speaking population in the digital literacy and empower them to learn how to navigate the internet to access to the information and services. We are currently engaging with over 15,000 people in Contra Costa County, and another 40,000 people in Sacramento County and surrounding region. We are very interested to access to this funding as a partner of any major organization(s) to meet the needs of the limited English-speaking populations.
6108	October 25, 2024 9:20 am	Jillian Spindle	Chief Strategy & Advancement Officer	Organization	Mission Economic Development Agency	San Francisoco	CA	94110	7. Proposed Allocation & Award Formula An award ceiling higher than $1M would be beneficial for a statewide ecosystem application, taking into account the number of partners and number of geographies that would be ideal for statewide impact.
6106	October 24, 2024 2:53 pm	Liz Thasiah	Vice President	Organization	Digital Equity Coalition of Santa Barbara County	Santa Barbara	CA	93101	1. Program Background We recommend the timeline for establishing Centralized Services as well as what those services might include be made public and if possible occur prior to the application deadline, so that applicants can build their proposals around resources expected to be provided. The SDEP lists some potential suggestions, but a list accompanying the RFA would be helpful to applicants. Please provide a list of State Agency Digital Inclusion Programs that will be proposed to be funded so that applicants can identify the resources already coming through their counties and draft applications that supplement these programs rather than duplicate them. The SDEP lists some potential suggestions such as Access to Technology, CSL Connected CA, etc., but a list accompanying the RFA would be helpful to applicants. 5. Eligible Use of Funds and Program Requirements Clarify how the CDT envisions applicants utilizing the State's "centralized services" and "agency digital inclusion" efforts to maximize subgrantee budgets. For example: will the state offer a no-cost option for digital navigation training to subgrantees? Will the state be engaging with ISPs to compile location-based funding opportunities? CDT should ensure that Centralized Services do not displace the locally developed digital inclusion services that are already serving a county or region, but rather include opportunities for locally developed digital literacy or other inclusion services to be recognized alongside the Centralized Services. 6. Who This Benefits Under Covered Populations, we recommend the state expand the definition of Incarcerated individuals to include Formerly Incarcerated individuals. 8. Funding Restrictions The allocation formula underfunds the County of Santa Barbara according to analysis conducted by California Emerging Technologies Fund (CETF) using potential households requiring adoption assistance that are eligible for federal assistance programs. Based on the number of households that qualify for federal assistance programs, the County of Santa Barbara would fall short of funding to support 1179 households in making complete adoptions. We ask that the allocations model be adjusted to ensure adequate funding for all California counties to support households in their efforts to adopt digital technology and improve their access to the digital economy.
6105	October 24, 2024 2:02 pm	Cynthia Gomez	Deputy Director of State Policy and Advocacy	Organization	Coalition for Humane Immigrant Rights, CHIRLA	Los Angeles	CA	90057	5. Eligible Use of Funds and Program Requirements As a proud member of the Digital Equity LA coalition and a longstanding advocate for immigrant rights, CHIRLA is committed to ensuring that underserved populations, including immigrant communities, have access to affordable, high-quality internet and digital services. We strongly support CDT’s focus on developing regional and local digital equity ecosystems but urge CDT to ensure that awarded funds under Track 1 are aligned with the specific needs of communities like those we serve. In Los Angeles County, many Covered Populations face unique barriers to digital inclusion, especially those with language barriers, low digital literacy, and low-income households. To maximize the impact of these funds, it is crucial that subgrantees be required to work closely with community-based organizations like CHIRLA that have deep, trusted relationships with these populations. We also encourage CDT to emphasize the need for culturally and linguistically appropriate services in digital literacy programs and broadband adoption campaigns, especially for immigrant and refugee communities. Additionally, CDT should provide flexibility for local organizations to design implementation strategies that reflect the realities on the ground, such as unincorporated areas or communities where broadband access and affordability are still significant challenges. By aligning funding with the actual needs of the community and working with trusted partners, CDT can ensure long-term sustainability and success in bridging the digital divide.
6104	October 24, 2024 12:24 pm	Jorge Rivera	Executive Co-Director	Organization	Healing and Justice Center	El Monte	CA	91731	13. General Comment Not Related to Above Sections We are excited to express our strong support for the application being submitted by UNITE-LA, in collaboration with LAEDC and the DELA coalition, as part of Los Angeles' effort to advance digital equity. This initiative represents a comprehensive and inclusive approach to addressing the digital divide, particularly in underserved communities across LA County. By leveraging the combined expertise of key partners like UNITE-LA, LAEDC, and DELA, this application is uniquely positioned to ensure that the most marginalized populations—such as low-income households, communities of color, and individuals with language barriers—are included in digital equity efforts. Their strategic vision, focused on long-term sustainability, capacity building, and collaboration with trusted community-based organizations, will ensure that digital inclusion is not just a short-term fix, but a lasting solution. We are confident that this partnership will effectively address the barriers to digital access and opportunity for all Angelenos, and we strongly urge CDT to approve and support this vital application.
6103	October 24, 2024 11:06 am	Rebecca F. Kauma	Director of Digital Equity	Organization	County of Los Angeles	Los Angeles	CA	90063	1. Program Background The County of Los Angeles recommends that the California Department of Technology (CDT) develop a data-driven, real-time, user-friendly dashboard demonstrating how the Broadband for All Action Plan and California State Digital Equity Plan (SDEP) goals are being implemented effectively and successfully statewide. This includes visually displaying how the California Digital Equity Capacity Program funding is being allocated and spent in each County geographic area and statewide focusing on (e.g., centralized services, state agency digital inclusion efforts, and capacity subgrant program). See examples of data-driven, real-time, user-friendly dashboards below that were used to display the citywide and countywide impact of the American Rescue Plan Act of 2021 (ARPA) COVID-19 Pandemic relief funding. • County of Los Angeles: https://arptracking.ceo.lacounty.gov/public • City of Long Beach: https://app.powerbigov.us/view?r=eyJrIjoiODcxMzhhMTctYmQ0OS00NWY3LThlMTctNTE2ODAwZmYwZWIwIiwidCI6IjMxM2YxMWMzLTQyNjgtNGY2YS04ZDNiLWM3ZTY1MDE4M2U3OCJ9 2. Goals of the Capacity Subgrant Program The County of Los Angeles encourages the California Department of Technology (CDT) to engage and empower communities most impacted by the digital divide and focus on the Covered Populations as part of statewide Stakeholder Engagement efforts. The CDT should collaborate with trusted organizations to engage the Covered Populations through equity-centered, inclusive, culturally relevant, and sensitive strategies. This includes honoring the community’s time by providing gift cards and stipends for their engagement and participation in government and organizational decision-making processes. The County of Los Angeles recommends that the CDT apply an equity lens to community outreach and engagement efforts to mitigate key participation barriers such as but not limited to (e.g., child watch services, cultural and economic considerations, language access, location accessibility, safety needs, trust issues, timing challenges, and transportation needs, etc.). Please reference page 12 of the City of Long Beach Equity Toolkit for equity-driven community outreach and engagement best practices and strategies. • City of Long Beach Equity Toolkit: https://longbeach.gov/globalassets/health/media-library/documents/healthy-living/office-of-equity/city-of-long-beach-office-of-equity-toolkit Additionally, the County of Los Angeles encourages the CDT to collaborate with local and regional trusted coalitions, committees, and consortia to ensure that smaller cities, community-based organizations, and non-profits are engaged in the California Digital Equity Capacity Program efforts as part of Stakeholder Engagement efforts. As outlined in the California State Digital Equity Plan (SDEP), many smaller organizations experience barriers such as a lack of staff and organizational capacity and difficulty accessing and applying for grant funding. Many of these partners and stakeholders have credibility, trust, and relationships with the Covered Populations. The County of Los Angeles recommends that the CDT provide ongoing capacity building, technical assistance, training, and support to equip these organizations to apply, secure, and implement Digital Equity Capacity Grant Program funding. This includes ensuring that the engaged organizations are multi-sector and reflect the policy outcome areas in the SDEP, such as (e.g., education, healthcare, digital literacy and inclusion, workforce and economic development, essential services, accessibility, and civic engagement, and Tribal collaboration and partnership). The County of Los Angeles strongly recommends that the CDT adopt a systems change approach to ensure long-lasting and meaningful change in digital inclusion activities. A system is the relationship among interdependent, interconnected, and interrelated factors, people, and structures. Systems change is about shifting the conditions that hold the problem (digital divide) in place. Culture, history, ideology, and interactions of systems work together to perpetuate inequities. CDT can drive systems change efforts by supporting equitable policies and practices that address the diverse and unique digital equity needs of the Covered Populations. It is imperative to ensure that statewide funding and resources are allocated equitably to communities with the greatest digital equity needs. This allocation should be based on both quantitative and qualitative (community storytelling) data, emphasizing the importance of data-driven decision-making. Lastly, addressing power dynamics is crucial to empower the Covered Populations to have power, voice, and ownership in key decision-making processes. Please reference the Waters of Systems Change. • The Waters of Systems Change: https://www.fsg.org/wp-content/uploads/2021/08/The-Water-of-Systems-Change_rc.pdf The County of Los Angeles supports developing and refining local digital equity plans and encourages the CDT to ensure that all planning efforts result in tangible digital equity action, such as implementing digital inclusion activities, and efforts that address the critical systemic and institutional barriers, challenges, gaps, and root causes that the Covered Populations face. 3. Definitions The County of Los Angeles recommends that the California Department of Technology (CDT) defer to the National Digital Inclusion Alliance (NDIA) definitions, which are national industry standards for “digital equity ecosystem” and “digital literacy.” “A Digital Inclusion Ecosystem combines programs and policies that meet a geographic community’s unique and diverse needs. Coordinating entities work together in an ecosystem to address all aspects of the digital divide, including affordable broadband, devices, and skills. Indicators of a strong Digital Inclusion Ecosystem: • Existence of programs and policies addressing all aspects of the digital divide: • Affordable and subsidized broadband service options that meet the community’s needs • Affordable and subsidized device ownership programs that meet the community’s needs • Multilingual digital literacy and digital skill training that meet the community’s needs • Hardware and software technical support • Digital navigation services to guide residents to the above services” “Digital Literacy is the ability to use information and communication technologies to find, evaluate, create, and communicate information, requiring cognitive and technical skills.” The County of Los Angeles encourages the CDT to define and clarify the roles of subgrantees, subrecipients, and contractors based on Federal guidance from the Code of Federal Regulations (CFR). 4. Eligible Applicants The County of Los Angeles recommends that the California Department of Technology (CDT) require all primary applicants to provide tangible examples and relevant experience with the following criteria. This includes providing and demonstrating key outputs, outcomes, and previously achieved and met equity indicators. • Local/regional coalition-building • Digital equity or digital inclusion planning, or programming • Managing federal or state grants • Strategic planning or service delivery in the County they are applying for and with local partners in place • Awarding grants or subgrants • Statewide coalition-building • Digital equity or digital inclusion planning, or programming • Managing federal or state grants • Strategic planning or service delivery for the specific Covered Population(s) or outcome area(s) they are applying for • Applicants with a statewide network of partners The County of Los Angeles recommends that the CDT allow for both one and multiple application submittals per County geographic area, like the National Telecommunications and Information (NTIA) 's approach to the Digital Equity Competitive Grant Program application. Digital equity efforts are rooted in multi-sector partnerships. Hence, having more than one application submitted within a geographic area may be more appropriate. Los Angeles County, being the most populous County in the nation, with more than 10 million residents (2023, U.S. Census Bureau) and 87 percent of Los Angeles County residents identifying as Covered Populations (2024, DEA Population Viewer), understands the need for such flexibility of having the option to have either one or more than one application submitted within a geographic area. This approach ensures that each County's geographic area and its stakeholder organizations can choose the best collaboration and partnership strategy that aligns with their mission, vision, and goals if needed. 5. Eligible Use of Funds and Program Requirements The County of Los Angeles recommends that the California Department of Technology (CDT) takes into consideration the following suggestions for the development or refinement of regional/local digital equity plans: • Provide and share examples of other cities statewide that have developed digital equity and inclusion strategic plans (e.g., refer to the National Digital Inclusion Alliance Digital Inclusion Trailblazer roster) • Require and include local data collection efforts • Require and include community outreach and engagement efforts (e.g., engage the Covered Populations) as part of the regional/local digital equity plans development and be included in the decision-making process This includes uplifting The Spectrum of Community Engagement to ensure that communities most impacted by the digital divide have voice, power, and ownership in the decision-making of regional/local digital equity plans (e.g., include their lived experiences). Please refer to the City of Long Beach documents for best practices and examples of developing and implementing local digital equity plans. • City of Long Beach Digital Inclusion Roadmap: https://www.longbeach.gov/globalassets/digital-inclusion/media-library/documents/strategy-and-planning/long-beach-digital-inclusion-roadmap-july-2021 • City of Long Beach Digital Inclusion Implementation Plan: https://www.longbeach.gov/globalassets/digital-inclusion/media-library/documents/strategy-and-planning/digital-inclusion-implementation-plan 6. Who This Benefits The County of Los Angeles recommends that the California Department of Technology (CDT) consider the intersectionality among the Covered Populations. Communities are culturally diverse and must often navigate the lack of power and privilege through the lens of intersectionality. Each Covered Population experiences different disparities and may have differing life outcomes. Identity and intersectionality should be considered when serving the Covered Populations. All digital inclusion activities should be co-created using an equity framework, not a one-size-fits-all approach. The CDT needs to engage trusted stakeholder organizations with credibility and genuine relationships with the Covered Populations. All Covered Populations should have a voice and power in administrating the Digital Equity Capacity Subgrant Program. 7. Proposed Allocation & Award Formula The County of Los Angeles recommends that the California Department of Technology (CDT) also reference American Community Survey Data (ACS) 5-Year and 1-Year Estimates and the Affordable Connectivity Program (ACP) Enrollment Tracker data when determining statewide funding allocation for the California Digital Equity Capacity Program efforts. Additionally, the CDT should establish an equitable and inclusive process for reallocating and redistributing statewide funds to County geographic areas that do not use their funding allocation from the State. This includes incorporating data-driven and equitable decision-making by prioritizing County geographic areas with lower funding allocation based on digital equity needs. 8. Funding Restrictions The County of Los Angeles supports that no more than five (5) percent of the amount of the subgrant for this purpose, or $50,000, whichever is the higher amount, may be used for Track 1 or Track 2 digital equity planning activities. The County of Los Angeles recommends that the California Department of Technology (CDT) remove the cap on internet-enabled devices. As highlighted in the American Community Survey (ACS) 2022 5-Year Estimates, more than 150,000 (4.6 percent) of households in Los Angeles County do not have a computer. Additionally, as outlined in the California State Digital Equity Plan (SDEP), internet-enabled devices are a need. The cost of devices is a very real barrier to sustainable broadband adoption. Thirty-three percent of respondents to the SDEP telephone survey stated, “Nobody in my household has a desktop, laptop, or tablet computer” as a reason for not having internet access at home.” Ensuring all Covered Populations have access to and use high-quality, user-friendly, multi-functional internet-enabled devices and other digital equity elements (e.g., broadband internet services, digital skills, digital navigation services, and technical support services) is essential to achieving digital equity. 9. Information Requested from Applicants The County of Los Angeles recommends that the California Department of Technology (CDT) provide tangible examples of what specific documentation should be submitted as evidence verifying the lead applicant’s status as an eligible entity. Additionally, the County of Los Angeles suggests that the CDT requires the lead applicant to provide tangible examples and relevant experience, as shown below. This includes providing and demonstrating key outputs, outcomes, and previously achieved and met equity indicators. • Capacity to implement the proposed activities and meet key milestones • Experience managing similar partnerships or coalitions • Experience managing federal or state grants or subgrants • Experience engaging with or serving Covered Populations • If second-tier subgrants are proposed, a description of the lead applicant’s experience in making grants or subgrants to other organizations As requested in the Digital Equity Competitive Grant Program Notice of Funding Opportunity (NOFO), the County of Los Angeles recommends that CDT requires Letters of Commitment that outline the scope of work of the subrecipients and Letters of Support. The County of Los Angeles encourages the CDT to make the application simplified and user-friendly such as: • Simplified templates for required application materials • Example proposals to applicants to reference • Minimize redundant application questions • Clear and specific applications with character or word limits • Application resources (e.g., FAQs, technical assistance and support, videos, webinars, etc.) 11. Post-Award Expectations The County of Los Angeles recommends that the California Department of Technology (CDT) provide ongoing technical assistance, training, and guidance to the primary applicants and their subrecipients to ensure they can meet and exceed the Post-Award Expectations and reporting requirements. This includes ongoing resources and convenings to ease grant program administrative burdens and build organizational staff capacity (e.g., meetings, office hours, and online platforms). 13. General Comment Not Related to Above Sections The County of Los Angeles recommends that the California Department of Technology (CDT) use equity-centered resources for grant program development, implementation, management, and evaluation (e.g., Government Alliance on Race and Equity Racial Equity Toolkit, Long Beach Equity Toolkit for City Leaders and Staff, National Digital Inclusion Alliance State Digital Equity Implementation Manual). Additionally, the CDT should provide opportunities to share and showcase statewide, regional, local, and grassroots digital equity grant programming best practices. In alignment, the CDT must offer ongoing resources to support effective data collection, analysis, monitoring, reporting, and community storytelling. This includes standardizing key outcomes, outputs, equity indicators for usage, and uplifting community-centered storytelling (e.g., art, articles, dance, interviews, music, photos, quotes, success stories, and videos). CDT should also create an interactive real-time virtual statewide digital equity ecosystem map that compiles all the digital inclusion resources, services, and programs collected as part of the Digital Equity Ecosystem Map (DEEM) Tool. • Government Alliance on Race and Equity Racial Equity Toolkit: https://belonging.berkeley.edu/sites/default/files/gare-racial_equity_toolkit.pdf • Long Beach Equity Toolkit for City Leaders and Staff: https://longbeach.gov/globalassets/health/media-library/documents/healthy-living/office-of-equity/city-of-long-beach-office-of-equity-toolkit • National Digital Inclusion Alliance State Digital Equity Implementation Manual: https://www.digitalinclusion.org/wp-content/uploads/2024/04/NDIA-State-Digital-Equity-Implementation-Manual-2024.pdf
6101	October 23, 2024 4:40 pm	Stephanie Tapia Onate	Communications & Policy Coordinator	Organization	Alliance for a Better Community	Los Angeles	CA	90017	6. Who This Benefits As a proud member of the Digital Equity LA coalition and an advocate for Latina/o communities in Los Angeles County for over 25 years, Alliance for a Better Community (ABC), is dedicated to bridging the digital divide and ensuring equitable access to high-speed internet for all communities, especially those that have been historically underinvested in, such as Southeast Los Angeles. For Track 1: Regional/Local Ecosystems, we recommend that subgrants prioritize hyper-local organizations, particularly those serving covered populations—such as aging individuals, people with language barriers, and racial or ethnic minorities—that already have strong, trusted relationships within their communities. By partnering with community-based organizations like ABC, which deeply understand the unique needs and challenges of these populations, digital equity initiatives will be more effective in reaching the most marginalized individuals. Furthermore, we strongly urge CDT to provide ongoing technical support and capacity building for smaller community-based organizations to ensure their participation in regional ecosystems is both meaningful and sustainable, empowering them to play a key role in closing the digital divide.
6098	October 23, 2024 3:49 pm	Liam Arnade-Colwill	Youth Advocacy Manager	Organization	Para Los Ninos	Los Angeles	CA	90026	2. Goals of the Capacity Subgrant Program CDT's strategy to promote "Long-lasting and Meaningful Change" will need to further elevate the importance of regional and local digital equity plans. It will therefore be crtical to highlight the importance of and funding for these local planning efforts to help communities identify their needs and chart out a path for sustainability and resource funding beyond NTIA grant dollars. "This Program is structured around funding further planning, ecosystem development, and capacity building for statewide and regional/local coalitions" should also include program evaluation activities and data collection to further enhance local and regional knowledge of digital equity conditions. On Track 1 funding for local digital equity plans and digital equity capacity building, the Program should additionally focus on the planning of broadband infrastructure development strategies as they align with long-term sustainability of broadband adoption and ecosystem development. 3. Definitions As a member of the Digital Equity LA (DELA) coalition, I’ve seen firsthand the incredible work that local community organizations and grassroots groups do every day to help bridge the digital divide in Los Angeles County. While the current definition of the Digital Equity Ecosystem is a great start, we believe it could be even stronger by specifically highlighting these community-driven efforts. In our coalition, we’ve seen how local nonprofits, advocacy groups, and community-based organizations are often the first to step up and help people in underrepresented communities—whether it’s providing digital literacy training, distributing affordable devices, or connecting families to low-cost broadband options. These smaller organizations are vital to the ecosystem because they know their communities inside and out, and they bring trust and cultural understanding that larger entities might not have. To build a truly inclusive digital equity ecosystem, it’s important that CDT acknowledges these smaller, yet incredibly impactful, organizations as key assets. By supporting the efforts already in place on the ground, we can make sure that everyone—no matter their background or zip code—has the tools and opportunities they need to thrive in today’s digital world. 4. Eligible Applicants We are excited to express our strong support for the application being submitted by UNITE-LA, in collaboration with LAEDC and the DELA coalition, as part of Los Angeles' effort to advance digital equity. This initiative represents a comprehensive and inclusive approach to addressing the digital divide, particularly in underserved communities across LA County. By leveraging the combined expertise of key partners like UNITE-LA, LAEDC, and DELA, this application is uniquely positioned to ensure that the most marginalized populations—such as low-income households, communities of color, and individuals with language barriers—are included in digital equity efforts. Their strategic vision, focused on long-term sustainability, capacity building, and collaboration with trusted community-based organizations, will ensure that digital inclusion is not just a short-term fix, but a lasting solution. We are confident that this partnership will effectively address the barriers to digital access and opportunity for all Angelenos, and we strongly urge CDT to approve and support this vital application."
6098	October 23, 2024 3:49 pm	Sarah Washington	Resource Management Manager	Organization	iFoster	Truckee	CA	96160	3. Definitions Covered Populations Please consider including Former Foster Youth as a sub-group of covered populations. In the state of California there are roughly 38,349 former foster youth (FFY) ages 18-26. As youth are transitioning out of care, this is the most critical time to be digitally connected so they have access to the resources they need to thrive as they enter independence and adulthood. Including FFY as a covered population would help improve the following social determinants of health and the impact on foster youth. -Economic Stability- Within 4 years of aging out of care, 50% are unemployed and those that are employed only earn $7,500/year. Being digitally connected would allow FFY to actively seek employment, advance the skills needed to attain a job, and remain employed once hired -Social and Community- Close to 4,500 California youth in foster care age out every year with few supports Being digitally connected would allow FFY to stay connected with their supports rather than lose them due to not having a way to stay in contact as they navigate transitioning out of care -Neighborhood Environment- 50% will experience homelessness Being digitally connected would allow FFY to access the resources they need to find housing resources, fill out housing applications, and keep housing once it is secure -Educational Access- 3% of foster youth achieve a college degree within 4 years of aging out and only 8% over their lifetime Being digitally connected would allow FFY the opportunity to apply for colleges, apply for financial support for college, as well as having access to the technology to succeed in college -Health Care Access & Quality- 52% of individuals recently aged out reported receiving a physical exam in the past year. Even more concerning, 31% of people had to visit the emergency room two or more times in the past year Being digitally connected would allow FFY the capability to schedule physical exams, mental health appointments and have access to their vital records. In having the access to be proactive with their health, it should help eliminate the high percentage of emergency room visits. Digital Literacy The guidelines state, “that the skills associated with using technology to enable users to find, evaluate, organize, create, and communicate information is important.” Please consider using solution-oriented digital competency training. Part of providing access includes ensuring that covered populations can use their technology and understand its value in accessing the information, resources and services they need through leveraging digital literacy curriculum that already exists and that already has a proven impact. iFoster’s digital literacy curriculum was developed through funding from California Advanced Services Fund for Broadband Adoption (Feb, 2020) which has been successfully used to train 12,704 and certify 7,917 Transitional Age Youth (TAY) and is currently imaged as self-directed training modules onto every phone provided to foster youth in California as part of the permanent California Foster Youth LifeLine program. Digital Navigators Digital Navigators are important to the advancement of digital equity for all in the state of California. In addition to digital navigators being “trusted community organizations or community members” a value addition to this definition would be that Peer Support Specialists (PSS) are added to this list. Training peers to be the navigators will allow trust for the covered populations by receiving information, instruction and benefit access from peers who look like them, talk like them, and know the barriers they are facing and have faced. Having PSS as Digital Navigators will help meet Goal 3: All Californians can access training and support to enable digital inclusion by meeting 3 of the objective goals, 3.4, 3.5 & 3.6. 5. Eligible Use of Funds and Program Requirements The guidelines state that “Track 2 subgrants will fund digital equity activities that serve at least one Covered Population or outcome area.” Once again, please consider identifying Former Foster Youth (FFY) as a sub-group of covered population as well as Peer Support Specialists (PSS) to be added to become Digital Navigators to reach the covered populations and outcome areas.
6095	October 23, 2024 10:51 am	Carlos Rodriguez	Community Organizing Director	Organization	Innovate Public Schools	Redondo Beach	CA	90277	5. Eligible Use of Funds and Program Requirements On "Plans to collaborate with or make second-tier subgrants to key stakeholders in the county/region, especially those that represent the interests of or provide services to Covered Populations," we strongly recommend that the capacity grant leave open the opportunity for lead applicants to add additional Tier 2 partners after submission and during implementation to provide allowances for Tier 2 partner readiness.
6094	October 23, 2024 10:31 am	Natalie Gonzalez	Deputy Director	Organization	Digital Equity Los Angeles (DELA)	Thousand Oaks	CA	91362	1. Program Background Transparency and Accountability: Given the significant work already underway in Los Angeles County’s digital equity ecosystem, we strongly recommend that the CDT provide a clear and transparent process for sharing updates and progress reports on the State Digital Equity Plan (SDEP). Regular updates on project milestones, funding allocations, and strategic shifts are crucial to ensure that local initiatives remain aligned with state-level actions. Additionally, given that device funding caps have been set through the competitive grant program, we suggest that CDT clarify how the different grant programs (such as the competitive and capacity subgrants) will be distinguished in future updates, particularly in terms of device-related funding. Ensuring transparency on how these funding streams are applied will help local organizations better understand where opportunities for device funding exist and adjust their strategies accordingly. Regular, accessible updates on the CDT website will further enable community organizations to stay informed and adapt their efforts to support the state’s progress, fostering continued coordination across LA County’s digital equity ecosystem. 7. Proposed Allocation & Award Formula Support for Long-Term Capacity Building & CDT Reports to support statewide communication for localized efforts - CDT should clearly outline how it will provide updates and maintain the SDEP, with a focus on both new and existing projects within the Capacity Grant Program. Publicly available reports on the CDT website will allow local governments and partners in Los Angeles County to coordinate their efforts, ensuring that digital equity is achieved through ongoing infrastructure support and community capacity building. A transparent reporting mechanism, such as regular public meetings or a dedicated dashboard, will ensure state and local efforts remain in sync and responsive to community needs. 8. Funding Restrictions Given that many potential sub grantees may struggle with where to start with deploying digital inclusion activities, but know that there's a tremendous need, the 5% "cap" on planning activities is too low, and should be increased to up 25% or up to $250K, whichever is lower. Planning is important and critical to capacity building.
6088	October 22, 2024 9:21 am	Robert Cabeza	Consultant, Technology, Youth Development	Organization	R Cabeza Consulting LLC	Long Beach	CA	90814	11. Post-Award Expectations There should be a goal about cross generational training, young people teaching families and seniors for instance. There should also be more emphasis on teaching technology to young people to access college, scholarships, jobs, etc. There should also be more emphasis on teaching young people to be content creators from coding, to social media to creating digital art, digital engineering, etc. These are the main economic drivers in California. Workforce and technology needs to be much more open as far as figuring and possibilities.
6067	October 17, 2024 3:41 pm	Paula Reinman	VP Strategy and Communications	Organization	Marconi Society	Orinda	CA	94563	5. Eligible Use of Funds and Program Requirements As funding begins to flow to organizations and many new people join the digital equity field, we are seeing an imperative for professional development to build a digital equity talent pipeline. This is critical for program success and sustainability and is a key part of an organization's "capacity to implement proposed activities and key milestones." Thank you for including this important aspect under Eligible Use of Funds for Track 2. I suggest that professional development also be included as an eligible use of funds for Track 1 funding. One way to do this could be by listing capacity-building or professional development in "assets to be leveraged" under the heading "Development or refinement of regional/local digital equity plans ." Thank you for your consideration.
6055	October 15, 2024 7:15 am	Teresa Valenzuela	Community Outreach Manager	Organization	San Diego Futures Foundation	San Diego	CA	92105	2. Goals of the Capacity Subgrant Program To foster a movement through our Youth IT-Digital Bridge Program, we prepare workforce interns for their CompTIA A+ certification through a three-part approach: 1) classroom instruction, 2) hands-on experience in our hardware department, and 3) practical training as community help desk technicians. The third component seamlessly integrates into our Digital Bridge Program, which leverages our Tech-Express van to reach community host sites. Through this initiative, we deliver our programs and services directly to underserved populations, offering digital skills workshops, low-cost computer sales, and personalized assistance from help desk technicians to support home network systems.
6053	October 14, 2024 4:04 pm	Karlha Arias	Co-Founder	Organization	yuda LLC	Stanislaus	CA	95350	2. Goals of the Capacity Subgrant Program We urge the California State Digital Equity Plan to prioritize Central Valley counties like Stanislaus, where healthcare and education applications have been deployed without adequate community training. The absence of a digital equity consortium in the Central Valley has left these regions underserved. To address this gap, funding must be allocated directly to programs that focus on digital literacy, particularly in communities that face significant barriers to access. Without investing in these counties, the full potential of this grant will not be realized, leaving large populations behind. We request specific investment in local EdTech initiatives, including ours, which focus on building long-term digital skills and providing culturally sensitive training for marginalized groups. These programs will empower underrepresented populations to fully participate in both education and healthcare technologies, ensuring they are not left out of California's digital future. Additionally, as emerging technologies like artificial intelligence (AI) become increasingly integrated into every sector, it is critical that EdTech programs in underserved communities include training on these technologies. AI, automation, and related skills are becoming essential for workforce readiness, and it is vital that communities in the Central Valley, particularly BIPOC women, non-English speakers, and low-income residents, are not left behind in this transformation. By including AI training in EdTech initiatives, we ensure that our communities stay up to date with technological advances and are equipped to participate in the tech economy on an equal footing.
6046	October 9, 2024 2:12 pm	Raul Moreno	CEO	Organization	Moreno Seeds Foundation	Fresno	CA	93710	6. Who This Benefits Have you considered including farmworkers in the populations.
6045	October 9, 2024 10:49 am	Bill Payne	President & CEO	Organization	San Diego Second Chance Program	San Diego	CA	92114	3. Definitions The list of covered populations on this form includes both incarcerated and formerly incarcerated people, but the Program Guidelines only lists (currently) incarcerated people. It is important to modify the covered populations in the California Digital Equity Capacity Subgrant Program to include formerly incarcerated individuals alongside the incarcerated population because this group faces significant barriers to reintegration, including limited access to digital tools and skills. Formerly incarcerated individuals often struggle with digital literacy, which is crucial for accessing employment, education, healthcare, and other social services. Including them in the grant’s covered populations ensures they receive targeted support to develop digital skills, which can help reduce recidivism, improve reentry outcomes, and promote their long-term self-sufficiency and community reintegration. Digital inclusion for this population would also foster equity by addressing a critical gap in resources that can enhance life outcomes post-incarceration.
6029	October 3, 2024 11:01 am	Gina Mascaro	Senior Director of Development	Organization	Long Beach City College Foundation	Long Beach	CA	90808	4. Eligible Applicants Long Beach City College Foundation, Lifetime Learning Center for Senior Studies would like to apply for this grant to support Senior Students with WIFI and those in the surrounding community. We are in the 6th district in Long Beach, which has highest diversity and lowest income and believe a grant to provide computers would encourage adult learners. The Center has has the instructors that can teach classes for the awardees to learn how to use their computers, etc.

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