4. Collaboration and Stakeholder Engagement

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4.1 Inclusive and Participatory Planning Process

CDT, CPUC, and the CBC began the public engagement process that has informed this Digital Equity Plan while developing and implementing the Broadband for All Action Plan. This engagement included quarterly public meetings of the CBC, a series of Broadband for All Summits and webinars in 2021 and 2022, and a Broadband for All Digital Equity and BEAD Kick-Off in October 2022 – an event that more than 800 people attended following outreach to leaders of organizations serving covered populations throughout the state.

Inclusivity, accessibility, and equity were at the forefront of the planning and engagement process. In 2022, Governor Newsom’s Equity Executive Order directed “State agencies and departments to take additional actions to embed equity analysis and considerations in their mission, policies and practices.”[1] This Equity Executive Order shortly followed the appointment of California’s first State Chief Equity Officer who, “provides statewide leadership and consultation on diversity, equity, inclusion, and accessibility regarding State operations, procurement, information technology, and human resources.”[2] And while the State’s Broadband for All Action Plan has embodied these values of equity since its inception, this guidance empowered CDT to take the steps necessary to engage with the broadest and most diverse segments of California’s population.

CDT, CPUC, and other State agencies and departments developed and implemented a multi-component, mixed-method outreach program and engagement process for maximum participation and engagement with covered populations. The engagement was organized around five primary components, each of which is summarized in this section:

  1. Statewide Digital Equity Planning Group
  2. Outcome Area Working Groups
  3. Statewide Digital Equity Surveys
  4. Regional Planning Workshops
  5. Ongoing Stakeholder Engagement

4.2 Outreach Approach

Throughout the engagement process, CDT prioritized accessibility and inclusivity, emphasizing outreach to and engagement with residents, stakeholders, and communities that identify as, represent, or provide services to members of covered populations. These outreach efforts included:

  • Outreach was undertaken to historically underserved communities (e.g., low-income, tribal, rural, and ethnic minorities) through trusted messengers and culturally specific media such as partnering with AARP of California to engage aging individuals and distributing the online survey over WeChat. CDT worked with hundreds of outreach partners, including those with focuses on certain covered populations, outcome areas, and geographies.
  • Various engagement formats, such as virtual, in-person, individual and group listening sessions and consultations, were employed.
  • Events that were open to the public and all interested parties were held.
  • ASL interpretation and closed captioning were made available for online engagements.
  • Surveys included written and audio-enabled formats in the top 14 languages in California allow survey respondents with language barriers or low-levels of literacy to contribute to the process.
  • In-person workshops throughout California were held at community-friendly venues, with food and refreshments provided, and language interpretation and childcare services when requested.
  • Presentation decks and summaries of suggested strategies were provided to the public after each event.

These methods helped CDT reach more than 50,000 Californians, whose perspectives and experiences shaped every component of this plan.

4.3 Summary of Outreach and Engagement Methods

Digital Equity Statewide Planning Group (SPG)

Developed to advise CDT on the statewide digital equity planning process, the SPG consists of 22 state entities, including member organizations of the CBC and additional organizations with direct connections to covered populations and those with subject matter expertise tied to key policy outcome areas. This body met quarterly during 2023 during the planning process. All meetings were open to the public, and all recording and artifacts are posted on the Broadband for All portal. A complete list of SPG member entities and meeting dates can be found below and in Appendix L.

California Broadband Council MembersEight Covered Populations and Outcome Area Experts
Department of Technology
Public Utilities Commission
Governor’s Office of Emergency Services
Department of Education
Department of General Services
Department of Transportation
California Emerging Technology Fund
Department of Food & Agriculture
California State Library
Governor’s Office of Tribal Affairs
Department of Housing & Community Development
Department of Correctional Rehabilitation
Department of Public Health Services
Government Operations Agency
Department of Veterans Affairs
Department of Aging
Department of Rehabilitation
Labor and Workforce Development Agency
Rural Counties Representative of California
Office of Data and Innovation

Digital Equity Statewide Planning Group Meeting Dates

  • January 25, 2023
  • April 26, 2023
  • July 26, 2023
  • October 25, 2023

Outcome Area Working Groups (OAWG)

CDT developed six OAWGs to convene subject matter experts and practitioners to develop strategies that align with State policy priorities through the lens of the digital equity barriers experienced by covered populations. The OAWGs focused on Education; Health; Digital Literacy and Inclusion; Workforce and Economic Development; Essential Services, Accessibility, and Civic Engagement; and Tribal Collaboration. The OAWGs assisted in developing statewide stakeholder maps and asset inventories of existing digital equity programs and resources and provided recommendations to CDT within their assigned policy areas. These working groups met four times each during the planning process between February and June 2023. Membership and meetings were public, and all recordings and artifacts are posted on the Broadband for All portal. See below and Appendix L for details on OAWG convenings and Appendix M for a list of co-chairs.

Priority Areas Co-Chairs Key Parties
  • Dept. of Education, University of California
  • California State University
  • Chancellor’s Office of Community Colleges
  • Corporation for Education Networks In California (CENIC)
  • School districts and higher education
  • CBOs serving children, youth and families
  • Dept. of Public Health
  • Dept. of Health Care Services
  • California Covered and Health Initiatives
  • Insure the Uninsured Project, Office of Planning and Research (OPR)
  • Community health providers, clinics, health focused CBOs
Digital Literacy and Inclusion
  • CDT
  • CPUC
  • CDA
  • State Library
  • Common Sense Media
  • Device providers including refurbishers
  • Digital inclusion practitioners
  • ISPs
Civic Engagement, Essential Services and Accessibility
  • CDT
  • Government Operations Agency
  • Office of Data and Innovation
  • Dept. of Rehabilitation
  • Assistive technology experts (UI/UX)
  • Senior and disability-serving CBOs
Economic and Workforce Development
  • CPUC
  • Community Colleges
  • Labor and Workforce Development Agency
  • GO-Biz
  • Fiber Broadband Association
  • NextGen Policy
  • CBOs
  • Labor
  • ISPs
  • Major Employers, small businesses
  • DVBE
Tribal Collaboration
  • Governor’s Office of Tribal Affairs
  • CDT
  • CPUC
  • NTIA
  • Tribal Chairpersons Associations
  • Tribes

Statewide Digital Equity Surveys

CDT developed multiple surveys to obtain qualitative and quantitative data to more accurately understand the digital equity barriers experienced by covered populations and the organizations that serve them.

  • Digital Equity Telephone Survey: CDT, in partnership with CETF and researchers from the University of Southern California Annenberg School for Communication and Journalism, conducted a statewide telephone survey that engaged more than 3,500 residents through random direct dialing to collect information about their experiences, needs, and aspirations regarding broadband access and digital equity. CDT consulted with Rural County Representatives of California and the California Department of Rehabilitation to ensure the voices of rural residents and those with disabilities would be heard in the survey. See Appendix O for the survey methodology.

    Appendices contain three charts highlighting the methodology and distribution of respondents to the telephone survey can be found in Appendices. Appendix P is a summary of the data collection, Appendix Q is the four neighbor regions and corresponding sample size, and Appendix R is covered population distribution.
  • Digital Equity Online Public Survey: To complement the telephone survey and allow more citizen input, CDT worked with the Broadband Equity Partnership to release a mobile-friendly, online public survey that generated over 40,000 responses from residents and members of covered populations. CDT promoted the survey at all Digital Equity meetings in collaboration with various ecosystem partners including State Agencies, Broadband Consortia, Communication Workers of America, RCRC, AARP of California, San Diego Association of Governments and Southern California Association of Governments to distribute the survey as widely as possible. The survey proved to be one of the most accessible of its kind, collecting responses in 14 languages and with the support of audio translations for those with sight impairments or low literacy. Responses were particularly helpful for providing a deeper understanding of digital equity needs among specific covered populations. See Appendix S for the methodology.

    Appendices contain three charts highlighting the diverse communities that responded to the online public survey. Appendix T is respondents by language, Appendix U is respondents by covered population, and Appendix V is respondents by county of residence.
  • Digital Equity Ecosystem Mapping (DEEM) tool: CDT gained new insights into California’s digital equity landscape through the DEEM tool, including versions for all digital equity organizations, for Internet Service Providers, and for tribal communities. More than 460 government organizations, tribal entities, schools, libraries, community-based organizations, labor organizations, philanthropies, ISPs, and private sector organizations completed the DEEM tools which identified organizations, programs, resources, and gaps in California’s digital equity ecosystem and further informed the State’s asset inventory included in this SDEP. See Appendix W for the methodology and Section 3.2 for the findings.

Regional Planning Workshops

The State contracted with CETF and partnered with regional broadband consortia and other local entities to conduct 17 in-person Broadband for All, Digital Equity, and BEAD Regional Planning Workshops and three Regional Tribal Consultations. These working sessions brought together over 2,200 residents, community groups, and leaders from diverse backgrounds to identify digital equity barriers for covered populations and recommend strategies to close the digital divide. See Appendix X for a complete list of regional planning workshops and Appendix Y for the standard Regional Workshop Agenda.

Ongoing Stakeholder Engagement

CDT conducted over 375 individual meetings, consultations, and listening sessions throughout the planning process (Appendix Z). It distributed monthly email updates and disseminated and posted meeting artifacts and information on the Broadband for All Portal. CDT continues to engage feedback from various state entities, organizations, and diverse communities in its planning and implementation process.

This engagement process allowed California to build a broad and diverse digital inclusion stakeholder network that includes nearly 8,500 individuals and entities, including state and local agencies, tribal entities, non-profit organizations, labor groups, community-based organizations, educational entities, philanthropies, internet service providers, and the private sector.

Public Comment Process

CDT posted the DRAFT State Digital Equity Plan on the California Broadband for All portal SDEP webpage. To encourage participation and increase accessibility, CDT posted a .pdf version of the draft plan on its Broadband for All portal, which was remediated to ensure screen readers and other adaptive technologies could utilize it. CDT also embedded an HTML version on the portal, allowing translation into over 100 languages. Public comments were received through a form on the portal whereby residents and organizations could provide comments on each section of the plan. The form contained voice-to-text functionality and could be translated into over 100 languages as well. For transparency, CDT posted artifacts from the various components of the SDEP planning process that informed the DRAFT SDEP for the public view and reference on the SDEP page.

CDT conducted a 45-day public comment period for California residents and digital equity partners to provide feedback on the draft State Digital Equity Plan. The public comment period opened on December 12, 2023, and closed on January 25, 2024.

To promote the public comment process, California hosted a State Digital Equity Plan Informational Webinar on December 15, 2023, with 266 participants registering and 164 attending. CDT promoted the public comment process on various social media channels, sent out five emails to its over 10,000 stakeholder networks, developed a partner outreach toolkit translated into seven languages, and gave three presentations on the public comment process at stakeholder convenings hosted by SoCal Transformation, Los Angeles County, and the California Telehealth Network. CDT staff conducted outreach to organizations that serve covered populations to ensure voices from the community were included. These outreach activities resulted in 1,453,465 media impressions.

As a result of this comprehensive outreach, California received a total of 442 public comments – from 301 residents and 141 organizations. Every public comment was posted to the Broadband for All portal SDEP submitted comments page, usually within 24 to 48 hours after receiving them. These comments reflect the diverse voices and perspectives essential for feedback on the State Digital Equity Plan.

Expedite Infrastructure Investments (expedite vs. equity)

Summary of Comments – Expedite Broadband for All infrastructure investments implies that the state is placing speed of completion over equity. “While CADE fully supports expeditious infrastructure buildout, we urge CDT to take great care in ensuring that equity is not sacrificed in the process of fast-tracking projects.” Commentators also expressed that infrastructure investments should be deployed equitably.

Response: Commenters express concern that CDT framed Key Activity 1 in the SDEP, as “expedite Broadband for All infrastructure investments”. This was framed as such in response to multiple stakeholder input during extensive planning and engagement session and regional workshops who cited the urgency of completing infrastructure projects to meet the need in their communities. Commentators believe the use of the “expedite” preferences speed over equity. Commentators also expressed that infrastructure investments should be deployed equitably.

Action: Amended Key Activity 1 to read “Complete Broadband for All infrastructure investments within federal and state deadlines.” (Pages 22, 64 & 136)

Mapping / data (evolve vs. transform)

Summary of Comments: Many commentators noted that language regarding “evolve” data and mapping does not reflect the urgency needed to provide significant updates to data and mapping that doesn’t reflect their communities’ experiences. Many commentators also expressed a need to “transform” mapping and data, include new resources like Microsoft data, provide funding to local entities to gather data, and allow for easy updates to the state interactive broadband map. Others commented on the need for ongoing public input and increased transparency and accessibility of mapping resources.

Response: Enacted in 2023, Assembly Bill 286 (Wood) – Broadband infrastructure: mapping, requires additional information and user-features to be included on the interactive broadband map that is published and maintained by the CPUC. AB 286 will allow users to submit specified self-reported data and requires CPUC to validate self-reported data before using that data as evidence in a proceeding.

Mapping is a complex issue that is guided by federal and state statutes and requirements that vary by program. CDT and CPUC will continue to work with stakeholders to update maps consistent with federal and state statutes and programmatic requirements, incorporate public input, and improve transparency of the state’s mapping and data during the SDEP and BEAD implementation process.

Action: Amended Key Activity 3 to read “Refine digital equity data and maps.” (Pages 22, 64 & 138)

Definition of Covered Populations / Additional Covered Populations

Summary of Comments: CDT received comments about expanding covered populations specifically to include children, foster youth, affordable housing communities, and the unhoused, among others, which are also priority populations for the State.

Response: CDT notes that Broadband for All aims to achieve digital equity for all Californians and members of covered populations. Many of the populations requested fall within current covered population groups like covered households as there is much intersectionality between and among covered populations.

While this plan is intended to benefit all Californians, per federal guidelines, its efforts, and those activities funded by the State’s pending capacity grant allocation, must focus investments of the “eight covered populations” as defined in the Digital Equity Act.

Action: No changes were made to the Statewide Digital Equity plan.

Measurable Objectives for Incarcerated Individuals

Summary of Comments: A few commentators noted that measurable objectives for incarcerated individuals were lacking and highlight a failure of the plan to focus on unique and substantive barriers. 

Response: CDT will work to further refine baselines and objectives during SDEP implementation in collaboration with the California Department of Correctional Rehabilitation, the California Prison Industry Association, and other advocates and stakeholders. 

Action: The specific barriers and baselines for incarcerated individuals were amended to include measurable objectives. (Pages 89-93)

Adjust 150% FPL / High-Cost of Living

Summary of Comments: Many commentators, like TURN and the Department of Social Services, recommended that “covered households” include households with an income at or below 200 percent of the Federal Poverty Level (FPL) to account for the extremely high cost of living in California. Commentators also noted that, “using 150 percent of FPL excludes many families living in poverty from the Draft Plan, thus hindering the state’s ability to close the digital divide.” Others added that the current definition doesn’t take into consideration other expense factors and individuals on fixed income who do not qualify for consideration are still negatively impacted and unable to afford broadband service. 

Response: CDT appreciates these comments that were echoed during the SDEP planning process. While the state’s Broadband for All initiative is focused on all California residents, and members of covered populations, this SDEP must particularly focus on the eight covered populations. The Digital Equity Act defines “covered households” as “at or below 150% of the federal poverty line”.  While the state may apply a higher threshold to its own programs to adjust for the higher cost of living, federal digital equity capacity grants investments must be directed to covered populations as defined in the Digital Equity Act.

We recognize the importance of meeting communities where they are and will continue to take this into consideration as programs are developed. Additional sources of funding from the private and public sectors are encouraged to provide funding to support these efforts.

Action: No changes were made to the Statewide Digital Equity plan.

Specific Barriers for Individuals who are Members of a Racial or Ethnic Minority Group and Individuals with Language Barriers

Summary of Comments: We received questions regarding the barriers for members of a racial or ethnic minority group and if they should be identical to barriers for individuals with language barriers. They suggest that by doing this there may be gaps in accurately identifying race and ethnicity barriers as there are other disparities that are not linked to language i.e., institutional racism and discrimination. Several commentators offered more specific data on the lack of access to affordable highspeed internet in disadvantaged communities and the need for access to devices and digital literacy training. Developing programs should be built that recognize the typical lack of support for training and strategies due to systemic racism and should be based in trust.

Response: CDT appreciates the comments on the duplication of specific barriers for “individuals with language barriers” and “members of a racial or ethnic minority group”. 

Action: The specific barriers for individuals who are members of a racial and ethnic minority group were amended to include structural racism, discrimination, and discriminatory practices. (Pages 14 & 102-105)

Barriers for Aging Individuals (60+) & Organizations

Summary of Comments: Many commentators cited that while “lack of perceived need” is not accurate as a barrier for aging individuals, while also stating “many older adults don’t understand the difference between a broadband connection and a cellular connection. They may think that they are already connected since they are able to get online with a smart phone.”

Many commentators also cited “lack of in-language capacity” and “coordination and collaboration” as barriers for organizations working in the digital equity space.

Response: CDT appreciates the comments that express concern over the inclusion of “lack of perceived need” as a specific barrier for aging individuals while also stating that “many older adults don’t understand the difference between a broadband connection and a cellular connection. They may think that they are already connected since they are able to get online with a smart phone.”

Action: Amended the specific barrier for aging individuals from “lack of perceived need” to “Lack of distinction between broadband connection and cellular connection”. (Pages 13 & 87-89)

CDT expanded upon “lack of in-language capacity” and “coordination and collaboration” as barriers for organizations. (Pages 20, 75, & 146-147)

Status of ACP & Potential Successor Programs

Summary of Comments: A significant number of commentators provided their thoughts on the Affordable Connectivity Program (ACP) and its funding running out. They offered testimonials on how this program going away will impact the communities they serve. Some commentators urged CDT to engage with federal representatives and utilize partnerships to advocate for the program’s continuation. Comments also encouraged the development of alternative or supplementary funding mechanisms or a successor program to ACP and provide support for trusted institutions to support community members with awareness and enrollment in other the low-cost broadband plans.

Response: CDT and CPUC understand that the funding for the Affordable Connectivity Program will expire unless Congress allocates additional funding to continue the program. In response to this, CDT and CPUC sent a letter to the California Congressional delegation advocating for the allocation of additional dollars to continue the program. While ACP is a valuable tool to address affordability and adoption, SDEP efforts will continue to address affordability and adoption by leveraging and expanding the Get Connected! California mobilization, which includes broadband council members, state agencies, internet services providers, broadband consortia to continue to promote low-cost private sectors offers, federal and state LifeLine programs, and any other successor programs or subsidies.

Further, CPUC’s BEAD Initial Proposal Volume II as submitted to NTIA for review and approval outlines CPUC’s proposed approach that would require BEAD subgrantees to provide both a Low-Cost Broadband Service Option to income-qualified customers and Middle-Class Affordable Service Option to all customers. This requirement and the specific parameters of the Low-Cost Broadband Service Option and Middle-Class Affordable Service Option are subject to NTIA’s approval of the Initial Proposal Volume II and the CPUC’s subsequent adoption of the NTIA-approved version Initial Proposal Volume II.

Action: SDEP revised to reflect the current state of the Affordable Connectivity Program. (Pages 45-46 & 142-143)

State-Managed Efforts vs. Local Efforts

Summary of Comments: Some commentators advocated for the need for a state-wide effort to document and share digital equity services, specifically related to digital literacy and low-cost broadband options. Our Voice: Communities for Quality Education asks that the state adopt tools to track data that reflect the needs of Californians, especially given that broadband maps don’t accurately reflect need. CSUDH suggests that a comprehensive database or platform is created to list and track all Infrastructure Investment and Jobs Act (IIJA)/ Bipartisan Infrastructure Law (BIL) programs and grant recipients. Various groups like AARP and Los Angeles County Internal Services Department provided similar suggestion recommending the development of an atlas of program and information gather by the state’s digital equity survey and Digital Ecosystem Mapping tool and regularly update those and make available to the public. Other comments cited “in-language capacity” and “coordination and collaboration” as barriers from local digital equity organizations.

Response: CDT acknowledges the link and interdependency of state managed and local efforts coordinated and funded by capacity grants during the SDEP implementation phase. State-managed efforts will include procuring or developing SDEP campaign materials, digital literacy training platform(s), digital navigation guidance, and other resources and tools, in-language, in consultation with subject matters experts and community-based organization. CDT will make these resources available Broadband for All portal. These tools would support ecosystem partners in further supporting digital equity efforts including those funded by capacity and competitive grants.

Action: Clarifying language added to the Implementation section of the SDEP. (Page 140)

Digital Literacy Training

Summary of Comments: Many commentators provided input on the need for digital literacy training platform(s) and curricula to be made available in multiple languages, and modalities (virtual – synchronous and asynchronous, in-person), and developed with input from subject matter experts.

Response: CDT is not able to provide additional information until funding and allowable use guidelines are issued. However, CDT intends to procure and leverage existing digital literacy training platforms, to the greatest extent possible and allowable under federal capacity grant rules and requirements, which are not yet known, and make those available in multiple languages, and modalities (virtual – synchronous and asynchronous, in-person), and developed with input from subject matter experts and stakeholders.

Action: No changes were made to the Statewide Digital Equity plan.

California Connect Corps, Digital Navigation and grant framework

Summary of Comments: Many commentators provided input on the details associated with the development of the California Connect Corps digital equity capacity grant program, expressing a desire to leverage existing experience and expertise of the diversity of statewide and local entities that provide digital equity and digital navigation services. Commentators have also recommended that CDT develop these programs to be flexible, nimble, and easier to navigate than existing programs.

Commentators were seeking specificity in how programs will be deployed – in person vs virtual to ensure inclusivity and ‘meet the people where they are’ and by de facto, virtual is not as inclusive due to barriers and access to tech. Commentators have also express a desire for pre-grant and post-sub grant award technical assistance.

Response: At present, CDT is not aware of the state’s digital equity capacity grant allocation, nor the rules and requirement attached to the funding. We recognize the importance of meeting communities where they and will seek further public input as activities and programs mentioned in the SDEP are further developed.

CDT has further clarified its approach to development of these programs and will seek input from the stakeholders and subject matters experts in the further development of these programs. CDT will endeavor to develop the California Connect Corps digital equity grant program to be flexible, nimble and easy to apply for an navigate, and available to as many current providers and new entities allowable consistent with federal digital equity capacity grant guidance and requirements which have not yet been released. CDT will also seek technical assistance to potential grantee pre- and post-capacity grant award.

Action: Additional language added in the implementation section to clarify the role of community input in developing the grant program. (Pages 136 & 138-140)

Implementation and Timeline Details

Summary of Comments: Commentators expressed the need to implement the plan as soon as possible, given the critical nature of the effort and Californians’ need for improved access to online resources.

Response: All stakeholders and members of the public are invited to attend and participate in the quarterly public meetings of the California Broadband Council and the Middle-Mile Advisory Committee. Stakeholders and members of the public are invited to attend and participate in the quarterly Statewide Digital Equity Implementation Group and Outcome Area Working Group meetings that will be online and open to the public throughout the SDEP implementation period. We highly encourage residents and stakeholder wishing to be notified of these engagement opportunities to provide their information here:  https://broadbandforall.cdt.ca.gov/contact-us/

Additionally, CDT will form a Community Advisory Committee to create a forum for individuals of covered populations to have a voice during the SDEP implementation
period. In the coming months, CDT will provide details on how to engage in this

Action: CDT has further expanded the implementation section, including the timeline to be more detailed and specific on key activities and measurable objectives. (Page 155-158)

Trusted Messengers and Collaborators

Summary of Comments: CDT received many comments about the kind and types of entities it should engage and collaborate with during the SDEP implementation phase. These include trusted messengers, such as schools, cities, counties, CBOs, anchor institutions. There were also multiple comments from the press and the role of local news as partners, specifically culturally relevant media that can deliver news in-language.

Response: CDT agrees that trusted messengers, which vary by community and covered population are and will continue to be critical to achieving digital equity.

Action: Additional language added to further emphasize public housing authorities and affordable housing entities, continuing and adult education entities, and ethnic media and local news outlets as trusted messengers and collaborators. (Pages 19-20, 60, 122, 148, 152-154)


Summary of Comments: Some comments focused on the need for devices to be relevant and usable for the current and at least a few future years and indicated that large screen devices such as laptops, desktops, Chromebooks, and tablets, are critical for a full and equitable computing experience. Another commented that to ensure that all California residents can obtain a free or low-cost computer, establishing a robust supply of free and affordable devices through accessible, resilient, community-level distribution systems is critical. Another suggested that when giving computers to those in need, give Microsoft Windows Operating System (OS) or Apple OS (macOS) computers so that those needing to edit large files using desktop software, and multitask between multiple websites and applications when completing science, technology, engineering, and mathematics related (STEM) tasks.

Response: CDT appreciates comments on the need to develop a device program that gets low-cost affordable devices to members of covered populations who most need them. CDT will engage subject matter experts and stakeholders in the further development of the program to advise on devices need for specific covered populations to cater to different hardware and software needs.

Action: Added the language to include clarity on devices and specific needs for specific covered populations in the implementation section. (Page 139)

Wired vs Wireless / Alternative Technologies / EMF

Summary of Comments: CDT received numerous comments from advocates regarding wired vs. wireless and alternative technology solutions. Many commentators preferred wired solutions citing greater capacity, lower maintenance costs, longer lifetime, and lack of line-of-sight constraints, and health-related concerns. Others favored deployment of all available technologies citing speed of deployment, cost, and geography, terrain. Some of the technologies favored were fixed wireless, low-earth orbit satellites and other emerging technologies.

Response: CDT defers to CPUC and refers to its BEAD Initial Proposal Volume II, page 20 of which has a section on “prioritization of fiber projects,” which indicates that CPUC proposes to apply the federal requirement of prioritizing fiber where feasible but also fund wireless where fiber costs exceed the Extremely High Cost Per Location Threshold:

“Given these two considerations, the CPUC plans to prioritize end-to-end fiber proposals, consistent with the BEAD NOFO, and to make awards for alternative technologies—such as fixed wireless and coaxial cable— where the costs of fiber exceed the Extremely High Cost Per Location Threshold, per NTIA’s requirements, or where no proposals are received for fiber because of geographic or other constraints.”[3]

Page 22 describes the Extremely High Cost Per Location Threshold, noting: “…For that reason, the CPUC anticipates using the Extremely High Cost Per Location Threshold (EHCPLT) mechanism for making awards for alternative technologies, such as fixed wireless and coaxial cable, that may be necessary to address the needs of some locations. Consistent with NTIA rules, the CPUC will make those awards as necessary only for locations that do not receive fiber proposals or whose fiber proposals exceed the NTIA-mandated EHCPLT.”[4]

Action: No changes were made to the Statewide Digital Equity Plan.

AT&T and their plan to relinquish Carrier Of Last Resort (COLR) obligations

Summary of Comments: Commentators are expressing concern about AT&T’s pending application to relinquish its Carrier Of Last Resort (COLR) obligations in many communities throughout California.

Response: CPUC is evaluating AT&T’s application to relinquish its Carrier Of Last Resort obligations, which has a proceeding number of Application (A.) 23-03-003: https://www.cpuc.ca.gov/ATTCOLR. While AT&T’s application does not directly request authority to discontinue service for any customers at this time, approval of this application could enable service termination in the future. The CPUC is receiving public input on AT&T’s application and will evaluate AT&T’s application in accordance with statute and existing CPUC decisions.

Action: No changes were made to the Statewide Digital Equity plan.

Artificial Intelligence

Summary of Comments: If older adults are not included in this revolution, the digital divide will only widen. 

Response: Governor Newsom’s Generative Artificial Intelligence Executive Order develops guidelines for State agencies and departments to analyze the impact that adopting a GenAI tool may have on vulnerable communities, including criteria to evaluate equitable outcomes in deployment and implementation of high-risk use cases.

CDT intends to leverage the Outcome Area Working Groups to engage partners, stakeholders, and subject matter experts to provide input and feedback on related issues like Generative AI and other emerging technologies to address impacts to vulnerable and covered populations.

Action: Incorporated Generative AI and other emerging technologies into sections on digital literacy and digital skills. (Pages 87 & 153)

Public Cooperatives

Summary of Comments: In Key Activity 1, the Plan states all entities tasked with building-out broadband infrastructure will continue to build-out of existing Broadband for All investments. Ensuring these entities are collaborating and including existing, grant-funded infrastructure in their planning is essential to expediting the connection of all Californians to high-performance broadband. In these planning efforts, the creation of new, local broadband cooperatives will increase the number of ISPs providing service. Creating new, local broadband cooperatives that are community-owned and not-for-profit will increase competition, make serv1ices more affordable and provide an opportunity for more local digital navigators to encourage adoption and provide education to “covered populations.”

Response: CDT appreciates that a full range of options and eligible entities will need to be enabled to deploy connectivity to unserved and underserved communities.

Action: No changes were made to the Statewide Digital Equity plan.


Please be advised that the footnotes in the HTML version of the California Digital Equity Plan may differ from those found in the PDF version. This discrepancy is due to format-specific adjustments necessary for the HTML version.


[1] https://www.gov.ca.gov/2022/09/13/governor-newsom-strengthens-states-commitment-to-a-california-for-all/, accessed September 15, 2023.

[2] Ibid.

[3] https://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M520/K763/520763574.PDF, page 20

[4] https://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M520/K763/520763574.PDF, page 22