Public Comments for the California Digital Equity Plan

The following comments were received in response to the draft California Digital Equity Plan. All public comments submitted through the public comment form will be reviewed by the Office of Broadband and Digital Literacy (OBDL). All comments received are a part of the public record and will be posted without change.

IDDateNameTitleTypeOrganizationCityStateZipComments
4923January 26, 2024 at 12:31 amK.M.ResidentSanta Cruz950601. Executive Summary
WIRED connection is superior to wireless in all respects, and wireless broadband—especially the basic services offered to low-income families—will NOT solve the digital divide.

Wireless is unreliable and unable to meet the demands of present and future digital communications. Providing funding for rollout of wireless installations will take it away from much safer, reliable, energy-efficient WIRED internet.

Wireless will set the state back in terms of climate change management because wireless uses a huge amount of energy compared to WIRED broadband.

Wireless facilities increase fire risk and cyber security risk

Wireless facilities impact the growing percentage of the population with disabilities related to radiofrequency radiation (RFR) exposure.

Wired infrastructure offers greater capacity, predictable performance, lower maintenance costs, and a longer technological lifetime than wireless technologies. Fiber service is not degraded by line-of-sight issues and is not affected by capacity issues.
4922January 25, 2024 at 11:22 pmC.S.ResidentBurbank915061. Executive Summary
I have a friend who is retired, and is living purely off of social security. His financial strains have lead to depression and mental illness. He's tried to repair both his mental health and his financial situation, and believe it or not, having free broadband access has been critical for both. His state provided mental health services are *only* provided digitally, and his debt consolidation plan requires he maintain connectivity. It's also essential for communicating with his family, who live on the east coast.
4921January 25, 2024 at 11:02 pmfounderOrganizationFiber-Up My NeighborhoodPomonaCA4. Collaboration and Stakeholder Engagement
The biggest challenge to date with the collaboration and engagement strategy as set forth by Scott, Sunne and the CPUC is that they are compromised by being extremely out of touch with community. I had the opportunity to attend the San Bernardino, Orange and Los Angeles meetings and was sorely disappointed with the lack of representation of community leaders at the San Bernardino and Orange meetings. Scott comes from Comcast, Sunne has on her board the monopolies and general counsel that is at the root e.g. DIVCA of facilitating monopolistic capture and the very creation of the digital divide in my expert opinion. The CPUC who is set to be the recipient of $1.83 billion in BEAD monies is highly compromised in that they to this day cannot account for $200 - $300 million dollars collected from the telcos self-reporting account for among other things, to upgrade copper to fiber. Three decades of fees and tax deference have gone to the incumbent players (ATT, Verizon, et al) according to Bruce Kushnick author of The Book of Violations & Egregious Acts: Trillion Dollar Broadband Scandal with the purpose of upgrading copper to fiber. It is well documented through the CPUC's own 2018 Network Exam that the incumbent players rather than upgrade copper lines with fiber, apparently diverted those funds some where else. To date at least $200 million in rate payer funds have not been accounted for, and now we are set to trust the CPUC to be good stewards of another $1.83 billion in BEAD dollars. This is absurd. Until the CPUC can reconcile where the $200 million lost dollars are, as reported by Propublica in December of 2020, we must ask the state legislature to step in and find another more appropriate steward for these resources.

There was/is talk of a citizens oversite committee. This committee needs to be assembled immediately and be given power and authority to steward BEAD, middle mile and FFA funds to the benefit of those living in the digital divide. There have already been "secret" meetings with middle mile investments that have at one point circumvented original proposed maps to the exclusion of parts of Compton, Oakland and the San Gabriel Valley. The maps were then corrected to reinstitute proposed maps covering these areas after a public outcry of foul play.

We most recently came to find out from our local representative that L.A. County will be the recipient of zero to no BEAD dollars because "we have no projects ready." This challenge falls squarely on the shoulders of the leadership of this initiative, Scott, Sunne and the CPUC who have not prepared municipalities or local elected officials on what these dollars meant, and have refused to use their bully pulpit to course correct the parameters of how the money is to be allocated. The maps in the current form are a failure in the absolute and should not be used as a parameter to allocate money. The process is much much easier than what is currently being played out as fair and equitable. The incumbent players know is exactly where the perimeters of their digital red-lining took place, and we need to look no further than the data they have at their disposal. Why we are forcing the most under-resourced entities in this project to do the heavy lifting of data collection that is already in the possession of the incumbent players. It is a mystery that may be interpreted as a predesign to ensure those living in the digital divide continue to do so and be excluded from meaningful resources that will severely impact their quality of life.

Given the parameters set forth by the leadership as noted above - for allocating BEAD, FFA and middle mile dollars, monies that exist because of Pomona, El Monte, East L.A. South L.A., MacArthur Park, Santa Ana, Oakland, etc. which now ironically are set to receive the "crumbs", because they are "not ready", speaks volumes as to the critical need to rethink the entire plan on how funds intend to be allocated.

First we must take a full inventory of dark fiber; Second we must execute a full audit on the CPUC to identify and reconcile funds collected to funds spent, and what those funds were spent on, these findings will then provide an inventory of resources that will serve to expedite the closing of the digital divide; Third we must assemble the Citizens Oversite Committee immediately and grant them power to dictate and override bad decisions of the leadership in this endeavor; Fourth we must have an on-going accountability transparent and up to the minute allocations and locations where these funds are going, characterized by color maps and accessible to all who desire to know.

So much more to say here and at every point of this plan. Unfortunately we are under-resourced and out of time. We are hopeful consideration will be given to our comments on behalf of the representation of millions of people living in the digital divide; and will be implemented at some level as suggested herein. We fully support the comments as submitted by LADEAL.
4920January 25, 2024 at 10:56 pmDirectorOrganizationEMF Safety NetworkWindsorCA2. Introduction and Vision for Digital Equity
Last April I attended the BEAD workshop that was held in Santa Rosa, CA. There were about 70 people in attendance and they fed us a great lunch!

I found it very informative to hear the many issues being considered regarding BEAD funding. Some people weighed in on their challenges to getting good internet access. These challenges included the high cost of service as well as adequate signal to their homes.

After much study, our organization, EMF Safety Network, has found that the most important thing necessary for best connectivity is FIBER (wired) infrastructure (the middle and final mile). I spoke on the following points:

WIRELESS is notoriously unreliable and unable to meet the demands of present and future digital communications. Providing funding for a massive rollout of wireless installations will take it away from the much safer, more reliable and energy-efficient option of WIRED internet connections.

For instance:
• Wireless will set the state back in terms of climate change management because wireless uses a huge amount of energy compared to WIRED broadband.
• Wireless facilities increase fire risks.
• Wireless greatly increases cyber security risks.
• Wireless facilities impact the growing percentage of the population with disabilities related to radiofrequency radiation (RFR) exposure.
• WIRED infrastructure offers greater capacity, predictable performance, lower maintenance costs, and a longer technological lifetime than wireless technologies.
• Fiber service is not affected by capacity issues.
• The truth is, wireless broadband, especially the basic services offered to low-income families, will NOT solve the digital divide.

In conclusion, WIRED connections are technologically superior to wireless in all respects and will provide much better future for everyone.

Thank you for this opportunity to submit comments.
4919January 25, 2024 at 10:33 pmResearch DirectorOrganizationSouth Bay Cities Council of GovernmentsLos AngelesCA1. Executive Summary
Executive Summary: Vision, Goals and Objectives

The SDEP is a product of the once-in-forever multi-billion dollar federal investment to advance digital equity to the point that it can begin to narrow the “digital divide.” The digital divide originated with the first microcomputer and the 300 baud modem in the mid 1970s and has been deepening every month since as technology development widens the gap between leading and trailing edges at an increasing pace.

Despite its 50 year history, the divide became a political priority during the COVID pandemic as the world suddenly shut down in March, 2020. Essentially overnight most transactions became virtual as access shifted from wheels to wires. The environment benefited while the economy suffered, largely due to lack of preparation. Those in the covered populations designated by the responding federal legislation suffered the most.

The task at hand is to prevent similar impacts in case of another shutdown, from a pandemic or other type of disaster, and to help those near the trialing edge of digital technology -- if not to catch up at least to somehow close the gap. That’s a daunting goal fraught with the complexity of modern technology intersecting with the multitude of human and social conditions.

Availability of this rarest of federal funding commitment, the severity of the problem, and the expected turbulent future make it essential that we get it right.

The SDEP is extremely important because it will inform how these federal and state funds will be allocated to various initiatives. Programs and policies not recognized will have little or no chance of receiving funds for implementation.

The SBCCOG comments are intended to introduce an innovation that we hope will be included in the SDEP. Innovation is important because the draft SDEP currently puts all its “eggs in one basket” – a form of Universal Service. The statewide strategy also assumes “one size fits all.” It will shape a monoculture around individual households getting better connections made affordable to those with lowest incomes by continuous public subsidy and supported by a patchwork of devices, training and technical assistance. That strategy has strengths but also significant weaknesses.

These comments are based on SBCCOG’s experience developing our own digital equity programs. We assembled, through a public-private partnership, the South Bay Fiber Network (SBFN). It is a sub-regional middle mile network that delivers high speed services at below market rates to 41community anchors, including all civic center. It is 80% leased from a dark fiber wholesaler. New construction was minimized to reduce both costs and time. The SBFN was implemented in just 10 months during the COVID shutdown.
In addition, the SBCCOG’s process that will produce a sub-regional plan for advancing digital equity among several of the covered populations is approximately 60% complete. This has involved identifying the location of concentrations of covered populations within each South Bay city and surveying residents and small businesses located there. Focus groups and individual interviews are scheduled for February. Advertised network speed offerings, under and un-served Census blocks, and subscription rates by Census tract have been mapped in relation to the SBFN route.

Universal Access
Based on those experiences and analyses, the SBCCOG is pursuing an alternative implementation strategy for advancing digital equity that is consistent with the Vision, Goals and Objectives in the draft SDEP. The key difference is it prioritizes investment in 1) the front line organizations that address people’s needs and provide the devices, training and support to advance basic digital literacy; 2) the secondary organizations that deliver the education, health, medical, and other essential services which in many cases need to become more digitally literate themselves; and 3) eventually reaches the broadband network build-out that realizes the goal of Universal Service. In other words, it reverses the order of deployment while reaching the same end.
This is a “Universal Access” model with roots in the public access video production facility that was a staple of municipal cable franchises between the 1960s and 1990s, now updated to the internet age. A prototype of an Internet Access Center (IAC) was developed by the Drew Economic Development Corporation in the MLK Transit Center at the Compton Metro Blue Line rail station in the mid-1990s, funded by the Los Angeles County Transportation Commission (Metro).

In outline, the universal access model begins with a newly formed or existing community anchor organization that receives one-time seed money to work with community members to develop a physical facility that provides offices, computer labs, meeting rooms, and other maker-spaces, equipped with high performance computers, peripherals, a range of productivity software and specialized technologies like 3D printers, digital audio/video devices, scanners, computer projectors, etc. as identified by community input. The Internet Access Center should be served by a 10 Mbps middle mile fiber network with connections to data centers for access to the global internet. In the South Bay, the SBFN would provide that service.

Like the prototype in Compton, the facility will also host virtual services including distance education, tele-medicine, e-government, workforce training, and whatever else meets the needs of the community. Those applications led LA Metro to invest in the pilot project, referred to as the Blue Line TeleVillage.

The Internet Access Center would be designed to offer a robust set of services from basic digital literacy to advanced skills training. It would be supported by a web of smaller satellite anchors located around the community that can offer device and broadband access supported by basic training. While developing a last mile strategy for the South Bay, we discovered that in many cases the community anchors themselves need support for adopting digital technologies to enhance their services.

The Universal Access model can address some of the challenges faced by the Universal Service approach. Here are some examples:
• The potential rate of adoption is a significant unknown when evaluating the capital investment required for delivering last mile services to a neighborhood, especially in disadvantaged communities. The ACP before being phased out did succeed in attracting new subscribers but it had to be marketed to the candidate households (cost of approximately $6 million), eligibility had to be established, a formal application was required and some level of monthly fee was required of consumers. Universal Access through the IAC would have an obvious physical presence in the community and be supported by anchors who function as digital equity satellite centers. Adoption would involve walking in the door and meeting an available “navigator” with no fees required.
• In the Universal Service model internet connections, access to devices (of variable quality), as well as training and technical support are fragmented and provided by a patchwork of non-profits and government agencies (such as libraries). While the participating organizations deserve a great deal of respect for their contributions, the system itself is inefficient. The same organizations would benefit from having a central facility to work with. The entire chain-of-needs can be most efficiently and effectively delivered by being integrated through a single source, and the digitally disadvantaged will benefit from the simplicity.
• Government funding will be needed just as in the ACP. However it would take the form of seed money sufficient to equip and operate the IAC for a period of approximately 3 years. During which time the managing community organization would develop a business plan to sustain itself without the need for continuous public subsidies. Continuing consumer subsidies for network services, like the ACP, would not be required or at least could be minimized.

The experience using a range of devices and applications over ultra high-speed internet connections will lead residents to become knowledgeable consumers of internet service and devices to purchase for their homes. Participants will have acquired skills and established goals. The result will be market development for both ISPs and technology manufacturers and retailers. At this point the totality of the SDEP vision, goals and objectives will be fulfilled.

Performance metrics would provide a more robust assessment of utility than inputs such as miles of network built used by Universal Service. Universal Access could be evaluated in terms of outcomes such as number trained at various levels of digital sophistication (not just basic literacy, as needs evolve like up a ladder as a result of accelerating aspirations), businesses started, resumes completed, jobs filled, certificates earned, medical conditions treated, GED certificates earned, vehicle miles travelled reduced, or job skills acquired.

The Universal Access model provides a foundation for addressing “divides” common to the 8 covered communities. They include the mobility divide and divides around education, medical care, civic participation, etc. since those services can be brought to covered households in a community setting. It could also address climate conditions such as extreme heat by providing a cool place to congregate, or a central place to gather for strategic information or recovery from a natural disaster. When combined with a micro-grid for low cost locally produced always-on electricity, it functions as a “resilience center.” The IAC can also serve as a catalyst for revitalizing a neighborhood center in decline.

It promises to develop a digital culture that engages residents, small businesses, government agencies, CBOs, faith organizations, schools, and the entire city or neighborhood where it appears.
Realistically the Universal Access model may also become the default for attracting the remaining federal funds. The FFA and BEAD program priorities are constructing networks in unserved areas while the South Bay has an abundance of dark fiber infrastructure and small pockets of underserved Census blocks. This context, common to most suburban areas in Los Angeles County, makes it more cost-effective to lease from dark fiber wholesalers rather than overbuild those assets. Our advisors have also mentioned other constraints related to those federal programs.

The Capacity Building and Competitive Grant programs expected to be announced by the NTIA sometime in spring, 2024 appear to be a better fit with the South Bay context and our plans for digital equity.

5. Implementation Strategy & Key Activities
Comments on Section 5: Expedite and complete existing Broadband for All infrastructure efforts.
We know where our target covered populations reside; which Census tracts have wire based service to the internet by advertised speeds, where the few unserved households are located, and which ones rely entirely on smart phones to access the internet. Those are places that would benefit from a shared Internet Access Center. The South Bay Fiber Network could extend 10 Mbps service to those centers, as well as to any other CBOs in the area on the condition of offering public access to devices accompanied by digital literacy training.

In order to implement that plan we recommend that the SDEP expand the definition of “infrastructure” to include the devices needed for a community to use the network, The entire use-chain system terminating in a designated public facility should be seen as infrastructure, just as school buildings, libraries, and public swimming pools are considered infrastructure.

Continue to leverage and explore all current and future funding

The SBCCOG supports this action. This is one way it would work in the Universal Access model.
The Internet Access Center should be designed to deliver a wide range of functions. Each of those functions could qualify for funding. For example, because of the ability to bring destinations virtually to the Access Center, the number of trips not taken should qualify for state and regional transportation funds. The AQMD could be approached for funds because of impacts reducing exhaust pollutants. The Center will be air conditioned and could attract support as a resilience center. We aspire to add a micro grid that will locally produce inexpensive renewable electricity for always-on power. Volume technology discounts could be negotiated by Los Angeles County from its bench of vendors who will benefit by showcasing the hardware devices, software, and furniture needed in each access center.

Coordinate and deploy last-mile programs to connect to Middle Mile Broadband Initiative.
This action most likely fits best in sub-regions that have not yet developed their own fiber network. The MMBI team contacted the SBCCOG in 2023 to ascertain whether the SBFN could be used to extend the state’s middle mile network. Our routes were not useful for them at that time.

Last mile programs will work off of the SBFN. The SBCCOG is a partner in a sub-regional middle mile network, the South Bay Fiber Network which serves 41 sites including all 15 civic centers plus the Workforce Investment Center One-Stops, the Beach Cities Health District and several other CBOs with below market prices for 1 to 10 Gbps service. The SBFN backbone was developed by leasing 80% of the network and building 20% which includes the “drops” to each of the customers forming to create the middle mile at the sub-regional scale. This was accomplished using $6 million of the sub-regional return from transportation Measure M.

We are currently searching for funds to expand the SBFN to additional CBOs and Internet Access Centers (if they are funded). The cost for that expansion is still being estimated, but the need will be in millions, not many tens of millions.

The middle mile termination vaults serve as “regen” points for extending fiber to deliver last mile service to adjacent neighborhoods. Expansion of the SBFN will bring more neighborhoods into play for private sector partners to build fiber to the home (FTTH).


Promote interim alternative technology solutions.

This can work well in those locations where it can provide cost effective high quality service in a more timely fashion.
For example, the SBFN in 2023 began working with WISPs to quickly and affordably extend service to pockets of underserved small businesses. While the negotiations remain in process, promoting alternative technology solutions has a place in our portfolio.

Promote the use of inclusive apprenticeships throughout network development

Jobs created by network construction are time-bound to the period of construction. Internet Access Center jobs would be permanent and will grow as new IACs are developed based on availability of government seed funds. Jobe could also grow as community interests justify new applications such as interest in local music production and recording, digitizing archive photos of the neighborhood, producing videos for You Tube and so forth. Virtual presence examples include developing new relationships with UCLA Extension in order to import language classes; with El Camino College for courses in basic accounting skills for small business, with Torrance Memorial Hospital for physician consultations, and so forth.
The proposed California Connect Corps will produce these sorts of apprenticeships and permanent full time jobs.

Convene digital equity stakeholders to strengthen collaboration.

This is a good idea as well. However, the convening will be best handled at the regional and county levels, rather than the state. LA Deal and the County of Los Angeles have each contributed to strengthening collaboration within the county and the SBCCOG recommends continuing state support for both.

Evolve broadband and digital equity data and maps.

This is another example of an action step that is dependent on the model chosen to implement Broadband for All. Maps are essential for guiding investment in either case. However, an IAC has the potential to collect rich data from neighborhood residents and businesses. Number of subscribers, service levels, costs, home devices, peripherals, applications used, reliability issues, satisfaction, role of smart phones, additional needs – as well as outcomes – can be collected through an IAC. Maps of those data would be extremely robust.

Launch the California Connect Corps (CCC) and digital equity grant programs to expand community-based digital inclusion programs.

We recommend that this program receive robust funding, whether for Universal Service or Universal Access. The CCC has the potential to train staff for Internet Access Centers, including in digital navigation skills. Local residents working in our local Centers is the ideal scenario. The SBCCOG currently collaborates with the South Bay Workforce Investment Board which will create synergy between that organization and the CCC initiative. One difference in scope of work is that Access staff will not need to spend much energy recruiting for the ACP, assuming funding is found for it to continue at least for a short while. Access to the Centers will be free or nominal as seed money will provide community subsidies rather than per household.

Fund new and expand existing State-managed digital inclusion programs.

State agencies will surely play a significant role in delivering digital inclusion programs. However, the SBCCOG recommends making local CBOs and government agencies the priority. Digital inclusion must advance at the grass roots because the locals are best positioned to advance inclusion in ways that resonate with the local target communities.

Develop and promote digital inclusion tools and best practices

Tools will best be developed locally so they can bubble up to the region and the state. The state can then share what it has learned with the other regions and locals.
Develop, fund, and make available a statewide digital literacy training platform.

Recruit local CBOs and local governments as a steering committee for this initiative. High level strategies frequently fail to connect with local problem solvers.

Promote low-cost offers and the Affordable Connectivity Program, and advocate for a sustainable successor program.

The federal government’s ACP fund has been expended and close-out plans are underway. It should be clear that permanent ACP subsidies will not produce sustained benefits without a dedicated funding source that does not require period political authorization.

Considerations of the state taking over the ACP should be based on a thorough evaluation of what the federal program produced. Concerns have been expressed by critics that, for example, some portion of those qualifying for ACP subsidies were already subscribers. The metrics should be based on outcomes to the extent possible.

The ACP subsidies are expensive in the aggregate. There are 6 million eligible for the ACP though only 2.4 million currently are members. A subsidy of $30/mo or $360 per year projects to over $2 billion annually if program marketing succeeds, as the state hopes.

In addition, the state invested $6 million just marketing the program to those that meet income criteria. And the program which is now depleted had no long term future because it was funded by a one-time investment.

The analysis of whether to continue the ACP with state funds, should consider the opportunity costs. IACs are a viable alternative for subsidizing those with the lowest incomes and they hold the promise of becoming self sustaining.

The basic question when considering whether to experiment with Universal Access is will community sharing the best outperform giving individuals the minimum. Including Universal Access in the SDEP will allow this question to be answered.
4918January 25, 2024 at 10:26 pmDirector Workforce Integration NetworkOrganizationCalifornia State University, Dominguez HillsApple ValleyCA1. Executive Summary
California State University Dominguez Hills (CSUDH) stands as a beacon of social and economic mobility, achieving remarkable accolades in recent years. In 2023, CollegNET ranked CSUDH as the #1 institution for social mobility, demonstrating our commitment to providing opportunities for upward mobility. Additionally, in 2022, we secured the #2 spot for economic mobility, emphasizing our dedication to fostering career success. CSUDH proudly bears the distinction of being a federally recognized Hispanic-Serving Institution, with a student population that is 65.5 percent Hispanic/Latino. Our commitment to inclusivity extends further, with 47.5 percent of our undergraduate students being first-generation, 66 percent Pell-eligible, and a substantial 88 percent comprising students of color. These statistics reflect our unwavering commitment to diversity and equal access to quality education.

In alignment with the State Digital Equity Plan (SDEP), CSUDH is dedicated to advancing digital equity across Southern California. However, a pressing issue of trust arises as we navigate the changing landscape of subsidy programs, such as the Affordable Connectivity Program (ACP). This vital program has already enrolled over 1.6 million households, underlining its significance in bridging the digital divide. Yet, with ACP funds expected to be depleted by spring 2024, a crucial need arises for a sustainable program to support these households and continue extending affordable internet access.

As a trusted partner of this historic infrastructure and digital equity endeavor, CSUDH has diligently educated students and community members about the program's benefits. The sudden discontinuation of ACP assistance threatens to undo the progress made in getting individuals online, and we must address this challenge promptly. We recognize that the ACP enrollment process had unnecessary complexities, demanding verification steps that could have been simplified through public documentation. Perhaps we can utilize systems like those that efficiently register young men for selective service to seamlessly provide automatic internet assistance for those on public benefits. Extending access to subsidized internet services can only be enhanced by considering internet access as a public utility. These initiatives are not merely conveniences; they are vital tools for equipping residents to navigate and thrive in an increasingly digital world. The achievements of CSUDH in social and economic mobility, coupled with our unwavering commitment to diversity, position us as a critical ally in achieving the digital equity goals outlined in the state's plan and BEAD initiatives. CSUDH remains steadfast in its dedication to empowering individuals and fostering a more equitable digital future for all Californians.

This plan raises a critical question: how will funding be equally allocated to address equity and practicality? According to DEEM findings, over 60% of DEEM respondents reported difficulty accessing funds. Balancing equitable access with targeted support based on population density is a crucial consideration, one that requires careful deliberation and data-driven solutions.

ADOPTION - Digital Inclusion Activities (Literacy & Training)
While the Priority Outcomes of Education and Digital literacy/inclusion are laudable, achieving them poses a significant challenge for deeply rooted anchor institutions in underserved communities. These institutions, despite being the lifeblood of their communities, lack sustainable funding to provide continuous access to digital training. This funding gap, coupled with privacy/security concerns, acts as a major roadblock to reaching Goal 3. Existing grants like CASF and BEAD offer digital literacy training as a funded activity, but it often remains a low priority or gets deferred to the next funding announcement. This creates uncertainty and hampers long-term planning. Anchor institutions face unique challenges in securing sustainable funding due to their community-driven nature and limited administrative resources. This leaves them in a precarious position, unable to deliver on the digital inclusion goals they themselves champion. In the DE Capacity Grant, perhaps equip anchor institutions with the resources and expertise to navigate the grants landscape, ensuring they can access and utilize available funding effectively. Explore innovative funding models with public-private partnerships and prioritize distribution effectively.

3. Current State of Broadband and Digital Inclusion
Section: 3.3 Overview of Digital Equity Needs and Barriers
Localized Labor Supply for Broadband Infrastructure Jobs: Broadband access is a critical aspect of digital equity, and the lack of labor access for broadband infrastructure jobs is a significant barrier to achieving widespread connectivity. Long-term wage stagnation in the telecommunications industry has hindered the hiring and retention of skilled workers, further exacerbating the problem.

Suggestion: State investment in comprehensive pre-release training programs for justice-involved individuals, tailored to the specific needs of the broadband infrastructure sector. According to the CDCR report (https://lao.ca.gov/Publications/Report/4686), there is untapped talent among justice-involved individuals who could fill the workforce gap in the broadband infrastructure sector. Pre-release training programs have the potential to equip these individuals with the skills necessary to contribute to the expansion maintenance and emergency response capacity of broadband networks. For example, incarcerated people who may volunteer for climate-related emergency response, when broadband infrastructure is at risk from fire, flood, or storm, would benefit from training for the hazardous nature of the work they are deployed to do to protect broadband infrastructure. Furthermore, credentialing those who undertake emergency response and restoration work, and providing career awareness and training for occupations to which these experiences and skills may be transferable, provides benefits across the economic and social ecosystem. This approach not only addresses the labor shortage but also has the potential to reduce recidivism rates by providing meaningful employment opportunities using current technology. This, in turn, enhances their earning potential and economic stability. These suggestions not only fill the labor gap but also contribute to the rehabilitation and reintegration of formerly incarcerated individuals into society. Further, there is significant crossover in competencies and skills between many "clean energy jobs" and "broadband infrastructure jobs." Just as the Digital Equity Plan objective 3.5 states that “fiber workers are predominantly white (59.6%) and male (89.8%)”, the US DOE together with HBCUs reported “the energy sector workforce, which lags on gender and ethnic and racial minority representation …has disproportionately impacted Black and Hispanic energy workers.” Broadband infrastructure competency training and credentialing programs that include enrollment of those under judicial supervision will increase diversity and provide a double sector benefit across the economy, provided that training also extends to the employers who must recruit, retain and promote based on competency.
Pros:
● Addressing labor shortage.
● Reducing recidivism.
● Contributing to workforce development.
Cons and Trade-offs:
● Initial investment required for training programs.
● Institutional infrastructure

Broadening skills-based language instead of field-related language could help students see themselves in occupations and fields that have been previously exclusionary. Providing training in these skills is a key step in increasing economic equity for first-generation and racial/ethnic minority students. When equipped with these capabilities, individuals from underserved communities can access job opportunities that were traditionally beyond their reach and impact the social and economic need for digital fluency and connectivity in their communities.

To expose students to less familiar career paths, CSUDH-WIN has focused on the skills required to be successful in the target fields. This focus has allowed us to expose students to applied fields not usually associated with digital equity and broadband work like Sociology, Anthropology, Digital Media Arts, and Health Sciences.

1. Data Analysis: Proficiency in data analysis is a valuable skill in the digital age. It enables individuals to extract insights from data, make informed decisions, and solve complex problems. This skill is applicable across various industries, including IT management and online infrastructure. The call for accurate and additional data and maps in many states digital equity plans across the nation is indicative of the importance of training students to be proficient in this skill. While BEAD V2 calls out the need for software engineers, the occupation titles do not reflect the skills that will enhance the work more broadly.

2. Project Management Tools: Project management skills are essential for overseeing and coordinating complex projects, including the deployment of broadband infrastructure. Project management tools help individuals plan, execute, and monitor projects effectively, ensuring they are completed on time and within budget. There is a great need for project management support in anchor institutions as projects funded are implemented. As Connecting Minority Communities Pilot Program awardees, CSUDH WIN recognizes the need for project management support for institutions that are embarking on innovative journeys in broadband work alongside their regular duties, like workforce integration or social impact efforts. This industry is called out in BEAD V2 Section 9.1.2.1 as an occupation category required to deploy.

3. Marketing Tools: In the digital era, marketing is crucial in promoting products and services. Proficiency in marketing tools allows individuals to reach a broader audience, drive engagement, and contribute to the growth of online infrastructure and IT-related businesses. By providing student training in this skill, we have been able to participate in developing marketing materials for the ACP and equipment deployment in community-based organizations which helps minimize this burden on our CBO partners. It is important to note these technical skills will be required to share messaging about the initiatives to come.

Through the implementation of the CMCPP grant, CSUDH has often acted as a bridge in navigating some of the challenges of consuming complexly written information and sharing it with our community-based partners while training students to become advocates for digital equity and knowledge about broadband infrastructure employment and efforts. By engaging in curricular projects that inform digital equity solutions, students are further introduced to IT Management, Online Infrastructure, and Broadband infrastructure employment opportunities.

One example of a partnership with community, public sector, and higher education stakeholders is a proposed project within the CSUDH WIN program: The Digital Divide & Discrimination Project (DD&D) will join with the “Neighborhood Resilience Initiative” to help determine the current and potential financial, social, and community impact of the new South Bay Fiber Network. In 2020, 100+ miles of fiber backbone connecting 19 community organizations and local government facilities were leased. The original intent was to provide broadband with more bandwidth (1-10 gigabit) at a lower cost to the participating cities. This has been accomplished effectively and now the opportunity to expand the network into the business and residential community is the next phase. We have established relationships with these organizations. htps://southbaycities.org/programs/south-bay-fiber-network-addressing-the-digital- divide/ The plan for this project is to have California State University Dominguez Hills (CSUDH) business and entrepreneurship students work with a coalition of local governments, agencies, and resources in the South Bay region of Southern California to focus on the underserved and marginalized communities that have a network nearby but do not have affordable, practical broadband services.
The project has three goals:
1. Assess the level of digital access and adoption: To determine if digital discrimination is occurring in a community. This will be done by analyzing data on broadband adaptability, Internet usage, and digital skills in the community. (Data analysis)
2. Identify the barriers to digital access and adaption: Once the level of digital access and adoption has been assessed, it Is important to identify the barriers and challenges faced by the community. These barriers can include a lack of infrastructure, affordability, and digital literacy. We will use existing data, focus groups, and surveys to determine these barriers. (Market Research)
3. Develop targeted solutions: These solutions can include policies to promote equal access to broadband services, digital skills training (teaming with Goodwill), and initiatives to increase access to digital services and devices. (Michael Grimshaw, 2023)
2. Public Interventions and ISP Accountability: The statistics presented in the plan reveal that 35% of California households have access to only one broadband provider offering service greater than 25/3 Mbps, and only 6.8% have access to three providers offering such service. This lack of choice in service providers is a significant concern, particularly in underserved communities.
To address this issue, public interventions in the form of capital subsidies, such as those offered through the California Advanced Services Fund (CASF), are necessary to incentivize providers to expand their services to these underserved areas. Moreover, accountability measures must be put in place for ISPs that receive subsidies. Currently, the burden is on community members to challenge coverage maps, which is impractical given the resources available to them. Instead, ISPs should be required to prove their coverage in these areas.
• Statistics: 61% of DEEM telephone survey respondents identified cost as the primary barrier to obtaining home internet service. Lack of consumer choice and competition among Internet Service Providers (ISPs) was also highlighted as a barrier. The Public Interest Advocacy Center (PIAC) reports that areas with limited ISP choices often experience higher prices, lower connection speeds, and poorer customer service. This further widens the digital divide and limits access to online opportunities.
I recommend that the state continue to offer capital subsidies to ISPs but with the condition that they provide evidence of service coverage in anchor community institutions. This approach ensures that subsidies are effectively used to expand broadband access where it is needed the most but also that the burden is not placed on poorly equipped community-based organizations to familiarize themselves with complicated industry conversations surrounding broadband first, middle, or last mile efforts.
Pros:
• Encouraging ISP expansion:
• Ensuring accountability for subsidies.
Cons and Trade-offs:
• Potential resistance from ISPs.
• Administrative efforts to verify coverage.
Section: 3.4 Specific Barriers and Baseline for Covered Populations and Digitally Disadvantaged Communities
Nelson Mandela once said, “No one truly knows a nation until one has been inside its jails. A nation should not be judged by how it treats its highest citizens, but its lowest ones.”
Recommendations to include students as a covered population ensure their needs for digital access and inclusion programs are brought to the forefront of discussions; digital equity goes hand in hand with economic equity.

Historically, racial, and ethnic minorities, including first-generation students, have faced significant barriers when pursuing careers in technical fields such as IT management, online infrastructure, or broadband infrastructure positions. These barriers have limited their access to well-paying jobs and opportunities for career advancement. However, by providing targeted training in transferable skills, we can empower these individuals to explore less familiar career paths and bridge the digital divide.
Historically, technical fields have been characterized by a lack of diversity. Racial and ethnic minorities have often been excluded due to systemic barriers and lack of exposure to these career paths. By training these students in transferable skills, we increase their confidence and diversify the talent pool for technical positions.
The State Digital Equity Plan for California emphasizes the importance of equitable access to digital skills and opportunities. Training first-generation and racial/ethnic minority students in skills like data analysis, project management, and marketing tools directly aligns with this objective. It ensures that individuals from all backgrounds have the knowledge and abilities needed to thrive in the digital age.
1. Recommendations for Incarcerated Individuals: The plan references an open letter from the Benton Institute for Broadband & Society, which offers three sound recommendations to increase digital equity for incarcerated individuals: I. Providing non-proprietary, publicly owned network infrastructure in correctional facilities. II. Enabling affordable and equitable communication services for incarcerated people. III. Investing in digital literacy infrastructure in correctional facilities.
These recommendations are crucial for ensuring that justice-involved individuals have access to digital resources, which can significantly impact their lives upon release.
Statistics: Research indicates that access to education and training during incarceration reduces recidivism rates.
I strongly support the recommendations mentioned in the plan and suggest further collaboration with institutions like California State University Dominguez Hills (CSUDH) to implement practical solutions. CSUDH, in collaboration with groups of incarcerated individuals and correctional leaders, has developed tools and platforms with Workbay for Corrections Tablets and the Reentry civilian-side platform. These platforms are customized, and localized, and provide visibility to jobs, wages, and personalized recommendations, optimizing success for justice-involved individuals. In July 2023, CSUDH demonstrated such a tool at the US Chamber of Commerce Foundation and can be reviewed here: In addition to developing technical tools to support training our campus also has a Project Rebound program for released individuals seeking a degree program as well as a master’s program for those still incarcerated. Increasing support for training programs to address broadband infrastructure jobs could improve recidivism rates in the state by providing employment pathways for this underserved group.
Pros:
• Reducing recidivism through education and employment opportunities.
• Empowering justice-involved individuals with valuable skills.
Cons and Trade-offs:
• Initial investment required for infrastructure and education programs.
Documenting and Promoting Public Resources for Incarcerated Individuals: The plan rightly emphasizes the importance of documenting and promoting public resources and services that are consistent with the security requirements for access by incarcerated individuals. This ensures that these individuals can access valuable educational and vocational programs.
Alternative Approach: To strengthen this aspect, I suggest that the state collaborate with educational institutions and organizations like CSUDH to identify and curate a comprehensive list of resources that meet security requirements. This list can be made available to incarcerated individuals, providing them with opportunities for skill development and learning.
Pros:
• Access to a curated list of resources tailored to security requirements.
• Enhanced educational and vocational opportunities for incarcerated individuals.
Cons and Trade-offs:
• Administrative efforts to curate and maintain the resource list.
We must prioritize digital equity for justice-involved individuals. By implementing the recommendations and collaborating with educational institutions like CSUDH, we can make a meaningful impact on the lives of incarcerated individuals, reduce recidivism, and build a more equitable society.

4. Collaboration and Stakeholder Engagement
Utilize the Digital Equity Ecosystem Map (DEEM) to overlay BEAD-identified priority areas Volume I (Appendix 2-5) draft-cpuc-bead-ipv1-as-submitted.pdf (ca.gov) with organizations offering digital inclusion programs SDEP (Appendix H), such as affordability initiatives and digital literacy training, facilitating a streamlined review process for funded areas and their associated support services.
• Example & work in progress to expand using SDEP Appendices: CSUDH Broadband Map Layers (arcgis.com) with designated CMC partners: Broadband Map Layers (arcgis.com).
While the DEEM tool provides valuable insight into the digital equity landscape, its true potential lies in leveraging this data to actively engage stakeholders. How will the state utilize this information to map stakeholder roles and responsibilities and foster meaningful collaboration across state agencies, community organizations, and private entities? How will trusted messengers (CAIs, non-profits, etc.) be compensated to keep them involved in the implementation and execution?
This is a great start for a well-defined ecosystem of stakeholders. How will this plan identify and clarify the roles and responsibilities of various entities, including government agencies, non-profits, ISPs, and community leaders?
What specific metrics and performance indicators will be implemented to assess ISPs and their contributions to digital equity goals? How will the state ensure transparent reporting and consequences for non-compliance?
While the State Digital Equity Plan (SDEP) recognizes the vital roles of state/regional consortia, municipalities, and CAIs, misalignment and confusion regarding lead roles and responsibilities can hinder effective collaboration at the local level. This fragmented approach undermines our ability to present a cohesive and unified voice in SDEP implementation.
Section: 4.1 Inclusive and Participatory Planning Process
Readability of Public-Facing Documents: Public-facing documents are a crucial part of engaging communities and stakeholders in the digital equity planning process. However, it is concerning to note that several readability indices indicate that the documents used for Regional Planning Workshops and public engagement are written at a relatively high level of difficulty, with scores ranging from 13 to 16.5.
This level of complexity may pose a significant barrier to community members and partners who wish to participate in the planning process. It is essential to ensure that information is accessible to a wide range of individuals, regardless of their educational background or reading proficiency.
Recommendation: To address these issues, I recommend simplifying the language used in public-facing documents. Complex sentences should be broken down into shorter, more understandable ones, and adherence to plain language principles should be a priority. By adopting a clearer and more accessible approach, the notice of meetings can foster greater understanding, participation, and engagement from community members and partners.
Pros:
• Increased accessibility and inclusivity in the planning process.
• Greater understanding and participation from a diverse range of stakeholders.
Cons and Trade-offs:
• Potential need for additional time and effort in document revision.
Need for Alternative Formats to Ensure Readability: It is also important to consider alternative engagement formats ensure the readability of community-facing communications. If the goal is to gain feedback in a short amount of time (45 days), then providing resources such as multiple visuals, tools, and content that simplify complex information can be highly beneficial.
For example, the Affordable Connectivity Program (ACP) created various visuals, tools, and content that leaders could use to ensure correct interpretation and facilitate the communication of information to anchor institutions. This approach can decrease the workload of individual organizations and increase participation in implementing strategies funded by the state digital equity plan.
Pros:
• Enhanced clarity and understanding of digital equity initiatives.
• Increased efficiency in gaining feedback and participation.
Cons and Trade-offs:
• Initial investment may be required for the development of tools and content.
Section: 4.3 Summary of Outreach and Engagement Methods
Missed Opportunity with Incarcerated Population: The State Digital Equity Plan mentions various efforts to ensure that historically underserved communities, such as low-income, tribal, rural, and ethnic minorities, have a voice in the digital equity survey. However, there is a noticeable absence of participation from the incarcerated population, which includes approximately 95,600 individuals in state prisons.
This oversight represents a significant missed opportunity to understand the unique digital literacy and fluency needs and experiences of individuals within the correctional system. With a planned decrease in state prisons and the parolee population, focusing on digital upskilling through pre-release programs could play a vital role in reducing recidivism rates and increasing employability potential.
Recommendation: I recommend that the state actively involve incarcerated individuals in digital equity surveys and needs assessments. By providing access to digital literacy programs and surveys within correctional facilities, we can gain valuable insights into the digital needs of this population. Additionally, applications like https://www.workbay.net/correctional-facilities offer workforce training programs that align with security requirements, making them suitable for use within correctional settings.
Pros:
• Gain insights into the digital needs and challenges faced by incarcerated individuals.
• Reduce recidivism rates through digital upskilling and education.
• Increase the employability potential of justice-involved individuals.
Cons and Trade-offs:
• Investment required for implementing digital literacy programs in correctional facilities.
Compensation for Community-Based Organizations: The State Digital Equity Plan correctly acknowledges the pivotal role of local leaders and community-based organizations in promoting digital inclusion. These organizations are deeply connected to their communities and serve as trusted sources of information and guidance.
However, it's essential to recognize that involving community-based organizations often requires significant time and effort from their staff members. The plan highlights that one staff member's participation took 30% of their time and incurred additional costs. To ensure the active involvement of these organizations, compensation should be considered for their contributions.
Recommendation: I recommend that the state allocate resources to compensate community-based organizations for their valuable work in digital equity planning. Recognizing and valuing community contributions is essential to the success of any initiative. Compensation can offset the costs incurred by these organizations, such as staff time and travel expenses.
Pros:
• Encourage active participation of community-based organizations in digital equity planning.
• Recognize and value the diverse perspectives and skills they bring to the table.
• Alleviate financial burdens on these organizations.
Cons and Trade-offs:
• Budget allocation for compensating community-based organizations.
In conclusion, involving the incarcerated population in digital equity surveys and compensating community-based organizations for their contributions are essential steps to ensure a comprehensive and inclusive digital equity plan for California. By addressing these issues, we can better understand the digital needs of all communities and support their digital inclusion efforts.

7. Appendices
While the current network of 52 Digital Navigation service providers (Appendix H) offers valuable support, it largely overlooks the immense potential of educational institutions as lead partners in developing a sustainable framework. With only two CSUs (Fresno & Humboldt) and one Department of Education Adult Education agency represented, we miss out on a wealth of diverse perspectives and expertise crucial for serving different populations, particularly the learning community. CSUDH has Digital Navigation services that are not listed in Appendix H.
4917January 25, 2024 at 10:23 pmJ.B.ResidentFelton950183. Current State of Broadband and Digital Inclusion
There needs to be strategic planning processes developed by all sectors in order to build, sustain and grow digital inclusion. The shiftED program out of the Santa Cruz County Office of Education has created a framework and strategic planning process as well as assessment tools to assist educational agencies in creating digital literacy, roadmaps centered around equity instruction, and professional development. Planning tools should be considered and focused on to create and sustain as well as grow successful digital literacy capacity. https://shifted.santacruzcoe.org
4916January 25, 2024 at 10:13 pmP.R.ResidentPatricia Rubano920542. Introduction and Vision for Digital Equity
There are many reasons to stay with wired infrastructure. It is both safer and more energy-efficient. It offers greater capacity, predictable performance, lower maintenance costs, and a longer technological lifetime than wireless technologies. Fiber service is not degraded by line-of-sight issues and is not affected by capacity
issues.
I am 70 years old and try not to be simply 'stuck in the past'. I recognize advancements that make sense and are positive. I see too many other changes that do not make sense and have not been thought through. Many 'advances' have made life more convenient, but also far more complicated and vulnerable when they don't work.
4915January 25, 2024 at 9:33 pmG.B.ResidentOrangevale956621. Executive Summary
Any/all help for Seniors would be greatly appreciated! Considering most of us are living on a fixed income...
4914January 25, 2024 at 9:30 pmDirector of AdvocacyOrganizationFamilies In SchoolsLos AngelesCA5. Implementation Strategy & Key Activities
Families In Schools (FIS) values the opportunity to provide feedback on California’s draft State Digital Equity Plan. Founded in 2000, FIS is a nonprofit based in Los Angeles, California. Our mission is to involve parents and communities in their children’s education to achieve lifelong success. Our work is organized around two core competencies: curriculum and professional development and advocacy. FIS provides training, coaching, and leadership development to educators and parents and engages parents through direct or collective action on state and local advocacy campaigns.

In our work at FIS, we have witnessed firsthand how the digital divide exacerbates existing educational disparities, particularly low literacy rates. This divide does not merely hinder access to technology; it perpetuates a cycle of educational and economic disenfranchisement. Students and families within the covered populations are often those most in need of educational resources, yet they are the very groups most likely to be cut off from the digital lifeline that facilitates learning. For instance, during and since the pandemic, we consistently encountered barriers where low literacy rates intersect with limited digital access. This intersection creates a compounded disadvantage, limiting not only the educational opportunities but also the future economic prospects of these communities. The absence of reliable internet access means that students from low-income, predominantly Black and Latino communities are often unable to access or fully engage with digital learning tools, further widening the literacy gap.

To ensure that California is reaching students and their families who are among the eight “covered populations” addressed in the California Department of Technology’s (CDT) plan and moving toward the objective that “students and educators have access to home internet and devices that can be used in remote and digital learning environments,” FIS believes the CDT should not simply “evolve” the data and maps as stated in Key Activity 3 but instead “transform” the maps utilizing “community-provided data.”

Continuing to rely on flawed maps will perpetuate the decades of broadband disinvestment occurring in low-income, predominately Black and Latino communities. It will also undercut California’s efforts to address barriers against individuals with an income at or below 150% Federal Poverty Level, individuals with disabilities, individuals with language barriers including English learners and those with low levels of literacy, members of a racial or ethnic minority group, and individuals residing in rural areas.

As our literacy campaign, ReadLA! -- Justice and Literacy for All expands statewide with the aim of increasing the number of third graders reading on grade level in Los Angeles, we are confronted with the pervasive impact of the digital divide. This divide is not just a barrier to digital access; it represents a multifaceted obstacle to educational equity and literacy in our statewide efforts. We have consistently observed that the communities most affected by low literacy rates are also those most severely impacted by inadequate digital infrastructure. This overlap is not coincidental but indicative of a broader systemic issue that requires a holistic and community-driven approach to resolve.

By integrating community feedback into the decision-making process, we can ensure that broadband investment is both equitable and effective. Therefore, it is paramount for the State of California to involve communities in the process of making maps and determining eligible areas through a public comment period, allowing for community members to offer feedback, provide data, and identify areas and communities in need of broadband investment so they are not excluded from these maps and further disenfranchised.

It is crucial that California’s efforts in closing the digital divide go hand in hand with addressing educational disparities. Transforming the data and maps to reflect the true needs of these communities is a critical step in ensuring that broadband investment reaches the areas where it can have the most profound impact on breaking the cycle of low literacy and digital exclusion. By doing so, we are not just investing in infrastructure; we are investing in the future of our children and the socio-economic upliftment of our communities.
4913January 25, 2024 at 9:28 pmBoard ChairOrganizationFresno Coalition for Digital InclusionFresnoCA1. Executive Summary
Goal 1, Objective 1.4: Increase the percentage of Californians who have a choice of at least three internet service providers.

Goal describes the objective for all California residents to have access to three (3) ISP choices, but there is nothing in the implementation plan that describes how this would happen. CA should encourage a public option (support school districts, municipalities, etc, in building open access networks). Anchor institutions have significant infrastructure and assets in the most underserved communities; specific support for building to, and through these public facilities to support the surrounding communities is needed to incentivize this type of development. Creative solutions should be identified to help these new players into the market with technical and support resources that narrow the challenges and risks associated with providing new public services outside of agencies’ existing mandates.

2. Introduction and Vision for Digital Equity
The Framework for the Plan is defective in that it fails to acknowledge, measure, or plan to correct the existing conditions that create discrimination in broadband access and delivery.

The Federal Communications Commission’s November 2023 definition of “discrimination” to include policies and practices that have a “discriminatory effect” must be the framework for California’s Digital Equity Plan. Past governmental and industry approaches have created discriminatory effects now baked into the entire broadband ecosystem. This draft Digital Equity Plan must therefore aggressively, explicitly, and effectively lay out exactly how the State of California will dismantle and rebuild the structures, policies, and practices that have resulted historically in discriminatory denial of adequate broadband access based on communities’ income level, race, ethnicity, or national origin.

The Goals/Objectives/Strategies portion of the Plan defines the problem using egregiously inaccurate data, and then fails to identify responsible parties, timelines, and funding sources such that there is no actual path to implementation.

5. Implementation Strategy & Key Activities
Key Activity 1: Expedite and complete existing Broadband for All infrastructure efforts

As the state continues to buildout the MMBI network, preferential access must be provided to the MMBI network in areas of poverty and historically underinvested neighborhoods to incentivize the development of last-mile solutions in these neighborhoods.
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Key Activity 3: Evolve broadband and digital equity data and maps.

The Plan’s use of the term “evolve” does not capture how urgently necessary it is to correct the equity data and maps on which implementation of this Plan must depend. “Evolution” is a process not detectable within a human lifetime—of necessity, it is slow and infinitely iterative. Such a timescale will not lead to equitable outcomes. Without correction, now, of the equity data and maps, the geographic focus of equity efforts, and the public funding that follows, will fail to deliver access where most urgently needed.

Notwithstanding Governor Newsom’s 2022 Equity Executive Order directing State agencies and departments to “take additional actions to embed equity analysis and considerations in their mission, policies and practices,” this draft Digital Equity Plan pays only lip service to either equity analysis or considerations. Acknowledging the meetings, surveys, focus groups, etc. described at pp. 108-111 of the Plan, we have seen here in Fresno County that the most important information surfacing from community involvement has been the utter inadequacy of the data on which funding decisions are made, and a refusal, to date, to upgrade the data to reflect local realities.

The FCC and CPUC data on unserved and underserved populations is substantially incorrect and its statistically significant inaccuracies massively understate the unserved populations in low-income neighborhoods both in rural and urban neighborhoods and especially in multi-dwelling complexes.

California should radically transform the quality of the CPUC maps by including large-scale, crowd-sourced data based upon speed tests that can be used as an additional layer on the CPUC maps and be used to challenge carrier claims regarding the status of a serviceable location as unserved, underserved, and unconnected.

This requires support for anchor institutions to 1) collect this data (for example, use of the myQoI open-source Windows and Android apps), 2) analyze this data across Wi-Fi and wireline speed tests, geolocations, carriers, and over time, 3) transform this data with serviceable location fabric to serve as challenges, and 4) export this data with appropriate privacy safeguards into regional or state data lakes, and 5) develop agreement standards on how this data is interpreted (such as how many underserved speed test measurements establish that a serviceable location is in fact unserved).

This requires that the CPUC allow for crowd-sourced, large-scale data challenges that include whether a location is underserved, unserved or unconnected, without requiring an affidavit from the consumer and without an invoice from the carrier. It is foolish to require a carrier’s tier level when the speed tests statistically demonstrate that the speeds are below any plan for carriers. The current challenge process does not allow for crowd-sourced, large-scale challenges, nor does it support an individual resident to perform this challenge given the inordinate requirements for a challenge.

Also, assessments of availability, affordability, and adoption must take into account that these factors affecting access are interrelated and often determined by carrier service characteristics and other attributes like limited choice: in low-income Fresno neighborhoods, residents mostly have access only to Comcast DOCSIS 3.0. In particular, we need better data for resident units within an MDU, as well as the actual speeds of anchor institutions’ internet connectivity.

Finally, ultimately the most critical attribute is performance. For example—based upon its own reporting to Fresno Unified School District—Comcast does not deliver any service at all to many homes (contrary to its claims on its FCC 477 forms).

Moreover, contrary to what is shown on the CPUC maps, ISPs deliver such poor service to many of our residents’ households that they too must be considered unserved. Our analysis of myQoI data shows that 27% of residents in metro Fresno are unserved (using the 25/3 standard), though the CPUC maps based upon carriers’ claims show only 4%.
---

Key Activity 4: Launch the California Connect Corps and digital equity grant program to expand community-based digital navigation and digital inclusion programs.

Digital Literacy and Digital Navigator programs by our community-based organizations and anchor institutions have been an unfunded mandate: though such programs are absolutely required to assist our residents in accessing the services that they need, there has essentially been no viable long-term funding source(s) for this essential work. Of course we are supportive of the concepts described in the implementation portion of the plan, but the lack of specificity makes it impossible to provide constructive comments.

Therefore, we respectfully request that the California Department of Technology engage in an open process to learn from the organizations that have been working in this space, to inform the development of a draft plan that would then be published for public comment. Without more information on how the California Connect Corps will be structured, or the digital equity grant requirements for CBOs and anchor institutions, we are unable to provide any meaningful comments.
---

Key Activity 7: Promote low-cost offers and the Affordable Connectivity Program (ACP) and advocate for a sustainable successor program.

The wind-down of the Affordable Connectivity Program has already begun, with ISPs already sending out notices to customers receiving ACP subsidies. By the time this Digital Equity Plan is finalized, the ACP program is likely to have exhausted the available funds with no viable replacement program in place. The Digital Equity Plan draft is completely dependent on ACP in both the goals and implementation strategies for increasing affordability. CDT must revise this plan to reflect the current realities of the demise of the ACP program and be specific about how the State intends to ensure that access is affordable to all Californians.
4911January 25, 2024 at 8:48 pmL.H.ResidentSann Rafael949012. Introduction and Vision for Digital Equity
Many studies have shown that wired connection is much safer than wireless. It is also more reliable, as witnessed in the horrific California and Hawaii fires where the only residents who could receive alerts and information were those with landlines since the cell towers and antennas were malfunctioning.
Wired networks are cheaper to maintain, and provide connectivity for more people for less expense.
As has been proven from numerous tests, a wireless network is much more unstable than a wired one. We have had copper lines for decades and they still perform perfectly. Wireless networks are unreliable and costly to maintain. They do not solve the issue of the digital divide. Folks have to pay high prices for the use of cell phones and low income people cannot easily afford the cost.
Property values are unstable in a wireless environment. Homeowners have been shocked to realize that the properties adjacent to cell towers/antennas decrease in value up to 20% of the market value.
The most efficient and effective connection will come from the installation of a fiber optic network. It is also cheaper than broadband and has a much greater longevity.
Please be careful about what you assume to be true and get the facts before taking action on this misguided plan. Thank you.
4910January 25, 2024 at 8:46 pmL.W.ResidentSmartsville959772. Introduction and Vision for Digital Equity
WIRED connection is superior to wireless in all respects, and wireless broadband—especially
the basic services offered to low-income families—will NOT solve the digital divide.

• Wireless is inferior "dirty" technology, unreliable, and unable to SAFELY meet the demands of present and future digital communications. Provide funding for safer, reliable, energy-efficient WIRED internet, not wireless installations.
• Wireless is unreliable and unable to meet the demands of present and future digital communications. Providing funding for the rollout of wireless installations will take it away from much safer, reliable, energy-efficient WIRED internet.

• Wireless will set the state back in terms of climate change management because wireless uses a huge amount of energy compared to WIRED broadband.

• Wireless facilities increase fire risk and cyber security risk

• Wireless facilities impact the growing percentage of the population with disabilities related to radiofrequency radiation (RFR) exposure.

• Wired infrastructure offers greater capacity, predictable performance, lower maintenance costs, and a longer technological lifetime than wireless technologies. Fiber service is not degraded by line-of-sight issues and is not affected by capacity issues.

You can read The Draft State Digital Equity Program here: Broadband for All portal
4909January 25, 2024 at 8:39 pmJ.R.ResidentLos Angeles900652. Introduction and Vision for Digital Equity
Wireless broadband will not solve the digital divide. I reside in East Los Angeles. Low income people don't have the resources to use wireless. We certainly don't need to be vulnerable to cyber-security issues - and more importantly RFR radiofrequency radiation. The results of research on the detrimental effects is extremely troubling. Please protect your citizens.
4908January 25, 2024 at 8:29 pmDigital Equity SpecialistOrganizationLead for America - American Connection CorpsWichitaKS1. Executive Summary
On behalf of Lead for America (LFA) and our American Connection Corps (ACC) program, we would like to take this opportunity to thank your office and governor for prioritizing digital inclusion opportunities strategically in your state, particularly in regards to reaching rural and underserved communities and incorporating more boots-on-the-ground approaches through non-profit and community partnerships and Digital Navigator models like the American Connection Corps.

We currently have 3 members based out of California: 2 members are serving with the City of Santa Paula and we have a member serving the Ministerial Association of Colusa County dba PenumaCare.

Need & role for digital navigators

Nearly 20% of Americans lack a broadband connection or digital device at home according to the 2020 US Census. The Boston Consulting Group (BCG) recently studied digital navigator programs over a few years and found from a survey of over 1,500 people that digital navigators can significantly increase the effectiveness of digital equity programs (https://www.bcg.com/publications/2022/how-to-close-digital-divide-with-human-approach).
With support from a digital navigator, over 65% of survey respondents were able to obtain internet access, computer or tablet at home, and over 85% reported using the internet more. This illustrates the crucial role that digital navigators can play and the importance of continuing to support these roles across California in the coming decade.

As outlined in the Boston Consulting Group study, digital navigator programs "come in many shapes and sizes," including four major archetypes: 1) Intervention Specialists 2) Digital-Inclusion Specialists 3) Social-Change Agents and 4) Functional-Skill Builders.

We applaud your plan’s emphasis on continuing the partnership with the American Connection Corps (ACC) and believe this will strengthen California’ digital navigation efforts and support knowledge sharing between existing and new digital navigators. We encourage {INSERT} to explore ways of expanding the ACC partnership and statewide placement opportunities even further, as we have similarly expanded statewide to serve Idaho, Illinois, and Massachusetts through 10-20 placements across each state.

Lead For America and our ACC program believes in investing heavily and holistically in our ACC AmeriCorps Members to not just be “entry level” contributors but to become emerging civic leaders that also serve as “Digital Navigators 2.0++.” Our model goes beyond the basic DN approach to encompass all 4 archetypes of the digital navigator. We provide our ACC Members with four (4) in-person training intensives per year, access to digital inclusion experts and nationally recognized Northstar digital literacy assessment curriculum, and weekly group support calls to ensure their effectiveness, impact, and preparation. Our ACC members “do whatever it takes” to get things done when it comes to advancing digital equity in their communities.

In the plan draft proposed in January 2024, the California state broadband office highlights the important roles of Digital Navigators in the following ways:
On page 9 of the plan it states that a priority outcome area is digital literacy & inclusion
Oon page 17, Objective 3.1 seeks to increase the availability of digital literacy, cybersecurity, and skills training programs
On page 21 the plan discusses training existing social workers, health workers, educators, librarians and other community service workers to serve as digital navigators
On page 22 the plan aims to launch a California Connect Corps to expand community-based digital navigation and digital inclusion programs

With this context in mind, we believe that the plan needs to be more ambitious. We would like to see the following changes implemented to support digital navigators:
Support the development of the 4 types of digital navigators: 1) Intervention Specialists 2) Digital-Inclusion Specialists 3) Social-Change Agents and 4) Functional-Skill Builders.
Develop and provide increased financial support for outreach campaigns
Develop dedicated support lines to assist community members with digital literacy skills such as: identifying scams and cybersecurity risks, access patient portals for medical treatment, submitting job applications and much more.
Invest in research and evaluation to improve existing program design and closely measure impacts

Role of nonprofits & community organizations

Local nonprofits serve as a trusted, community resource which can be easily accessed by members of the community. Many individuals already accessing a nonprofits services may also be eligible for federal/state broadband programs.

In the plan draft proposed in January 2024, the California state broadband office highlights the importance of nonprofits in the following ways:
Page 22 and 23 of the plan mentions the California Connect Corps will support nonprofit organizations to advance digital inclusion

With this context in mind, we’d like to see additional partnerships with existing digital navigator programs such as the American Connection Corps. We have witnessed firsthand the transformative impact of the American Connection Corps and AmeriCorps on individuals and communities alike in the 28 states we are currently serving - ranging from Kansas to the Carolinas and from Maine to California. For example in 2023, Lead for America implemented a groundbreaking public private partnership with the state of Massachusetts and Comcast to provide Digital Navigators to nonprofits and regional planning organizations statewide by placing 15 American Connection Corps members across the state of MA. Read more about this innovative partnership approach to digital navigation here: https://masstech.org/news/mbi-comcast-partners-to-expand-broadband-adoption

Since 2021, ACC has successfully graduated 75 AmeriCorps members who have hosted over 360+ digital skill-building workshops and community forums, and launched 75+ public-private partnerships. As a result of these members service they have enrolled 6,500+ households into the American Connectivity Program (ACP) Benefits and channeled $45,503,609 to local communities.

3. Current State of Broadband and Digital Inclusion
Partnership with public housing authorities

We appreciate that the plan acknowledges the lack of infrastructure and available internet on page 105 & 106. We’d like to see an expansion of partnership opportunities with public housing authorities. These partnerships could help to expand initiatives to ensure support for federally supported residential communities. Public housing authorities and federal programs can support digital opportunity efforts based on their current engagement in supporting high-speed internet availability, affordability and adoption. In addition, partnerships with municipal housing authorities to include affordable at-home internet service at multi-unit dwellings. We’d like to see the plan expand to partner with specific affordable housing developers.

8. Not Related to Above Sections
In summary, we applaud this historic investment to enhance digital inclusion efforts afforded by the Infrastructure Investment and Jobs Act. Implemented strategically by states with local needs in mind, these crucial funds can reduce and eliminate historical, institutional, and structural barriers to technology access and use. We greatly appreciate both the State of California’s and the NTIA’s comprehensive approach to designing and implementing the State Digital Equity Capacity Grant Program and the Digital Equity Competitive Grant Program, which will significantly increase and improve the direction of resources dedicated to removing systemic barriers and providing equal access to opportunity. Thank you for your ongoing work and partnership with nonprofits including Lead For America and the American Connection Corps!
4907January 25, 2024 at 8:26 pmV.B.ResidentGrass Valley959491. Executive Summary
WIRED connection is superior to wireless in all respects, and wireless broadband—especially the basic services offered to low-income families—will NOT solve the digital divide.
4906January 25, 2024 at 8:24 pmR.P.ResidentSquaw Valley936755. Implementation Strategy & Key Activities
I'm a middle-aged, homeless man. No car, and I live pretty far below the poverty line. I have a hidden disability. I'm trying to earn a degree and change my outlook. Online learning makes this possible. I'm getting help through the Department of Rehab and my success with online education is considerable. I will graduate soon and my life is going to improve I think. We're it not for Internet connection, none of this would be possible for me. It's literally the difference. It is my hope that broadband access becomes accessible across the board so that I can continue to broaden my quality of living. I want off of welfare.
4905January 25, 2024 at 8:02 pmD.A.ResidentPenn Valley959468. Not Related to Above Sections
WIRED connection is superior to wireless in all respects, and wireless broadband-especially the basic services offered to low-income families-will NOT solve the digital divide.

Wireless is inferior "dirty" technology, unreliable and unable to SAFELY meet the demands of present and future digital communications. Provide funding for safer, reliable, energy-efficient WIRED internet, not wireless installations.

Wireless will set the state back in terms of climate change management because wireless uses a huge amount of energy compared to WIRED broadband.

Wired infrastructure offers greater capacity, predictable performance, lower maintenance costs, and a longer technological lifetime than wireless technologies. Fiber service is not degraded by line-of-sight issues and is not affected by capacity issues.
4904January 25, 2024 at 7:35 pmExecutive DirectorOrganizationCITRIS Health, University of CaliforniaBerkeleyCA3. Current State of Broadband and Digital Inclusion
The SDEP Draft (p. 76) lists the following barriers to digital equity for aging individuals (60+):
1. Lack of perceived need
2. Inadequate devices/technology
3. Lack of digital skills training
Working in the digital literacy and age tech environment for over 10 years, we are concerned that the initial barrier, "Lack of perceived need," may lead to the misconception that older adults lack interest in adopting broadband or lack the ability to engage digitally, both of which are not accurate.

Based on our program, research and training experience, it's evident that older adults are enthusiastic about becoming digitally engaged, and they express a keen desire to acquire the necessary skills in a supportive environment. We have developed multiple technology-based programs and services with and for older adults, and it is a universal issue that older adults are very interested in using technology, are increasingly dependent upon using technology to obtain information, knowledge and services, yet have significant barriers of access to technology.

Instead of "Lack of perceived need," we believe that there are a number of significant barriers to digital equity, most importantly in the lack of in-language digital skills training, limited access to internet services, and limited affordability of internet connectivity and technology. This was especdially apparent during the pandemic and was central to our developing Lighthouse, a digital literacy training program for isolated older adults.

For both individuals with disabilities and older adults, affordability of broadband connection and devices is a significant compounding factor that prevents these covered populations from having access. Across California, 26.2% of people with disabilities live in poverty, twice the rate of the population without a disability. Even with the ACP benefit, internet access and devices are out of reach for those with fixed incomes. There is a sizable group of older adults and individuals with disabilities that do not qualify for the ACP program but who still struggle financially due to the cost of living in California.

We agree (SDEP, p. 83) that people with disabilities would benefit from greater access to assistive and adaptive technologies. We would like to note, however, that this issue is not just about affordability but also about availability. There is a significant supply side challenge in your city or county. The availability of assistive technologies in your city or county is limited to just a few organizations who aren’t able to adequately meet the need or demand, and who lack the resources to expand device lending libraries. Second, there is a lack of awareness among community members about the range of assistive technologies that exist and information about how different devices and software can improve their quality of life. Our research also shows that there is a lack of staff awareness and training around the use of assistive and adaptive technologies to better meet client needs.

In terms of the in its work to advance digital inclusion for older adults or adults with disabilities?

In terms of the SDEP Draft listing the key barriers organizations experience in digital inclusion efforts (p. 19, 64:
• Funding and Sustainability. • Staff and Organizational Capacity • Difficulty Accessing and Applying for Funding. • Lack of Awareness and Engagement) we think it is critical to add the issues of "Lack of Language Appropriate Technology and Digital Literacy Training."

Thank you for your consideration of these recommendations.
4903January 25, 2024 at 7:14 pmSenior Policy & Advocacy ManagerOrganizationHuman I-TBellCA2. Introduction and Vision for Digital Equity
On behalf of Human-I-T I would like to thank the California Department of Technology and the State of California for undertaking the task of developing the State Digital Equity Plan and seeking public comment. Though a requirement, the proposal, and public input, will serve as an important blueprint for constructing a bridge to bring Californians across the digital divide and ensure that they thrive once they have arrived. Human-I-T looks forward to supporting your efforts.

With more than a decade of experience providing digital inclusion services, Human I-T is the country’s leading digital equity practitioner and nonprofit refurbisher of electronics and technology. We strongly support the California Department of Technology’s vision of “A California in which all residents have access to high-performance broadband, affordable service and devices, and the training and support necessary to enable digital inclusion for economic and other social benefits”.

We believe access to broadband is a right, not a privilege, and that the following best practices are critical to achieve adoptions:

Holistic Digital Navigation: Focus on addressing all aspects of digital inclusion, including connectivity, access to devices, digital skills, and technical support. Provide comprehensive support to individuals or communities to ensure they have the necessary resources and knowledge to fully participate in the digital world.

Assisted at Time of Call, Not 'Air Traffic Control': Be responsive and proactive in assisting individuals seeking support. Instead of acting as a controlling authority, aim to provide personalized assistance in real-time, addressing their specific needs and challenges, with solutions in-the-moment rather than pushing them to make additional phone calls or visit additional websites.

Culturally Competent Services: Recognize and respect the diverse cultural backgrounds and identities of the communities served. Tailor services to meet the unique needs and preferences of different cultural groups, ensuring that everyone feels included and valued.

Collaborative Process with Trusted Partners: Foster partnerships with community-based organizations (CBOs), local governments, educational entities, and other trusted stakeholders. Work together to identify and address digital inequities, leveraging collective expertise and resources to achieve more significant impact.

In-person and Remote Support through Various Communication Channels: Offer both in-person and remote support options to accommodate different circumstances and preferences. Utilize multiple communication channels, such as phone, email, chat, or video conferencing, to ensure accessibility and convenience for individuals seeking assistance.

5. Implementation Strategy & Key Activities
Public/Private Partnerships will be vital to success. We encourage the Michigan High Speed Internet Office to work with partners such as Human I-T and other organizations with the experience of working with governmental entities to close the digital equity gap. Our successful collaborations with municipalities has empowered thousands of residents in those cities to pursue their goals. With this expertise we suggest the California Department of Technology require grantees and sub-grantees to have a proven track record of being digital literacy and adoption practitioners.

Human-I-T is supportive of the plan to seek a long-term alternative to the Affordable Care Program. Human-I-T believes the State of California lawmakers should begin planning for these long-term costs now and work with their broadband offices and community stakeholders to plan for a foundation that can support these needs after the federal funds are spent. Further, the same attention should be applied to support Digital Equity and Literacy work beyond the scope of the Digital Equity Act funding being made available.

With regards to Focus Area 1: Key Activities & Digital Equity Programming Activities for Funding Eligibility -

1. E-waste service efforts should be limited to non-profit technology refurbishers and businesses that qualify under each municipalities small-business, women-owned, veteran-owned and minority-owned businesses regulations.
2. Plan should make clear that municipalities may opt to provide refurbished devices to the community through the funding opportunity.

With regards to Focus Area 2: Grant Program Development, Implementation, Management, & Evaluation:
1. Plan should be in line with new state payout guidelines, provide a minimum of 25% of funding upfront (AB 590)
2. Plan should ensure timely payment: ie; reimburse applicants within 60 days of report submission
3. In an effort to focus dollars on direct impact and ensure organizations of all size can equitably compete for these grants, create reporting standards that are straightforward
4. Allow nonprofits to set their own timeline for reimbursement reports, and require no more than two reports total (interim and final report)
5. Allow 20% overhead for managing/ supporting grant execution
6. Create a more concrete plan for engaging philanthropy. The current report is high-level with no goals, timeline, or process for engaging other funders' ie; multi-year unrestricted grants to support digital adoption efforts.

With regards to Focus Area 4: Closing Gaps, Additional Funding, & Sustainability :
1. Plan should include funding for in-person data collection since we know that many communities we work with
2.
4902January 25, 2024 at 7:07 pmV.W.ResidentNapa945591. Executive Summary
I love my landline and hate electromagnetic radiating toxic technology.
Keep communication simple and accessable.
4901January 25, 2024 at 6:58 pmJ.H.ResidentSAN DIEGO921111. Executive Summary
Please put more money into fiberoptics instead of expanding wifi and 5G towers. These towers are ugly to look at and are deleterious to people's health and well-being, especially for children and the elderly! Furthermore, wired optics are more reliable than wireless systems. Thank you for your attention to this important matter.
4900January 25, 2024 at 6:55 pmPolicy and Advocacy ManagerOrganizationAlliance for a Better CommunityLos AngelesCA5. Implementation Strategy & Key Activities
Alliance for a Better Community values the opportunity to provide feedback on California’s draft State Digital Equity Plan. We are a Latino/a policy and Advocacy organization located in Los Angeles focussed on advancing social, economic, racial equity and justice for the Latino/a community and the Los Angeles region through power building and policy advocacy.
In Section 5 of the Draft Digital Equity State plan, ABC strongly urges the state to take decisive action on key issues.ABC calls for community involvement in the "evolve broadband and digital equity maps" section, requesting a method for public review and the opportunity to request updates to collected data.We would like to highlight the necessity of including public WiFi in areas that are hardest to connect, such as parks, transit stops, city/county buildings, and large business corridors and recommends information on connectivity be easily visible, provided in different languages, and accessible to those with hearing and sight impediments.
Furthermore, the organization calls for efforts to work alongside elected officials in developing accountability for Internet Service Providers (ISPs) and advocates for equitable costs for services beyond advocating for increased funding for temporary solutions.
ABC underscores the importance of a single universal entry point for individuals eligible for free or low-cost WiFi or tech equipment. It urges the establishment of clear deliverables for grantees and inclusive definitions of "digital equity stakeholders." The organization recommends expanding eligible activities for grant funding to include policy and advocacy on digital equity, recognizing the role of nonprofit organizations as community leaders.
Moreover, ABC emphasizes the need for culturally competent programs for immigrant and non-English speaking communities, suggesting partnerships with local educational institutions and community colleges. We highlight the special support required for small business owners, microentrepreneurs, and street vendors to access digital services and the internet, emphasizing the significance of public access to WiFi for these populations.
Additionally, the organization advocates for long-term funded programs instead of one-time funding, allowing for effective planning and execution. We recommend communicating resources and programs in partnership with local organizations and community leaders. The organization stresses the importance of developing user-friendly statewide tools that are easy to use and teach to the community, ensuring practicality beyond policymaking.
The state's implementation plan falls short in addressing some key objectives. While we appreciate the addition of objective 1.4—aimed at increasing the percentage of Californians with three internet service provider choices—there is a lack of clarity on the plan or timeline for achieving this goal. We recommend the state invest in locally-driven public open access middle and last mile models to ensure widespread availability of a public option in Los Angeles, fostering market competition and prioritizing solutions not solely driven by profit.
Moreover, for the overarching goal of equitable access for all Californians, it is crucial that broadband infrastructure deployment prioritizes digitally redlined communities. Highlighting the importance of infrastructure build-out in rural and low-income urban areas becomes imperative, considering the unique connectivity challenges faced by these communities.
Lastly, ABC calls for capacity building support for local organizations with flexibility in fund utilization. It emphasizes the necessity of allocating funding to communities for accurate identification of broadband gaps before using maps, ensuring data systems reflect the ground reality approved by the community.
4899January 25, 2024 at 6:51 pmB.D.ResidentLos Angeles900413. Current State of Broadband and Digital Inclusion
I am a 75 year old single mom on a pension who care- gives my 43 year old permanently disabled daughter. Internet access
and timely response to the multiple government agencies relevant to her care are critical for keeping up with changes and new requirements. Missing deadlines has led to her losing services. I have paid for all internet charges with no discounts. Spectrum is withdrawing its special needs discount, as are other carriers. Charges are, in fact, going UP. HELP PLEASE
4898January 25, 2024 at 6:44 pmL.S.ResidentBloomington923166. Conclusion
Internet is not a right to have. The state has no responsibility to provide it. This state has highest taxes. Citizens do not want to pay more for " free internet for all".
4897January 25, 2024 at 6:30 pmAssociate Director of Digital EquityOrganizationFelton InstituteSan FranciscoCA3. Current State of Broadband and Digital Inclusion
PART A: COVERED POPULATION - Aging Individuals (60+)

The SDEP Draft (p. 12, 76) lists the following specific digital equity barriers for aging individuals (60+):
1. Lack of perceived need
2. Inadequate devices/technology
3. Lack of digital skills training

ACTION 1: Remove “lack of perceived need” from this list

We think it's possible to misunderstand this phrase to suggest that older adults lack the desire or aptitude to adopt broadband or engage in digital activities, which is just untrue. Actually, the rate at which older adults are embracing broadband is much the same as that of the general population. When it comes to broadband adoption, older adults in California have advanced further than any other demographic since 2014. For instance, less than 50% of persons 65 and older who had broadband were using it in 2014. This percentage increased to 91% by 2023, matching the state of California as a whole (SDEP Telephone Survey, 2023).

It is unclear what is meant to be understood by the phrase "lack of perceived need." A "reliance/dependence on mobile phones" is used to determine "lack of perceived need" in another section of the SDEP Draft (p. 70). It's not always the case that senior citizens who rely heavily on their phones believe they can live without a broadband connection. They understand that their digital device can do much more than make phone calls when they can access photo apps and bus apps, schedule doctor’s appointments, and manage their health with health apps, all of which help to improve their daily life. The San Francisco Public Library and several groups, including Community Living Campaign, Felton Institute, Self Help for the Elderly, and many more, attest to the growing appeal of workshops, tech assistance pop-ups, and classes centered around enhancing smartphone abilities.

Lastly, from our work with older adults, we observed that many do not know the difference between broadband and cellular. Older adults may think they are connected because they can access the internet with a smartphone. While this may seem like a lack of need for broadband, it is often a misconception that can be addressed through digital literacy education.

3. Current State of Broadband and Digital Inclusion
ACTION 2: Replace “lack of perceived need” with “lack of digital literacy skills” as the top barrier

We suggest that "lack of digital literacy skills" be the main obstacle to digital equity for older people, rather than "lack of perceived need."

Based on our experience working with close to 2000 older adults, people with disabilities and mental health clients required more training. The older adults and adults with disabilities, including mental health clients, prefer a series of one-on-one tech training sessions to address their specific needs, interests, and digital skill levels closer to where they live especially for participants with mobility impairments. Additionally, the information presented in the SDEP Draft, it seems that a deficiency in digital literacy is the most statistically significant obstacle to digital equity for older adults: only 42% of older adults reported having advanced digital skills, compared to 56% of telephone survey respondents overall (SDEP, 78). The remaining information in this section about older people indicates that there are 1-2% statistically insignificant differences from the total respondents.

3. Current State of Broadband and Digital Inclusion
ACTION 3: Include “insufficient In-language digital skills training and access” as a barrier

It is noteworthy that in the SDEP Public Online Surveys, people with limited English proficiency, immigrants, and members of racial or ethnic minority groups were under-represented (sometimes significantly underrepresented), while people living in rural areas (which are significantly less diverse than the general population) were over sampled. Given this, we think that one of the biggest challenges to digital equity and inclusion in California is linguistic hurdles. In the entire state, older people are more likely to be immigrants or to speak a language other than English as their first language.

In San Francisco, there are 52% of adults who are 60 years of age or older speak a primary language other than English. Digital inclusion programs present significant challenges for people with limited English proficiency, particularly for those who speak Cantonese and Mandarin (the languages spoken by most older persons), Spanish, Vietnamese, Russian, Korean, and Japanese.

3. Current State of Broadband and Digital Inclusion
ACTION 4: Include “lack of free or affordable broadband and device options” as a barrier

Affordability is an essential concern since many older individuals with low incomes have financial hardships that make it difficult or impossible for them to afford for devices or internet connections. The majority of eligible older people are not aware of the Affordable Connectivity Program's (ACP) possible cost relief. Many of those who meet the requirements also find it challenging to enroll because the application process is complicated and is limited to English and Spanish. Ultimately, a sizable portion of older individuals struggle financially despite not being eligible for the ACP program because of San Francisco's and California's high cost of living.

3. Current State of Broadband and Digital Inclusion
PROPOSED CHANGE:
Revise the list of barriers, in priority and order, to the following:
1. Lack of digital literacy or skills
2. Insufficient In-language digital skills training and access
3. Lack of free or affordable broadband and device options

PART B: COMMENTS ON COVERED POPULATION - Individuals with Disabilities

The SDEP DRAFT, p. 83, lists the following specific barriers for individuals with disabilities:
• Inadequate accessible hardware and software
• Training on hardware and software
• Accessibility of online services

ACTION: Add “lack of free or affordable broadband and device options” to the list of barriers

Apart from the previously mentioned obstacles, one of the main contributing factors that hinders those with disabilities from gaining access is the cost-effectiveness of internet connections and equipment. The "2021 Empowered San Francisco Technology Needs Assessment Report," which examined the obstacles to digital equity for older adults and people with disabilities, found that the two biggest obstacles were: 1) the high cost of devices (cited by 27% of respondents) and 2) the high cost of high-speed internet (28% of surveys). In the State, twice as many persons with disabilities—26.2%—live in poverty as those without impairments. Cities such as San Francisco (33.3%), Oakland (35.7%), and Sacramento (35.5%) have even higher percentages.

Additional notes: We concur that increased accessibility to assistive and adaptable technologies would be beneficial for those with impairments. First off, it's important to remember that availability and cost are two sides of this issue. San Francisco is facing a major supply-side crisis. Few organizations in San Francisco have access to assistive technologies; they are unable to sufficiently fulfill demand or need, and they do not have the funding to build out their gadget lending libraries. Second, community people are not well-informed about the variety of assistive technology available or how various hardware and software might enhance their overall quality of life. Additionally, our research demonstrates a deficiency in staff awareness and training.

At the same time, the needs of people living with disabilities can and do vary greatly depending on the nature of the disability (for example, physical or intellectual) and the experience of living with it (for example, congenital or acquired). Older adults who experience loss of vision later in life may face challenges in adapting to and relying on technology, as well as making the transition from visual learning to auditory and demonstrative learning.

3. Current State of Broadband and Digital Inclusion
PART C: COMMENTS ON ORGANIZATIONAL BARRIERS

SDEP highlighted several barriers organizations experience to make an impact on digital equity (p. 19, 64):

• Funding and Sustainability
• Staff and Organizational Capacity
• Difficulty Accessing and Applying for Funding.
• Lack of Awareness and Engagement

ACTION: Add “Lack of language capacity” to this list

There is a shortage of Language Skills in Helping Individuals with Limited English-Language Skills. We discovered that it is a constant challenge to provide in-language digital literacy skills training and support, especially when we connect with other organizations to learn of each other’s successes and challenges. It's Very Hard to Find and Pay Multilingual Staff. Developing or translating digital literacy resources and tools into languages like Chinese and Vietnamese is a skill that many organizations lack.

3. Current State of Broadband and Digital Inclusion
ACTION: Add “Lack of coordination and collaboration” to this list

Insufficient collaboration and coordination between government departments and groups offering digital inclusion programs. We've heard that the majority of organizations don't know about efforts to promote digital inclusion outside of what they offer. This results in competition for limited resources and a duplication of effort, which has little effect on the people most vulnerable to digital inequality. It is recommended that Community-Based Organizations, service providers, and government agencies prioritize and incentivize greater cooperation and collaboration of programs and services around common objectives through funding opportunities.
4896January 25, 2024 at 6:29 pmFellow, Tech EquityOrganizationThe Greenlining InstituteOaklandCA8. Not Related to Above Sections
I. Introduction

The Greenlining Institute works toward an equitable future which allows for communities of color to build wealth, live in healthy areas, access economic opportunities, and are ready to meet the challenges posed by climate change. As an organization, we see closing the digital divide as a necessary step in equipping communities of color with the tools and connectivity that is necessary to survive and thrive in today’s society. In today’s day and age, access to vital information and opportunities are increasingly found online. Because of this, many Californians who lack access to functioning devices, quality internet, and high-grade infrastructure continue to experience the negative effects of a growing digital divide and are unable to fully participate in today’s technologically connected world. As a way to combat this, it is imperative that the California Department of Technology (CDT) listens to the needs of communities across the state and grants the necessary tools needed to achieve the goals outlined in the State Digital Equity Plan (SDEP). In response, the Greenlining Institute (GLI) submits the following comments.

II. Encouraging CBO Participation, Expanding Digital Inclusion Digital Navigation Activities Within the State

The first area in which the CDT can improve the SDEP is within the key activity of launching the California Connect Corps and the activities thereafter. Under this initiative, the main goal is to “support nonprofit organizations to conduct outreach to underserved populations to advance digital inclusion (pg. 114).”1 In order for such a goal to be achieved, there needs to be inclusionary processes for which nonprofits can partner with the state in closing the digital divide.
One way that the state of California can enhance the process and encourage more participation by local organizations is to learn from and implement similar processes undertaken by other states. For example, in Pennsylvania, a key part of their digital equity plan (2) details that the state will seek to:
Establish a separate bucket of funding using up to 10% of the total Digital Equity Act funds received by Pennsylvania to be set aside for small organizational subgrantees that have small budgets and limited staff; specific definition to be developed after the amount of funding is known (p.105)
In emulating a plan like this, California should set aside a similar percentage of funding for organizations that are often overlooked and assist them in procuring resources for their projects. To further simplify the CBO application process and increase overall participation, the CDT should also implement a ministerial review process,3 similar to the process developed by the CPUC in the California Advanced Services Fund Adoption Account program which streamlines grants for digital equity programs that fit certain financial criteria, through a rapid approval process.
As it stands, the ministerial review procedure requires that “the applicant has at least one year’s experience conducting digital literacy training or broadband access project or if they have completed at least one digital literacy training or broadband access project (pg. 3).”4 While this helps ensure that experienced members within the digital equity space are continuing this work, it has the potential to disregard smaller organizations that may be a good fit but lack the experience or confidence to participate in these programs. In GLI’s Town Link Report5, a key recommendation is that organizations that may not have existing experience in digital inclusion efforts but “have existing intake and referral services and can add digital navigator services to their portfolio” (pg. 6) should be specifically targeted for funding due to the fact that digital equity work would easily fit into their current infrastructures. Moreover, in order to further diversify partnerships within the program and prioritize organizations that were based in communities of color and low income neighborhoods, GLI utilized other criteria to determine an applicant's ability to conduct digital equity work. This included examining their methods of interacting with priority community members and the strength of these communication channels. By using these unique markers, organizations were able to demonstrate their existing strengths and commitments even if they were new to the digital space. In addition to implementing a more holistic selection criteria such as that in the Town Link program6, the state should also make it accessible for grantees to partner with each other and utilize each others’ resources. In the case of Town Link, digital literacy training organizations were able to partner with local organizations that conducted recruitment among their community to build out classes for digital literacy.
Providing digital literacy resources for grantees, improving application requirements, and implementing unique qualifying markers for applicants can and should be replicated on the state level so that a variety of committed organizations can have an equitable chance at doing their part in closing the digital divide. In a similar vein, the department should also set aside funding to recruit such groups -especially in communities of color- and assist them in the application process. Through targeted and strategic forms of help, participation in these very communities will inevitably rise and in doing so, the state of California would position itself as a state which creates opportunities for trusted organizations to succeed no matter where they are based, their size, or their initial scope of work.
To further address small organizational participation, the CDT should allocate additional funding for enrollment support. As found in the Town Link report, resources such as digital navigators prove to be invaluable as they work to connect and enroll residents in programs like the ACP. More importantly, much of this work is “provided in-person, [with] step-by-step enrollment assistance to interested residents (pg. 33).”7 On the other hand, it was reported during the Town Link initiative that while digital navigators proved to be essential, “partners indicated that guiding community members through enrollment processes often consumed significant time and resources (pg. 33).”8 Thus, there is a critical and demonstrated need for additional funding which would allow CBOs to offer in person services regardless of any time and resources required.
Furthermore, the state should create its own team of digital navigators who can be deployed throughout the state. In their digital equity plan, the state of Pennsylvania once again raises a strong point on this matter when they point out that “while volunteers at libraries,
non-profits, and other organizations have been instrumental in providing digital skills services, there is a huge need for paid digital equity professionals, including digital navigators (pg. 24).”9 By offering pay for these positions, California would take on a critically important role in providing a vital tool for organizations to rely on, especially if they currently lack the funds, resources, and infrastructure on their own to sustain this critical position. Thus, organizations can pivot their focus and resources in different ways to further contribute to the goal of closing the digital divide. Additionally, by creating its own department of digital navigators, the state stands not only to increase overall enrollment of the position but ensures longevity of a highly needed public resource.
The last way in which the CDT can incentivize more participation from community organizations can be through activities that begin before the official application period opens. Specifically, the department should publish a clear checklist of requirements that is quickly distributed to counties and then to organizations. After this, state employees should also conduct information sessions where the checklist can be used as a primary tool and during these sessions, organizations will have the opportunity to get real time help with their applications as well as clarity on the process and requirements for funding. As always, such sessions should be offered in person as well as online so as to ensure that community members have all opportunities to join.

III. Develop and promote digital inclusion tools and best practices

In the current version of the SDEP, it is stated that “the State will continue to work to improve and expand the myriad digital inclusion programs and services offered by State agencies and other statewide partners (pg. 115).”10 One way for California to explore ways to improve digital inclusion programs is by conducting workshops with the goal of meeting people where they are. In doing this, the work should not stop at conducting informational sessions in the usual library, church, or school but should also be in more intentional spaces. For example, if a high need area has multiple apartment spaces, the state can look into utilizing the common spaces in these living communities in order to garner more participation even if it is with smaller but more frequent meetings in various locations. As it pertains to these workshops, digital literacy requirements should be expanded to include an emphasis on digital safety, specifically how to keep vital information safe and how to know who to trust when giving up vulnerable personal information. Advertising for this should also not be limited to bulletins or website announcements and should also be channeled through social media or text campaigns. Again, in doing so, the state will be meeting people ‘where they are’ even in the virtual space.
Another important aspect of demonstrated need which requires improvement is access to technological tools such as computing devices. With the funding, the CDT needs to work to get devices into California households while keeping costs realistic. One opportunity is to partner with industries that have high technology turnover rates such as banks, government agencies, and universities. Another option is to partner with refurbishing companies to offer devices at a lower cost with warranty options that suit the needs of consumers.

IV. Promoting Low-Cost Offers and Resources Within the State

Currently, in an attempt to combat unaffordable prices for internet services, programs such as ACP and Lifeline exist for low-income communities. While this is a vital resource for California, it is still underused compared to the amount of need that is demonstrated within the state.11 For many, this is due to the fact that they simply do not have knowledge of the program or that they are eligible. As a measure to combat this, the state should use existing services to its advantage for outreach purposes. In the state equity plan for Pennsylvania, the state details their utilization of their PA 211 system which connects Pennsylvanians to resources and assistance on a statewide level.12 Taking this into account, California should use similar systems to notify residents of this program. For example, in Alameda county, the 21113 information portal and phone number is used to convey transit information, health and housing information, and reentry information. Using this portal would be an imperative opportunity to ‘meet people where they are’ and add digital resources to this already highly utilized product. Moreover, to build on this the department should also focus on adding digital resources sections to information based apps and web services for the counties that have this infrastructure in place, such as the FresGo app in Fresno county.14 In both instances, California should also add a feature to allow individuals to check their own eligibility (as is the case in Pennsylvania) as doing so would only prove to increase awareness and usage of the program and make it easier on the individuals in priority areas to sign up.
The last case in which the CDT can improve the outreach for low cost programs would be to emulate successful methods demonstrated by other agencies. A notable example would be the getcalfresh.org website where users are easily able to apply for food stamps “in 10 minutes.”15 Through the straightforward process and easy-to-use interface, many more Californians are able to access this vital resource quicker than ever before. In regards to improving the experience for ADP eligible customers, the department should require that in addition to allowing Californians the opportunity to find providers in their area, customers should also be able to compare them all in one trusted place.
Additionally, it would prove beneficial to offer enrollment help for eligible users through signup guides offered in many different languages and formats (such as video or PDF instructions with photos) that can be distributed by providers, digital navigators, community based organizations, and found on web pages relevant to the ACP and state digital equity programs.
Lastly, with the understanding that the ACP program is not a permanent resource, it is imperative that the CDT apply the outreach recommendations to other state programs so that eligible community members are prepared with other options in the event that ADP ceases to exist.

V. Conclusion:

We believe that this State Digital Equity Plan is a key initial step to closing the digital divide in California. With these considerations, the state has the opportunity to be more strategic and equitable about how funding is accessed, who has priority to access it, and how to improve programs that exist to close the divide. We look forward to seeing a final, more equitable State Digital Equity Plan .

Footnotes:
1. California Department of Technology. (2023, December 12). California Digital Equity Plan. pg. 114. Broadband for All.
https://broadbandforall.cdt.ca.gov/wp-content/uploads/sites/19/2023/12/Draft-SDEP_For-Public-Comment_12.11.23.pdf

2. Pennsylvania Department of Community and Economic Development. (2024, January 22). Connected and Empowered: A Digital Equity Plan for the Commonwealth of Pennsylvania. Pg. 105, https://dced.pa.gov/download/pbda-digital-equity-plan/?wpdmdl=122633&refresh=65b02dbbb6eee1706044859

3. California Public Utilities Commission. (n.d.) Broadband Adoption Account Requirements and Frequently Asked Questions. Pg. 3.
.https://www.cpuc.ca.gov/industries-and-topics/internet-and-phone/california-advanced-services-fund/casf-adoption- account

4. See Footnote 3

5. The Town Link program was an Oakland based partnership between the City of Oakland and over ten local CBOs to provide digital navigator services and digital literacy training. Partners included social service organizations that worked with immigrants, seniors, re-entry populations and were successful in integrating digital navigator services into their existing scopes of work with the proper funding, support, technical assistance and training.

See Le, V., & Phan, C. (2023, April). Achieving Digital Equity: The Oakland Town Link Program Playbook. pg. 6, The Greenlining Institute. https://greenlining.org/wp-content/uploads/2023/04/GLI_Town-Link-Report_FINAL.pdf

6. See Le, V., & Phan, C. (2023, April). Achieving Digital Equity: The Oakland Town Link Program Playbook. pg. 30, The Greenlining Institute. https://greenlining.org/wp-content/uploads/2023/04/GLI_Town-Link-Report_FINAL.pdf

7. Le, V., & Phan, C. (2023, April). Achieving Digital Equity: The Oakland Town Link Program Playbook. pg. 33, The Greenlining Institute. https://greenlining.org/wp-content/uploads/2023/04/GLI_Town-Link-Report_FINAL.pdf

8. See footnote 5

9. Pennsylvania Department of Community and Economic Development. (2024, January 22). Connected and Empowered: A Digital Equity Plan for the Commonwealth of Pennsylvania. Pg. 24, https://dced.pa.gov/download/pbda-digital-equity-plan/?wpdmdl=122633&refresh=65b02dbbb6eee1706044859

10. California Department of Technology. (2023, December 12). California Digital Equity Plan. pg. 115. Broadband for All.
https://broadbandforall.cdt.ca.gov/wp-content/uploads/sites/19/2023/12/Draft-SDEP_For-Public-Comment_12.11.23.pdf

11 According to the most current state updates, out of a total of roughly 13 million households within the state,5 million (or 45% of CA households) are eligible for ACP subsidies. Of this number, about 2 million households are enrolled (49% of eligible households are already enrolled).

CA.gov. (n.d.). Affordable connectivity program enrollment tracker. Broadband for All. https://broadbandforall.cdt.ca.gov/affordable-connectivity-program/acp-enrollment/

12. Pennsylvania Department of Community and Economic Development. (2024, January 22). Connected and Empowered: A Digital Equity Plan for the Commonwealth of Pennsylvania. Pg. 97, https://dced.pa.gov/download/pbda-digital-equity-plan/?wpdmdl=122633&refresh=65b02dbbb6eee1706044859

13. 2-1-1 Alameda County. (2023, September 21). https://211alamedacounty.org/

14. FresGO 311 – City of Fresno. (n.d.). City of Fresno. https://www.fresno.gov/3-1-1/

15. CalFresh. (n.d.). Apply for California Food Stamps Online | GetCalFresh.org. https://getcalfresh.org
4895January 25, 2024 at 6:28 pmPresident & CEOOrganizationUnited Ways of CaliforniaCA3. Current State of Broadband and Digital Inclusion
United Ways of California lauds the creation of this SDEP and recognizes the immense amount of time, effort and coordination it took to put this together. We are excited about its components and content and would like to make the following comments primarily related to Section 3 of the Plan-Current State of Broadband and Digital Equity, but also regarding Section 4-Collaboration and Stakeholder Engagement, and Section 5-Implementation Strategy and Key Activities:

-We hope that the state will continue to establish objective definitions of “quality” and “reliable” internet, and continue to hold ISPs accountable to these standards, as, as the plan mentions, overall broadband adoption numbers do not reflect the reality of the highly varying degrees of connectivity.

-We also hope that the ongoing work on the broadband mapping tool(s) will continue to evolve and become more publicly available to help stakeholders know if Californians are un/derconnected due to lack of infrastructure, or lack of funds. Californians need, and should expect, full visibility, accountability and transparency in this regard, because community leaders and public officials seeking to increase broadband adoption are flying blind. Statewide broadband maps and household surveys give a decent sense of the big picture, but they do not enable communities to track progress. Companies currently are not required to report statistics on the number of likely eligible households and the rate of subscription to affordable programs, either at the state or local level. California should require such reporting and set up a clearinghouse to bring together and analyze data across all providers, and make it available to support broadband outreach and enrollment.

-We also hope that the state will continue to foster a competitive, non-monopolistic network of ISPs in every corner of California so that clients are not forced into subpar, expensive plans due to lack of choice. Likewise, we hope that the state will take steps towards establishing a “recommended” price level for households to pay for broadband, similar to (but firmer than) the federal government’s recommendation that households pay a maximum of 2% of their disposable income for broadband.

-We are encouraged by the state’s focus to enroll households into the ACP and hope that the state will continue to do so, or implement an alternate program in case federal ACP funding is allowed to lapse.

-We are grateful for the state’s consistent communication with stakeholders throughout the entire Drafting process, and hope that there will be further consolidation and streamlining of broadband-related communications as more stakeholders are welcomed under the state broadband umbrella.

-We applaud the state’s effort to implement a Digital ID system and eligibility verifier for benefits, for all Californians, and would be happy to share our experience building and implementing our own Benefits Screener (formerly Benefits Kitchen) that has served tens of thousands of Californians already. We would be thrilled to share any lessons learned and help design, implement, and scale the state’s system.

-We hope for uniform eligibility for all low-cost broadband options, regardless of ISP: Carriers should either align and agree on all eligibility rules, or commit to reciprocity, where the carrier serving a household’s address will treat as eligible any household that meets another carrier’s affordable plan. [e.g., child enrolled in free and reduced meals program, or person with a disability]. This is not currently the case with all ISPs offering low-cost plans.

-We believe in inviting community partners inside: We should allow nonprofits, schools and local government to certify a household is eligible for a provider’s plan, and even order and track installation of an affordable plan (we can track UPS packages and pizza deliveries, with appropriate protections the same should be possible for broadband enrollment).
4894January 25, 2024 at 5:56 pmP.L.ResidentSan Francisco941241. Executive Summary
WIRED connection is superior to wireless in all respects, and wireless broadband—especially the basic services offered to low-income families—will NOT solve the digital divide.
4893January 25, 2024 at 5:55 pmA.L.ResidentSan Francisco941241. Executive Summary
Wireless will set the state back in terms of climate change management because wireless uses a huge amount of energy compared to WIRED broadband.
4892January 25, 2024 at 5:50 pmChief Operating OfficerOrganizationCalifornia Department of Social ServicesSacramentoCA8. Not Related to Above Sections
The California Department of Social Services (CDSS) collected feedback from various Program areas; including, but not limited to, some of our critical programs and services to low-income families with children, individuals such as older adults or people living with disabilities, and equity programs serving special target populations. Please see comments below for California Department of Technology consideration during the open comment period for the draft State Digital Equity Plan.

1. Executive Summary
Executive Summary Page. 5

Flagging for chart, even though someone may have an income above 150% of the poverty level this does not automatically mean they can pay for efficient internet. There should be consideration for additional ways to show need, especially due to the high costs of living in CA. (Page. 5)

Individual need may also vary. (People may also need hands on IT support to navigate successfully). (Page. 5)

Goal 3 is essential! By when? 5 years from now? (Page. 5. table)

Vision, Goals, and Objectives Page. 7

Digital Literacy and Inclusion (Page. 7)

The Digital Literacy and Inclusion quadrant should include the word “Equity” in its definition/description. The word “Equity” is missing from this vision, although implied it should be explicitly called out. (Page. 7)

Fonts are overlapping (table on Page. 8 Goal #3)

Current State of Broadband and Digital Equity Page. 9

Local level can include the child care safety- net programs. For example, in the Child Care and Development programs, Local Planning Council (LPCs) and Child Care Resource and Referrals (R&Rs) can also help to get the word out. It may be helpful to mention this so there is recognition that they can serve a part of the outreach as they have also been a part of the stakeholder engagement forums. (pg. 19)

Similar to counties and local entities, if there are opportunities to add more to the duties of program client local/community partners, this can be a more robust effort. However, that workforce may need to be supported by additional compensation or funding allocation. Should this report acknowledge how to compensate the workforce for additional duties related to broadband access and expansion? (Page. 21)

Covered populations? While this is the terminology that we have used during the digital equity planning effort, it has occurred to CDSS that it may be confusing or if taken literally than can be interpreted to mean a population that is already covered or already has access to services as opposed to the population we are trying to target for expansion. (Page. 10)

Access (Page. 11)

“Broadband for All vision” is stated but a brief mention or discussion of equity is warranted.

Access issue (when referring to “lack of awareness of low cost offers” Page. 11)

Same issue with Registry like systems - the less information requested the better. (When referring to “mistrust of government and corporations Page. 11)

Good point (referring to objective 1.4 on Page. 16)


Is there a way to also include the Early Learning and Care (ELC) workforce (when referring to disadvantage communities on Page. 19)? They are part of the child care advocacy community that participated on some of the stakeholder calls and are interested in this effort.

Essential for all data related development and platforms. (When referring to digital equity Page. 21

In agreement that “Those intended to be served must be involved in planning and delivering the services.” On Page. 21

Page. 24 of the report refers to the “establishment of data-matching agreements between the state and federal government for subsidy eligibility”. It may be worth highlighting that there are benefits confirmation services for CDSS programs, currently available for CalFresh and CalWORKs, and used for example to confirm eligibility for lifeline phones and reduced court fines, may be also be further explored for this purpose.

What’s Next Page. 25

In addition to “stakeholders,” also include the use of “community partners” which is more suited as more inclusive and less historically charged. In some programs for CDSS, this has come up on discussion that “stakeholders” invokes ownership and objectification and can feel disparaging by the people who are served or beneficiaries of the programs and it also gives no acknowledgement of the role of community based organizations that play a vital role in service delivery and support. This is particularly sensitive terminology for tribes too.

More define timelines are in this chart and connects with the Master Plan for Early Learning and Care (MELC) timeline for goals. This is just an observation, in case it’s helpful to connect with other master plan efforts for California. (Page. 26)

2. Introduction and Vision for Digital Equity
Digital Literacy and Inclusion (Page. 33)

There is mention of many state agencies and nonprofits that are engaged in providing digital literacy and inclusion programming, e.g., the California State Library’s Connected California program, EveryoneOn, #OaklandUndivided, etc. It is worth mentioning that several of CDSS’ programs serving newcomer communities (i.e., this Plan’s covered populations, including racial or ethnic and people with language barriers) currently provide digital literacy/inclusion support and training resources. These partners include local government and nonprofit or school district/educational entities.

Tribal Collaboration (Page. 36)

Explaining the barriers to digital equity that are unique to tribes and tribal lands. Deserves a deeper dive than two paragraphs that are dedicated in this report so readers can have a better understanding into how tribal collaboration will look. Also, not all tribal collaboration will be the same across tribal communities; this should be discussed, as well.

2.3 Alignment with Existing Statewide Initiatives - Page. 37

This work should be integrated into Department’s communication and alignment with the equity work, for example, at CDSS with what we are doing with Quality Counts California (QCC) in the child care and development space. Will there be opportunities or regular touch points for information exchange and continued alignment in the years ahead under this plan? (Page. 37)

Digital Equity Act (Page. 41)

How will this Plan ensure a wider pool of direct service partners and programs receive funding at scale, or are continuously funded, through the Digital Equity Capacity or Competitive Grants, to support access, affordability, and adoption, to individuals with disabilities or language barriers and members of racial or ethnic minority groups?

Local Digital Equity Plans (Page. 43)

It is beneficial to see the geographic spread across local governments that have established digital equity plans which informed the development of this Plan. Even though this listing represents only a sample of digital equity plans from across the
state, it is nevertheless concerning that digital equity plans were not invited or included from rural areas as well as nonprofit or philanthropic agencies. CDSS’ partners and communities of practice include a significant number of nonprofit actors, community-based organizations, and/or philanthropic partners who are doing good work on the digital literacy and inclusion front to mobilize and support economic advancement, civic engagement, and access to broadband services.

Covered Populations (Page. 44)

Re-emphasizing the critical need to include the voices and choices of all unserved or underserved covered populations, with particular focus on equitable methods to convene and engage partners, considering the overall share of California’s population at greater proportion, for individuals with a language barrier or those who are members of racial or ethnic minority group.

Strategies (Page. 53)

Strategies to ensure communicates impacted states that they will “consult and empower covered populations”. The Spectrum of Community Engagement (https://movementstrategy.org/resources/the-spectrum-of-community-engagement-to-ownership/) utilized by statewide equity leaders like the Capitol Collaborative on Race and Equity encourages us to move beyond consultation toward involvement, collaboration, and toward empowerment. Consultation would be to gather public comment, while involvement would include community members in workshops focused on decision making and design of program. The State Digital Equity Plan should consider how ongoing collaboration and design can continue to occur throughout the multi-year planning and implementation effort so this can truly embody equity work and become more than a one-time consultation in the first year of planning.

3. Current State of Broadband and Digital Inclusion
3.1 Introduction - Page. 56

Can any of this include how the history of systemic inequities affect Californians geographically? That is important context for equity work and would be helpful to incorporate into this report so readers truly understand what we are trying to solve for. (Page. 56)

3.2 Digital Equity Assets - Page. 59

How is the level of digital literacy (basic, intermediate, advanced) defined and measured?

It might be beneficial to consider targeted interventions for the different groups that have been identified as having lower digital literacy skills.

Top Barriers for Organizations (Page. 65)

Are there specific barriers that are unique to tribal communities that should be outlined here?

3.3 Overview of Digital Equity Needs and Barriers - Page. 66

It would be helpful to provide a brief introduction about what Local Digital Equity Coalitions are and why they are important. This will give individuals who are unfamiliar with the topic a better understanding.



What kind of updates does CDT plan to make to the DEEM tool on an annual basis? Will these updates be based on user feedback or changing digital equity needs?

3.4 Specific Barriers and Baseline for… - Page. 73

This data provides insight into the various challenges people face when it comes to using or accessing technology. The most common challenge, according to this survey, is the affordability of technology.

Individuals who are Members of a Racial or Ethnic Minority Group (Page. 91)

For Baselines that include only data for the general “Individuals who identify as part of an ethnic or racial minority group” would it be possible to provide more data to include focus on specific populations? Otherwise, the statements feel very broad and does not assist with strategizing for racial equity.

Women, and Those Who Identify as Female (Page. 99)

There are objectives concerning digital literacy and cybersecurity, are we potentially missing an intersection of domestic violence and cyber security? Women and those who identify as female face unique levels of harassment and violence online from strangers and partners. For example, could cyber security training be provided as part of DV services to protect victims of stalking? Please consider resources from the National Network to End Domestic Violence (https://nnedv.org/content/internet-computer-safety/) and their project Safety Net (https://www.techsafety.org/blog/2019/10/31/cyber-safety-for-survivors-of-domestic-violence).

4. Collaboration and Stakeholder Engagement
Collaboration and Stakeholder Engagement (Page. 108)

Express care with the use of the term “stakeholder” as mentioned previously in feedback. Consider replacing or at least including “community partners” or something like it to be more inclusive.

5. Implementation Strategy & Key Activities
5.1 Key Activities - Page. 112

#4 Are we trying to say, "underserved and uncovered populations?"

Tribal Collaboration (Page. 124)

What did those partnerships and consultations look like with tribal entities? What are next steps or how is the partnership going to progress moving forward in the implementation process?


5.5 Funding and Sustainability - Page. 124

Can the report provide more description on how partnership was done? Partnered and engaged for feedback? (Page. 124)

Are you able to name these tribes? (Page. 124)

8. Not Related to Above Sections
General point: if many Californians are using smart phones to access the internet, has the state also established mobile-first design as an approach for state websites, online applications, etc. to improve access while we increase availability of computer/tablet-based internet access. This was brought up during some of the engagement sessions, but it would be helpful to hear more about this or have some acknowledgement in this report.
4891January 25, 2024 at 5:46 pmO.G.ResidentLos Angeles900311. Executive Summary
I agree and support the priorities listed in the executive summary.
4890January 25, 2024 at 5:45 pmCity PlannerOrganizationCity of Bell Gardens Community Development Department Planning DivisionCity of Bell GardensCA1. Executive Summary
The implications of a statewide digital equity and inclusion plan can have various positive impacts on the community and for the city of Bell Gardens, CA including increased access to technology, enhanced educational and expanded job opportunities, community engagement and participation, healthcare access, economic development, social inclusion, and governmental efficiencies. Residents that may not have had access to digital resources before could now have equal opportunities to bridge the digital divide for education, employment, and communication. A plan could also serve as the blueprint for the city to further support broadband access, which is now a necessity and more of a utility, rather than a luxury. It would be appropriate to consider ways to increase local governmental jurisdictions as anchor institutions that help provide free and accessible broadband internet services and Bell Gardens is happy to partner in solutions.

4. Collaboration and Stakeholder Engagement
Before implementing any plan, it is important to consider the unique needs and characteristics of the Bell Gardens community. Conducting outreach to the city of Bell Gardens, considering the challenges of access to very-low, low-, and moderate-income households and participants that speak a primary language other than English, requires a strategic and inclusive approach. Bell Gardens recommends community partnerships through the jurisdictional relationships, multi-lingual communication, localized outreach events, door-to-door campaigns, mobile outreach events, inclusive surveys, and the deployment of community health workers and community-based organizations. The use of existing community networks and flexible timing will ensure an inclusive effort that results in maximum participation and artful ways to strategize a comprehensive plan for outreach and accessible broadband.
Digital inequality is not a technological problem and the pandemic in the U.S. has disproportionately impacted individuals and families living in poverty. Thus, making broadband affordable for low-income communities must be a priority. In May of 2021, Congress created Emergency Broadband Benefit, an FCC internet subsidy program which ended on December 31, 2021. March of 2022, Congress created the Affordable Connectivity Program (ACP), a new long-term, $14 billion program, to replace the Emergency Broadband Benefit Program. By establishing strong partnerships with Internet service providers, local jurisdictions can leverage their expertise, resources, and market presence to enhance the affordability and accessibility of connectivity in the city. This collaborative approach will not only improve the enrollment process but also allow for customized solutions, targeted outreach, and continuous improvement based on the feedback and needs of our community. The state should support convening with tools that facilitate regional councils or meetings to assess local need and solutions.

5. Implementation Strategy & Key Activities
The state of California can support entities that demonstrate a need for funding digital equity inclusion programs through various mechanisms and initiatives. Grant programs and competitive funding opportunities can encourage active participation in the broadband for all initiative and should have clear guidelines and assistance for smaller jurisdictions and those with few staff to ensure successful and winning scopes of work that merit funding. Needs assessment and prioritization guidelines can establish capacity building opportunities where they are needed most and indicate where technical assistance for staff would ensure equity across the regions of all income levels. There may also be opportunities for public-private partnerships and incentives such as tax credits or recognition for private sector engagement and flexible funding models that lead toward long-term sustainability. Bell Gardens is happy to help explore alternatives that would meet the state's monitoring and evaluation requirements to ensure both equality and equity in broadband service access and provision.

6. Conclusion
Implementation of this plan will go a long way toward necessary broadband infrastructure and access in the region. Where shortfalls occur, updates will be necessary, however, funding sources could also be allocated and better advertised toward local government to develop digital equity inclusion plans. Bell Gardens welcomes any opportunity to be of service to the local and regional community to ensure future progress beyond the scope of the plan.
4889January 25, 2024 at 5:42 pmSpokespersonOrganizationPlumas Wired!PortolaCA2. Introduction and Vision for Digital Equity
WIRED connection is superior to wireless in all respects, and wireless broadband—especially the basic services offered to low-income families—will NOT solve the digital divide.

Additional points:
• Wireless is unreliable and unable to meet the demands of present and future digital communications. Providing funding for rollout of wireless installations will take it away from much safer, reliable, energy-efficient WIRED internet.

• Wireless will set the state back in terms of climate change management because wireless uses a huge amount of energy compared to WIRED broadband.

• Wireless facilities increase fire risk and cyber security risk

• Wireless facilities impact the growing percentage of the population with disabilities related to radiofrequency radiation (RFR) exposure.

• Wired infrastructure offers greater capacity, predictable performance, lower maintenance costs, and a longer technological lifetime than wireless technologies. Fiber service is not degraded by line-of-sight issues and is not affected by capacity issues.
4888January 25, 2024 at 5:36 pmDirector of Community ImpactOrganization#OaklandUndividedLivermoreCA5. Implementation Strategy & Key Activities
Understanding that those most affected by the digital divide aren’t able to submit comments through the State Digital Equity Plan’s ONLINE public form due to lack of internet access or language barriers, #OaklandUndivided worked with Homies Empowerment, an independent, grassroots community-based organization out of East Oakland, and El Timpano, an organization that informs, engages, and amplifies the voices of Latino and Mayan immigrants of Oakland and the wider Bay Area, to solicit responses to a very simple question that could help inform the state’s approach to achieving digital equity: The government is trying to understand why many non-native English speakers don't have access to home internet. We would like to hear your opinion to share with legislators. Tell us, is it difficult for you to connect to the internet? and why?

The responses below represent Oakland residents whose voices and opinions are often unheard by decision-makers. Once again, we urge the State to prioritize meaningful community engagement with covered populations by working in collaboration with trusted community groups who will ensure that these voices are lifted and incorporated into future state plans.

El Timpano sent out this question through its SMS platform to its approximately 2600 Spanish and Mam-speaking Oakland subscribers through their SMS platform. These are some of the responses that we obtained in just the first two days. Those who responded were entered into a drawing to obtain one of 20 Target gift cards. Homies Empowerment collected responses from Oakland residents during one of their weekly community food distribution events. Working with trusted community organizations allowed us to obtain candid responses from community members.

All those who responded were either native Spanish or Mam speaking. Below are their responses with translation provided in parentheses in English.

“Es un poco dificil acceder al internet por los altos costos”
(It is a bit difficult to access the internet due to the high costs) - Maricela, 49, Oakland

“Si es dificil. Cuando el internet es muy bajo. Los niños aveses les cuesta conectarse. Es muy despacio”
(Yes, it's hard when the internet connection is poor. The kids have a hard time connecting. It's very slow) - Oakland resident

“Hola ! Yo tengo internet por parte del programa de las escuelas es económico pero muchas veces es un poco lento para que mis hijos agan su tarea en la computadora, pero pues el sueldo no alcanza para más”
(Hello! I have internet through the school program. It’s cheap, but sometimes too slow for my children to do their homework on the computer. With our salary, we can’t afford to get faster Internet)- Hilda, 44, Oakland

“Hola pues deberían de poner free internet x casa ciudad x q es bastante caro. Tenerlo en velocidad alta y solo así se puede conectar uno con papeleos tareas y otras cosas eso es lo q deberían hacer los legisladores tener internet free en cada ciudad I condado x q los legisladores gastan en otras cosas más q ni son productivas y asqueado en este caso todos los es planted se beneficiarían eso es mi opinión”
(Hello, I think that the Internet should be provided in every household in the city because it is expensive. This way people can connect with work, complete tasks, and do other things online. I believe that legislators should prioritize providing free internet to the citizens instead of spending money on unproductive things. This would benefit everyone and that is my opinion) - Pati, 59, Oakland

“Para mi es difícil conseguir internet o una computadora por que es muy caro”
(It is difficult for me to get internet or a computer because it is very expensive) - Blanca, 34, Oakland

“Hola buenas tardes , si sería muy vien para todos si para muchos Qe no tenemos internet y no podemos pagarlo nos ayudaría mucho gracias”
(Hello, good afternoon, it would be really helpful to obtain help paying for internet because many of us cannot afford it.) María, 56, Oakland

“Estoy de acuerdo con esa herramienta muy fundamental , soy Latina habla española y ayudaría mucho a como padre de familia poder desarrollar y desenvolverse a los niños en la lengua inglesa y en las escuelas hay muchas reuniones virtuales en las cuales muchas veces nos desentendemos por falta de internet y herramientas”
(I agree with this very fundamental tool, I am a Latina who speaks Spanish and it would help a lot as a parent to be able to help our children learn the English language and in schools there are many virtual meetings in which we often disengage due to lack of internet and tools) - Marina, 30, Oakland

“Porque no tenemos el dinero para costar el Internet. Y Si hay Internet gratis No lo sabemos o no sabemos a quien preguntar para aplicar a ello.”
(Because we don't have the money to pay for the Internet. And if there is free Internet, we don't know or we don't know who to ask to apply for it.)- Oakland resident

“Por qué no tengo el dinero para pagar un internet y el básico q dan en escuelas es de baja calidad”
(Because I don't have the money to pay for internet, and the one they give in schools is of low quality)- Oakland resident

“Yo donde vivo no tengo internet. Para hacer mis tareas tengo que ir ala casa de mi amiga Quería conectarme Internet. Me salía muy el costo 50$ eso es muy difícil para. Yo pienso que todas las personas de bajos ingresos debemos tener Internet a bajo costo. Muchas gracias”
(I don't have internet where I live, so I have to go to my friend's house to do my homework. I wanted to get internet access at my home, but the cost was too high for me - $50 is a lot of money, and it's really difficult for me to afford it. I believe that low-income individuals, should have access to affordable internet. Thank you.) - Paula, Oakland

“Es dificil por que las compañias no mantienen los precios cade mes aumentan. Por eso yo ya no pude estudiar ingles por yo estudiava por linia”
(It has become difficult for me to continue studying English online due to the fluctuating prices charged by the companies.) - Oakland resident

“Si tenemos servicio de internet pero muy seguido mi hija no puede conectarse para sus tareas en su laptop , no sé si sea que no es rápido o porqué, pero al decirle el problema a la compañía que tenemos dicen que tenemos que pagar más y si es caro ahora será mas costoso si pedimos otro servicio”
(We do have internet service, but my daughter often has trouble connecting to her laptop for homework. I'm not sure if the speed is the issue or something else. When I contacted our service provider, they suggested upgrading to a more expensive plan but if my internet plan is expensive now it’ll be even more expensive with another plan.) - Rosa, 55, Oakland

“Es por que tenemos a nuestros hijos como aprendices de ingles como su primer idioma es español en casa y uno tiene gastos vive cheque a cheque y en ocasiones los servicios de Internet son caros y no se puede contratar sabemos que hay unos programas de bajos ingresos pero en ocasiones no calificamos también la falta de tener una computadora para cada hijo es difícil son gastos y no los podemos solventar”
“We have our children learning English as their second language since their first language at home is Spanish. We live paycheck to paycheck, and sometimes, we can't afford internet services. Although there are low-income programs available, we don't always qualify for them. Furthermore, we can't afford to buy a computer for each child, which makes it difficult for them to access online resources. These expenses are beyond our means.” - Carlos, 50, San Leandro

“Porque lo que se gana es poco para pagar Internet en casa. Es mi caso. Y eso sube la Energía.”
(Because what you earn is not enough to pay for Internet at home, in my case, and that increases the energy cost.) - Rebecca, 39, Oakland

“Hola buenas tardes !! Nosotros tenemos internet de bajos recursos y pues si ha veces está muy bajo y para mi hija y mi nieta es muy difícil ha veces conertarce para haces sus tareas y proyectos q tienen q hacer pero es por que desgraciadamente el internet es una herramienta que todos necesitamos hoy en día y pues para tener un internet más alto pues muy caro y pues con las necesidades q por las q estamos viviendo tenemos q tener probidades más necesarias para sobrevivir gracias”
(Hello, good afternoon! We have low-income internet, which can be very slow at times. This makes it difficult for my daughter and granddaughter to complete their school tasks and projects. Unfortunately, we all rely on the internet as an essential tool these days. However, having a higher-speed internet plan is very expensive, and with the current needs we are facing, we have to prioritize our expenses to survive. Thank you.) - María, Oakland

“Hola buenas tardes, un gran porcentaje de la gente que viene de nuestros países no son de la ciudad y muchos no tienen acceso a Internet y si los papás no lo tuvieron es complicado para los hijos, y con la barrera del idioma an más, aún para mi todavía se me hace difícil y tengo que pedir ayuda a mis hijos”
(Good afternoon! A significant number of people who come from our countries didn’t live in the city and didn’t grow up with access to the Internet. If parents didn’t have access, it can be complicated for their children to know how to use it. Adding to this, the language barrier makes it even more challenging. As a result, I still find it difficult to use the Internet and have to ask my children for help.) - Oralia, 63, Oakland

“Hola es difícil cuando nosotros cómo padres no tenemos conocimiento del idioma y de cosas de computadora. Nuestros hijos si son grandes tal ves nos ayuden pero qué pasa cuando nuestros hijos son pequeños? No es fácil tener la información en nuestro idioma.”
(Hello, it can be challenging as a parent when we lack knowledge of a language or computer skills. Although older children may be able to assist us, it can be difficult when our children are still young. It's not always easy to find information in our native language.) - Teresa, Oakland

“Si es verdad es un poco difícil tener este servicio está muy caro yo cuando necesito hacer o usar este servicio voy a las bibliotecas públicas.”
(It can be difficult to afford this service as it is quite expensive. Personally, I utilize public libraries when I need to use it.) - Cresy, 44, Oakland

“Yo pienso que muchas personas que apenas están aprendiendo el inglés no tienen acceso al Internet por falta de información en su idioma. El descuento que yo mencione que yo uso para mi mensualidad, esa información la estube buscando en español para compartirla con una conocida que no habla el inglés y no pude encontrarlo. Entonces es un poco más difícil ”
(I think that many people who are just learning English do not have access to the Internet due to lack of information in their language. The discount that I mentioned that I use for my monthly payment, I was looking for that information in Spanish to share it with an acquaintance who does not speak English and I couldn't find it. So it's a little more difficult) - Oakland resident

“Aveces los niños no tienen computadoras en casa y aveces les cuesta mucho leer libros pero d leer día a día ya sea en computadora o en libros ayudará”
(Sometimes children don't have computers at home and sometimes it is very difficult for them to read books, but reading every day, whether on the computer or in books, will help.) - Herlinda, 31, Oakland

“Si por que es muy difícil pagar los servicios de internet”
(Yes, because it is very difficult to pay for internet services.) - Maria, 46, Oakland

“Pues aveces no tienen acceso al Internet porque esta caro para poder obtenerlo en casa y solo lo tienen cuando buscan en una librería”
(Well, sometimes they don't have access to the Internet because it is expensive to get it at home and they only have it when they search in a library.) - Maria, 62, Oakland

“Algunas de la personas latinas muchas veces no contamos con internet, ya que en muchas ocasiones este suele estar a un costo muy alto, pero sin embargo eso no quiere decir que para nosotros los latinos no sea de gran importancia el poder utilizar el internet, nuestros hijos necesitan el internet para realizar sus tareas, también muchas personas utilizan su internet para poder comunicarse con su doctor a través de un correo electrónico, o para comunicarnos con nuestros familiares en el exterior.”
(Latinos oftentimes don’t have internet because the cost tends to be too high, but that doesn’t mean that we Latinos don’t think it’s important to use the internet, our children need the internet to complete homework assignments, and many folks use the internet to communicate with their doctor by email, or to communicate with our family abroad.)- Oakland resident

“Por que muchos latinos no tenemos conocimiento del idioma inglés ni lo básico en tecnología”
(Because many Latinos do not have knowledge of the English language or the basics of technology.)- Oakland resident

“Hay muchas personas que son Immigrantes llegando a California y hay pocos recursos para que inmigrantes tengan ayuda a establecer un trabajo fijo de salario digno. Si no tienen internet en la casa puede ser por falta de suficientes ingresos. También por la barrera de idioma. A veces hasta no tener un seguro social puede ser barrera para acudir a recursos o servicios como el internet.”
(There are many people who are Immigrants coming to California and there are few resources for immigrants to help establish a steady, living-wage job. If they do not have internet at home it may be due to lack of sufficient income. Also because of the language barrier. Sometimes even not having social security can be a barrier to accessing resources or services such as the internet.)- Oakland resident

“Creo que la comunidad no a sido informado correctamente.”
(I think the community has not been informed correctly.)- Oakland resident
4886January 25, 2024 at 5:32 pmVP of Programs and StrategyOrganizationEveryoneOnLos AngelesCA5. Implementation Strategy & Key Activities
The digital divide persists, impacting millions of Californians. To bridge this gap, we urge the state to prioritize community-driven solutions, upskilling initiatives, and accessible tools to empower everyone to thrive in the digital world. We support the California Digital Equity Plan’s Key Activities #4, 5, 6, and 7 with the following recommendations:

Key Activity #4: Launch the California Connect Corps and digital equity grant programs to expand community-based digital inclusion programs.

A national study by EveryoneOn revealed that 38% of individuals seeking information about internet support programs like discounts trust local partners like libraries, schools, and community nonprofits the most. EveryoneOn supports the development of the California Connect Corps and encourages the program to:
- Prioritize grants for existing, successful digital navigator programs with deep local connections and track records serving marginalized communities
- Focus on developing innovative solutions that support, complement and build upon existing efforts.

Key Activity #5: Fund new and expand existing State-managed digital inclusion programs.

Connecting isn't enough. While broadband access is crucial, bridging the digital divide requires reaching the hardest-to-reach households and equipping them with the skills to thrive in today's digital world. To that end, EveryoneOn recommends the state prioritize partnerships with key sectors to meet underserved communities where they are:

Education:
- Work with schools to train teachers on integrating digital literacy into existing curriculum.
- Expand training programs for teachers to include not just technology integration but also effective pedagogy for online and blended learning environments.
- Encourage schools to offer digital literacy courses for parents and caregivers, empowering them to support their children's digital journeys.

Healthcare:
- Train healthcare professionals on utilizing telehealth effectively to reach patients in underserved areas.

Workforce Development:
- Lobby for the inclusion of digital skilling in all workforce development programs.
- Work with employers to develop targeted training programs and certifications aligned with specific digital skills needed in each sector.
- Create resources and support systems to help individuals in transition navigate the digital world and find suitable employment.

Finally, let's not forget accessibility. The state should prioritize ensuring all digital platforms and services used in these sectors are accessible to people with disabilities. This includes utilizing screen readers, alternative input methods, and clear language explanations to remove barriers and promote inclusivity.

Key Activity #6: Develop and promote digital inclusion tools and best practices.

EveryoneOn applauds the development of the new Learning Management System (LMS) as a crucial step towards digital inclusion. However, we want to emphasize the importance of sustainability and equity to ensure its long-term impact. Therefore, we recommend the following:

- Sustained Funding: Creating a dedicated and ongoing funding stream is vital for the LMS's maintenance and updates. This ensures the curriculum stays relevant and meets the evolving needs of learners. We urge the state to factor in long-term funding requirements for the LMS within its digital equity initiatives.

- Targeted Resources for High-Need Populations: Specific skill gaps exist within high-need populations like seniors and individuals with disabilities. We encourage the state to intentionally prioritize and develop targeted resources within the LMS that cater to these unique needs. This could include accessible interfaces, culturally relevant content, and tailored learning pathways.

- Robust Evaluation and Feedback: Measuring the LMS's efficacy is crucial for continuous improvement. We recommend developing standardized surveys and other evaluation tools to gather feedback from users of diverse backgrounds. This data can inform curriculum updates and resource allocation, and ensure the LMS effectively serves all communities.


Key Activity #7: Promote low-cost offers and the Affordable Connectivity Program, and advocate for a sustainable successor program.

EveryoneOn's 2022 National Study on Broadband Connectivity During the Pandemic concluded that 62% of of low- and lower-income households would require significant cost relief (relative to market price) to have broadband service at home. This lack of access hinders educational opportunities, job prospects, and healthcare access. For that reason, EveryoneOn recommends that the state take immediate action by:

- Advocating for permanent and expanded internet affordability programs like the Affordable Connectivity Program (ACP).
- Supporting the development of state-level affordability programs tailored to California's specific needs and demographics.
- Advocating for the improvement of existing and future internet affordability programs by:
* Streamline application processes: Reduce complexity to make program enrollment easier and faster for eligible households.
* Funding remote application assistance: Empower community organizations and digital navigators to assist applicants remotely, particularly those in rural or underserved areas.
- Implementing policies that incentivize ISPs to offer tiered plans with basic tiers starting at $10 or less per month that guarantee a minimum of 100 Mbps download and 20 Mbps upload speeds. This sets a baseline for functionality while remaining affordable for low-income households.

2. Introduction and Vision for Digital Equity
Section 2.5 Objectives and Strategies

Covered Populations

While California's digital equity plan strides towards bridging the digital divide, it cannot be fully realized without prioritizing the unique needs of women, particularly women of color. According to recent findings from a qualitative study EveryoneOn conducted, supported by the Benton Institute for Broadband and Society, “the national [digital inclusion] research narrative lacks representation, notably of women and particularly those from diverse racial and ethnic groups such as African American/Black and Latinas.” These communities face a complex and intersectional set of barriers, from gender-based digital literacy gaps to limited access to technology and discriminatory online experiences. Excluding them as a "covered population" hinders our progress and perpetuates a digital underclass. Therefore, EveryoneOn urges the state to proactively address these challenges by explicitly recognizing and supporting women of color in its digital equity initiatives. Dedicated funding, targeted programs, and partnerships with community organizations focused on empowering women can dismantle these barriers and unlock their full potential in the digital landscape. It's time to ensure California's digital future is not only inclusive but actively champions the advancement of women of color, laying the foundation for a more equitable and prosperous future for all.
4885January 25, 2024 at 5:18 pmChief Information OfficerOrganizationCalifornia Department of Social ServicesSacramentoCA1. Executive Summary
Flagging for chart, even though someone may have an income above 150% of the poverty level this does not automatically mean they can pay for efficient internet. There should be consideration for additional ways to show need, especially due to the high costs of living in CA. (Page. 5)

Individual need may also vary. (People may also need hands on IT support to navigate successfully). (Page. 5)

Goal 3 is essential! By when? 5 years from now? (Page. 5. table)

2. Introduction and Vision for Digital Equity
Digital Literacy and Inclusion (Page. 7)

The Digital Literacy and Inclusion quadrant should include the word “Equity” in its definition/description. The word “Equity” is missing from this vision, although implied it should be explicitly called out. (Page. 7)

Fonts are overlapping (table on Page. 8 Goal #3)

Current State of Broadband and Digital Equity Page. 9

Local level can include the child care safety- net programs. For example, in the Child Care and Development programs, Local Planning Council (LPCs) and Child Care Resource and Referrals (R&Rs) can also help to get the word out. It may be helpful to mention this so there is recognition that they can serve a part of the outreach as they have also been a part of the stakeholder engagement forums. (pg. 19)

Similar to counties and local entities, if there are opportunities to add more to the duties of program client local/community partners, this can be a more robust effort. However, that workforce may need to be supported by additional compensation or funding allocation. Should this report acknowledge how to compensate the workforce for additional duties related to broadband access and expansion? (Page. 21)

Covered populations? While this is the terminology that we have used during the digital equity planning effort, it has occurred to CDSS that it may be confusing or if taken literally than can be interpreted to mean a population that is already covered or already has access to services as opposed to the population we are trying to target for expansion. (Page. 10)

3. Current State of Broadband and Digital Inclusion
Access (Page. 11)

“Broadband for All vision” is stated but a brief mention or discussion of equity is warranted.

Access issue (when referring to “lack of awareness of low cost offers” Page. 11)

Same issue with Registry like systems - the less information requested the better. (When referring to “mistrust of government and corporations Page. 11)

Good point (referring to objective 1.4 on Page. 16)


Is there a way to also include the Early Learning and Care (ELC) workforce (when referring to disadvantage communities on Page. 19)? They are part of the child care advocacy community that participated on some of the stakeholder calls and are interested in this effort.

Essential for all data related development and platforms. (When referring to digital equity Page. 21

In agreement that “Those intended to be served must be involved in planning and delivering the services.” On Page. 21

Page. 24 of the report refers to the “establishment of data-matching agreements between the state and federal government for subsidy eligibility”. It may be worth highlighting that there are benefits confirmation services for CDSS programs, currently available for CalFresh and CalWORKs, and used for example to confirm eligibility for lifeline phones and reduced court fines, may be also be further explored for this purpose.

4. Collaboration and Stakeholder Engagement
What’s Next Page. 25

In addition to “stakeholders,” also include the use of “community partners” which is more suited as more inclusive and less historically charged. In some programs for CDSS, this has come up on discussion that “stakeholders” invokes ownership and objectification and can feel disparaging by the people who are served or beneficiaries of the programs and it also gives no acknowledgement of the role of community based organizations that play a vital role in service delivery and support. This is particularly sensitive terminology for tribes too.

More define timelines are in this chart and connects with the Master Plan for Early Learning and Care (MELC) timeline for goals. This is just an observation, in case it’s helpful to connect with other master plan efforts for California. (Page. 26)

Digital Literacy and Inclusion (Page. 33)

There is mention of many state agencies and nonprofits that are engaged in providing digital literacy and inclusion programming, e.g., the California State Library’s Connected California program, EveryoneOn, #OaklandUndivided, etc. It is worth mentioning that several of CDSS’ programs serving newcomer communities (i.e., this Plan’s covered populations, including racial or ethnic and people with language barriers) currently provide digital literacy/inclusion support and training resources. These partners include local government and nonprofit or school district/educational entities.

Tribal Collaboration (Page. 36)

Explaining the barriers to digital equity that are unique to tribes and tribal lands. Deserves a deeper dive than two paragraphs that are dedicated in this report so readers can have a better understanding into how tribal collaboration will look. Also, not all tribal collaboration will be the same across tribal communities; this should be discussed, as well.

5. Implementation Strategy & Key Activities
2.3 Alignment with Existing Statewide Initiatives - Page. 37

This work should be integrated into Department’s communication and alignment with the equity work, for example, at CDSS with what we are doing with Quality Counts California (QCC) in the child care and development space. Will there be opportunities or regular touch points for information exchange and continued alignment in the years ahead under this plan? (Page. 37)

Digital Equity Act (Page. 41)

How will this Plan ensure a wider pool of direct service partners and programs receive funding at scale, or are continuously funded, through the Digital Equity Capacity or Competitive Grants, to support access, affordability, and adoption, to individuals with disabilities or language barriers and members of racial or ethnic minority groups?

Local Digital Equity Plans (Page. 43)

It is beneficial to see the geographic spread across local governments that have established digital equity plans which informed the development of this Plan. Even though this listing represents only a sample of digital equity plans from across the
state, it is nevertheless concerning that digital equity plans were not invited or included from rural areas as well as nonprofit or philanthropic agencies. CDSS’ partners and communities of practice include a significant number of nonprofit actors, community-based organizations, and/or philanthropic partners who are doing good work on the digital literacy and inclusion front to mobilize and support economic advancement, civic engagement, and access to broadband services.

Covered Populations (Page. 44)

Re-emphasizing the critical need to include the voices and choices of all unserved or underserved covered populations, with particular focus on equitable methods to convene and engage partners, considering the overall share of California’s population at greater proportion, for individuals with a language barrier or those who are members of racial or ethnic minority group.

Strategies (Page. 53)

Strategies to ensure communicates impacted states that they will “consult and empower covered populations”. The Spectrum of Community Engagement utilized by statewide equity leaders like the Capitol Collaborative on Race and Equity encourages us to move beyond consultation toward involvement, collaboration, and toward empowerment. Consultation would be to gather public comment, while involvement would include community members in workshops focused on decision making and design of program. The State Digital Equity Plan should consider how ongoing collaboration and design can continue to occur throughout the multi-year planning and implementation effort so this can truly embody equity work and become more than a one-time consultation in the first year of planning.

3.1 Introduction - Page. 56

Can any of this include how the history of systemic inequities affect Californians geographically? That is important context for equity work and would be helpful to incorporate into this report so readers truly understand what we are trying to solve for. (Page. 56)

3.2 Digital Equity Assets - Page. 59

How is the level of digital literacy (basic, intermediate, advanced) defined and measured?

It might be beneficial to consider targeted interventions for the different groups that have been identified as having lower digital literacy skills.

6. Conclusion
General point: if many Californians are using smart phones to access the internet, has the state also established mobile-first design as an approach for state websites, online applications, etc. to improve access while we increase availability of computer/tablet-based internet access. This was brought up during some of the engagement sessions, but it would be helpful to hear more about this or have some acknowledgement in this report.

8. Not Related to Above Sections
Top Barriers for Organizations (Page. 65)

Are there specific barriers that are unique to tribal communities that should be outlined here?

3.3 Overview of Digital Equity Needs and Barriers - Page. 66

It would be helpful to provide a brief introduction about what Local Digital Equity Coalitions are and why they are important. This will give individuals who are unfamiliar with the topic a better understanding.



What kind of updates does CDT plan to make to the DEEM tool on an annual basis? Will these updates be based on user feedback or changing digital equity needs?

3.4 Specific Barriers and Baseline for… - Page. 73

This data provides insight into the various challenges people face when it comes to using or accessing technology. The most common challenge, according to this survey, is the affordability of technology.

Individuals who are Members of a Racial or Ethnic Minority Group (Page. 91)

For Baselines that include only data for the general “Individuals who identify as part of an ethnic or racial minority group” would it be possible to provide more data to include focus on specific populations? Otherwise, the statements feel very broad and does not assist with strategizing for racial equity.

Women, and Those Who Identify as Female (Page. 99)

There are objectives concerning digital literacy and cybersecurity, are we potentially missing an intersection of domestic violence and cyber security? Women and those who identify as female face unique levels of harassment and violence online from strangers and partners. For example, could cyber security training be provided as part of DV services to protect victims of stalking? Please consider resources from the National Network to End Domestic Violence and their project Safety Net.

Collaboration and Stakeholder Engagement (Page. 108)

Express care with the use of the term “stakeholder” as mentioned previously in feedback. Consider replacing or at least including “community partners” or something like it to be more inclusive.

5.1 Key Activities - Page. 112

#4 Are we trying to say, "underserved and uncovered populations?"

Tribal Collaboration (Page. 124)

What did those partnerships and consultations look like with tribal entities? What are next steps or how is the partnership going to progress moving forward in the implementation process?



5.5 Funding and Sustainability - Page. 124

Can the report provide more description on how partnership was done? Partnered and engaged for feedback? (Page. 124)

Are you able to name these tribes? (Page. 124)
4884January 25, 2024 at 5:16 pmA.B.ResidentLos Angeles900121. Executive Summary
I just was notified by my Internet service provider, Starry Internet, that as of May 1 my Internet will go up to $65 a month. It’s not their fault it’s the fault of the Congress of the United States inability to get the discount reinstated as per President Biden‘s wishes.
4883January 25, 2024 at 5:13 pmExecutive Co-DirectorOrganizationHealing and Justice CenterEl MonteCA8. Not Related to Above Sections
Healing and Justice Center
Public Comment Submission
California Digital Equity Plan

We at the Healing and Justice Center commend the State of California for its efforts in drafting the California Digital Equity Plan. As an organization dedicated to ensuring equitable access to critical resources, we submit the following comments and recommendations for consideration:

Broadband Funding and Market Competition
The allocation of BEAD funding should be focused on supporting Goals 1 and 2 of the plan. We believe that achieving objective 1.4, which aims to increase the number of Californians with access to at least three internet service providers, is essential. This would not only encourage healthy market competition but also address issues related to affordability and service quality. We advocate for the introduction of public options in the ISP market to prioritize public interest over profit motives. A wholesale model could effectively cover 95% of Los Angeles County.

Workforce Development in Broadband Sector
We propose the development of collaborative workforce programs in partnership with the CDT and CPUC. These programs should aim to connect individuals receiving digital skills training with opportunities in the broadband workforce, especially in underserved communities. Emphasis on hands-on training and resources is vital to support the workforce effectively.

We urge you to strengthen the language used to cite which existing anchor-institutions and community-based organizations (health and otherwise) are providing such digital inclusion services already, or at least how those health-centered partners will be identified and included in the program— i.e., health care anchor institutions, community health clinics, health-based nonprofit organizations etc.

In addition, there needs to be more in-depth details, specificity, guidelines, and explanation on the sustainability of such a grant program.

Infrastructure Deployment and Digital Equity
It is imperative that broadband infrastructure deployment prioritizes digitally redlined communities. This involves identifying barriers to progress and establishing robust accountability measures. Flexibility in the allocation of funds is also essential to cater to the unique needs of rural and low-income urban areas.

The plan lacks clear strategies for certain objectives, particularly objective 1.4. We recommend state investment in locally-driven, public open access models for middle and last mile connectivity. This approach would ensure broader competition and equitable broadband access across communities.


Data Accuracy and Mapping for Equitable Broadband Deployment
The current mapping and data collection methodologies need a fundamental transformation, not just to be “evolved”. Accurate data regarding broadband coverage, adoption rates, pricing, service offerings, speed tests, and reliability are crucial.

We suggest incorporating tools like Microsoft’s Broadband Interactive Map or tools like the Socioeconomic Vulnerability Index to inform broadband and digital equity data and to improve accuracy and inclusiveness in data collection and mapping.

Municipalities, public entities, and community organizations should get compensated for providing a wide range of data to the CPUC that gives a more holistic picture of the issues driving broadband gaps, so that the state can be more surgical and precise with solutions enabled by historic levels of public funding.

Continued reliance on inaccurate or biased maps risks perpetuating the racist driven digital redlining, and historical disinvestments in oppressed communities. As has been proven by multiple reports, digital discrimination exists and any tools used to correct this must be inclusive and accurate.

We emphasize the need for accurate and comprehensive broadband maps, allowing for public input. The CDT should ensure transparency in how data is collected, used, and how it influences funding decisions and project opportunities.

Affordability and Accessibility of Broadband Services
While the focus on affordability is commendable, there's a need for a sustainable program ensuring affordable services beyond the current timeframe. This involves engagement with federal representatives, partnerships with industry stakeholders, public awareness campaigns, and media engagement. Utilizing data to showcase affordable connectivity benefits and the importance of public awareness campaigns and media engagement is crucial.

Additionally, any subsidies for affordability must have in place measures that will not allow ISPs to profit from public funds. Any such behaviors and actions should be thoroughly scrutinized and penalized to discourage such predatory practices.

Plan Evaluation and Updates:
Regular progress reports, including measurable objectives and key performance indicators, are vital. A comprehensive evaluation of the State Digital Equity Plan should be publicly reported every two years to track progress and ensure transparency.

These recommendations address the need for equitable access to high-speed, affordable internet services, emphasizing the importance of addressing digital redlining and ensuring digital equity. They align with our organization's goal of ensuring every individual's access to quality internet service and highlight the significance of community involvement, data accuracy, and a competitive broadband market.


Goals and Objectives (Section 3, Pages 18-20):

Concerns: The goals might be broad and not sufficiently quantifiable. There's a need for more specific, measurable objectives to track progress effectively. If the language is too general or lacks precision, it might not convey the urgency or the specific focus areas effectively.

Target Populations (Section 4, Pages 21-27):

Concerns: The plan should ensure comprehensive coverage of all marginalized groups and offer tailored solutions for each. There's a risk of overlooking unique barriers faced by different sub-groups within these populations. Terms defining the target groups need to be clear and inclusive, avoiding any ambiguity.

Strategies and Actions (Section 5, Pages 28-37):

Concerns: Strategies lack detailed implementation plans or clear timelines. The actions listed need to be practical and achievable within the plan’s timeframe. The language should be action-oriented and specific, avoiding vague or open-ended statements that do not lead to concrete outcomes.

Implementation and Oversight (Section 6, Pages 38-40):

Concerns: There might be a lack of detailed oversight mechanisms to ensure accountability and effective implementation. Clear indicators of success and periodic review processes are essential. Ensure the language around implementation is robust and demonstrates a commitment to regular monitoring and evaluation.

Funding and Resources (Section 7, Pages 41-43):

Concerns: The plan needs to detail specific funding sources and ensure they are adequate for the proposed actions. There's a risk of underfunding or misallocation of resources. Financial aspects should be outlined with clarity, including the allocation process, to avoid any misinterpretation.

Challenges and Barriers (Section 8, Pages 44-46):

Concerns: The document should include practical solutions to the identified challenges. It’s essential to address how these barriers will be overcome effectively. The language should realistically portray challenges while also illustrating proactive approaches to tackle them.

Appendices (Pages 147-196):

Concerns: Appendices must provide comprehensive supporting data and evidence. There's a need for ensuring that all supplementary materials are up-to-date and relevant. The appendices should be easily understandable and well-organized to serve as a useful reference for all stakeholders.
4882January 25, 2024 at 5:11 pmDirector of Older Adult ServicesOrganizationSan Francisco Dept of Public Health Behavioral Health ServicesSan FranciscoCA3. Current State of Broadband and Digital Inclusion
At SFDPH Behavioral Health Services, we serve the most vulnerable older adults with behavioral health challenges. Many live in support service housing, board and care, and some in their own homes. There is a lack of in-language digital skills training and access for these clients as many of them expressed interest and desire to learn how to use the internet so they can check their medical appts, refill medications, and chat with their friends and families.
Clients who live in some residential programs have access to Broadband and was given an ipad while also provided with instructions on its usage by the staff. We see a significant decrease in client's agitation, and they are able to be more independent and interactive with their peers and community.
Please consider funding for programs to be able to provide broadband to these underserved population so that older adult clients can benefit from the digital technology that everyone else is able to enjoy. Thank you
4881January 25, 2024 at 5:02 pmD.A.ResidentSAN DIEGO921202. Introduction and Vision for Digital Equity
WIRED connection is superior to wireless in all respects, and wireless broadband—especially the basic services offered to low-income families—will NOT solve the digital divide.

Wireless is unreliable and unable to meet the demands of present and future digital communications. Providing funding for rollout of wireless installations will take it away from much safer, reliable, energy-efficient WIRED internet.

Wireless will set the state back in terms of climate change management because wireless uses a huge amount of energy compared to WIRED broadband.

Wireless facilities increase fire risk and cyber security risk

Wireless facilities impact the growing percentage of the population with disabilities related to radiofrequency radiation (RFR) exposure.

Wired infrastructure offers greater capacity, predictable performance, lower maintenance costs, and a longer technological lifetime than wireless technologies. Fiber service is not degraded by line-of-sight issues and is not affected by capacity issues.
4880January 25, 2024 at 5:00 pmExecutive DirectorOrganizationLoaves, Fishes & ComputersSalinasCA1. Executive Summary
Loaves, Fishes & Computers (LFC) appreciates the opportunity to comment on the California Digital Equity Plan. LFC serves the Monterey, San Benito & Santa Cruz Counties, focusing on underserved individuals and disinvested communities.

A majority of our disinvested community members in Monterey County live in highly rural and unicorporated areas of Monterey County. Nearly 98% (3,696 square miles) of Monterey County’s total land area (3,771 square miles) is unincorporated and sparsely populated. The communities are described as North Monterey County, the city of Salinas & the Salinas Valley, the Monterey Peninsula, & South Monterey County. Many persons living in these rural & remote areas have limited or no broadband access.

Nearly 60.8% (266,768) of our 437,325 population (2022) identify as Hispanic/Latinx. Most of LFC's participants are low-income agricultural & hospitality workers, out-of-school youth, immigrant adults, unemployed adults, and seniors. Many of the participants have limited English proficiency; Spanish is their primary language; 26% (118,078) of our population have not completed high school education; 12.4% (54,229) live in poverty. Specific communities within these county regions have higher levels of low educational attainment and higher levels of poverty.

The California Digital Equity Plan comes at a time when more and more need for affordable access to quality devices (beyond smartphones), affordable and reliable internet connectivity, and foundational digital skills are needed to navigate our society. LFC focuses on serving our community with the tools and resources to have digital access, including refurbished computers, repair services, tech support, digital literacy classes, and workforce development opportunities. Having access to training and support to enable digital inclusion is a high priority. LFC appreciates that the Digital Equity Plan includes this as a goal and asks that the State of California prioritize these objectives, including cybersecurity awareness and increasing access to digital literacy support services. We ask that the State of California continue to work closely with local nonprofits and grassroots organizations to provide these necessary resources, identify current efforts, and provide support to increase and enhance these services.


LFC is dedicated to closing the digital equity gap by providing services that support digital equity and thereby a person’s ability to achieve economic self-reliance. We believe that to achieve an inclusive economy, digital equity must be addressed as a priority issue. Proper connectivity, access to quality devices, and digital skills are all critical services for inclusive economic development.
4879January 25, 2024 at 4:56 pmDirector, Community DevelopmentOrganizationSourcewiseSanta ClaraCA3. Current State of Broadband and Digital Inclusion
Since 1973, Sourcewise, a nonprofit community-based organization, has played a pivotal role in providing high quality supportive services, collaboration, and leadership as the Area Agency on Aging (AAA) to Santa Clara County. Our mission is to provide adults and their caregivers the tools and services they need to effectively navigate their health and life options. Through a comprehensive network of resources, Sourcewise strives to educate, prepare, and support and advocate for all adults, their families, and their caregivers in Santa Clara County.

Our programs target and serve the aging population (60 and older) with the greatest economic and social needs, especially those who are from low-income, racially and ethnically diverse vulnerable and underserved households. In fiscal year 2023, the Sourcewise team of 90 diverse staff, directly served 100,901 older adults, persons with disabilities, their caregivers and their families in Santa Clara County. We offer 17 direct programs and services, focused on seven areas of need: Nutrition, Caregivers, Health, Medica and Evidence Based, Supportive Services, Workforce Development, Advocacy, and Isolation & Digital Inclusion.
Since 2021, Sourcewise has been supporting older adults through several digital inclusion projects including: 1) the Google Home Smart Speaker pilot project, 2) partnering with the California Department of Aging to execute the Connections, Heath, Aging and Technology (CHAT) iPad program and 3) we are currently providing services through our Digital Connections iPad program.

The SDEP Draft (p. 76) lists the following three barriers to digital equity for aging individuals (60+). We are providing input and recommendations to update the following three barriers:
1. Lack of perceived need
2. Inadequate devices/technology
3. Lack of digital skills training

From our experience working with older adults there is a great interest and need for digital supportive services. We believe the term "Lack of perceived need," is confusing and suggests older adults are not interested in adopting broadband, devices or digital skills training.

Instead, we believe that older adults are very interested about becoming digitally engaged, but they want to be able to receive services that are flexible to their specific needs and are accessible whether it be virtual in the comfort of their own home, in-person, or a combination and in their specific language.
In place of "Lack of perceived need," we believe that a more significant barrier to digital equity is the "lack of in-language digital skills training and access.” Santa Clara County is a highly diverse county with over 100 languages spoken. We have a small team, which consists for two Digital Inclusion Coordinators, who are bilingual Spanish and Mandarin respectively, but we know there are many other languages that are needed such as Vietnamese, Korean, Tagalog, etc. We are only currently able to serve the additional languages on a limited virtual basis. We believe with sustainable funding, we could hire a permanent Vietnamese speaking staff member to provide in-person training to a population, which has express great interest, but has dropped off due to lack of appropriate bilingual support staff. We have used translation services, but in our experience translations services creates inefficiencies in services, because it increases the amount of time to answer and respond to a client’s question.

For both individuals with disabilities and older adults, affordability of broadband connection and devices is a significant compounding factor that prevents these covered populations from having access. Across the State, 26.2% of people with disabilities live in poverty, twice the rate of the population without a disability. Even with the ACP benefit, internet access and devices are out of reach for those with fixed incomes. There is a sizable group of older adults and individuals with disabilities that do not qualify for the ACP program but who still struggle financially due to the cost of living in San Francisco and throughout California.

We agree (SDEP, p. 83) that people with disabilities would benefit from greater access to assistive and adaptive technologies. We would like to note, however, that this issue is not just about affordability, but also about availability. There is a significant supply side challenge in Santa Clara County. The availability of assistive technologies combined with support staff is limited to just a few organizations who are unable to adequately meet the need or demand, and who lack staffing to be able expand device lending libraries. Second, there is a lack of awareness among community members about the range of assistive technologies that exist and information about how different devices and software can improve their quality of life. There is also a lack of staff awareness and training around the use of assistive and adaptive technologies to better meet client needs.
4878January 25, 2024 at 4:52 pmK.W.ResidentForestville954362. Introduction and Vision for Digital Equity
I am an older person that cannot tolerate the frequencies of wireless. I depend upon a landline and wired internet access through that line. If you get rid of landlines, I will have NO PHONE OR INTERNET. This is completely unacceptable.
There are many other reasons to support wired connections: stability and safety in emergency conditions, dependability of the connection, much less energy needed to run, and greater capacity of the connection.
WE NEED WIRED connections for all these reasons and more.
Please don't abandon people such as myself. Wired internet and landline are my essential connections to family far from me, and the rest of the world.
4877January 25, 2024 at 4:52 pmC.H.ResidentSanta Barbara931112. Introduction and Vision for Digital Equity
WIRED connection is superior to wireless in all respects, and wireless broadband—especially the basic services offered to low-income families—will NOT solve the digital divide.

• Wireless is unreliable and unable to meet the demands of present and future digital communications. Providing funding for rollout of wireless installations will take it away from much safer, reliable, energy-efficient WIRED internet.

• Wireless will set the state back in terms of climate change management because wireless uses a huge amount of energy compared to WIRED broadband.

• Wireless facilities increase fire risk and cyber security risk

• Wireless facilities impact the growing percentage of the population with disabilities related to radio frequency radiation (RFR) exposure.

• Wired infrastructure offers greater capacity, predictable performance, lower maintenance costs, and a longer technological lifetime than wireless technologies. Fiber service is not degraded by line-of-sight issues and is not affected by capacity issues.

WOULD YOU WANT A CELL ANTENNA NEAR YOUR BEDROOM?
4876January 25, 2024 at 4:46 pmJ.R.Resident959468. Not Related to Above Sections
I appreciate the goals for the state to help all residents gain internet service. It would be very nice if this would include special assistive devices for those of us who are deaf/hard of hearing, blind and may have physical limitations that hinder use of a computer. I have been actively using computers my entire life. At the age of 72, I am losing my eyesight and cannot read the articles well. Content varies from source to source so setting a size for text is unhelpful. I am also nearly deaf and when I am lucky enough to have hearing aids that link to my computer, when my hearing aids malfunction, I lose my ability to hear. Finally, if we have a loss of mobility in arms or hands, it is nearly impossible to manage a computer. Please consider making these disabilities a little less “painful” by helping us overcome the loss of internet access due to disabilities. Thank you!
4875January 25, 2024 at 4:43 pmR.W.ResidentSacramento958144. Collaboration and Stakeholder Engagement
Dear California Department of Technology,

We, the California News Publishers Association, California Black Media, Ethnic Media Services, represent diverse newsrooms across the state of California. CNPA has been serving California since 1888 and represents over 450 publications across California, including print, digital, for-profits and nonprofits. California Black Media partners with over 30 independent newsrooms throughout California. Additionally, Ethnic Media services works with close to 300 publications through out California. We have worked with trusted media outlets for decades and partner regularly on projects to ensure our members stay informed and provide services to help them continue to improve their trusted work in their respective communities. We wish to be at the table and help get the important information necessary out to the public through our trusted publications.

We applaud and fully support California’s goals of full digital equity and have supported efforts to increase access and increase digital literacy throughout the state. The lack of this equity is why we have fought so hard to preserve public notices, which are required to be shared with communities through newspapers of general circulation. Many members of our associations are also newspapers of general circulation, which have been adjudicated by a court of law to reach a substantial number of subscribers in the areas they serve. These adjudicated outlets provide their communities with legally required notices that inform the public about everything from foreclosures, lien sales, government spending and contracts and many more. There is only one county out of California’s 58, Lassen County, that does not have a newspaper of general circulation. However, our members in the surrounding areas do distribute in Lassen County.

As the plan states, “CDT recognizes that some key activities must be more targeted to certain populations whose needs are greater than others.” It is essential that those resources and services leverage the trust California residents have in the diverse constellation of media outlets, languages, and platforms that are closest to Californians of all ages and ethnicities. California has already been successful at leveraging the trust Californians have in their local news outlets to promote important public awareness messages via the California State Library System’s Ethnic Media Outreach Grants program. CNPA, CBM and EMS members have been actively involved in the program and have shown impressive results.
Moreover, research of the last two decades has shown that areas that lack local news have lower voter turnout, less competitive elections, fewer residents informed about their Congressional representation and less likelihood of even Googling the mayor. Our members strive to ensure the important information gets out and this is why our diverse communities trust our outlets.

We also want to highlight a problem we have been seeing popping up around the state, media outlets and organizations claiming to represent “local news” but have not spent the time in the communities our trusted outlets have. They do not speak for us. At the core of our mission is a commitment to “plead our own cause,” a phrase inspired by the words and wisdom of activist, educator, and pioneering journalist Ida B. Wells.

The CDT should leverage that trust in advertising new and upgraded broadband services and digital skills-building programs throughout the state, particularly our outlets that serve covered populations where they live and in the languages, they communicate in. The plan notes that while California has been a leader for years in digital equity, a gap analysis shows that lack of awareness and engagement is a key barrier to achieving digital equity goals. “The role of community engagement in promoting digital equity supports and services cannot be stressed enough.”

We thank the California Department of Technology for its careful, diligent efforts to advance broadband and digital inclusion throughout the state. We look forward to the opportunity and partnership in achieving California’s continued commitment to serve our diverse communities.


Sincerely,

Brittney Barsotti, CNPA

Regina Wilson, CBM

Sandy Close, EMS
4874January 25, 2024 at 4:42 pmDeputy DirectorOrganization#OaklandUndividedOaklandCA1. Executive Summary
California Draft State Digital Equity Plan
#OaklandUndivided

#OaklandUndivided (#OU) is an equity-based, collective impact initiative launched in May 2020 to harness the people's power to solve one of modern society’s most persistent structural inequities - the digital divide. #OaklandUndivided consists of a coalition of our founding partners, including the City of Oakland and Oakland Unified School District, trusted anchor institutions, over 20 community-based organizations, as well as elected and appointed officials and community leaders throughout Oakland. At #OaklandUndivided, we believe in taking a comprehensive approach to digital equity that addresses the structural inequities that undergird the divide. We believe digital equity impacts virtually every sector and intersection of society: Education, Healthcare, Workforce (employment), and Economic Development.


Comments to the California Department of Technology (CDT) for the California Draft State Digital Equity Plan

As noted in the State Digital Equity Plan, accessing the Internet is an increasingly essential part of engaging in a 21st-century society. We want to first acknowledge that planning is a critical step to closing the digital divide. Crafting a State Digital Equity Plan in partnership with the community is a necessary first step in meeting our collective goal of connecting the unconnected. While the draft plan certainly outlines and highlights the pressing need in our state as well as the end goals, we are concerned with the lack of explicit action steps that will illuminate how the State plans on reaching said goals. We highly recommend that the California Department of Technology (CDT) utilize the recommendations below when revising their draft in order to truly achieve Broadband for All.

1. Prioritize meaningful community engagement with covered populations by working in collaboration with community members and trusted partners.

The current State Digital Equity plan boasts of extensive community engagement. However, the format of these various engagement tools have resulted in conclusions that lack nuance and fail to account for the structural barriers faced by those most impacted by the digital divide.

Statewide Surveys
The statewide surveys conducted were long, did not compensate people for their time, and were conducted largely online. Ironically, individuals that lack access to the Internet and/or the digital skills to engage in the process offer arguably the most valuable input about the barriers to getting connected. The format of these surveys resulted in a lack of participation by those most impacted by the digital divide and an unrepresentative sample of our population. For example, while approximately 28% of Californians speak Spanish at home according to the U.S. Census Bureau, only 5% of CDT's statewide surveys were conducted in Spanish. This suggests the need for more targeted outreach to this population.

#OaklandUndivided recommends partnering with existing local nonprofits and community-based organizations in order to elicit feedback, while also compensating community members for their time and input. An example of this is #OaklandUndivided’s partnership with El Timpano, an organization that informs, engages, and amplifies the voices of Latino and Mayan immigrants of Oakland and the wider Bay Area. #OaklandUndivided paid to use El Timpano’s SMS platform, asking a question to the 2,600 Oakland Spanish speakers currently subscribed to their service. We offered $25 gift cards to the first 20 community members who responded to the following question: The government is trying to understand why many non-native English speakers, English learners, don't have access to home internet. We would like to hear your opinion to share with legislators. Tell us, is it difficult for you to connect to the internet? and Why?

By working with trusted messengers like El Timpano, Oakland Housing Authority, Homies Empowerment, Oakland Unified School District, and others, we are able to learn from a wide variety of individuals in impacted communities. All of those surveyed belonged to one or more of the covered populations. Our surveys indicate that the following barriers have kept Oaklanders in covered populations from accessing home internet:

Cost: Of those surveyed at Oakland Housing Authority, 92% identified the cost of service as a major barrier to reliable, high-speed home internet connections. Due to tier flattening, monopolistic markets, divestment in high-poverty communities, low-income residents throughout the state oftentimes pay the highest rates for the lowest-quality service, and are forced into a perpetual cycle of upselling to higher cost plans while only getting 10% of the speeds they’re paying to receive [1]. Additionally, community testimonials [2] reveal that the lower-cost discount plans have burdensome enrollment processes and restrictive eligibility that limit access. Even if families can navigate the process, the resulting connection epitomizes the adage “you get what you pay for.”

Connection issues: A citywide internet speed study conducted in partnership with Oakland Unified School District and Hubble IQ demonstrated pervasive internet performance issues, primarily in Oakland’s least connected communities. The analysis of nearly 300,000 performance tests at over 10,000 unique locations, found that 1 in 3 active wireline subscriptions performed below the threshold for broadband speeds [3]. Unfortunately, the State Digital Equity Plan makes no mention of disparate performance, instead, the internet is treated like a binary - you either have it or you don’t. Unlike other essential services, however, the internet is rationed and throttled, especially in high poverty communities.

Frustration at fluctuating costs and confusing internet costs: Consumers are not satisfied with internet companies [4]. Many Oakland Housing Residents have outstanding debt with internet providers because of surprise billing, junk fees, and misleading, temporary promotions. One resident shared that debt collection from her internet provider was incessant and so overwhelming that it drove her to tears, and left her begging the company to keep the internet on so her daughter could access online learning.

Language barriers: Of those surveyed at Oakland Housing Authority, 28% identified language barriers as one of the factors keeping them from having home internet. Several Spanish-speaking residents surveyed through El Timpano shared that they have to rely on their children for assistance navigating the internet.

Lack of accessible information in different languages on existing benefits or support programs to make the internet more affordable: Survey respondents in Oakland also shared that it’s often difficult for them to find information on internet discount programs available in their languages. One of the respondents from our survey with El Timpano shared that she couldn’t find any information in Spanish on an internet discount program that she uses to share with an acquaintance.

Not meeting requirements: Homies Empowerment found that barriers to broadband adoption also include not having or meeting all requirements imposed by ISPs to establish services, such as having a social security number, a bank account, or qualifying credit. Even if residents have a choice of internet service providers, these requirements often leave community members with zero or only one option.

Recommendation: Community engagement plans that utilize existing communication channels through trusted community partners and compensate community members for their time will yield both the largest number of responses and the most accurate information. In the spirit of transparency, we urge the Department to provide the results from their phone survey and DEEM survey for independent review and analysis.

In-Person Planning Workshops
While the State held a number of in-person planning workshops, the standardized format of these regional events was limiting and did not allow for local input. Asking community members who may have limited knowledge of a covered population to speculate their barriers to access led to, at times, problematic or stereotypical conclusions that are now reflected in the Draft State Digital Equity Plan.

As such, the plan fails to include reasoning or evidence for the claims about covered populations. This is especially troubling given that the main barriers to access identified within this draft plan focus primarily on the covered populations’ perception or abilities rather than on the structural barriers that prevent them from connection. There seems to be a reluctance to place any responsibility at monopolistic providers that charge higher rates for worse quality service [5], failing to not only improve, but maintain their dilapidated infrastructure while focusing on profit margins in wealthier regions [6].

Recommendation: We strongly believe that the data collected in these in-person planning workshops should be heavily scrutinized before it informs this Draft State Digital Equity Plan. We urge the Department to revisit the data collected and instead identify structural issues that inhibit access, moving beyond personal responsibility to policy solutions.

Meetings & Listening Sessions
The various meetings on this subject and listening sessions were ineffective due to the lack of community awareness and the timing of these meetings. For those who did attend, commenters were often constrained to one representative per organization and a 2-minute time limit.

After conferring with the community about the opportunity to attend yet another listening session last month, we were told that Oaklanders’ frustration stems not from a lack of forums to express concerns, but rather by the lack of tangible actions taken in response to the urgent issues that have been raised for several months.

Survey fatigue can be overwhelming and it is unfair to ask for the community to continue to devote time to these various meetings and listening sessions when, time and time again, no actions are taken as a result of their comments.

Recommendation: #OaklandUndivided strongly recommends the Department seek local input from trusted messengers such as CBOs, LEAs, and local newsgroups on effective ways to both advertise these events and engage community members. Furthermore, due to frequent sparse attendance, we recommend that commenters should be allowed unlimited time.

To ensure equity, we suggest ensuring access to interpreters, including American Sign Language, incorporating closed captioning into videos, and guaranteeing that the selected meeting locations adhere to ADA accessibility standards. We also recommend ensuring the accessibility of meeting locations by considering the proximity to public transportation or providing ride-share app vouchers to facilitate community member attendance. Additionally, we recommend organizing listening sessions at various times of the day/week to accommodate people’s work schedule. Lastly, the state should make an effort to offer childcare services during these sessions, considering community members who may be parents.

In order to ensure that community members feel heard, we also suggest that the council members provide a summary of public comments after each meeting and clearly outline the steps to address these variety of concerns.

2. The remaining, secured funding for the Middle Mile Broadband Initiative must be prioritized in the least connected, highest poverty urban, rural and tribal communities.
While the Digital Equity Plan urges “expediting” the construction and development of the MMBI, we strongly urge the State to utilize the remaining, secured funding to instead prioritize connecting the lowest-income, least-connected communities that cannot afford to wait.

The first $2 billion led to Middle Mile builds in wealthy communities ranging from Beverly Hills in Los Angeles County to Pleasanton in Alameda County, deferring projects in the most dense concentrations of unconnected residents in both Southeast L.A. and East Oakland. To further expedite this process will continue to inherently bias regions of California with the most resources and surplus capacity which, more often than not, are the same communities that have been prioritized by private investment for decades. Given Governor Newsom’s recent budget proposal of $1.5 billion to actualize the entire 10,000 mile network network [7], the State must proceed with intention instead of expedience above all else in order to recenter equity and ensure funding is allocated to areas with the highest need – the least connected, highest poverty communities.

Recommendation: The Department must prioritize equity over expediency. This can be done by prioritizing the least connected, highest poverty urban, rural and tribal communities before any more money for the Middle Mile Broadband Initiative is spent in wealthy, demonstrably served communities.

3. The current State Broadband Maps are discriminatory and require significant revision in partnership with community members and organizations.
The State’s broadband map determines eligibility for this once-in-a-generation $8 billion broadband infrastructure investment. Absent urgent intervention, the California Public Utilities Commission (CPUC) will continue to rely on egregiously inaccurate, self-reported data from profit-motivated internet companies that have already perpetuated divestment in marginalized, predominantly Black and brown urban, rural and tribal communities. There is no time to “evolve” the maps. This time must be different.

#OU is concerned by the recommendation that urban areas - the places where nearly 3 of every 4 disconnected reside [8] - shift focus from this $8B generational broadband infrastructure, and instead consider applying for CASF or other programs “better suited” for urban populations. CASF annual expenditure is approximately 1/8000th of the one-time funding available through SB 156 & BEAD, and our community cannot afford to wait for a more convenient season.

In May of 2023, #OaklandUndivided and other community groups presented evidence [9] that the State Broadband maps were not just demonstrably inaccurate but discriminatory. Publicly available data show dense clusters of “unserved” locations added by the CPUC have active accounts with internet providers offering speeds up to 2GB. In Alameda County, the CPUC designated nearly 8X as many “unserved” locations in the wealthiest, most connected areas (SEVI 0-25%) as they did the highest poverty, least connected areas (SEVI 75-100%). These maps have already caused disparate impact as CDT divested millions of planned investment in low income, high need areas across the state. Oakland saw its funding projection slashed by 56% and South Central Los Angeles by 77% — versus an overall statewide reduction of 17% [10]

For months, CPUC has refused to make any changes to the FFA Last Mile map, and has made no indication that BEAD map, which determines $1.87 billion of public funding, will be made any differently. The most recent draft of the State’s BEAD plan, submitted to the NTIA for approval, disempowers communities from providing accurate data at scale by requiring that each challenge must include three speed tests as well as the submission of (1) a certification of the speed tier to which the customer subscribes and (2) an agreement, using an online form provided by the CPUC, that grants access to these information elements to the CPUC, any contractors supporting the challenge process, and the service provider. These highly restrictive requirements do not allow community members to submit challenges. As such, it is critical that the base map is as accurate as possible.

Recommendation: We urge CPUC and CDT to (1) uncouple funding decisions from the demonstrably inaccurate, discriminatory map until the State audits all redesignated “unserved” locations in wealthy communities, and (2) adopt challenge rules that enable the highest poverty, least-connected communities to add unserved locations at scale by removing overly burdensome requirements on the un- and underserved.

4. Prioritize affordability by (1) seeking an alternative to the Affordable Connectivity Program and (2) encouraging market competition.
The single best predictor of whether you have fast and reliable internet is whether you can afford it. In survey after survey, the lion’s share of people who don’t have internet at home say it’s because it’s too expensive [11]. In fact, the State’s phone and online survey identified cost as the main barrier to internet with 61% of CDT survey respondents, these findings were replicated in Oakland where 92% of respondents indicated prohibitive cost was their main barrier.

Affordable Connectivity Program (ACP)
While affordability is a critical part of the California Digital Equity Plan Framework, much of this plan uplifts the Affordable Connectivity Program (ACP) as the solution for overcoming this barrier. While a $7B bipartisan ACP Extension Act has been proposed in Congress, the Federal Communication Commission is taking steps to wind down the ACP with the last day to enroll soon approaching. As this program is projected to expire in April 2024, it is essential that the State considers alternative solutions for affordability that do not rely on the mercy of federal funding.

Encouraging Market Competition
Today, more than two-thirds of Californians have one or no options for high-speed internet access. There have been many studies within the last year documenting the impact of monopolistic markets in low-income communities. Independent journalists, non-profits, and universities arrive at the same findings: time and again, the lowest-income communities were stuck with the worst deals – higher prices for the same speeds as their wealthier neighbors. Importantly, in the areas with competition between providers, advertised prices are more affordable.

The link between infrastructure and affordability is clear - monopolistic markets in low-income communities make the internet unaffordable and inaccessible to hundreds of thousands of Californians. To connect all Californians, we must build open-access, affordable infrastructure that fosters competition and spurs innovation in the neighborhoods bearing the brunt of the digital divide. There is a threat of underutilization of the Middle Mile network if the pricing structure doesn’t incentivize municipalities, and innovative, community-based providers to build out in neighborhoods where margins are thin and return on investment requires patience beyond the next quarterly shareholder meeting.

Recommendation: The most effective mechanism to expand access in these communities is CDT’s unilateral authority to establish a differential pricing structure of the Middle Mile network. In consultation with network experts and legal counsel, we propose that CDT offer reduced rates based on the type of client and location of the access point. We recommend differential pricing apply to communities that are either (1) CalEPA’s designated “disadvantaged community,” and/or (2) in the top two quartiles of the Socioeconomic Vulnerability Index (50-100%). Recognizing that municipalities and non-profits prioritize people (not profits), both of these entities should have free access to the network within priority communities with applicable strand caps. Additionally, community-based, residential ISPs that offer a low-cost plan should be charged reduced rates or zeroed out license fees for at least 5 years.

Furthermore, actualizing the goal that all Californians have access to affordable broadband requires working in partnership with the legislature to recommend common sense regulation which will increase competition in a historically monopolistic marketplace. It is critical that these once in a generation investments are not solely dedicated to incumbent providers that already have a stranglehold on the market.



[1] https://www.sfchronicle.com/tech/article/broadband-internet-access-oakland-18327759.php

[2] https://www.youtube.com/watch?v=-ec173lb-A0

[3] https://www.mercurynews.com/2023/12/24/why-are-comcast-and-att-trying-to-block-millions-in-state-money-to-boost-oaklands-high-speed-internet/

[4] https://www.cnet.com/home/internet/survey-shows-customers-dissatisfied-with-isps-but-some-are-better-than-others/

[5] https://themarkup.org/still-loading/2022/10/19/dollars-to-megabits-you-may-be-paying-400-times-as-much-as-your-neighbor-for-internet-service

[6] https://www.cpuc.ca.gov/industries-and-topics/internet-and-phone/service-quality-and-etc/network-exam-of-att-and-frontier-verizon

[7] https://laist.com/news/1-5-billion-to-be-added-to-states-broadband-plan

[8] https://www.nytimes.com/2021/06/01/business/rural-urban-broadband-biden.html#:~:text=About81percentofrural,thatdon'thaveone

[9] https://docs.google.com/presentation/d/1g8T5HT3ZEXcrOW_HYaYJ7Q05jECXAUb3GHTYErwRJX4/edit?usp=sharing

[10] https://www.mercurynews.com/2023/08/26/good-old-fashioned-redlining-why-was-oakland-cut-out-of-state-plan-for-high-speed-internet/

[11] https://www.edweek.org/technology/the-number-one-reason-students-still-lack-internet-at-home-parents-cant-afford-it/2021/11, https://mikeconlow.substack.com/p/pews-home-broadband-2021-survey
4873January 25, 2024 at 4:36 pmRegional Planning Program ManagerOrganizationSan Diego Association of GovernmentsSan DiegoCA3. Current State of Broadband and Digital Inclusion
The Digital Equity Ecosystem Mapping tool provides a snapshot of existing programs and helps identify gaps and opportunities. The included gap analysis highlights two crucial issues for the sustainability of digital equity efforts in the state: securing funding and addressing gaps in awareness and engagement. We encourage the CDT and other State entities to advocate for sustained digital equity funding at both the state and federal level to address these gaps.

Additionally, we appreciate the CDT’s efforts with the statewide digital equity survey. This information will be essential to further identifying gaps in service and establishing the most urgent digital equity needs for Californians. Here in the San Diego Region SANDAG worked to get more than 12,000 responses to the survey, getting critical data for the state and the region. This effort exemplifies the success of digital equity efforts when the State partners with regional and local entities. The CDT should continue to leverage state and regional agencies to implement the SDEP. Additionally, the CDT should provide access to survey results for regional and local agencies, including local speed test results, to compliment the data that is being used to inform efforts taking place at the local level.

4. Collaboration and Stakeholder Engagement
We wish to underscore the importance of leveraging local expertise to solve complex regional problems. Leaning on trusted local partners for the implementation of this plan will be crucial to its success, and the CDT's proactive engagement will ensure their participation in the various outreach and stakeholder events outlined in the plan. In San Diego, the Regional Digital Divide Taskforce stands ready leverage existing partnerships to accelerate the implementation of the SDEP.

5. Implementation Strategy & Key Activities
The SDEP outlines a statewide digital literacy training platform, and we recommend that the CDT incorporate feedback from local experts in the platform's creation. Organizations such as California Emerging Technologies Fund, San Diego Futures Foundation, Computers to Kids, and others who are pioneers in this space should be active participants in developing additional resources. Additionally, we ask that SDT consider that an online platform might exclude participation from certain covered populations who lack access to broadband or devices.

The California Connect Corps is an exciting initiative with the potential to positively impact many communities throughout the State. This funding opportunity should be open to local governments (including MPOs) and non-governmental organizations alike, allowing for each region to determine the organization(s) that is best suited to take on a leadership role for implementation. We also encourage the CDT to draw from lessons learned and best practices from similar programs such as the CASF Adoption Account and leverage existing initiatives to take advantage of potential efficiencies.

Finally, we stress the importance of allowing for flexibility in grant implementation as this digital equity space is very dynamic and entities would benefit from the ability to adjust grant goals as circumstances change.
4872January 25, 2024 at 4:34 pmDirector of Race Equity PolicyOrganizationThe Utility Reform Network (TURN)OaklandCA1. Executive Summary
The Utility Reform Network (TURN) Public Comment, California Department of Technology Draft California Digital Equity Plan.

TURN is a fifty-year-old independent nonprofit organization in California that promotes racial and economic equity advancement and accessibility through regulatory and legislative work to achieve equitable, safe, reliable, resilient, and affordable communications services. At several levels of government, either directly or through coalitions, TURN advocates for policies that support the widespread deployment of high-quality and affordable communications services.

Government Code Section 11546.46 requires the California Department of Technology (CDT) to develop a state digital equity plan that identifies the “barriers to digital equity faced by covered populations in the state.” Section 11546.46 requires CDT to draft a plan with several assessments, measurable objectives, collaboration plans, and lists of collaborators for the plan. In addition, Section 11546.46 requires that the state digital equity plan assess the “existing digital navigator programs in the state” and recommend “a statewide strategy for digital navigators to serve covered populations.” The baseline requirements and definitions are in federal law, Public Law 117-58 (Section 60302, “Digital Equity Act of 2021”). CDT must also balance with other federal statutes that require it to harmonize efforts with the National Telecommunications and Information Administration's (NTIA) Broadband Equity, Access and Deployment (BEAD) program currently being implemented by the state. As required by federal and state law, CDT released for public comment a draft of the state digital equity plan (Draft Plan).

[1.A. Covered Populations]
TURN recommends 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. The guiding legislation for the Draft Plan, AB 2750 (AB 2750 (2022), Government Code Section 11546.46) states that covered populations should include “but not be limited to” those listed in the statute. The statute provides CDT with a minimum for inclusion while also allowing the agency to use its subject area expertise on the digital divide to better identify “demographics that are underserved in regard to internet access and digital literacy” (AB 2750). Therefore, CDT has the authority and flexibility to raise the minimum threshold of 150 percent of the FPL to that of 200 percent FPL.

California has been consistently ranked as one of the most expensive states to live in for years (Forbes, 2024 (https://www.forbes.com/advisor/mortgages/cost-of-living-by-state/); CNBC, 2018 (https://www.cnbc.com/2018/06/28/these-are-americas-most-expensive-states-to-live-in-for-2018.html)) and increases in the Federal Poverty Guideline have not kept up with the increase in the cost of living in California. 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.

To illustrate how inappropriate the FPL is for California, we offer a comparison to other methodologies that demonstrate a better understanding of the high cost of living given several inputs. For example, the Self-Sufficiency Standard, developed by the University of Washington, calculates the real cost of living in each county of California. The Self Sufficiency Standard considers the cost of energy utilities, insurance, food, housing, childcare, and other essential goods and services. Using these costs, the Self Sufficiency Standard calculates the minimum income necessary to support over 719 different household types in each county, thus reflecting the wide range of what poverty looks like in California. Using this methodology, we see a significant gap between the minimum income needs of Californians and the FPL. For instance, 150 percent of FPL for a family of four is $45,000 annually (chrome-extension://efaidnbmnnnibpcajpcglclefindmkaj/https://aspe.hhs.gov/sites/default/files/documents/1c92a9207f3ed5915ca020d58fe77696/detailed-guidelines-2023.pdf), whereas the Self Sufficiency Standard for a family of four living in Alameda County, with two school-age children, is $113,638 (https://selfsufficiencystandard.org/calculator/). Even in California’s most affordable county, Modoc County, the Self Sufficiency Standard is $61,650 – a difference of over $16,000. When comparing 150 FPL to a methodology that considers the real cost of living, we see that it is far too low and will exclude many families who are experiencing poverty.

Furthermore, many income-qualified programs use income thresholds above 150 percent FPL. For example, Californians who are income-eligible for Section 8 housing would not be considered a covered household in the current Draft Plan because Section 8 vouchers are based on the Area Median Income (AMI). Similarly, Californians who are income-eligible for Low-Income Home Energy Assistance Program (LIHEAP) would not be covered households in the Draft Plan because the program is based on State Median Income (SMI). Table 1, below, offers a comparison between all three measures.

Table 1. Comparing Section 8 Housing Income Eligibility Limit and LIHEAP Income Eligibility Limit, to 150% FPL.

County 150% FPG (Family of Four) Section 8 50% AMI LIHEAP60% SMI
Yolo $45,000.00 $52,450.00 $62,313.00
Santa Barbara $45,000.00 $73,950.00 $62,313.00
Los Angeles $45,000.00 $63,050.00 $62,313.00
Monterey $45,000.00 $60,200.00 $62,313.00
San Benito $45,000.00 $55,650.00 $62,313.00
San Diego $45,000.00 $68,900.00 $62,313.00

TURN recognizes that federal law requires CDT to use the FPL in its determination of an income threshold for covered households. However, the state law’s language makes it clear that the threshold of 150 percent FPL is a minimum requirement, and that CDT is “not limited” to that number. TURN strongly recommends that CDT revise the Draft Plan to raise the threshold to 200 percent FPL to better reach California’s low-income households.

[1.B. Reliability Baseline Measures]
The Draft Plan appropriately identifies Objective 1.3 to “increase the percentage of Californians who report that their Internet service is reliable” and describes that “only 62% [of survey respondents] report that their service is reliable for their household needs” (Draft Plan, page 15, citing Survey, page 30). The underlying survey draws initial conclusions on observed trends. TURN offers additional considerations for the observed trends that go beyond speed service tiers that may be priced too high for consumers. For example, the infrastructure deployed near certain populations and the maintenance of this infrastructure could have a negative impact on the reliability of the broadband service experienced by some subsets of the population surveyed.

Nevertheless, a significant percentage of the respondents surveyed report that their broadband service is not highly reliable; 38 percent of all respondents did not provide a high rating for reliability (Survey, page 30). Moreover, the survey showed similar dissatisfaction with the reliability of respondent’s broadband service: low-income households (42 percent); households with language barriers (46 percent); and rural households (46 percent). (Survey, page 30). Similarly, 41 percent of racial and ethnic minorities in the survey did not highly rate the reliability of their broadband service. The disparity in these figures should raise concern that even if a household receives broadband service, regardless of advertised and delivered speed, the service cannot be conclusively deemed reliable.

Having identified concerns with reliability, the Draft Plan explains that the target is to achieve “universally reliable service by 2030” (Draft Plan, page 26 (Objective 1.3)), through a series of key activities (Draft Plan, pages 112-120). TURN provides additional comments about the Digital Equity Plan Implementation Strategy and Key activities below (V. Comment to Digital Equity Plan Implementation Strategy and Key Activities).

2. Introduction and Vision for Digital Equity
As a threshold matter, CDT’s Draft Plan requires further harmonization with the CPUC’s Broadband Equity, Access, and Deployment (BEAD) Initial Proposal submitted to the National Telecommunications and Information Administration in December 2023 (all references herein refer to Volume II of the CPUC’s Initial Proposal). In particular, the Draft Plan should clearly refer to equity in all objectives and key activities, including those related to BEAD Program-funded deployment and so that the objectives and implementation strategies use consistent terms and clear implementation strategies.

NTIA’s collective guidance implementing relevant federal statutes requires 1) CDT and the CPUC to harmonize digital equity efforts and 2) incorporate equity throughout the implementation of both the Digital Equity Act and BEAD-related provisions. For example, NTIA recommends that the state “should prioritize unserved and underserved areas to infuse both the (CPUC) Five-Year Action Plan and the (CDT) Digital Equity Plan with digital equity at their cores (NTIA, Digital Equity Guide for the States: How to Prepare for Success (Dec. 1, 2022), page 21). NTIA further suggests that “states can accomplish this by ensuring stakeholder engagement plans are comprehensive enough to provide a clear landscape of covered populations’ access to high-speed internet” (id.).

Accordingly, TURN first recognizes that the timing of the CDT Draft Plan frustrated CDT’s ability to incorporate updated BEAD Program plans the state submitted to NTIA. This is because CDT released the Draft Plan (November 2023) before the CPUC submitted the BEAD Initial Proposal (December 2023). CDT’s Draft Plan refers almost exclusively to the CPUC’s Five-Year Action Plan (August 2023) submitted to the NTIA and not the CPUC’s Initial Proposal. Moreover, various aspects related to digital equity in the CPUC’s Five-Year Action Plan deferred to its Initial Proposal. The CDT Draft Plan can and should be updated accordingly to reflect California’s BEAD Initial Proposal to NTIA. TURN provides feedback to these specific topics and recommendations on how to improve the CDT Draft Plan.

Second, the Digital Equity and BEAD Programs documents (CPUC’s Five-Year Action Plan, CDT’s Draft Plan, and CPUC’s Initial Proposal) often rely on different terminology or cite ongoing efforts in one another, and this leads to potential uncertainty. This produces varying use of terminology in NTIA guidance. For example, the statutory requirements for the Draft Plan under the Digital Equity Act require the Draft Plan to include “implementation strategies,” while NTIA provides an example that disaggregates implementation strategies into “key activities” (NTIA, State Digital Equity Plan External Best Practices, page 7), a term that is not used by CPUC’s Five-Year Action Plan or Initial Proposal. The practical impact of inconsistent terminology is that some implementation strategies remain unclear across the CDT and CPUC documents. For example, the CPUC’s Five-Year Action Plan provides a placeholder for “[k]ey strategies” and refers to the CPUC’s ongoing BEAD rulemaking (Five-Year Action Plan, page 103). The CPUC’s Initial Proposal notes the discussion of key strategies contained in the CDT’s Draft Plan, while offering further implementation strategies based on the conclusion of that phase of the CPUC’s BEAD rulemaking. The need for further harmonization is underscored by the acknowledgment offered in the CPUC’s Five-Year Action Plan and Initial Proposal project that BEAD Program funding will be insufficient to meet both the state’s deployment and digital equity—or non-deployment—needs. Further, the CPUC largely defers consideration of non-deployment-related activities (Initial Proposal, page 65), and thus in practice, a large part of this work needs to be described in detail in the CDT’s Draft Plan.

Third, the CDT Draft Plan should be updated to benefit from the CPUC’s work in the CPUC Initial Proposal. In the CPUC’s Five-Year Action Plan, the CPUC deferred further elaboration of its key strategies, in part, to its Initial Proposal (Five Year Action Plan, page 103). The CPUC’s Initial Proposal emphasizes equity in the scoring of BEAD Program project proposals, with 10 of 100 possible points going to proposals that offer to serve Disadvantaged Community and Low-Income Areas (Initial Proposal, page 37). Therefore, the current CDT Draft Plan did not benefit from the finished analysis in the CPUC’s Initial Proposal, and accordingly should be updated with these considerations in mind.

For example, this emphasis on equity in deployment is not currently reflected in the Draft Plan. The Draft Plan refers to BEAD Program deployment in two places. Key Activity 1 proposes to “[e]xpedite and complete existing Broadband for All infrastructure efforts” and goes on to propose that “[s]tate agencies tasked with building out broadband infrastructure will continue and expedite the build-out of existing Broadband for All investments and BEAD-funded projects” (Draft Plan, page 112). Objective 1.1 seeks to “[i]ncrease the percentage of Californians who are connected to broadband internet service” and identifies a selection of connectivity based on covered populations (Draft Plan, page 15). Neither key activity nor objective in the Draft Plan acknowledges the CPUC’s Initial Proposal emphasis on equity. As drafted, only one objective expressly refers to covered populations, while the remaining objectives and key activities would consider any measurable success for “Californians” or “all Californians” as moving towards digital equity. However, aggregate improvements to the given metrics may conceal inequities, for example, accelerated access in wealthier and whiter areas versus less wealthy and BIPOC areas. Therefore, the objectives and key activities should be qualified to ensure that success is measured to include minimization of disparities between covered populations and others. Further, the qualification would satisfy the NTIA’s collective guidance, TURN encourages the CDT to harmonize across CDT and CPUC documents, and in particular equity in deployment. For example, the Objectives can be updated to read:
Objective 1.1: Equitably increase the percentage of Californians who are connected to broadband internet service in a manner that eliminates disparate outcomes for covered populations.
Objective 1.2: Equitably increase the percentage of community anchor institutions that are connected to broadband internet service in a manner that eliminates disparate outcomes for covered populations.
Objective 1.3: Equitably increase the percentage of Californians who report that their internet service is reliable in a manner that eliminates disparate outcomes for covered populations.
Objective 1.4: Equitably increase the percentage of Californians who have a choice of at least three internet service providers in a manner that eliminates disparate outcomes for covered populations.
Objective 2.1: Equitably decrease the percentage of Californians who cite cost as the primary barrier to internet service in a manner that eliminates disparate outcomes for covered populations.
Objective 2.2: Equitably reduce the percentage of Californians who rely solely on a smartphone to use the internet in a manner that eliminates disparate outcomes for covered populations.
Objective 2.3: Equitably increase the percentage of Californians enrolled in low-cost internet options and subsidies, including the Affordable Connectivity Program or successor program.
Objective 2.4: Equitably reduce the average cost that covered populations pay for internet service.

3. Current State of Broadband and Digital Inclusion
Regarding the covered population described as “individuals who are members of a racial or ethnic minority group,” two important points need to be considered, which are not reflected in the Draft Plan. First, the phrase “minority group,” is not defined in the Draft Plan or in AB 2750, leaving it open to interpretation. Given that the discussion in Section 3.4 indicates that CDT consulted with Latine-serving organizations, we infer that “racial or ethnic minority” is being used as a synonym for Black, Indigenous, and other People of Color (BIPOC), rather than referring to a mathematical minority of the population. This is important to clarify because Latine people are no longer a minority percentage of the population in California. According to the 2021 American Community Survey (ACS), Latine people constituted 39.5 percent of the state population, whereas non-Hispanic whites were 35.76 percent. In fact, according to the same survey, twelve counties in California are now over 50 percent Latine (ACS 2021).

However, despite no longer being a minority of the state’s population, Latine people face significant barriers to internet access, internet adoption and digital literacy due to a long history of housing discrimination and disinvestment in Latine communities, among other barriers. During the 1930s and 1940s Latine neighborhoods were redlined along with Black neighborhoods, thereby restricting residential mobility and thwarting the ability to accumulate generational wealth through home ownership. In the 1950s and 1960s, during the height of government-sponsored “urban renewal” programs that saw the demolition of numerous Black communities across the country (Alexander von Hoffman (2008) The lost history of urban renewal, Journal of Urbanism: International Research on Placemaking and Urban Sustainability, 1:3, 281-301, DOI: 10.1080/17549170802532013), Latine communities in California were likewise demolished. Most notably, perhaps, was the demolition of Los Angeles’ long-established Latine community, Chavez Ravine, to make way for the building of Dodger Stadium. During the forced displacement of Chavez Ravine residents, most families received little to no compensation for the loss of their property and shelter, thus creating a persistent economic disadvantage for Latine households that persists today and prevents many from accessing the internet (López, R. W. (2009). Community resistance and conditional patriotism in cold war Los Angeles: The battle for Chavez Ravine. Latino Studies, 7, 457-479). In places where Latine communities exist today, we see lower levels of infrastructure investment and, not unrelated, lower levels of internet access. For these reasons, TURN agrees that Latine people should be included as a covered population despite the size of the population and thus the language of “minority” is not appropriate or accurate. TURN recommends adopting the language of BIPOC to better represent the people this covered population is trying to describe.

Secondly, the Draft Plan does not recognize that many BIPOC communities (currently “racial or ethnic minority group”) who face barriers to internet access are English speaking. In Section 3.4, “Specific Barriers and Baseline for Covered Populations and Digitally Disadvantaged Communities,” the “unique barriers” identified for “individuals with language barriers” are the same as those listed for “racial and ethnic minority groups.” While TURN recognizes the importance of in-language communications to increase internet adoption and digital literacy for those not fluent in English, these two populations are in no way synonymous and should be studied carefully and recognized for their unique circumstances.

When working to identify the specific barriers for racial and ethnic minorities (BIPOC), CDT reports having consulted with Central Valley Immigrant Integration Collaborative (CVIIC), the Latino Coalition for a Healthy California, PIQE, the Canal Alliance, Mission Economic Development Agency, and Self-Help for the Elderly. Of these six organizations, four are specifically Latine-serving, five are rooted in serving immigrant populations from non-English speaking countries, and although PIQE is a national organization that does not mention a racial or ethnic group on its website, only four out of 19 people listed on their staff page are not Latine. Although these organization do important and meaningful work, they are not able to offer insight on the specific barriers facing Black and Indigenous populations. The absence of Black and Indigenous voices likely contributed to CDT’s failure to identify the unique barriers of BIPOC communities, particularly native English speaking BIPOC communities.

If the Draft Plan is to succeed at closing the digital divide it must include the populations most impacted by it – Black and Indigenous populations. According to the 2022 American Community Survey (https://data.census.gov/table/ACSST1Y2022.S2802?q=Telephone,Computer,andInternetAccess ) Black and Indigenous (including Native Americans, Native Hawaiians and Native Alaskans) people have the lowest levels of internet access in the home; meaning that they are the most impacted by the digital divide. Although CDT hosted events a few “tribal consultations,” these were not meaningful engagements, as evidenced by the absence of their feedback in the Draft Plan. Moreover, there was a complete absence of consultation with Black-serving organizations, reflecting the exclusion of Black voices in the SDEP process entirely. By not meaningfully consulting with Black-serving or Indigenous-serving organizations, CDT did not capture the experiences of some of the most marginalized populations in the state and failed to consider the unique barriers these populations face in accessing the internet and gaining digital literacy skills.

TURN strongly recommends that CDT revise and resubmit the Draft Plan after gaining feedback from Black-serving and Tribal-serving organizations to accurately reflect the unique barriers faced by these communities. Without this inclusion, the Draft Plan fails to be equitable and falls short of meeting the federal and state statutory requirements, and ultimately is not on the path to meaningfully reducing the digital divide.

4. Collaboration and Stakeholder Engagement
TURN provides feedback regarding the collaboration and stakeholder engagement with Black-serving and Tribal-serving organizations in our comments on Section Three.

5. Implementation Strategy & Key Activities
The Draft Plan dedicates a lot of space to discussing goals and objectives, or ideal outcomes, but provides little in the way of actionable steps to accomplish those goals and achieve those ideal outcomes. As discussed in TURN’s comments on the Introduction and Vision of Equity section of the Draft Plan, this may be a product of the Draft Plan’s reliance on the now-dated CPUC BEAD Five-Year Action Plan and need to harmonize its latest BEAD Initial Proposal. In this section, TURN provides feedback on each of the key activities outlined in the Draft Plan.

The first activity in the Draft Plan is to “expedite and complete existing Broadband for All infrastructure efforts,” specifically mentioning the last mile and middle mile projects without acknowledgment of the significant equity problems advocates have raised about each. TURN recommends that CDT revise its Draft Plan to reflect the lessons learned from two other related broadband efforts so that the Draft Plan does not produce inequitable results.

One broadband effort that initially produced bad results, but advocates intervened to support more equitable results, was the CPUC’s last mile project through the Federal Funding Account. That broadband deployment project began with a map of priority areas that identified the whitest, wealthiest, and least polluted communities in the state as being the highest priority for investment. If used, this map would have funneled public dollars away from communities in need and toward the most privileged populations in the entire state. TURN, along with Digital Equity LA, the California Alliance for Digital Equity, the Center for Accessible Technology and many other organizations, held ex parte meetings with the CPUC as the agency considers Black and Indigenous populations in the SDEP Draft and the problems with relying on business-case models to determine the spending of public money. TURN submitted alternate maps, which prioritized underserved locations that are also considered disadvantaged (as defined by SB535), low income and/or have high levels of pollution according to CalEnviroScreen. The CPUC adopted TURN’s suggestions.

Likewise, the second broadband effort involved the issue of inequitably distributed federal funding in the CDT-administered deployment of the statewide, open-access Middle-Mile Broadband Initiative. CDT released an initial middle mile map and then the agency notified the public that the map would be “optimized.” TURN and others expected there would be only slight changes to the maps to improve the data. Instead, the original map was removed from public view and replaced by a new map utilizing a phased approach to deployment. The phased approach included wealthy, predominantly white communities like Beverly Hills in the first phase, and BIPOC communities like Baldwin Hills, Ladera Heights and Compton in the second phase, which is yet to be funded. This map indicated that middle mile would be deployed to white communities, while deployment to BIPOC communities—the most likely to be without internet in the home—would be postponed indefinitely. Here, TURN and allied organizations identified the strong concerns and lobbied CDT, state legislators and Governor Newsom. Subsequently, CDT abandoned its proposed phased approach (although funding for the full project remains unclear until the state budget is finalized). If not for the intervention of consumer advocates, the middle mile project would have siphoned public dollars away from the very populations the Draft Plan is meant to help.

The fact that the approaches of two different state agencies, working on two different broadband infrastructure projects, produced the same racist outcome points to a systemic issue with the methodologies and assumptions being employed by the state. For this reason, adopting a key activity that simply says to “expedite and complete existing…infrastructure efforts,” is extremely troubling. Speeding up an inequitable approach will only fast track harm to already underserved and vulnerable populations, will deepen the digital divide, and cause lasting harm for generations. The repetition of problematic outcomes indicates that the state needs to invest in research to ascertain the systemic problem in their approaches.

The key to building equitable broadband infrastructure is not to build faster, but to build equitably, so that underserved covered populations receive reliable and affordable high-speed internet. The Draft Plan should call for an equity analysis to be conducted on last- and middle- mile projects as grants are given out, to ensure that money is going to places with high percentages of low-income and/or BIPOC residents. With these tools, California has a chance to be the nation’s leader in addressing digital inequity and closing the digital divide.

Related to infrastructure deployment, is Key Activity 3, “[e]volve broadband and digital equity data maps” (Draft Plan, page 22). The single paragraph dedicated to this activity only considers broadband availability but fails to mention measuring 1) adoption, 2) speed, and 3) reliability (i.e. frequency of outages) (id.). To meaningfully address the digital divide, people need to be able to use the internet to access telehealth, education, and employment, to name a few. However, without stable and affordable broadband in the home, people will not have the connection necessary to participate in these activities.

TURN agrees that a key activity involves updating the broadband and digital equity data and maps (Draft Plan, page 114). However, CDT should explore investments in the map and data tracking efforts that capture broadband service reliability. This effort would paint a clearer picture of where broadband service dollars are needed so that current broadband customers do not live in silence, plagued with unreliable broadband service. As stated elsewhere in the feedback, TURN recognizes the high percentage of dissatisfaction of the survey respondents, specifically the several subcategories, and highlights that this may not be solely attributable to a speed offering. Tracking service reliability in some way will help steer coveted tax dollars and even private investment in key areas that may not require a lot to make a difference in broadband service for Californians throughout the state.

Furthermore, using language like “evolve” is vague and reminiscent of CDT’s use of the word “optimize” when making dramatic and inequitable changes to the middle mile deployment map. Words like evolve, optimize, and even transform, have vaguely positive connotations but offer no information about the types of changes, nor the methods to be used in making changes, to maps. Stating that broadband maps and data will evolve does not protect against the recurrence of inequitable maps that funnel public dollars away from low-income and BIPOC communities.

Lastly, the Draft Plan does not explain how this “evolved” data will be collected. Currently, both FCC and California broadband maps rely on ISP-provided data, despite there being a clear conflict of interest when it comes to reporting whether a location is served. As CDT and CPUC move forward in their revisions of the map, TURN recommends incorporating crowd-sourced data from the public. We suggest that a mechanism be created so that individuals can submit the results of speed tests in addition to reporting outages, and the frequency of video lagging or freezing, which are generally related to jitter and latency. These measures will give insight into who is connected, whether their speed as they experience it (rather than as advertised to them) meets the threshold to be considered “broadband,” and whether that connection is stable and reliable. Furthermore, TURN strongly urges CDT, and CPUC when relevant, to make the submission of this data as easy as possible for the public. Requirements such as submitting one’s internet or cable bill or signing an affidavit, are not only onerous but unjust. Such requirements not only create barriers that deter the public from submitting data, but they also require people to sacrifice their privacy to receive the public investments owed to their communities.

Regarding Key Activity 2, “[c]onvene digital equity stakeholders to strengthen collaboration,” (Draft Plan, page 22), indicates a continuation of the activities that were done during the creation of the Draft Plan. Unfortunately, there has been widespread disappointment in the quality of public engagement efforts made during this time (these concerns were raised with CDT repeatedly by TURN, California Community Foundation, OaklandUndivided, and others). TURN encourages the CDT to focus on meaningful engagement that is reflected in planning, and to specify how that will be accomplished. For instance, TURN recommends all community events include language translation for the most common non-English language in the community, food, and childcare, and be held after normal business hours so that people have a chance to attend after work or school. These provisions significantly reduce the barriers to meaningful participation, thus allowing for more substantive engagement. Referring to Section 5.6, the bulk of Key Activity 2 is focused on engaging with advisory committees and councils (California Broadband Council, Middle-Mile Advisory Committee, Get Connected! CA Mobilization, Statewide Digital Equity Implementation Group, six Working Groups, Citizens Advisory Committee), however nowhere in the Draft Plan is it made clear how one can become part of these committees and/or councils to be able to participate meaningfully. Furthermore, the only engagement that seems to be open to the public is through ad hoc updates to the CDT website, or by attending an ad hoc webinar. TURN encourages CDT to revise the Draft Plan to include a schedule of dates when updates will be provided to the public (i.e. biweekly, monthly, bimonthly, quarterly, etc.), concrete steps on how the various committees and groups are to be engaged, and clear instructions on how to join each group.

Turning to Key Activity 4, “[l]aunch the California Connect Corps and digital equity grant programs to expand community-based digital inclusion programs,” (Draft Plan, pages 22-23), TURN finds it troubling that CDT was unable to provide either specifics on the grant program, or information on how those specifics will be developed. TURN suggests that CDT revise this section to include details on the application process, eligibility criteria, award amounts, and other pertinent details. If program details have not been finalized at this time, then CDT should provide information on how people can meaningfully participate in the development of the grant program and outline a transparent plan to provide the public with program details. The Draft Plan should also provide some insight into the exact dollar amount that will be dedicated to California Connect Corps, the dollar amount dedicated to other grant programs mentioned in the Draft Plan, and the amount budgeted for each of the other key activities listed.

More generally, TURN provides this feedback on the key activities related to service. In the comments above, TURN identified concerns with resiliency and now provides feedback to the Draft Plan’s target to achieve “universally reliable service by 2030” (Draft Plan, page 26 (Objective 1.3)), through a series of key activities (Draft Plan, pages 112-120). Completing the existing infrastructure efforts should include ways to “ensure new broadband infrastructure is resilient to wildfires and disasters,” as stated in the draft (Draft Plan, page 113). However, this effort should be complemented with efforts to use these same or similar methods for existing infrastructure that supports broadband service because existing and new elements in the network must function, even with backup systems, during times of wildfires and disasters. Hardening, redundancy, and alternative pathways are the designs that ensure that broadband service is not disrupted at times when customers need to communicate with or receive important and timely information from government offices, utilities, and broadband service providers. For example, efforts to have backup power (such as batteries or generators) to power important broadband service equipment are needed not just within the new structure but also in the existing equipment. Places in California inside high-fire threat areas are especially susceptible to disruption, and yet, these residents are most in danger of losing communication if they cannot use their broadband service. Ensuring resilient strategies on new infrastructure deployments alone is only a piece of a bigger puzzle. Continuing this pathway without addressing the current infrastructure is not going to reduce the high percentages of dissatisfaction with broadband service drastically.

As the CDT considers key activities related to resiliency and reliability and their corresponding objectives, it should consider clarifying the distinction between resiliency and reliability and accounting for the CPUC’s BEAD Initial Proposal and existing resiliency requirements.

First, the Draft Plan should clearly distinguish between the concepts of reliability and resiliency. While interrelated, resiliency and reliability represent distinct qualities of a network—where reliability relates to the general availability and quality of the service, and resiliency refers to the ability of a network to survive and quickly recover from specific events, such as a natural disaster like a wildfire. Yet, the Draft Plan identifies the objective to “increase the percentage of California’s who report that their internet service is reliable” without a corresponding key activity related to reliability, (Draft Plan, page 15, Objective 1.3). Likewise, the Draft Plan identifies a key activity to “[e]nsure new broadband infrastructure is resilient to wildfires and disasters” without a corresponding resiliency objective (Draft Plan page 113). In other places, the Draft Plan uses the terms resiliency and reliability interchangeably (Draft Plan, page 67, Key Activity 1). The Draft Plan would benefit from greater internal consistency. CDT should ensure that both resiliency and reliability are clear objectives and accompanied by corresponding key activities. People in California rely on internet access every day, from being able to have reliable access for daily activities like remote education or telehealth or during an emergency when internet access would be needed to communicate with emergency responders or receive time-sensitive information.

Objective 1.3 should add resiliency and read as: Increase the percentage of Californians who report that their internet service is reliable and reduce the number and duration of internet service outages during and after a natural disaster.

Strategy for Goal 1 should incorporate reliability: Ensure new broadband infrastructure is more reliable and resilient to wildfires and disasters.

Finally, Key Activity 1 should add a bullet to account for its reliability objectives: Ensure new and existing broadband infrastructure is made more reliable. Aligns with California’s efforts to consider service quality requirements for broadband and recognizes the essential nature of reliable broadband access for full participation in society.

Moreover, the Draft Plan should acknowledge the CPUC’s BEAD Initial Proposal submitted in December 2023, which acknowledges the CPUC’s existing resiliency-related requirements. The NTIA’s Notice of Funding Opportunity (NOFO), which implements the federal BEAD-related statutory provisions, directs the state to ensure that the BEAD program-funded network “outages should not exceed, on average, 48 hours over any 365-day period except in the case of natural disasters or other force majeure occurrence” (NTIA, BEAD NOFO, page 65). The NOFO requires the state to ensure that networks are designed to meet this requirement and directs states to establish and enforce performance metrics once the networks are operational (id.). The CPUC’s Initial Proposal outlines adopted risk mitigation processes in the section designated “12.4 Strategies for mitigating climate risks,” and goes on to observe that “[p]roviders are required to provide 72 hours of backup power for their facilities in Tier 2 and Tier 3 high fire threat districts in order to maintain minimum service during disasters or electric grid outages” (BEAD Initial Proposal, page 183). Furthermore, the CPUC outlines its strategies to meet the NTIA’s resiliency directives (BEAD Initial Proposal, page 182).

The Draft Plan acknowledges that the CPUC is actively engaged in promulgating resiliency standards (Draft Plan, page 39). However, since the release of the Draft Plan, the CPUC has provided clarification on existing requirements and proposed additional resiliency strategies as part of its required submissions to the NTIA (Initial Proposal, pages 182-183). Incorporating these existing requirements and new proposals would strengthen the Draft Plan because they would provide means to address the risks of wildfires and disasters identified in the Draft Plan (Draft Plan, pages 14, 54, 95, 113).

Key Activity 1 should be modified to reflect these existing requirements: Ensure broadband infrastructure is resilient to wildfires and disasters. Given California's susceptibility to natural disasters, such as wildfires and earthquakes, this Plan recognizes the need to ensure that infrastructure deployments meet the state’s resiliency requirements as well as other best practices for resiliency.

The Draft Plan would also benefit from acknowledging the CPUC’s Decision 21-10-020, which requires a facilities-based provider to submit a Tier 1 advice letter to the CPUC and impacted communities when a declared disaster damages a provider’s facilities or causes a service outage (CPUC, Decision 21-10-020, Ordering Paragraph 4, pages 27-28). The covered provider must also meet in-person with the impacted community to “discuss any rebuilding plans and consider incorporating any comments made by the affected community while working on their restoration” (Decision 21-10-020, Ordering Paragraph 5, page 28).
4871January 25, 2024 at 4:34 pmRegional Planning Program ManagerOrganizationSan Diego Association of GovernmentsSan DiegoCA2. Introduction and Vision for Digital Equity
SANDAG appreciates CDT’s attention to the impactful work taking place at the local level by incorporating the regional plans. SANDAG is actively engaged in addressing digital equity challenges, evident in the development and implementation of our dedicated Digital Equity Strategy and Action Plan. Within the San Diego Region, numerous organizations have devised their own comprehensive strategies to address the digital divide. These organizations, which come from a wide variety of backgrounds and have many distinct missions regularly collaborate through our region’s Digital Divide Task Force. Many regions throughout the state have similar regional or local collaboratives that have profound insight into their locale’s greatest needs. We encourage the CDT to leverage these existing collaboratives when implementing future grant programs and initiatives.
4870January 25, 2024 at 4:31 pmRegional Planning Program ManagerOrganizationSan Diego Association of GovernmentsSan DiegoCA1. Executive Summary
The San Diego Association of Governments (SANDAG) brings together local decision-makers to develop solutions to regional issues, including Digital Equity efforts in San Diego. We appreciate the California Department of Technology’s (CDT) work in fostering equitable broadband access across California. The State’s commitment to bridging the digital divide is crucial to addressing equitable outcomes throughout the State and aligns with SANDAG's own Digital Equity Strategy and Action Plan.

Increased affordability and access to digital skills are pivotal objectives to bridging the digital divide. In that regard, SANDAG requests that CDT ensures that eligible state and federal funding sources are directed to the communities and households of the most need and the most affected by the digital divide. Prioritizing the allocation of resources to these underserved communities will contribute significantly to achieving equitable access to digital opportunities, fostering inclusivity, and narrowing the digital divide.
4869January 25, 2024 at 4:30 pmBroadband Systems EngineerOrganizationMarin County, Digital MarinSan RafaelCA1. Executive Summary
Executive Summary
The County of Marin and the Digital Marin project supports the State Digital Equity Plan (SDEP) vision and is dedicated to collaborating with the many public and private partners working to bring equitable, resilient, affordable broadband access and digital literacy to the residents of our eleven municipalities and twenty-nine unincorporated communities.

We fully endorse Key Activity 4: Launch the California Connect Corps and digital equity grant program to expand community-based digital navigation and digital inclusion programs to uplift, fund, and promote Digital Navigator Service Providers.

We additionally support Key Activity 3: Evolve broadband and digital equity data and maps. We laud the state and federal government for developing user-friendly first-generation national and state broadband maps and datasets that identify all "broadband serviceable locations" at the address level in our counties.

The FCC National Broadband Map identifies the internet service providers for each location, the type of service (fiber), and advertised speeds. FCC regulations require all ISPs to report this data every six months, finally allowing local governments to track public and private broadband infrastructure and access investment in their communities.

However, the term "evolve" must result in giving local governments the ability to not only combine state and federal broadband data with local parcel and housing data, for example, but to share the data with internal and external partners as freely as possible.

“Fabric” license agreements between private and public entities could severely inhibit data sharing by introducing uncertainty, risk, and legal jeopardy. The state is encouraged to mitigate these barriers if it expects to realize the transparent collaboration levels envisioned in the plan.


THE IMPORTANCE OF DATA SHARING

County broadband offices are experts in identifying broadband funding sources and understanding the competitive broadband landscape, local housing, and the potential location of covered populations.

Digital Navigator Service Providers are experts at working with people and providing digital equity solutions.

Data sharing streamlines the process of finding real people living in real homes with real problems that can be solved through public and private investment and partnership.

Over the last several years, three private residential "fiber" providers have entered the Marin residential market, overbuilding the incumbent cable company, which held a monopoly position for over twenty years, generating an estimated $125 million in annual revenue. However, the largest of these companies chose to construct "cherry-picked" networks in highly curated sections of select, often wealthier neighborhoods composed of single-family homes, bypassing apartment buildings and condominium complexes even when they are next to a household with fiber service.

Many of Marin's low-income and often larger families with school-age children live in apartment buildings with one choice of high-speed internet service provider – the cable company. Where fiber is available, we currently see non-discounted advertised prices for existing customers that are 35%-50% lower than the cable company for the equivalent, if not superior, level of service required to meet larger households' minimum in-home computing demands.

Unlike other essential services like water or electricity, where every household has equal access to capacity and the ability to manage consumption, broadband is sold by bandwidth bottlenecks, with each bandwidth or speed tier capable of supporting a reasonably predictable but limited number of users and devices.

When a larger, low-income household that needs 800 Mbps of bandwidth to meet its daily computing demand is forced to downgrade to lower speeds to meet its budget, everything in a family’s digital daily life is downgraded. This is the affordability gap defined.

Digital Navigator Service Providers should be able to quickly locate potential covered populations, like those described above, without duplicating efforts already undertaken by local governments. Data sharing closes the data gap and lays the foundation for effective partnerships and successful public investments.
4868January 25, 2024 at 4:18 pmDirector of PolicyOrganizationRebuild Local NewsWashingtonDC4. Collaboration and Stakeholder Engagement
January 25, 2024

To the California Department of Technology,

We write to you as a national organization representing more than 3,000 newsrooms nationwide, including hundreds in California. Our organization advocates for smart public policies to support the future of the local press. We believe your office has a significant opportunity to support the continued development of a robust local press in California while also pursuing broadband access and digital equity.

We are joined by our partners Alameda Post, El Tímpano, Cityside Journalism Initiative, Shasta Scout, India Currents and L.A. Public Press.


We applaud California’s demonstrated commitment to achieving the full promise of digital equity, including highlighting internet access as essential to civic participation. However, we would encourage the CDT to incorporate local newsrooms in its inventory of "trusted messengers" for the California Connect Corp and related grant programs, particularly on projects relating to digital literacy and civic engagement among covered populations. As the plan states, “CDT recognizes that some key activities must be more targeted to certain populations whose needs are greater than others.” It is essential that those resources and services leverage the trust California residents have in the diverse constellation of media outlets, languages, and platforms that are closest to Californians of all ages and ethnicities. California’s local newsrooms already play an essential role in supporting the civic health of communities and have been building programs to address the gaps in digital skills. The Public Media Group of Southern California has been a founding and active member of the Internet Action Team in L.A. County, a coalition of business, non-profit and civic leaders dedicated to creating an equitable Los Angeles. El Tímpano, a news outlet that serves the Latino and Mayan communities in the Bay Area, participated in Townlink, an initiative led by The Greenlining Institute and the City of Oakland to close the digital divide. El Tímpano provided information for Latino and Mayan immigrants on digital access resources. Also, encouraged by their community leaders and audience engagement group, the LAist in mid-January officially dedicated an editorial beat to Digital Equity.

Although trust in institutions, including the press, is falling across the U.S., trust in local news remains high, even accounting for variations in political affiliation and generation. Residents of California already trust their local newsrooms, particularly those owned and operated in California, to give them credible information about their communities and their state. The CDT could and should leverage that trust in advertising new and upgraded broadband services and digital skills-building programs throughout the state, particularly outlets that serve covered populations where they live and in the languages they communicate in. The plan notes that while California has been a leader for years in digital equity, a gap analysis shows that lack of awareness and engagement is a key barrier to achieving digital equity goals. “The role of community engagement in promoting digital equity supports and services cannot be stressed enough.” Taking this approach as the CDT rolls out new programs, opportunities and resources would not only leverage the trust audiences have in their local news outlets, but support local newsrooms, which are a vital community resource. In fact, California has already been successful at leveraging the trust Californians have in their local news outlets to promote important public awareness messages via the California State Library System’s Ethnic Media Outreach Grants program.

Moreover, many of these outlets already practice what the CDT identifies as digital literacy programs. For example, El Tímpano collaborated with local grassroots organizations as well as national experts on dis- and mis-information to develop its own curriculum that uses popular education to train Latino immigrants on what dis- and misinformation is, how to recognize it, and steps they can take to defend their communities against the spread of disinformation. This media literacy initiative has been recognized by leading experts in disinformation as a groundbreaking and impactful approach that, unlike many other disinformation initiatives, is led from the ground up. This and programs like it could be scaled across covered populations to address digital and media literacy gaps.

Moreover, the connection between local news outlets and digital equity runs deeper still. Digital equity describes the conditions in which residents have the resources, infrastructure and skills to be full participants in their democracies, economies and societies, which is impossible to achieve without strong local news. A robust body of research completed over the last two decades has shown that areas that lack local news have lower voter turnout, less competitive elections, fewer residents informed about their Congressional representation and less likelihood of even Googling the mayor. California communities are no different. Annelise Pierce, managing editor of Shasta Scout, said “Countless readers have told us that the ability to learn about public meeting agenda items of importance has allowed them to advocate for a better community in the ways they wish to.” But it doesn’t stop there. A journalist who studied successful news outlets in West Virginia wrote, “There is an undeniable correlation between a strong local news product and a persevering local business dynamic.”

In the past, the civic scaffolding provided by local news could be, broadly speaking, counted on. However, Northwestern University, the leading news desert watchdog, now estimates an average of 2.5 newspapers close weekly. Local nonprofit newsrooms, public broadcasters and digital-native upstarts are creatively working to fill gaps, and many of the remaining newspapers are ambitiously innovating their business models. Still, it’s not enough to make up for the precipitous losses. In California, Glenn, Sutter, Sierra and Alpine counties are all news deserts. Alpine County is what Rebuild Local News calls a double desert, meaning it lacks both local news outlets and access to high speed broadband services. These statistics do not account for communities in cities that are un- or underserved by local news and have limited access to broadband. They also don’t account for areas that seem to have local news, but the outlets lack the resources to cover the community well. In California, Salinas attracted national attention when the L.A. Times revealed Salinas had no local newspaper to report on local government actions and profiled its negative effect on its citizens.

Areas that lack robust local news tend to be rural, have higher than average poverty rates, lower than average education attainment or a high concentration of residents who speak a language other than English. These criteria closely mirror predictors of poor broadband access or adoption. Yet, building broadband alone in these communities without fortifying local news will not fulfill the full promise of digital equity. As research has shown, it will exacerbate division by filling the information void with national news or outright disinformation, neither of which provide the civic benefits of local newsrooms highlighted above. One expert even told Rebuild Local News building out broadband access without also shoring up local news is like providing “high-speed access to garbage.”


In the plan, CDT highlights the need to increase accessibility to government services and information to improve outcomes for essential services. While we applaud the focus on improving government websites and accessibility standards, we stress that supporting the role of local news to engage and inform communities on the actions of their leaders and the effects they have on their lives is crucial to supporting civic engagement. Local newsrooms often act as an unofficial community forum, inviting members of the public to discuss important civic and community issues. For example, Oaklandside invites members of the community to write essays on issues like Covid-19 or gun violence in its Amplify Oakland series. Meanwhile, the L.A. Public Press empowers community members to confront civic and community challenges by publishing explainers. India Currents also brought seniors together to educate them on the Stop the Hate campaign, while also sharing stories about their lives as new Americans. These are but a few examples of the ways local news outlets serve covered populations. Local news outlets are in a perfect position to train communities and leverage broadband programs to provide local news and information, an essential component of digital equity and sought-after outcomes of universal broadband.

The CDT should also think strategically about how to strengthen local news resources in areas that lack both local news and broadband resources or with high proportions of covered populations. Such investments would meet the civic objectives of California’s Digital Equity Plan and increase the likelihood that all of California’s digital equity investments will be sustainable, resulting in long-term civic participation among all residents. The CDT could also consider funding projects that dedicate reporting resources to covered populations, particularly rural communities. The CDT could proactively mitigate barriers by funding reporting efforts across the state by partnering with state broadcasters, statewide nonprofits or news outlets that are proven to serve covered populations. To that end, special attention should be paid in areas that both lack local news and broadband services, like Alpine County. California already has resources that could be mobilized to support these objectives. The state could partner with the Berkeley Local Journalism Fellowship program, launched with a $25 million investment from the California legislature, to build the capacity of newsrooms that reach covered populations and/or fill existing information gaps. Projects like these could be strategically scaled in areas with high concentrations of covered populations and limited broadband access or adoption. Such a strategy would support the civic infrastructure of California communities, making it more likely that California’s digital equity investments will be sustainable and result in robust civic participation among all California communities.

We thank the California Department of Technology for its careful, diligent efforts to advance broadband and digital inclusion throughout the state. Its thorough and ambitious plans will surely help connect California residents to a better, more connected future.

Sincerely,

Madeleine Bair
Founding Director, El Tímpano

Annelise Pierce
Managing Editor, Shasta Scout

Adam Gillitt
President & Publisher, Alameda Post

Cityside Journalism Initiative

L.A. Public Press

Vandana Kumar
President and CEO, India Currents Foundation

Anna Brugmann
Policy Director, Rebuild Local News
4867January 25, 2024 at 4:13 pmS.W.ResidentCosta Mesa926262. Introduction and Vision for Digital Equity
Wireless will set the state back in terms of climate change management because wireless uses a huge amount of energy compared to WIRED broadband.

Wired infrastructure offers greater capacity, predictable performance, lower maintenance costs, and a longer technological lifetime than wireless technologies. Fiber service is not degraded by line-of-sight issues and is not affected by capacity issues.
4866January 25, 2024 at 4:12 pmProject ManagerOrganizationCalifornia Alliance for Digital EquityCA1. Executive Summary
The California Alliance for Digital Equity values the opportunity to provide feedback on California’s draft State Digital Equity Plan. We are a dedicated group of local and statewide advocates focused on all forms of digital equity, from device acquisition to broadband access to digital literacy.

Vision, Goals, and Objectives

CADE values the California Department of Technology (CDT)’s work in preparing the draft Digital Equity Plan. The Plan offers many important objectives and goals to close the digital divide. However, it concerns us that these objectives are paired with very limited implementation plans that lack detailed tactics or measurements for success. CADE urges the department to strengthen the Plan’s objectives with more clarity, specificity, and a clear timeline of actionable steps for how the objectives will be addressed. Without a clear, actionable timeline, the plan lacks accountability for the objectives to be met. Other published state digital equity plan drafts (ex/Pennsylvania) have included such timelines, and more specificity including measurable objectives, key performance indicators, short-term targets, and long-term targets.

We also caution against defining availability, access, and adoption goals in the Plan as unique from one another and/or separate. Broadband availability, access and adoption issues that plague Californians today are different but interrelated. According to a recent University of Southern California Annenberg School for Communication and Journalism and the California Emerging Technology Fund survey, Californians spend an average $83.60 per month on broadband, and such exorbitant costs are the top barrier to adoption. This is just one of many data points that clearly demonstrate affordability and adoption are correlated, and it is important to clearly recognize these linkages in the Digital Equity Plan.

Notably, certain solutions to the goals and objectives outlined in the Plan are also interconnected. For example, if the state achieves objective 1.4, increase the percentage of Californians who have a choice of at least three internet service providers, we believe that will be a solution to objectives 2.1 and 2.4 as communities will see a healthier market competition between providers. As California Community Foundation and the Electronic Frontier Foundation (EFF) have revealed in a policy memo, having one or two options results in low-quality and unaffordable internet, leading to low adoption rates. We would go a step further with respect to objective 1.4 to say that the State should invest in options that ensure most people have at least one public option, in which public interest usurps profit motive. In EFF’s 2021 paper, Wholesale Fiber is the Key to Broad US FTTP Coverage, a wholesale model - public open access infrastructure leased to providers - was predicted to serve 95% of Los Angeles County and be cost effective.

Finally, in order to address equitable access and meet any of the Plan’s outlined goals, it remains critical for the State to stop relying upon existing CPUC and CDT maps in making investment decisions, and instead use other tools such as Socioeconomic Vulnerability Index, or the State needs to make large investments to completely transform broadband and digital equity data and maps. We need a clear picture of the California residents who are actually being served, rather than who could be served, which requires the use of granular adoption data.

5. Implementation Strategy & Key Activities
The California Alliance for Digital Equity values the opportunity to provide feedback on California’s draft State Digital Equity Plan. We are a dedicated group of local and statewide advocates focused on all forms of digital equity, from device acquisition to broadband access to digital literacy.

1. Expedite and complete existing Broadband for All infrastructure efforts

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. Our partners have raised many concerns about last year’s dramatic changes to the Middle-Mile Broadband Initiative (MMBI) network map, specifically about how the revised map deprioritized broadband infrastructure buildout in historically disenfranchised communities that lack affordable, reliable internet across the state. It is our understanding that network changes have been made partly to expedite MMBI buildout. This is disappointing, as the least connected, most disadvantaged communities always deserve to be prioritized over the speed of buildout in all Broadband for All projects. Otherwise, these projects will not meet their goal of working to close the digital divide and they will be an unfortunate waste of taxpayer dollars. Emphasizing the significance of infrastructure build-out in communities of color and low-income communities across all geographies (rural, urban, and suburban) is imperative.

Separately, CADE recommends that CDT establishes a third-party or additional oversight to ensure accountability that affordable pricing is built in with the additional ISPs in communities providing service.

Finally, 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.

2. Convene digital equity stakeholders to strengthen collaboration

CADE encourages CDT to establish new stakeholder outreach strategies to meaningfully connect with the many community and advocacy stakeholders that are actively engaged in the Broadband for All projects. While we appreciate the opportunity to attend and provide public comment at quarterly California Broadband Council (CBC) and Middle-Mile Advisory Committee (MMAC) meetings, the meetings offer very limited time for exchanges of information and communication. While members of the CBC and MMAC have over an hour to present information and updates, stakeholders and members of the public are provided with just two minutes. This is not a true or equal exchange of discourse or ideas. As a result, CADE highly recommends CDT hosts more stakeholder engagement events (ex/stakeholder roundtable discussions, public Q&A events, etc.) at which community stakeholders and CDT leadership can have in-depth conversations about Broadband for All initiatives. CADE also encourages CDT to commit to using insights from these events to guide the future direction of projects like the MMBI.

3. Evolve broadband and digital equity data and maps

In its current form the Plan states that CDT aims to “evolve” CPUC and CDT maps. That is simply not enough. We urge CDT to seek a complete transformation of the maps utilizing community-provided data.

The core issue afflicting state broadband infrastructure projects is the current use of inaccurate, discriminatory data. The FCC, CDT, and CPUC data on unserved and underserved populations is substantially incorrect and its statistically significant inaccuracies massively understate the unserved populations in low-income neighborhoods both in rural and urban neighborhoods and especially in multi-dwelling complexes. The primary data used to create the maps are mainly based on the information provided by internet service providers (ISPs), which renders the maps incomplete and not representative of the actual gaps in broadband access.

Under current regulations, fixing inaccuracies of the broadband maps requires the submission of challenges. The arduous nature of these challenges and lack of process transparency are a deterrent for consumers, communities, and cross-sector stakeholders to engage, ultimately weakening the ability of the maps to prioritize the funding and investments in broadband deployment.

Together, these mapping and data collection issues are the most significant barriers the State faces as it aims to close the digital divide and achieve digital equity across California.

Continued reliance on such flawed maps, without swift and substantial corrections, risks perpetuating decades of disinvestment in low-income communities and communities of color. This perpetuation exacerbates the digital divide rather than addressing it. As has been proven in multiple recent reports from various groups across the country, including the CCF’s pricing discrimination report, the UC Santa Barbara, and others, private companies tend to prioritize investments in high-income communities, leaving historically redlined areas with subpar infrastructure, limited options, and higher prices. It would be regrettable for the State to follow a similar trajectory. It is imperative to ensure that every home in underserved communities is accurately represented in data collection efforts.

Moving forward, the State should not use existing FCC, CPUC, and CDT maps to make its investment decisions. Instead, CADE urges CDT to seek a complete transformation of the maps utilizing community-provided data. CDT can do this by:

- Including various data sources such as community-anchor institutions and community-based organizations would help to illustrate the realities on the ground and which communities should be prioritized first;
- Maintaining a publicly accessible data-dashboard with toggle options to switch between calendar years to view the evolution of the maps would be helpful for communities to engage and provide feedback;
- Changing the process of submitting challenges would help increase engagement from communities and help illustrate the realities of communities in need;
- Creating a publicly accessible tracker to increase transparency and communication with the public on what has been done thus far with the broadband maps, at what stage they currently are, and what the next steps are needed to continue improving the accuracies of the maps; and/or,
- Using a third-party to increase oversight and accountability on the monitoring, assessment and evaluation of the steps used to evolve the maps.

By implementing these changes to the mapping and data collection processes the State will be able to access more precise and accurate data points that will reinforce the groundwork for equitable infrastructure development. Without accurate broadband maps, the State will not have the essential, foundational tools needed to effectively prioritize spending its limited funds where there is the greatest need.

7. Secure consumer subsidy program sustainability

It is commendable that the CDT prioritizes affordability for Californians and addresses the barriers faced by communities. However, the current objective appears somewhat vague and lacks emphasis on the crucial need for a long-term program ensuring affordable services. The ongoing advocacy for an extension of the Affordable Connectivity Program (ACP) is set to conclude in April 2024, with new applications freezing February 8, 2024. With this looming deadline in mind, CADE recommends that CDT focuses on advocating in support of extending the federal ACP program by:

- Engaging with federal representatives;
- Utilizing partnerships with broadband service providers, industry associations, community organizations and advocacy groups to collectively work together in advocating;
- Using reputable data to demonstrate the economic, educational, and social benefits resulting from affordable connectivity;
- Public awareness campaigns;
- Leveraging the CDT's influence to foster coordination among local and state entities in support of the extension; and/or,
- Media engagement.
4865January 25, 2024 at 4:11 pmDigital Literacy ManagerOrganizationSan Francisco Public LibrarySan FranciscoCA3. Current State of Broadband and Digital Inclusion
In our experience at SFPL, we often see seniors seeking digital assistance. They do so for a variety of reasons and come to us because we are trusted in the community. Perhaps the initial listed barrier on the draft; "Lack of perceived need," can be rephrased to clearly iterate that older adults want to be connected, given the opportunity to learn. Once gaining understanding, they often want to gain broadband access and engage digitally. In some cases, they are being asked to engage digitally with minimal instruction or opportunity and time to learn.

Our seniors want to be digitally savvy, they come with the hope that a little instruction will help them learn how to get and manage email, use their smart phones as an information source and connect beyond a voice call. Eagerness to learn exists, sometimes pacing support is required and instruction is best in small groups or on a 1:1 basis to ensure the grasp of concepts that are new and sometimes hard to recall if not practiced regularly.

Once gaining some basics, we see great interest in learning how to access fast internet to support devices that they may be learning to use and apps that they have come to enjoy.

Perhaps a statement that best describes the challenges that seniors face in digital learning is the lack of in-language digital skills and training access when they need it. The challenge is providing enough skills training at the right time and having the staffing, time and place to provide it, that is convenient for the learner and in the language that they need it. We serve a multi-lingual community and finding instructors in the language of need to meet the need can sometimes be a challenge. We try our best to meet the need of patrons with the resources we have and through community partnerships.

It is nice to see that the SDEP highlights (ps. 83) the need for access to assistive technology (AT). However, a challenge we see at the library is a lack of AT training availability for the end user. There are limited places where people with disabilities can learn about how AT may improve their individual digital literacy and digital access. Agencies often don’t know about the range of AT available to support people with disabilities, may lack access to the AT and the training necessary to teach a person in need of AT. At our our library we have access to AT computers with AT software to support users who are blind, low-vision or have reading difficulties. However, we face staffing and other challenges in supporting users of AT software. There also seems to be a lack of places in San Francisco where users can seek to learn how to use AT.
4864January 25, 2024 at 4:00 pmDirector of TechnologyOrganizationSan Rafael City SchoolsSan RafaelCA3. Current State of Broadband and Digital Inclusion
We serve families that do not have the funds, the understanding (language barrier or knowledge) or the housing for internet access. In our community, we have a number of families that are "doubled up" in a house. This means they are living in someone else's house, often in insecure circumstances (they can get kicked out at any time) who don't have the option to even establish any internet as internet service is often already for the owner /attached to an address who does not share this with the family.

How might we better established internet access that does not require a family or child to drive to a public area (parking lot as an example) at night to have access? As a district, we simply do not have enough funds to serve all of our non-internet families with hotspots. We had to choose to address our most impacted (homeless/shelter) as a priority.

In the past, I have found that reduced rate prorgrams for qualifying families through large companies (that were required at one point to do) like Comcast still was difficult for folks to navigate - proof of this, verification of that, etc. How can this be made easier?

I LOVE that you have education and training for families! Very much needed in many places.

In Marin County, there is a definite need for additional infrastructure and towers. Some of our schools struggle with consistent connectivity which affects student ability to work at times.
4863January 25, 2024 at 3:56 pmTech Equity FellowOrganizationThe Greenlining InstituteOaklandCA5. Implementation Strategy & Key Activities
*Note: This comment is pasted from a PDF document. Full document and citations are available here: http://tinyurl.com/Greenlining-Comments

Introduction:

The Greenlining Institute works toward an equitable future which allows for communities of color to build wealth, live in healthy areas, access economic opportunities, and are ready to meet the challenges posed by climate change. As an organization, we see closing the digital divide as a necessary step in equipping communities of color with the tools and connectivity that is necessary to survive and thrive in today’s society. In today’s day and age, access to vital information and opportunities are increasingly found online. Because of this, many Californians who lack access to functioning devices, quality internet, and high-grade infrastructure continue to experience the negative effects of a growing digital divide and are unable to fully participate in today’s technologically connected world. As a way to combat this, it is imperative that the California Department of Technology (CDT) listens to the needs of communities across the state and grants the necessary tools needed to achieve the goals outlined in the State Digital Equity Plan (SDEP). In response, the Greenlining Institute (GLI) submits the following comments.

Encouraging CBO Participation, Expanding Digital Inclusion Digital Navigation Activities Within the State

The first area in which the CDT can improve the SDEP is within the key activity of launching the California Connect Corps and the activities thereafter. Under this initiative, the main goal is to “support nonprofit organizations to conduct outreach to underserved populations to advance digital inclusion (pg. 114).” In order for such a goal to be achieved, there needs to be inclusionary processes for which nonprofits can partner with the state in closing the digital divide.
One way that the state of California can enhance the process and encourage more participation by local organizations is to learn from and implement similar processes undertaken by other states. For example, in Pennsylvania, a key part of their digital equity plan details that the state will seek to:
Establish a separate bucket of funding using up to 10% of the total Digital Equity Act funds received by Pennsylvania to be set aside for small organizational subgrantees that have small budgets and limited staff; specific definition to be developed after the amount of funding is known (p.105)
In emulating a plan like this, California should set aside a similar percentage of funding for organizations that are often overlooked and assist them in procuring resources for their projects. To further simplify the CBO application process and increase overall participation, the CDT should also implement a ministerial review process, similar to the process developed by the CPUC in the California Advanced Services Fund Adoption Account program which streamlines grants for digital equity programs that fit certain financial criteria, through a rapid approval process.
As it stands, the ministerial review procedure requires that “the applicant has at least one year’s experience conducting digital literacy training or broadband access project or if they have completed at least one digital literacy training or broadband access project (pg. 3).” While this helps ensure that experienced members within the digital equity space are continuing this work, it has the potential to disregard smaller organizations that may be a good fit but lack the experience or confidence to participate in these programs. In GLI’s Town Link Report, a key recommendation is that organizations that may not have existing experience in digital inclusion efforts but “have existing intake and referral services and can add digital navigator services to their portfolio” (pg. 6) should be specifically targeted for funding due to the fact that digital equity work would easily fit into their current infrastructures. Moreover, in order to further diversify partnerships within the program and prioritize organizations that were based in communities of color and low income neighborhoods, GLI utilized other criteria to determine an applicant's ability to conduct digital equity work. This included examining their methods of interacting with priority community members and the strength of these communication channels. By using these unique markers, organizations were able to demonstrate their existing strengths and commitments even if they were new to the digital space. In addition to implementing a more holistic selection criteria such as that in the Town Link program, the state should also make it accessible for grantees to partner with each other and utilize each others’ resources. In the case of Town Link, digital literacy training organizations were able to partner with local organizations that conducted recruitment among their community to build out classes for digital literacy. Providing digital literacy resources for grantees, improving application requirements, and implementing unique qualifying markers for applicants can and should be replicated on the state level so that a variety of committed organizations can have an equitable chance at doing their part in closing the digital divide. In a similar vein, the department should also set aside funding to recruit such groups -especially in communities of color- and assist them in the application process. Through targeted and strategic forms of help, participation in these very communities will inevitably rise and in doing so, the state of California would position itself as a state which creates opportunities for trusted organizations to succeed no matter where they are based, their size, or their initial scope of work.
To further address small organizational participation, the CDT should allocate additional funding for enrollment support. As found in the Town Link report, resources such as digital navigators prove to be invaluable as they work to connect and enroll residents in programs like the ACP. More importantly, much of this work is “provided in-person, [with] step-by-step enrollment assistance to interested residents (pg. 33).” On the other hand, it was reported during the Town Link initiative that while digital navigators proved to be essential, “partners indicated that guiding community members through enrollment processes often consumed significant time and resources (pg. 33).” Thus, there is a critical and demonstrated need for additional funding which would allow CBOs to offer in person services regardless of any time and resources required.
Furthermore, the state should create its own team of digital navigators who can be deployed throughout the state. In their digital equity plan, the state of Pennsylvania once again raises a strong point on this matter when they point out that “while volunteers at libraries, non-profits, and other organizations have been instrumental in providing digital skills services, there is a huge need for paid digital equity professionals, including digital navigators (pg. 24).” By offering pay for these positions, California would take on a critically important role in providing a vital tool for organizations to rely on, especially if they currently lack the funds, resources, and infrastructure on their own to sustain this critical position. Thus, organizations can pivot their focus and resources in different ways to further contribute to the goal of closing the digital divide. Additionally, by creating its own department of digital navigators, the state stands not only to increase overall enrollment of the position but ensures longevity of a highly needed public resource.
The last way in which the CDT can incentivize more participation from community organizations can be through activities that begin before the official application period opens. Specifically, the department should publish a clear checklist of requirements that is quickly distributed to counties and then to organizations. After this, state employees should also conduct information sessions where the checklist can be used as a primary tool and during these sessions, organizations will have the opportunity to get real time help with their applications as well as clarity on the process and requirements for funding. As always, such sessions should be offered in person as well as online so as to ensure that community members have all opportunities to join.

Develop and promote digital inclusion tools and best practices

In the current version of the SDEP, it is stated that “the State will continue to work to improve and expand the myriad digital inclusion programs and services offered by State agencies and other statewide partners (pg. 115).” One way for California to explore ways to improve digital inclusion programs is by conducting workshops with the goal of meeting people where they are. In doing this, the work should not stop at conducting informational sessions in the usual library, church, or school but should also be in more intentional spaces. For example, if a high need area has multiple apartment spaces, the state can look into utilizing the common spaces in these living communities in order to garner more participation even if it is with smaller but more frequent meetings in various locations. As it pertains to these workshops, digital literacy requirements should be expanded to include an emphasis on digital safety, specifically how to keep vital information safe and how to know who to trust when giving up vulnerable personal information. Advertising for this should also not be limited to bulletins or website announcements and should also be channeled through social media or text campaigns. Again, in doing so, the state will be meeting people ‘where they are’ even in the virtual space.
Another important aspect of demonstrated need which requires improvement is access to technological tools such as computing devices. With the funding, the CDT needs to work to get devices into California households while keeping costs realistic. One opportunity is to partner with industries that have high technology turnover rates such as banks, government agencies, and universities. Another option is to partner with refurbishing companies to offer devices at a lower cost with warranty options that suit the needs of consumers.
Promoting Low-Cost Offers and Resources Within the State
Currently, in an attempt to combat unaffordable prices for internet services, programs such as ACP and Lifeline exist for low-income communities. While this is a vital resource for California, it is still underused compared to the amount of need that is demonstrated within the state. For many, this is due to the fact that they simply do not have knowledge of the program or that they are eligible. As a measure to combat this, the state should use existing services to its advantage for outreach purposes. In the state equity plan for Pennsylvania, the state details their utilization of their PA 211 system which connects Pennsylvanians to resources and assistance on a statewide level. Taking this into account, California should use similar systems to notify residents of this program. For example, in Alameda county, the 211 information portal and phone number is used to convey transit information, health and housing information, and reentry information. Using this portal would be an imperative opportunity to ‘meet people where they are’ and add digital resources to this already highly utilized product. Moreover, to build on this the department should also focus on adding digital resources sections to information based apps and web services for the counties that have this infrastructure in place, such as the FresGo app in Fresno county. In both instances, California should also add a feature to allow individuals to check their own eligibility (as is the case in Pennsylvania) as doing so would only prove to increase awareness and usage of the program and make it easier on the individuals in priority areas to sign up.
The last case in which the CDT can improve the outreach for low cost programs would be to emulate successful methods demonstrated by other agencies. A notable example would be the getcalfresh.org website where users are easily able to apply for food stamps “in 10 minutes.” Through the straightforward process and easy-to-use interface, many more Californians are able to access this vital resource quicker than ever before. In regards to improving the experience for ADP eligible customers, the department should require that in addition to allowing Californians the opportunity to find providers in their area, customers should also be able to compare them all in one trusted place.
Additionally, it would prove beneficial to offer enrollment help for eligible users through signup guides offered in many different languages and formats (such as video or PDF instructions with photos) that can be distributed by providers, digital navigators, community based organizations, and found on web pages relevant to the ACP and state digital equity programs.
Lastly, with the understanding that the ACP program is not a permanent resource, it is imperative that the CDT apply the outreach recommendations to other state programs so that eligible community members are prepared with other options in the event that ADP ceases to exist.

Conclusion:

We believe that this State Digital Equity Plan is a key initial step to closing the digital divide in California. With these considerations, the state has the opportunity to be more strategic and equitable about how funding is accessed, who has priority to access it, and how to improve programs that exist to close the divide. We look forward to seeing a final, more equitable State Digital Equity Plan .

Respectfully submitted,
January 25th, 2024

/s/ Daniella Espinoza
————————————

Daniella Espinoza
Fellow, Tech Equity

The Greenlining Institute
320 14th Street, 6th Floor
Oakland, CA 94612
Phone: (510) 809-1808
daniella.espinoza@greenlining.org
4862January 25, 2024 at 3:52 pmE.T.ResidentAlbion954103. Current State of Broadband and Digital Inclusion
I live in a forested area in Mendocino County, where there is no broadband or fast internet service
available. like many other folks, my only recourse in case of emergency is my landline telephone.
Landlines are the cornerstone of connectivity in Mendocino County.

This county is a huge land mass with population concentrated around a few centers connected
by a few marginally maintained roads vulnerable to weather, fire, and seismic events.

Low income and elderly people are the main demographic in my remote rural stretch
at the edge of the Pacific Ocean. For many of us, landlines are our only means of communication.
Many of us do not drive nor own functioning vehicles. Highway 1 is the only road
between bridges in an earthquake/tsunami-prone area.

Wildfires and intense storms often disable cell towers for days. Internet connectivity is
often sketchy. And when the power goes out, which it does often, the landline is the only
connection to the outside world.

Emergency notifications (official & otherwise) often do not reach even those who have cell phones.
Predictably, rapid climate change will increase and intensify fire and weather incidents.

I feel that maintaining landlines should be the top priority in maintaining connections to and
throughout remote areas. Please see to it that we are not left isolated in emergencies.
4861January 25, 2024 at 3:41 pmC.G.ResidentAlbion954103. Current State of Broadband and Digital Inclusion
Landlines are the cornerstone of connectivity in Mendocino County.
This county is a huge land mass with population concentrated around a
few centers connected by a few marginally maintained roads vulnerable
to
weather, fire, & seismic events. Low income & elderly people are the
main demographic in my remote rural stretch at the edge of the Pacific
Ocean. For many, landlines are their only means of communication. Many
do not drive nor own functioning vehicles. Highway 1 is the only road
between bridges in an earthquake/tsunami-prone area. Wildfires &
intense
storms often disable cell towers for days. Internet connectivity is
often sketchy. Emergency notifications (official & otherwise) often do
not reach those who have cell phones. Predictably, rapid climate change
will increase & intensify fire & weather incidents.
I urge that maintaining landlines be the top priority in maintaining
connections to & throughout remote areas.
4860January 25, 2024 at 3:37 pmVolunteer Program ManagerOrganizationConard HouseSan FranciscoCA1. Executive Summary
Conard House’s Digital Literacy Program offers digital literacy courses to older adults and adults living with a variety of disabilities throughout San Francisco. Our organization’s mission is to help these populations understand how broadband access can be useful to them in their every life. Through training courses and workshops with community partners, we provide our clients with social media tools to help them overcome social isolation, access resources for healthy aging, slow the progress of cognitive impairment, and learn skills to manage personal finances or increase income.

The SDEP Draft (p. 76) lists the following barriers to digital equity for aging individuals (60+):
1. Lack of perceived need
2. Inadequate devices/technology
3. Lack of digital skills training
We are concerned that the initial barrier, "Lack of perceived need," may lead to the misconception that older adults lack interest in adopting broadband or lack the ability to engage digitally, both of which are not accurate.

Based on our experience, it's evident that older adults are enthusiastic about becoming digitally engaged, and they express a keen desire to acquire the necessary skills in a supportive environment. In today’s world, technology is an important part of social belongingness to the extent that we’ve integrated into our day to day life. When teaching digital literacy courses to older adults, we support them in not just remaining an integral part of our communities. They are eager to remain connected to friends and families, as well as develop the confidence to navigate technologies that they inevitably encounter in their environments. In addition, many of the older adults that we serve are no longer working, and therefore are eager to develop new digital skills that they can utilize during their free time. They take our course with the desire to learn how to attend remote support groups, church services, and find apps that will help them feel less isolated from others.

In place of "Lack of perceived need," we believe that a more significant barrier to digital equity is the "lack of in-language digital skills training and access.” Our clients often express that our courses and services are the only resources they have that allow them to learn and engage with technology at an accommodating pace. Several if not all of our clients have told us that in the past, when they’ve asked someone for help in learning how to use new technologies, they are met with impatience and frustration. As a result, they feel too intimidated to ask for support, at the expense of not being able to develop their digital skills. In our experience, we believe that the “lack of perceived need” amongst older adults is in reality a reinforced fear that their need of support will be perceived as a burden.


For both individuals with disabilities and older adults, affordability of broadband connection and devices is a significant compounding factor that prevents these covered populations from having access. Across the State, 26.2% of people with disabilities live in poverty, twice the rate of the population without a disability. Even with the ACP benefit, internet access and devices are out of reach for those with fixed incomes. There is a sizable group of older adults and individuals with disabilities that do not qualify for the ACP program but who still struggle financially due to the cost of living in San Francisco and throughout California.

We agree (SDEP, p. 83) that people with disabilities would benefit from greater access to assistive and adaptive technologies. We would like to note, however, that this issue is not just about affordability but also about availability. There is a significant supply side challenge in San Francisco The availability of assistive technologies San Francisco is limited to just a few organizations who aren’t able to adequately meet the need or demand, and who lack the resources to expand device lending libraries. Second, there is a lack of awareness among community members about the range of assistive technologies that exist and information about how different devices and software can improve their quality of life. Our research also shows that there is a lack of staff awareness and training around the use of assistive and adaptive technologies to better meet client needs.
4858January 25, 2024 at 3:20 pmR.S.ResidentSan Leandro945771. Executive Summary
In the course of our agency’s work with older adults experiencing food/shelter/financial insecurities, disabilities and digital challenges (e.g. lack of adequate finances, skills and availability, etc.), it has become increasingly apparent that agency staff would benefit from being trained as Digital Navigators to assist and guide their clients through the digital landscape, typical devices used and their associated benefits. Building digital skill sets fosters increased confidence, a better understanding of their environment, and improved communication with family and friends, etc. Digital technology has become a one of the foundations of current society and an older adult’s inability to successfully access and/or navigate this realm for whatever reason(s), excludes them from reaping the benefits of digital inclusion offers such as access to information and education, increased safety, independence and opportunities for socialization, as well as can promote mental and physical health.

1. Executive Summary
A comment with regard to reducing the percentage of those in California who rely on a smartphone to utilize the internet: Although smartphones are portable, convenient and in many cases serve as an essential tool to taking advantage of digital access, over reliance on such devices can impede older adults from availing themselves to larger devices such as tablets, laptops and desktops with features that provide a greater ease of use, such as larger screen and keyboard sizes. Access to such devices can be especially important for disabled older adults. Accessible, affordable and appropriate devices that support any given individual’s needs and circumstances, combined with affordable and accessible broadband, proper training and support can foster older adults’ digital literacy and confidence in approaching, utilizing and benefiting from being included in the digital landscape, an ever-increasing linchpin of today’s society.

2. Introduction and Vision for Digital Equity
Although some older adults who live on fixed incomes may be able to engage with technology and avail themselves to online services, many experience digital exclusion, due to a lack of adequate financial resources. While the Affordable Connectivity Program (ACP) can bridge the gap, many older adults do not meet the eligibility requirements and fall in to a “no man’s land” of digital exclusion. Add to that the high cost of living in many urban areas of California, such as San Francisco, Los Angeles and San Diego, etc. and access to affordable broadband and accompanying devices is prohibitive, if possible at all.
4857January 25, 2024 at 3:17 pmT.D.ResidentMendocino954604. Collaboration and Stakeholder Engagement
Regarding A2303003: ATT RELIEF FROM ITS CARRIER OF LAST RESORT OBLIGATION

The title says it all. ATT has an OBLIGATION to provide landline telephone service to people for whom it is a LAST RESORT.

It's hard to believe that in the 21st century, I'd have to defend the concept of universal access to telephone service. It's hard to believe AT&T would have the nerve to apply to take landlines away from the population here.

In this county, many people live far apart, on rural roads. They have minimal or, often, no cell service. There's a lot of poverty. Even if a home has cell service, poor families cannot afford multiple cellphones for the various members. Using a cellphone requires that a person (a child, a blind person, a person with Parkinson's) be able to gain access to the phone with a PIN and then dial a number -- even when they've fallen, or are trying to report a break-in, or they need an ambulance. There is no question that people would die without landlines.

People living in rural areas know that they exist at a disadvantage in many ways and have little political power, but we shouldn't be forced to live in conditions from before the turn of the century -- and not this one, but the one before that. Lacking Internet already affects the property values of isolated homes; lacking a landline would tank them.

The quality of every cell call is determined by the phone with the worst cell reception. If one party has one bar or no reception, in effect both do. If I have a friend who's without cell service, I can't talk with that friend. We both become more isolated.

Besides the inability to call for emergency services(!), how would workers hear that they're needed for a different shift? How would a parent find out that their child is ill and needs to be picked up from school early? How would you find out that your prescription is ready or that a lab test indicates you need immediate care? That someone found your lost dog? That your husband has been in a wreck and is in the E.R.?

I'm hearing impaired. I'm also the point person in our household for our medical care and finances, and I cannot hear well enough on our iPhones to do that work -- I've tried. In addition, some businesses' telephone trees don't recognize tones generated by my iPhone. In those instances, I can't input my PIN and I can't get a representative.

An unsung advantage of landlines is that our landline rings in our home, and our answering machine keeps messages, and both of us can see and hear them as messages come in, without having to access a device. Neither of us has access to messages on the other's cellphone when we're apart.

Our landline is the number we've given out for years. If we lose our landline, I'd have to contact all those people and places and businesses and healthcare providers (and I didn't keep a list), to change our primary contact number. Multiple all that by the number of people affected by this proposal.

What a waste of a whole community's time.

Please deny AT&T's application to abandon providing and servicing landlines in Mendocino county.

Thomas Digulla
P.O. Box 104
45091 Covelo St.
Mendocino, CA 95460
(707) 397-1815
4856January 25, 2024 at 3:14 pmJ.A.ResidentMendocino954605. Implementation Strategy & Key Activities
Regarding A2303003: ATT RELIEF FROM ITS CARRIER OF LAST RESORT OBLIGATION

The title says it all. ATT has an OBLIGATION to provide landline telephone service to people for whom it is a LAST RESORT.

It's hard to believe that in the 21st century, I'd have to defend the concept of universal access to telephone service. It's hard to believe AT&T would have the nerve to apply to take landlines away from the population here.

Both my parents worked when I was growing up, in Marin county, so I was a latchkey kid. Occasionally, the power would go out, and I'd be alone in the house in the dark, which was memorable all these years later -- but we had a landline and our neighbors were just a few steps away. I could dial "0" and get an operator to call for help if I needed it.

In this county, many people live far apart, on rural roads. They have minimal or, often, no cell service. There's a lot of poverty. Even if a home has cell service, poor families cannot afford multiple cellphones for the various members. Using a cellphone requires that a person (a child, a blind person, a person with Parkinson's) be able to gain access to the phone with a PIN and then dial a number -- even when they've fallen, or are trying to report a break-in, or they need an ambulance. There is no question that people would die without landlines.

People living in rural areas know that they exist at a disadvantage in many ways and have little political power, but we shouldn't be forced to live in conditions from before the turn of the century -- and not this one, but the one before that. Lacking Internet already affects the property values of isolated homes; lacking a landline would tank them.

The quality of every cell call is determined by the phone with the worst cell reception. If one party has one bar or no reception, in effect both do. If I have a friend who's without cell service, I can't talk with that friend. We both become more isolated.

Besides the inability to call for emergency services(!), how would workers hear that they're needed for a different shift? How would a parent find out that their child is ill and needs to be picked up from school early? How would you find out that your prescription is ready or that a lab test indicates you need immediate care? That someone found your lost dog? That your husband has been in a wreck and is in the E.R.?

I'm hearing impaired. I'm also the point person in our household for our medical care and finances, and I cannot hear well enough on our iPhones to do that work -- I've tried. In addition, some businesses' telephone trees don't recognize tones generated by my iPhone. In those instances, I can't input my PIN and I can't get a representative.

An unsung advantage of landlines is that our landline rings in our home, and our answering machine keeps messages, and both of us can see and hear them as messages come in, without having to access a device. Neither of us has access to messages on the other's cellphone when we're apart.

Our landline is the number we've given out for years. If we lose our landline, I'd have to contact all those people and places and businesses and healthcare providers (and I didn't keep a list), to change our primary contact number. Multiple all that by the number of people affected by this proposal.

What a waste of a whole community's time.

Please deny AT&T's application to abandon providing and servicing landlines in Mendocino county.

Jean Arnold
P.O. Box 104
45091 Covelo St.
Mendocino, CA 95460
(707) 397-1815
4855January 25, 2024 at 3:05 pmBroadband Systems EngineerOrganizationMarin County, Digital Marin Broadband ProjectSan RafaelCA5. Implementation Strategy & Key Activities
The County of Marin and the Digital Marin project supports the State Digital Equity Plan (SDEP) vision and is dedicated to collaborating with the many public and private partners working to bring equitable, resilient, affordable broadband access and digital literacy to the residents of our eleven municipalities and twenty-nine unincorporated communities.

We fully endorse Key Activity 4: Launch the California Connect Corps and digital equity grant program to expand community-based digital navigation and digital inclusion programs to uplift, fund, and promote Digital Navigator Service Providers.

We additionally support Key Activity 3: Evolve broadband and digital equity data and maps. We laud the state and federal government for developing user-friendly first-generation national and state broadband maps and datasets that identify all "broadband serviceable locations" at the address level in our counties.

The FCC National Broadband Map identifies the internet service providers for each location, the type of service (fiber), and advertised speeds. FCC regulations require all ISPs to report this data every six months, finally allowing local governments to track public and private broadband infrastructure and access investment in their communities.

However, the term "evolve" must result in giving local governments the ability to not only combine state and federal broadband data with local parcel and housing data, for example, but to share the data with internal and external partners as freely as possible.

“Fabric” license agreements between private and public entities could severely inhibit data sharing by introducing uncertainty, risk, and legal jeopardy. The state is encouraged to mitigate these barriers if it expects to realize the transparent collaboration levels envisioned in the plan.

THE IMPORTANCE OF DATA SHARING

County broadband offices are experts in identifying broadband funding sources and understanding the competitive broadband landscape, local housing, and the potential location of covered populations.

Digital Navigator Service Providers are experts at working with people and providing digital equity solutions.

Data sharing between stakeholders streamlines the process of finding real people living in real homes with real problems that can be solved through public and private investment and partnership.


OVERSERVED AND STILL UNAFFORDABLE FOR THE LEAST WELL OFF

Over the last several years, three private residential "fiber" providers have entered the Marin residential market, overbuilding the incumbent cable company, which held a monopoly position for over twenty years, generating an estimated $125 million in annual revenue. However, the largest of these companies chose to construct "cherry-picked" networks in highly curated sections of select, often wealthier neighborhoods composed of single-family homes, bypassing apartment buildings and condominium complexes even when they are next to a household with fiber service.

Many of Marin's low-income and often larger families with school-age children live in apartment buildings with one choice of high-speed internet service provider – the cable company. Where fiber is available, non-discounted advertised prices for existing customers are 35%-50% lower than the cable company for the equivalent, if not superior, level of service required to meet larger households' minimum in-home computing demands.

Unlike other essential services such as water or electricity, where every household has equal access to capacity and the ability to manage consumption, broadband is sold by bandwidth bottlenecks, with each bandwidth or speed tier capable of supporting a reasonably predictable but limited number of users and devices; lower demand environments can tolerate lower speeds and benefit from lower costs.

When a larger, low-income household that needs 800 Mbps of bandwidth to meet its daily computing demand is forced to downgrade to lower speeds to meet its budget, everything in a family’s digital daily life is downgraded. This is the broadband affordability gap defined.

Digital Navigator Service Providers, funded through the California Connect Corps program, should be able to locate covered populations quickly and efficiently, like those described above, without duplicating efforts already undertaken by the local government broadband office. Data sharing closes the data gap and lays the foundation for effective partnerships and successful public investments.
4854January 25, 2024 at 2:56 pmAVP, Government & Public AffairsOrganizationCox CommunicationsCA1. Executive Summary
Cox Communications is committed to promoting digital equity within the communities we serve. We recognize the importance of ensuring that everyone has access to digital resources and opportunities, and we are dedicated to continuing to bridge the digital divide.

At Cox, we understand that access to high-quality internet services is crucial for individuals and communities to thrive in today's digital age. Cox is a leading provider of broadband services with residential and commercial broadband speeds of up to 1 Gigabit and 100 Gigabits, respectively. Cox has been recognized by Ookla as the fastest broadband provider in the country (https://newsroom.cox.com/2023-10-16-Ookla-R-Ranks-Cox-as-Fastest-Provider-of-Internet-Speeds-in-U-S). We are committed to working collaboratively with community organizations, local governments, and other stakeholders to address the challenges associated with digital inequality. Our commitment is grounded in the following principles:

Affordable Access: Cox is dedicated to offering affordable internet plans to make high-speed internet access accessible to as many households as possible. Since 2012, Cox has offered a discounted internet program for qualifying low-income families with Connect2Compete and has expanded its affordable internet options with Connect Assist, a $30/month plan for those receiving public assistance and StraightUp Internet, a no contract, prepaid internet option. In addition to providing discounted broadband services to qualifying customers, Cox partners with a device provider to offer discounted computers and tablets to low-income customers as well.

Community Partnerships: Cox has and will continue to actively seek partnerships with local community organizations and government agencies to implement initiatives that promote digital literacy, skills development, and access to technology. Cox has a proven track record as an exceptional public-private partner through our work connecting students and school districts during COVID-19 with sponsored service agreements, E-Rate, and our collaborations with non-profits to promote Affordable Connectivity Program (ACP) events, local jurisdictions to deploy public wifi hotspots, and public entities such as housing authorities to enroll eligible individuals in discounted broadband service programs. By working in partnership with our local digital navigators, we create targeted programs that address the specific needs of our communities and encourage adoption of broadband.

Inclusive Outreach Programs: Cox is committed to conducting outreach programs that focus on reaching underserved and marginalized communities. Cox invests in community engagement initiatives, such as workshops, training sessions, innovation and technology labs, and digital literacy educational events such as our recent Tech Masterclass for seniors in Irvine, to empower individuals with the knowledge and skills needed to navigate the digital landscape. The Cox Digital Academy is a free online resource which supports digital literacy and teaches broadband users the basics of the internet, from setting up email to how to safely use the internet.

Investment in Infrastructure: Cox continually invests in upgrading and expanding our network infrastructure. Over the next five years, Cox will invest billions of dollars to provide symmetrical multi-gigabit speeds in preparation for the broadband demands of the future. Cox recently applied for California Advanced Services Fund (CASF) Infrastructure Grant Account and Federal Funding Account grants to further expand broadband access to reach un and underserved areas in California. By improving coverage and network reliability, we aim to extend the benefits of high-speed internet to more households, particularly those in rural, tribal, and remote locations.

Cox welcomes a discussion on how we can further contribute to digital equity in California. Our commitment to this cause aligns with our belief that everyone should have the chance to harness the power of technology for personal and professional growth.

Thank you for your time and consideration. We look forward to working together to build a more digitally inclusive community.
4853January 25, 2024 at 2:47 pmDirector of Business DevelopmentOrganizationThe Arc San FranciscoSan FranciscoCA4. Collaboration and Stakeholder Engagement
It is imperative to lean on service providers working within the communities of need to support digital equity outcomes. I think there should be more streamlined communication around outcomes, funding, needs, and opportunities so that service providers can establish programs quickly and are not left out of opportunities for the people they serve.

5. Implementation Strategy & Key Activities
Staff need the training and skills to advance and implement the plan's goals. Often, people who are working directly with underserved communities lack technical proficiency. There also needs to be training in multiple languages, in person, digitally, and plain language, to make it as accessible as possible. There should be planning for the sustainability of funding for ongoing needs.
4852January 25, 2024 at 2:44 pmExecutive DirectorOrganizationElderTech AcademyPinoleCA3. Current State of Broadband and Digital Inclusion
Page 76 - Lists the barriers to digital equity for older adults.
1) “Lack of perceived need”
— Based on our work, we believe that for older adults, that statement is misleading and inaccurate.

Our program participants (older adults) typically come to us frustrated and tech-phobic because they assume that the technology is beyond them and that their inability to learn it or use it is a product of their age or just not being “smart”. Nothing could be further from the truth.

Digital literacy mirrors language literacy in many ways, preventing people from participating fully in society. Its not that older adults don’t want to learn the technology, it’s that they no longer have public access to ongoing training resources and support; very little of what is available is tailored to their specific needs.

Older adults need access to ONGOING training and support and except for a handful of non-profits, those pathways have been effectively closed off. In 2009, statewide budget cuts on adult education programs were focused almost exclusively on older adult education/enrichment/lifelong learning. In 2013, these closures were formalized when older adult education was termed “redundant”; in 2022 the state education codes were revised to exclude OLDER adult education programming almost entirely. Enrichment/lifelong learning programs statewide (but locally implemented) were an excellent pathway for older adults to learn technology and we need to bring that back. We hope that any strategic planning will take this into account.

Finally, artificial intelligence: If older adults are not included in this revolution, the digital divide will only widen. Our organization has successfully rolled out an artificial intelligence initiative aimed at older adults and we see how important it is for older adults to learn about this. That said, policy on the state level has to be crafted so that older adults are included in [artificial intelligence] instructional initiatives.
4851January 25, 2024 at 2:38 pmSenior Vice President, Strategic PartnershipsOrganizationUNITE-LA, LA DEALLos AngelesCA1. Executive Summary
UNITE-LA values the opportunity to provide feedback on California’s draft State Digital Equity Plan. UNITE-LA is a co-convener of the Los Angeles Digital Equity Action League (LA DEAL), the California Public Utilities Commission-designated Regional Broadband Consortium (RBC) for the Los Angeles Region. LA DEAL is responsible for a collaborative community-driven process to assess and tackle the broadband gaps that exist in communities across the L.A. region, and seeks to address broadband access in a systemic and equitable way through true community representation and a strong infrastructure of civic leaders representing business, education, nonprofits, and government, so that underserved people have equal access to affordable, reliable, and high-speed internet service, and the devices and training to optimize their use.

Executive Summary

If the state wants to address systemic issues driving low adoption, then BEAD funding should be used primarily to support Goals 1 and 2. In particular, if the state achieves objective 1.4, increase the percentage of Californians who have a choice of at least three internet service providers, we believe that will be a solution to objectives 2.1 and 2.4 as communities will see a healthier market competition between providers. As California Community Foundation and the Electronic Frontier Foundation (EFF) have revealed in this policy memo: Internet Service Providers in LA - A Monopoly Story Fact Sheet (calfund.org), having one or two options results in low-quality and unaffordable internet, leading to low adoption rates. We would go a step further with respects to objective 1.4 to say that the state should invest in options that ensure most people have at least one public option, in which public interest usurps profit motive. In EFF’s 2021 paper, Wholesale Fiber is the Key to Broad US FTTP Coverage, a wholesale model - public open access infrastructure leased to providers - was predicted to serve 95% of Los Angeles County and be cost effective.

However, in order to address equitable access, the state needs to either not use maps in making investment decisions, and instead use other tools such as Socioeconomic Vulnerability Index, or the state needs to make large investments in Key Activity 3: Evolve broadband and digital equity data and maps. The key activity should be to TRANSFORM - not evolve - broadband and digital equity data and maps. First and foremost, it currently shows who COULD be served and not who actually IS served. Including adoption data would show who IS served. However, it is not enough that a household or business has adopted broadband. It is important to understand how much they are utilizing it. There are tools that track such data for public and private entities and make it openly accessible, including Microsoft’s Broadband Interactive Map. We agree that it should include pricing and service offering data. It should also include other indicators, such as speed tests, and reliability indicators such as levels of uptime.

5. Implementation Strategy & Key Activities
Section 5: Digital Equity Plan Implementation Strategy & Key Activities
The implementation plan is particularly lacking in some of the state’s objectives. While we were happy to see the state add objective 1.4, increase the percentage of Californians who have a choice of at least three internet service providers, there was no clear plan or strategy for how and through what time period the state would achieve that objective. We would suggest that the state invest in locally-driven public open access middle and last mile models to ensure that most of Los Angeles has at least one public option. This would increase market competition and ensure that an interest not motivated solely by profit is providing solutions to broadband access issues.

Objective 5.1. Expedite and complete existing Broadband for All infrastructure efforts.
Broadband infrastructure deployment needs to prioritize digitally redlined communities, if we want to reach the overarching goal of equitable access for all Californians. Emphasizing the significance of infrastructure build-out in rural and low-income urban communities is imperative, given the unique challenges these areas face in terms of connectivity.
In order to enhance the timely completion of broadband projects in underserved communities, it is imperative to systematically identify and eliminate barriers that may impede progress. Simultaneously, the establishment of robust accountability mechanisms becomes essential to ensure the expeditious and comprehensive fulfillment of commitments made towards the completion of the Broadband for All infrastructure efforts.
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.

5.3. Evolve broadband and digital equity data and maps.
The CDT should not simply “evolve” the data and maps; if the state seeks to be good stewards of BEAD and other public funds for broadband, then it should seek to “transform” the maps utilizing community-provided data. Municipalities, public entities, and community organizations should get compensated for providing a wide range of data to the CPUC that gives a more holistic picture of the issues driving broadband gaps, so that the state can be more surgical and precise with solutions enabled by historic levels of public funding.
Inaccurate and inconclusive data poses a significant obstacle to identifying areas in urgent need, hindering the effective deployment of broadband infrastructure and digital equity programs in the communities that require them most. As efforts are made to improve data systems, we strongly advocate for a heightened focus on accuracy and inclusivity in mapping endeavors. This emphasis is crucial to ensure that the state's digital equity initiatives are grounded in precise information, reaching all underserved communities.
Prioritizing data accuracy and relevancy within this initiative reinforces the groundwork for equitable infrastructure development. Continued reliance on flawed maps, without swift and substantial corrections, risks perpetuating decades of disinvestment in low-income, predominantly Black and brown communities. This perpetuation exacerbates the digital divide rather than addressing it.
As has been proven in multiple recent reports from various groups across the country, including the CCF’s pricing discrimination report, the UC Santa Barbara, and others, private companies tend to prioritize investments in high-income communities, leaving historically redlined areas with subpar infrastructure, limited options, and higher prices. It would be regrettable for the State to follow a similar trajectory. It is imperative to ensure that every home in underserved communities is accurately represented in data collection efforts.
To address this, we recommend timely provision of maps used to determine eligible areas, allowing for a public comment period. This period would afford communities the opportunity to identify excluded areas, offer feedback, and provide data and information that can reinstate those areas in consideration. Furthermore, the California Department of Technology (CDT) should uphold transparency in the data collection process, furnishing clear information on how data is gathered, utilized, and how the maps will inform potential funding and project opportunities.

Objective 5.7 Advocate for an extension of ACP or a successor program or develop a State-led affordable offer.
It is commendable that the California Department of Technology (CDT) prioritizes affordability for Californians and addresses the barriers faced by communities. However, the current objective appears somewhat vague and lacks emphasis on the crucial need for a long-term program ensuring affordable services. The ongoing advocacy for an extension of the Affordable Connectivity Program (ACP) is set to conclude in April 2024, with new applications freezing February 8, 2024. To enhance this advocacy, we recommend that the CDT's efforts encompass:
Engagement with federal representatives
Utilize partnerships with broadband service providers, industry associations, community organizations and advocacy groups to collectively work together in advocating,
Use reputable data to demonstrate the economic, educational, and social benefits resulting from affordable connectivity, public awareness campaigns, leverage the CDT's influence to foster coordination among local and state entities in support of affordable service plan programs, media engagement

3. Current State of Broadband and Digital Inclusion
Objective 3.5 as currently stated aims to expand the representation of members from covered populations in broadband infrastructure and technology jobs. We propose that the CDT collaborates with the California Public Utility Commission to create workforce development programs that will connect those receiving digital skills training with broadband workforce opportunities. To combat the workforce shortage, CDT should consider partnering with community organizations, advocacy groups, and educational institutions to develop a employment referral program. This can increase the number of local applications and can help reach into the communities of the covered populations. To support broadband workforce from covered populations and diverse backgrounds, CDT should incorporate hands on training and education, as well as resources to support worker's needs.
4850January 25, 2024 at 2:38 pmL.J.ResidentMendocino954601. Executive Summary
It is unethical to consider discontinuing landlines on the Mendocino Coast. Cell phones have no reception in many areas here, and landlines are the only means of calling for help in emergencies, or receiving notifications for evacuations should a wildfire take hold. Many of the residents are elderly and at risk for falls, stroke, heart attacks, etc, where minutes count in receiving treatment. There is no alternative in place should landlines be discontinued. You are opening yourself up to massive lawsuits if you discontinue and folks start dying because of your misguided and I must say, avaricious, policy plan.
4849January 25, 2024 at 2:14 pmP.G.ResidentNEVADA CITY959598. Not Related to Above Sections
I currently use a cell phone to provide internet service at my home. It has it's limitations, rain and snow can disrupt service. The more data I use, the slower the system becomes, to the point of being unusable.
Certain streaming services are unusable due to buffering or throttling of those services, a problem I do not experience when I'm at the office where I have cable internet service.
Having a fiber optic solution would be ideal, since the local cable franchise is not willing to bring cable into our neighborhood.
There is a fiber optic service that is planning on bringing service to our neighborhood and grants like this makes it possible to have high speed internet without using the cellular network or satellite service.
I support the effort to bring fiber optic service to the rural areas of California.
4848January 25, 2024 at 2:12 pmJ.G.ResidentGRASS VALLEY959492. Introduction and Vision for Digital Equity
• Wireless will set the state back in terms of climate change management because wireless uses a huge amount of energy compared to WIRED broadband.

• Wireless facilities increase fire risk and cyber security risk

• Wireless facilities impact the growing percentage of the population with disabilities related to radiofrequency radiation (RFR) exposure.

• Wired infrastructure offers greater capacity, predictable performance, lower maintenance costs, and a longer technological lifetime than wireless technologies. Fiber service is not degraded by line-of-sight issues and is not affected by capacity issues.

1. Executive Summary
Please protect us from dangerous and unreasonable infrastructure. Wired is the only way.
4847January 25, 2024 at 2:04 pmL.D.ResidentCarlsbad920102. Introduction and Vision for Digital Equity
Wireless facilities impact the growing percentage of the population with disabilities related to radiofrequency radiation (RFR) exposure.
4846January 25, 2024 at 1:57 pmDigital Equity Program DirectorOrganizationCommunity Tech NetworkSan FranciscoCA3. Current State of Broadband and Digital Inclusion
Since 2008, Community Tech Network (CTN) has been providing digital skills training for older adults in San Francisco, in Oakland in 2012 and in Sunnyvale in 2017. From 2021, CTN also provided digital skills training, devices and data plans for seven California Area Agencies on Aging counties: San Francisco, Santa Clara, San Mateo, Marin, Sonoma, Alameda and Contra Costa.

The Draft Equity Plan (p. 12, 76) lists the following specific digital equity barriers for aging individuals (60+):
Lack of perceived need
Inadequate devices/technology
Lack of digital skills training

Suggestion: Replace “lack of perceived need” with “lack of digital literacy skills” as top barrier

We believe that listing “Lack of Perceived Need” can lead to the misconception that older adults are not interested in broadband adoption or lack the capacity to be digitally engaged, which is simply not true. The reality is that older adults have adopted broadband at levels almost identical to the general population. In fact, since 2014, aging individuals have made more progress in broadband adoption than any other segment of the population in California, moving from less than 50% (of adults 65+) with broadband in 2014 to 91% in 2023 (2021/23 USC; 2017-19 Berkeley IGS Poll; and 2014-16 Field Poll), the same level of adoption for the State of California as a whole (2023 SDEP Telephone Survey).

In another section of the Draft (p. 70), “lack of perceived need” is determined by “a reliance/dependence on mobile phones.” Reliance on a mobile phone does not necessarily suggest that older adults feel that they don’t need a broadband connection.
Many of the older adults we serve have smart phones and still desire a separate device with a larger screen and a faster, more reliable broadband connection for more complex tasks, such as completing online forms, drafting emails and managing their finances online.

We have also discovered 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 smartphone. What may at first look like a “lack of perceived need” for broadband access, is more often than not a misunderstanding that we address in our digital literacy training.


Instead of “lack of perceived need,” we propose that “lack digital literacy skiIls” be the primary barrier to digital equity for older adults and adults with disabilities. In the data provided within the Draft, it appears that the statistically most significant barrier to digital equity for aging individuals is a lack of digital literacy: “While 56% of overall telephone survey respondents were found to have advanced digital skills, just 42% of aging individuals reported the same” (SDEP, 78). All of the other data in this section on aging individuals (points to statistically insignificant differences of 1-2% from overall respondents.)
Suggestion: Include “insufficient In-language digital skills training and access” as a barrier

It is important to note that the survey under-represented (sometimes significantly) people who have limited English language proficiency, immigrants, and members of racial or ethnic minority groups while residents in rural areas were oversampled in the SDEP Public Online Surveys. In light of this, we believe that language barriers are a significant obstacle to digital equity and inclusion in California. Statewide, older adults are more likely to be immigrants or speak a primary language other than English.

We have found that adults with limited English-language proficiency face substantial obstacles to digital equity. These language barriers can impede their ability to understand and engage with technology, navigate online services, and express their needs or seek help from a trusted source effectively. People will not seek the skills they need without a trusted community partner who can support digital literacy in their native language.

suggestion: Include “lack of free or affordable broadband and device options” as a barrier

Affordability is a critical issue, as many low-income older adults face financial constraints that make paying for internet services or a device difficult if not impossible. While the Affordable Connectivity Program (ACP) had the potential to alleviate costs, most eligible older adults were unaware of this benefit without our advice. In addition, many who qualify have difficulty enrolling because the application is only in English and Spanish and the application and enrollment process is complex. Finally, there is a significant group of older adults that do not qualify for the ACP or other subsidy program but who still struggle financially due to the cost of living throughout California.

PROPOSED CHANGE:
Revise the list of barriers, in priority and order, to the following:
1. Lack of digital literacy or skills
2. Insufficient In-language digital skills training and access
3. Lack of affordable broadband and device options

4. Collaboration and Stakeholder Engagement
CTN and our partners participated in three of the CA regional public engagement events. Those events provided a valuable opportunity for both program staff and our digital skills learners to gather with allies to identify our shared barriers and articulate our strategies for digital equity. Our government and nonprofit partners could meet each other and hear directly from the communities they hope to serve.
It would be extremely valuable to continue ongoing stakeholder engagement activities with individuals as well as organizations.
Suggestion: continue to convene annual, in-person stakeholder engagement activities to strengthen our community of allies and identify future opportunities for collaboration.

5. Implementation Strategy & Key Activities
Many of our mono-lingual, non-English-speaking learners rely on their local community partners who have cultural - but not digital skills - proficiency for technical advice and assistance.

CTN currently offers digital equity services and skills training by English, Spanish, Cantonese, Mandarin, Vietnamese, Korean, Tagalog, and Russian native speakers. Our materials are interpreted into culturally appropriate examples and idioms which creates familiarity and trust with our learners.

Supporting community allies with established digital skills curriculum and Digital Navigator best practices provides the opportunity for those communities to adjust a basic curriculum to make it relevant to their specific culture.

Suggestion: include language about culturally responsive instruction, not just translation in the goal to “expand the variety of languages offered for digital literacy training programs.”

5.4 Priority outcome areas: Workforce and Economic Development section:
To create sustainable, ongoing digital skills training and technical support, CTN provides Digital Navigator training at partner locations in Sonoma, San Mateo, San Francisco, and Santa Clara Counties. CTN-trained Digital Navigators lead workshops, provide advice at drop-in sessions, and help their communities with specific digital skills tasks, such as applying for the ACP and several CTN-trained Digital Navigators have been hired as staff for their community centers. Combined with basic job skills training, digital navigator training can be a pathway to teaching, community outreach and customer service careers.

Suggestion: include Digital Navigator training as a workforce and economic development strategy

5.5 Funding and Sustainability: Local Funding:

Like many nonprofits and community organizations, CTN and our partners rely on federal, state and local funding for its digital equity initiatives. CTN has received funding directly from the California Department of Aging, from county governments and from the California Public Utilities Fund Advanced Services fund grant recipients.

California’s effective advocacy for federal funds has supported many of the effective interventions identified in the state’s Digital Equity Plan and CTN hopes California will continue to be an ally for local and regional governments.

5.7 Evaluation: CTN agrees that data collection and research are a crucial component for measuring digital equity program effectiveness and best practices.

Suggestion: Ongoing, predictable funding for short, medium and long-term data collection and research is critical for Plan revisions and improvements to meet changing needs.
4845January 25, 2024 at 1:42 pmM.T.ResidentEncinitas920243. Current State of Broadband and Digital Inclusion
Wired infrastructure offers greater capacity, predictable performance, lower maintenance costs, and a longer technological lifetime than wireless technologies. Fiber service is not degraded by line-of-sight issues and is not affected by capacity issues.
4844January 25, 2024 at 1:21 pmK.W.ResidentGrass Valley959452. Introduction and Vision for Digital Equity
WIRED connection is superior to wireless in all respects, and wireless broadband—especially
the basic services offered to low-income families will NOT solve the digital divide.
Wireless is also inferior "dirty" technology, unreliable, and unable to SAFELY meet the demands of present and future digital communications. Please provide funding for safer, reliable, energy-efficient WIRED internet, not wireless installations.
Let's not waste funding for the rollout of wireless installations that take it away from much safer, reliable, energy-efficient WIRED internet.

Wireless uses a huge amount of energy compared to WIRED broadband.
Wireless facilities increase fire risk and cyber security risk
Wireless facilities impact the growing percentage of the population with disabilities related to radio-frequency radiation (RFR) exposure.

Wired infrastructure offers greater capacity, predictable performance, lower maintenance costs, and a longer technological lifetime than wireless technologies. Fiber service is not degraded by line-of-sight issues and is not affected by capacity issues.
Please get funding for Wired Technology!
4843January 25, 2024 at 1:12 pmSenior Policy CounselOrganizationNext Century CitiesWashingtonDC1. Executive Summary
Next Century Cities applauds the California Department of Technology's (“CDT”) efforts to ensure that all Californians have the skills, devices, and connections needed to equitably participate in society. Building lasting relationships with the community organizations and local leaders working directly with residents will help state broadband leaders ensure the plan is sustainable. Setting accessible, affordable, and reliable broadband as top goals for the state of California is a critical foundation for digital equity.

Next Century Cities (“NCC”) is a nonprofit nonpartisan 501(c)(3) coalition of over 240 member communities, including 32 cities and counties in California, that works collaboratively with local leaders to ensure reliable and affordable broadband access for every community. NCC also prioritizes helping others realize the economic, social, and public health importance of high-speed connectivity.

The objectives outlined in the California Digital Equity Plan (“the Plan”) addresses many critical aspects of broadband and digital equity. Equitable infrastructure deployment, technology skills development, device access, and affordable, reliable home broadband subscriptions are all integral to success in the global economy. Unfortunately, as technology progresses, so too does the digital divide. In the next several years, broadband speeds will likely increase along with consumer demand, and new devices and applications will become necessary to participate in society.

2. Introduction and Vision for Digital Equity
Next Century Cities applauds the CDT for including local broadband plans. One suggestion is to make the local digital equity plans available and easily accessible on a state website, which could help leaders from other communities develop plans of their own. States like North Carolina and Virginia have taken a statewide approach to helping county leaders develop digital equity plans. Oftentimes, momentum at the county and local levels can spur involvement from community and industry partners alike. Ongoing collaborations across state and local agencies, across sectors, is imperative to ensuring strategies are sustainable in the long-term.

CDT should also help community partners find trusted curricula and resources that agencies and organizations can use to provide high-quality cybersecurity and privacy trainings. Content should focus on a broad range of skills, while outreach should include partners working in a variety of sectors, including K-12, post-secondary, and adult education. CDT funding must include support for training through existing community partners, who can serve as trusted messengers.

3. Current State of Broadband and Digital Inclusion
Broadband data gaps remain a barrier to developing digital equity programs. In addition to inaccurate and overstated broadband access data, adoption data similarly lacks the granularity and detail needed to effectively address community needs.

Setting clear success metrics is a helpful start. Broadband and digital equity data often do not match residents’ experience. CDT should track both quantifiable metrics and qualitative input on digital equity programs to evaluate programmatic impact over time. Collecting robust, reliable data about affordability and broadband quality will remain critically important to evaluate as technology advances. In particular, better data about broadband affordability, device quality, and technology accessibility could help track progress toward the Plan’s goals and identify opportunities for improvement. Collaborating with community organizations and academic partners could help CDT spread the word about survey and other data collection opportunities while also building effective channels of communication with residents.

4. Collaboration and Stakeholder Engagement
CDT should build upon the many efforts to connect with residents and community leaders across the state. Maintaining transparency around CDT’s progress toward digital equity goals and open communication and feedback channels is imperative to the Plan’s success. Furthermore, CDT should continue surveying residents to track progress and understand remaining gaps over time.

Continued local coordination is imperative to ensuring that digital equity funding makes its way to the communities that need it most. As CDT evaluates funding proposals, coordination with local governments and community-based organizations is imperative to ensuring that digital equity awardees are trusted by the residents who grantees will ultimately serve. Including local partners in the selection and implementation processes could help CDT coordinate digital equity and deployment strategies, and track progress toward statewide goals.

5. Implementation Strategy & Key Activities
In communities without traditional anchor institutions, like schools and libraries, CDT should consider alternative venues where residents can convene, access information, and get online. Potential partners include faith communities, local nonprofits, social service organizations, and businesses.

As outreach and engagement continue, CDT should ensure that smaller entities are able to participate in funding opportunities. Developing resources to help community-based organizations directly serving covered populations apply for digital equity funding could fill longstanding digital inequities. Developing straightforward application processes, equipping local partners with information about opportunities as they arise, and ensuring that funding remains flexible for the variety of unique needs different communities face are all necessary to maximize funding’s impact.

Given the uncertainty surrounding whether the Affordable Connectivity Program (“ACP”) will continue, the CDT should pursue alternative possibilities for state funding to support households that will be unenrolled from the program. For example, CDT could explore a partnership with the California Public Utilities Commission to pursue expansions of state mechanisms for long-term Internet subsidization. Additionally, CDT should encourage affordability in its infrastructure investment programs by promoting competitive service offerings, like ensuring that open access networks support affordable broadband in communities where price is a barrier.

6. Conclusion
Next Century Cities appreciates the opportunity to comment on California’s Digital Equity Plan and looks forward to following the state’s progress toward ubiquitous broadband access and adoption.

8. Not Related to Above Sections
A formatted version of these comments is available here: https://nextcenturycities.org/wp-content/uploads/2021/05/2024.1.25-NCC-Comments-California-Digital-Equity-Plan.pdf
4842January 25, 2024 at 1:11 pmCOOOrganizationCruzio InternetSANTA CRUZCA2. Introduction and Vision for Digital Equity
Cruzio Internet is appreciative of the fact the plan includes the availability of, and affordability of access to, fixed and wireless broadband as a key objective.

We strongly recommend using economical, fast-to-deploy fixed wireless technology capable of multiple gigabits per second. In areas like ours, where a fiber deployment would be prohibitively costly or technologically challenging, fixed wireless can bring equivalent service at a far lower cost, and on a much faster timeline. Aerial fiber, hung on utility poles, is unsightly and subject to many risks including destruction or interruption from floods, fire, earthquakes, and even animals. Fixed wireless will quickly add the ability for thousands of rural residents to get internet connections with upload and download speeds similar to those in large cities, many at subsidized prices. Augmenting larger, slower projects, it will bring significant, lasting improvements in a short time.

Fixed connectivity has evolved significantly in recent years. Cruzio routinely deploys wireless links capable of sustaining 10 Gbps throughput. Point-to-point wireless can be installed in a matter of days, as opposed to weeks or months for fiber, and often offers lower real-world latency versus fiber connections.

Modern wireless technology is extremely reliable even in the harshest conditions. Higher-bandwidth links use narrow “pencil” beams that resist interference and make interception virtually impossible. Links licensed through the FCC are dedicated channels, and are not susceptible to shared channel performance degradation. Unlike fiber, wireless links are not susceptible to cuts and other physical interruptions.

Resilience is an important feature of all networks. Fiber tends to follow common routes along highways and places where right-of-way can be easily obtained. Wireless follows completely different, and easily shiftable routes. Since each medium experiences different threats, a multi-model approach ensures survivability of the network as a whole.

Fixed wireless links are easily upgradeable when technology advancements occur. An upgrade from 1 Gbps to 10 Gbps and beyond is often as simple as uninstalling and reinstalling radios at each end of the link. In our 12-year history of wireless deployment, we have fully cycled through 3 generations of wireless equipment, resulting in exponential increases in stability, bandwidth, and range. We build upgrade costs into our plans from the start. This upward trend is not slowing down.

As there is no physical connection between end points, minimal physical construction is required leading to a much-lower environmental impact than fiber, especially underground fiber.

In conclusion, Cruzio Internet strongly recommends adding fixed wireless extensions to planned middle and last mile projects.

We welcome any further questions.
4841January 25, 2024 at 12:58 pmB.N.ResidentCamptonville959221. Executive Summary
I think that the urgency of less emf's and radiation is very important and for people to be aware of its dangerous effects on people and nature.
• Wireless is unreliable and unable to meet the demands of present and future digital communications. Providing funding for the rollout of wireless installations will take it away from much safer, reliable, energy-efficient WIRED internet.

• Wireless will set the state back in terms of climate change management because wireless uses a huge amount of energy compared to WIRED broadband.

• Wireless facilities increase fire risk and cyber security risk

• Wireless facilities impact the growing percentage of the population with disabilities related to radiofrequency radiation (RFR) exposure.

• Wired infrastructure offers greater capacity, predictable performance, lower maintenance costs, and a longer technological lifetime than wireless technologies. Fiber service is not degraded by line-of-sight issues and is not affected by capacity issues.
4840January 25, 2024 at 12:51 pmS.F.ResidentStewarts Point954805. Implementation Strategy & Key Activities
This says it best.

In a recent Marconi Society sponsored workshop, Connecting Maine, Karem Durdag, CEO of GWI (Great Works Internet), the first US telecommunications carrier to be certified as a B Corporation, said it best. The tension that exists within digital equity and opportunities moving forward:
“… I think creative tensions or creative problem solving comes in where it requires intentionality. A, to acknowledge that the problem exists but to maintain intentionality in dealing with a whole bunch of multiple stakeholders that try to solve it. So I mean that there’s some really simple stuff. For example, In the state of Maine, as Jeff mentioned, there are population centers. Within those population centers there are areas which are distinctly not served. They have crappy internet service. Those areas tend to be low income or immigrant neighborhoods. But yet, 42 billion (million?) dollars is not going to help them. It’s just not. So, what do we do and how do we do it? I do believe to my core, and GWI does, that we have a moral, ethical and financial obligation to solve that. Because you are going to then aid and abet a deeper “chasming” of socio-economic considerations. So how do we do that? Well, maybe the answer lays in aggregating projects in a way that so that the federal capital that comes in that addresses rural areas. If it’s a large enough project it can aggregate in such a way so that the private capital can go into the metro areas. It requires an enormous amount of thinking. It requires an enormous amount of creative financial partners. But at least there is a way to try to do it. And I think those are the places where Maine Connected has certainly expressed it’’s interest in leaning and trying to figure that out. It has expressed it’s interest in trying to figure out how to, how does various various other bonding mechanisms might even work. It has expressed it’s interest in trying to figure out can it help connect the dots for the ISP, especially smaller ISPs that are not incumbents, on accessing capital stacking mechanisms to be able to a do large, large enough projects. Because the truth of the matter is the reason why the Rural Education Program succeeded in the 1910s and the 20s, or the National Highway Transportation System in the 50s or 60s succeeded is because of the fact we said, as a society we are going to get to everyone, everyone, no matter how hard it is, no matter how long it takes. And I think that’s how we have to do it. In the State of, in the State of Maine, that’s one issue. In the State of Maine, obviously, even in the rural areas, for example, there’s a tension between what the incumbents may have done or are doing, cherry picking, “donuting” areas and leaving certain stretches, swaths of land and premises still unserved but makes it awfully, awfully, awfully hard for a non incumbent to put together a competitor proposal for a federal program to say I can aggregate these projects and I can bring a competitive service to there, to those areas. How do we do that? Again, it requires a little bit of creative thinking. Is there a way for the smaller ISPs, when they aggregate projects, to lessen their costs to make the competitive applications bear fruit. Is there, are there ways that can leverage other partners in regional places to say they can aggregate large projects, to be able to bring fruit. Because at the end, the end of the day the goal for the federal funds that the State of Maine is getting, New Hampshire, Vermont, all, everybody is trying to administer is how can we provide universal access that carries some element of choice for the citizens. And I think that’s where we have to come in and I, so I don’t buy into reticent positions where we say so that’s, that’s what it is, and these other rules enhance that that’s what it’s going to be. Because that is not going to create infrastructure that is going last 50-60-70-80 years. I mean this is a generational moment. It’s not going to happen again in my lifetime in terms of a coalescing of a societal demand with the ability of the federal government to put a shoulder into it and the states expressing an enormous amount of capacity and expertises to solve that problem. So, it’s a marathon , it’s not a sprint. I urge everyone to think in terms of running a marathon and to intentionally figure out how to solve some very thorny problems and to acknowledge the tension. We have to acknowledge to tension and say how do we resolve it, by talking.”
Karem Durdag has put into words what I feel is the enormous risk of failure and a strategy, indeed, attitude for success.
4838January 25, 2024 at 12:29 pmDigital Equity and Inclusion CoordinatorOrganizationCity of Long BeachCity of Long BeachCA1. Executive Summary
Priority populations that are missing:
Undocumented Population

The City of Long Beach, via the Long Beach Values Act, has made a deliberate investment in undocumented people to support them with City services and on the pathway toward economic investment. California has a large undocumented population and digital inclusion resources should be tailored for this specific population that is disproportionately lower income and has a lower trust in government than other groups.

Unhoused Individuals

In 2023, the City of Long Beach, locking arms with the City of Long Angeles, declared an emergency on homelessness, diverting City staff and resources to focus on this critical emergency. Unhoused individuals have different needs than other people in the digital divide, often needing access to the internet on their smartphones to navigate bureaucratic housing resource processes. This makes them as unique of a population as people who are currently incarcerated. Unhoused individuals should be one of the priority populations.

Consumer Advocacy

The City of Long Beach’s Digital Inclusion Roadmap’s community-prioritized strategies highlighted the need for community members to have an option to resolve issues or problems they are having with Internet Service Providers (ISP). The City recommends that the State create a process by which they will implement the FCC’s new rule on Broadband infrastructure deployment and the provision of broadband internet access services. The FCC has said it intends to launch investigations into complaints and allegations filed through the informal complaint process or otherwise brought to the Commission’s attention, including from state, local and Tribal governments, and to pursue remedies and penalties where it determines a violation has occurred. It is imperative that the State comply with and implement the FCC’s new rule.

5. Implementation Strategy & Key Activities
Interim Alternative Technology Solutions

The State Digital Equity Plan advocates for “interim alternative technology solutions” for communities that cannot wait for broadband infrastructure to be built out. The City of Long Beach, via its community-created Digital Inclusion Roadmap, recommends the following interim technology solutions for communities not immediately able to access broadband connectivity:

Free internet: the State Digital Equity Plan highlights the need for low-cost internet but does not reference access to free internet services. Per our community engagement, many community members will not be able to pay any cost for internet and will only be connected if the internet services are free.

Hotspots: With that in mind, hotspots are still valuable short-term solutions to connect community members immediately to the critical resources available via the internet.

Lending at Libraries: Public libraries are community resources, usually conveniently located within a 15-minute walk for most communities. It is critical that we still consider that we use these as hubs for digital inclusion resources. Chromebook and hotspot lending services have proven to be successful at the Long Beach Public Library and need further investment and development.

Public schools: K-12 students who have a demonstrated need for free wi-fi should be supported by public schools in lending out hotspots at low to no cost.

Apartment Wi-Fi: The State Digital Equity Plan should consider landlords and other housing providers as important stakeholders. Outfitting an apartment with internet is a solution that maximizes collective impact. Financial incentives should be considered to help invest in free wi-fi for tenants who are already part of the Section 8 housing voucher program.

WiFi in Public Spaces: The community-created Long Beach Digital Inclusion Roadmap specifically highlights the importance of quality wi-fi in public spaces like parks, transit stops, City halls, and other public spaces. Every public space should be a place where residents can access Internet resources. Recently the federal Housing and Urban Development awarded the City a grant to install public wi-fi in 4 new park locations. This is particularly important for residents who are experiencing homelessness or who are precariously housed. The State Digital Equity Plan should reflect similar investments.

4837January 25, 2024 at 12:17 pmProgram ManagerOrganizationSan Francisco Department of Disability and Aging ServicesSan FranciscoCA3. Current State of Broadband and Digital Inclusion
PART A: COVERED POPULATION - Aging Individuals (60+)

The SDEP Draft (p. 12, 76) lists the following specific digital equity barriers for aging individuals (60+):
1. Lack of perceived need
2. Inadequate devices/technology
3. Lack of digital skills training

ACTION 1: Remove “lack of perceived need” from this list

RATIONALE:
1. We believe that this statement can lead to the misconception that older adults are not interested in a broadband adoption or lack the capacity to be digitally engaged which is simply not true. The reality is that older adults have adopted broadband at levels almost identical to the general population. In fact, since 2014, aging individuals have made more progress in broadband adoption than any other segment of the population in California, moving from less than 50% (of adults 65+) with broadband in 2014 to 91% in 2023 (2021/23 USC; 2017-19 Berkeley IGS Poll; and 2014-16 Field Poll), the same level of adoption for the State of California as a whole (2023 SDEP Telephone Survey).

2. Second, the meaning of the statement, “lack of perceived need,” is not clear. In another section of the SDEP Draft (p. 70), “lack of perceived need” is determined by “a reliance/dependence on mobile phones.” Reliance on a mobile phone does not necessarily suggest that older adults feel that they don’t need a broadband connection. In fact, for many older adults (for whom smart phone ownership has increased rapidly), smart phones serve as an important bridge toward digital inclusion. They allow older adults to access essential services, maintain connections with family and friends, and participate in day-to-day activities.

Our partner organizations such as Self Help for the Elderly, Community Living Campaign, Felton Institute, and many others point to the popularity of classes, tech support popups, and workshops that focus on developing smart phone skills.

3. Finally, based on our work with older adults, we have discovered 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. What may at first look like a “lack of perceived need” for broadband access, is more often than not a misunderstanding that can be solved through digital literacy training.

ACTION 2: Replace “lack of perceived need” with “lack of digital literacy skills” as top barrier

RATIONALE: Instead of “lack of perceived need,” we propose that “lack digital literacy skiIls” be the primary barrier to digital equity for aging individuals. In the data provided within the SDEP Draft, it appears that the statistically most significant barrier to digital equity for aging individuals in the SDEP Draft is a lack of digital literacy: “While 56% of overall telephone survey respondents were found to have advanced digital skills, just 42% of aging individuals reported the same” (SDEP, 78). All of the other data in this section on aging individuals (points to statistically insignificant differences of 1-2% from overall respondents.
ACTION 3: Include “insufficient In-language digital skills training and access” as a barrier

RATIONALE: It is important to note that individuals with limited English language proficiency, immigrants, and members of racial or ethnic minority groups were under-represented (sometimes significantly) while residents in rural areas (much less diverse than the population as a whole) were oversampled in the SDEP Public Online Surveys. In light of this, we believe that language barriers are a significant obstacle to digital equity and inclusion in California. Statewide, aging individuals are more likely to be immigrants or speak a primary language other than English.

Individuals with limited English-language proficiency, especially those who speak languages like Cantonese and Mandarin (the most widely spoken languages among older adults), Spanish, Vietnamese, Japanese, and Korean, face substantial obstacles to digital equity. These language barriers can impede their ability to understand and engage with technology, navigate online services, and even express their needs or seek help effectively.

In San Francisco, for example, 52% of adults who are 60 years of age or older speak a primary language other than English. Older adults with limited English proficiency participated in site-based programs such as ADRC and Congregate Meals at double the rate of older adults overall, indicating high engagement with service centers that provide language-specific services.


ACTION 4: Include “lack of free or affordable broadband and device options” as a barrier

RATIONALE: Affordability is a critical issue, as many low-income older adults face financial constraints that make paying for internet services or a device difficult if not impossible. While the Affordable Connectivity Program (ACP) has the potential to alleviate costs, most eligible older adults are unaware of this benefit. In addition, many who qualify have difficulty enrolling because the application is only in English and Spanish and the application process is complex. Finally, there is a significant group of older adults that do not qualify for the ACP program but who still struggle financially due to the cost of living in San Francisco and throughout California.

PROPOSED CHANGE:
Revise the list of barriers, in priority and order, to the following:
1. Lack of digital literacy or skills
2. Insufficient In-language digital skills training and access
3. Lack of free or affordable broadband and device options

PART B: COMMENTS ON COVERED POPULATION - Individuals with Disabilities

The SDEP DRAFT, p. 83, lists the following specific barriers for individuals with disabilities:
• Inadequate accessible hardware and software
• Training on hardware and software
• Accessibility of online services

ACTION: Add “lack of free or affordable broadband and device options” to the list of barriers

RATIONALE: In addition to the named barriers, affordability of broadband connection and devices is a significant compounding factor that prevents people living with a disability from having access. In the “2021 Empowered San Francisco Technology Needs Assessment Report” which focused on the barriers to digital equity for individuals with disabilities and older adults, the top two barriers to digital equity for adults with disabilities were: 1) unaffordable cost of high-speed internet (28% of surveys); and 2) unaffordable cost of device (27%). Across the State, 26.2% of people with disabilities live in poverty, twice the rate of the population without a disability. The rates are much higher in cities like San Francisco (33.3%), Oakland (35.7%), and Sacramento (35.5%).

Additional comments:
We agree that people with disabilities would benefit from greater access to assistive and adaptive technologies. First, we would like to note this issue is not just about affordability but also about availability. There is a significant supply side challenge in San Francisco. The availability of assistive technologies in San Francisco is limited to just a few organizations who aren’t able to adequately meet the need or demand, and who lack the resources to expand device lending libraries. Second, there is a lack awareness among community members about the range of assistive technologies that exist and information about how different devices and software can improve their quality of life. Our research also shows that there is a lack of staff awareness and training around the use of assistive and adaptive technologies to better meet client needs.

It is also important to recognize that the needs of individuals living with a disability can and do vary considerably depending on the type of disability (e.g. physical, intellectual) and their life experiences with a disability (e.g. congenital, acquired). For example, older adults who experience vision loss later in life can be challenged with needing to adapt to and rely on technology while also transitioning from visual to auditory and more tactile learning.


PART C: COMMENTS ON ORGANIZATIONAL BARRIERS

SDEP highlighted several barriers organizations experience to make an impact on digital equity (p. 19, 64):

• Funding and Sustainability
• Staff and Organizational Capacity
• Difficulty Accessing and Applying for Funding.
• Lack of Awareness and Engagement

ACTION: Add “Lack of language capacity” to this list

RATIONALE: Lack of language capacity in serving individuals with limited English-language proficiency. In the course of conducting 44 in-depth interviews with organizations and government agencies in San Francisco, we learned that the ability to provide in-language digital literacy skills training and support, especially for older adults and adults with disabilities, is a constant struggle. It is very difficult to find and adequately pay multilingual staff to provide these services. In addition, organizations often lack the capacity to develop or translate digital literacy tools and materials into languages such as Chinese and Vietnamese.


ACTION: Add “Lack of coordination and collaboration” to this list

RATIONALE: Lack of coordination and collaboration among organizations and government agencies that provide digital inclusion programming. What we have heard is that most organizations are unaware of digital inclusion efforts beyond what they provide. This leads to a duplication of efforts and competition for scarce resources, resulting in limited impact on the populations that are most at risk for digital inequity. We recommend prioritizing and incentivizing (through funding opportunities) closer collaboration and coordination of programming and services around shared goals among CBOs, service providers, government agencies.
4836January 25, 2024 at 12:11 pmE.K.ResidentSan Francisco3. Current State of Broadband and Digital Inclusion
We provided comment in the following areas:
• PART A: Aging Individuals (60+)
• PART B: Individuals with Disabilities
• PART C: Organizational Capacity



PART A: COVERED POPULATION - Aging Individuals (60+)

The SDEP Draft (p. 12, 76) lists the following specific digital equity barriers for aging individuals (60+):
1. Lack of perceived need
2. Inadequate devices/technology
3. Lack of digital skills training

ACTION 1: Remove “lack of perceived need” from this list

RATIONALE:
1. We believe that this statement can lead to the misconception that older adults are not interested in a broadband adoption or lack the capacity to be digitally engaged which is simply not true. The reality is that older adults have adopted broadband at levels almost identical to the general population. In fact, since 2014, aging individuals have made more progress in broadband adoption than any other segment of the population in California, moving from less than 50% (of adults 65+) with broadband in 2014 to 91% in 2023 (2021/23 USC; 2017-19 Berkeley IGS Poll; and 2014-16 Field Poll), the same level of adoption for the State of California as a whole (2023 SDEP Telephone Survey).

2. Second, the meaning of the statement, “lack of perceived need,” is not clear. In another section of the SDEP Draft (p. 70), “lack of perceived need” is determined by “a reliance/dependence on mobile phones.” Reliance on a mobile phone does not necessarily suggest that older adults feel that they don’t need a broadband connection. In fact, for many older adults (for whom smart phone ownership has increased rapidly), smart phones serve as an important bridge toward digital inclusion. They allow older adults to access essential services, maintain connections with family and friends, and participate in day-to-day activities.

The San Francisco Public Library and organizations such as Self Help for the Elderly, Community Living Campaign, Felton Institute, and many others point to the popularity of classes, tech support popups, and workshops that focus on developing smart phone skills.

3. Finally, based on our work with older adults, we have discovered 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. What may at first look like a “lack of perceived need” for broadband access, is more often than not a misunderstanding that can be solved through digital literacy training.

ACTION 2: Replace “lack of perceived need” with “lack of digital literacy skills” as the top barrier

RATIONALE: Instead of “lack of perceived need,” we propose that “lack digital literacy skiIls” be the primary barrier to digital equity for aging individuals. In the data provided within the SDEP Draft, it appears that the statistically most significant barrier to digital equity for aging individuals in the SDEP Draft is a lack of digital literacy: “While 56% of overall telephone survey respondents were found to have advanced digital skills, just 42% of aging individuals reported the same” (SDEP, 78). All of the other data in this section on aging individuals (points to statistically insignificant differences of 1-2% from overall respondents.
ACTION 3: Include “insufficient In-language digital skills training and access” as a barrier

RATIONALE: It is important to note that individuals with limited English language proficiency, immigrants, and members of racial or ethnic minority groups were under-represented (sometimes significantly) while residents in rural areas (much less diverse than the population as a whole) were oversampled in the SDEP Public Online Surveys. In light of this, we believe that language barriers are a significant obstacle to digital equity and inclusion in California. Statewide, aging individuals are more likely to be immigrants or speak a primary language other than English.

Individuals with limited English-language proficiency, especially those who speak languages like Cantonese and Mandarin (the most widely spoken languages among older adults), Spanish, Vietnamese, Japanese, and Korean, face substantial obstacles to digital inclusion programming.

In San Francisco, for example, 52% of adults who are 60 years of age or older speak a primary language other than English.


ACTION 4: Include “lack of free or affordable broadband and device options” as a barrier

RATIONALE: Affordability is a critical issue, as many low-income older adults face financial constraints that make paying for internet services or a device difficult if not impossible. While the Affordable Connectivity Program (ACP) has the potential to alleviate costs, most eligible older adults are unaware of this benefit. In addition, many who qualify have difficulty enrolling because the application is only in English and Spanish and the application process is complex. Finally, there is a significant group of older adults that do not qualify for the ACP program but who still struggle financially due to the cost of living in San Francisco and throughout California.

PROPOSED CHANGE:
Revise the list of barriers, in priority and order, to the following:
1. Lack of digital literacy or skills
2. Insufficient In-language digital skills training and access
3. Lack of free or affordable broadband and device options

PART B: COMMENTS ON COVERED POPULATION - Individuals with Disabilities

The SDEP DRAFT, p. 83, lists the following specific barriers for individuals with disabilities:
• Inadequate accessible hardware and software
• Training on hardware and software
• Accessibility of online services

ACTION: Add “lack of free or affordable broadband and device options” to the list of barriers

RATIONALE: In addition to the named barriers, affordability of broadband connection and devices is a significant compounding factor that prevents people living with a disability from having access. In the “2021 Empowered San Francisco Technology Needs Assessment Report” which focused on the barriers to digital equity for individuals with disabilities and older adults, the top two barriers to digital equity for adults with disabilities were: 1) unaffordable cost of high-speed internet (28% of surveys); and 2) unaffordable cost of device (27%). Across the State, 26.2% of people with disabilities live in poverty, twice the rate of the population without a disability. The rates are much higher in cities like San Francisco (33.3%), Oakland (35.7%), and Sacramento (35.5%).

Additional comments:
We agree that people with disabilities would benefit from greater access to assistive and adaptive technologies. First, we would like to note this issue is not just about affordability but also about availability. There is a significant supply side challenge in San Francisco. The availability of assistive technologies in San Francisco is limited to just a few organizations who aren’t able to adequately meet the need or demand, and who lack the resources to expand device lending libraries. Second, there is a lack awareness among community members about the range of assistive technologies that exist and information about how different devices and software can improve their quality of life. Our research also shows that there is a lack of staff awareness and training around the use of assistive and adaptive technologies to better meet client needs.

It is also important to recognize that the needs of individuals living with a disability can and do vary considerably depending on the type of disability (e.g. physical, intellectual) and their life experiences with a disability (e.g. congenital, acquired). For example, older adults who experience vision loss later in life can be challenged with needing to adapt to and rely on technology while also transitioning from visual to auditory and more tactile learning.


PART C: COMMENTS ON ORGANIZATIONAL BARRIERS

SDEP highlighted several barriers organizations experience to make an impact on digital equity (p. 19, 64):

• Funding and Sustainability
• Staff and Organizational Capacity
• Difficulty Accessing and Applying for Funding.
• Lack of Awareness and Engagement

ACTION: Add “Lack of language capacity” to this list

RATIONALE: Lack of language capacity in serving individuals with limited English-language proficiency. In the course of conducting 44 in-depth interviews with organizations and government agencies in San Francisco, we learned that the ability to provide in-language digital literacy skills training and support, especially for older adults and adults with disabilities, is a constant struggle. It is very difficult to find and adequately pay multilingual staff to provide these services. In addition, organizations often lack the capacity to develop or translate digital literacy tools and materials into languages such as Chinese and Vietnamese.


ACTION: Add “Lack of coordination and collaboration” to this list

RATIONALE: Lack of coordination and collaboration among organizations and government agencies that provide digital inclusion programming. What we have heard is that most organizations are unaware of digital inclusion efforts beyond what they provide. This leads to a duplication of efforts and competition for scarce resources, resulting in limited impact on the populations that are most at risk for digital inequity. We recommend prioritizing and incentivizing (through funding opportunities) closer collaboration and coordination of programming and services around shared goals among CBOs, service providers, government agencies.
4835January 25, 2024 at 12:09 pmPresident and CEOOrganizationCalifornia Emerging Technology FundConcord and Los AngelesCA1. Executive Summary
The California Emerging Technology Fund (CETF) commends the California Department of Technology (CDT) for the comprehensive approach and extensive outreach to invite input to the Draft Digital Equity Plan which is well summarized in the Executive Summary. CDT and California Public Utilities Commission (CPUC) along with other State Agencies, including especially the Governor's Office of Business and Economic Development (GOBiz), diligently participated in 17 Regional Workshops and 3 Tribal Consultations to listen to input by stakeholders and Covered Populations. CETF worked with regional partners to organize and co-convene these 20 Workshops, engaged several other statewide organizations to distribute information, and documented that more than 60,000 California residents were invited to attend the Workshops which resulted in 2,296 participants. This was an historical effort. The Workshops were structured to obtain reliably-representative views of residents throughout California. The Draft Digital Equity Plan is a solid foundational blueprint for fulfilling the intent of the IIJA State Digital Equity Plan and the Legislative directives in AB2750 (Bonta).

2. Introduction and Vision for Digital Equity
The California Emerging Technology Fund (CETF) supports the Draft Digital Equity Plan for Digital Equity. It is focused on outcomes for people with a commitment to reaching all Covered Populations. It is a coherent presentation of Objectives associated with the Goals for easy comprehension.

3. Current State of Broadband and Digital Inclusion
The California Emerging Technology Fund (CETF) thinks that the content on the Current State of Broadband and Digital Inclusion is accurate and is faithful to all the input from Covered Populations and stakeholders in the planning process. CETF concurs with the construct of Access, Affordability, Adoption to organize the approach. The Examples of Specific Barriers for Covered Populations are a faithful summary of input during the planning process. These insights underscore why outreach to Covered Populations is most effective when conducted by "trusted messengers" who are composed of and have established working relationships with the Covered Populations and communicate in-language and in-culture. At the same time, the "common barriers" for Covered Populations are essential to inform effective strategies to achieve Digital Equity. The most significant of these "common barriers" are: (1) low income; (2) need for information in-language and in-culture; (3) lack of awareness about affordable Internet service; (4) need for digital literacy; and (5) availability and access to an appropriate affordable computing device. The results of the 2023 Statewide Digital Equity Survey reveal a striking concentration of poverty for all digitally-disadvantaged residents within every Covered Population. As previously presented to the Statewide Planning Group, the following are the percentages of the Covered Population digitally-disadvantaged households (Unconnected and Underconnected): Overall Population 69.6%; Covered Households 100%; Language Barrier 81.7%; Racial and Ethnic Minorities 77.7%; People with Disabilities 75.8%; Women 73.9%; Aging Individuals 69.2%; LGBTQIA+ 62.5%; Rural Residents 58.3%; Veterans 57.7%. Poverty is more defining for being digitally-disadvantaged than any other factor in identify for Covered Populations. This underscores the relevance of Affordability in the assessment of the Current State of Broadband and Digital Inclusion which is even more urgent as a challenge given the Federal Communications Commission (FCC) "freeze" of the IIJA Affordable Connectivity Program (ACP) as of February 7 absent action by Congress to extend and reauthorize ACP.

The 2023 Statewide Digital Equity Survey also provides a sound basis to estimate the number of digitally-disadvantaged households and residents who must be reached to achieve Digital Equity. This data can be very helpful in defining the scale of the challenge and helping limited target resources to achieve Digital Equity. For example, based on the 2023 Statewide Survey: 9% of the Overall Population Households (HHs) are Unconnected (or about 1,189,583HHs and 3,550,982 residents) and 3% are Underconnected (or about 396,528 HHs and 1,183,661 residents); 13% of Covered Households are Unconnected (or about 355,342 HHs and 1,060,718 residents) and 5.8% are Underconnected (or about 158,537 HHs and 473,243 residents; 14.8% of Households with a Language Barrier are Unconnected (or about 603,880 HHs and 1,802,620 residents) and 3.8% are Underconnected (or about 155,050 HHs and 462,835 residents; and 12.2% Latino Households are Unconnected (or about 628,893 HHs and 1,877,285 residents) and 3.3% are Underconnected (or about 170,110 HHs and 507,790 residents). While there is some overlap among these population segments, in estimating the magnitude of the digitally-disadvantaged to be reached to achieve Digital Equity, this data indicates that there are no less than 2.5M HHs to get connected to the Internet, which will require a robust Adoption strategy as well in an infrastructure program for Deployment. Another important indicator of digitally-disadvantaged residents is the number of California HHs eligible for ACP, which is more than 5.8M (5,844,707 HHs was the March 2022 baseline). With almost 3M HHs enrolled currently, there are almost 2.9M who are the most digitally-disadvantaged and economically-fragile to reach.

In submission of the California Digital Equity Plan to NTIA, the State of California needs to underscore that California has more low-income residents and larger numbers of Covered Populations than any other state. While California is 13% of the nation's population, it is home to 15% of all poor people. California also is the home of more federally-recognized Tribes and Native Americans than any other state. Thus, the allocation of IIJA Capacity Grants and Competitive Grants needs to recognize equity for all low-income households and Tribes in the country and distribute federal resources accordingly. California's low-income households should not be short-changed in the allocation of federal dollars.

4. Collaboration and Stakeholder Engagement
The California Emerging Technology Fund (CETF) commends the California Department of Technology (CDT) and other State Agencies for their commitment to collaboration and stakeholder engagement. The planning process was comprehensive and inclusive. As stated in a previous comment, CETF work worked with Regional Partners and statewide organizations to invite more than 60,000 residents to participate in the 17 Regional Workshops. CETF also collaborated with NextGen Policy (NextGen Climate American, Inc.) to engage its network of more than 175 community organizations statewide to engage Covered Population residents. In addition, each Workshop featured several Covered Population residents sharing their lived experiences with all gathered. CETF also collaborated with the California State Association of Counties (CSAC) and engaged the Rural County Representatives of California (RCRC) to reinforce all the outreach by encouraging Counties to send all their program administrators and managers who serve the Covered Populations.

5. Implementation Strategy & Key Activities
The California Emerging Technology Fund (CETF) supports the Implementation Strategy and Key Activities. These Comments are offered to highlight important implementation approaches and considerations based on 15 years of experience of working statewide with community-based organizations (CBOs), Local Governments and other Public Agencies, Regional Broadband Consortia, Metropolitan Planning Organizations, Regional Organizations, Internet Service Providers ISPs), and other stakeholders who collectively have assisted more than 1M households get connected to the Internet with affordable service and have trained more than 1M residents in digital literacy.

The overarching focus and metric in implementation of the Digital Equity Plan is a full "Adoption" which all partners the Capacity Grants should be required to accomplish. There must be a common outcome for accountability (the "what") with the approach customized to reach the target population (the "how") derived from the on-the-ground expertise of the community organization as the trusted messenger in-language and in-culture.

A full "Adoption" must address the 3 barriers for low-income households (Dr. John Horrigan 2013 research): (1) Cost (including the cost for both Internet service and an appropriate computing device); (2) Relevance (the reason why outreach in-language and in-culture by “trusted messengers" is essential to explain to low-income unconnected HHs how they will benefit from being connected at home to the Internet); and (3) Digital Literacy (no one will subscribe to service and acquire a device if they don’t know how to use it to navigate the Internet). A successful Adoption usually involves the following steps in assisting residents in unconnected households to: (a) understand the benefits of being connected online at home; (b) become aware of available affordable Internet service options; (c) acquire an affordable device for connecting to the Internet; (d) learn the foundational skills of digital literacy; and (e) select and sign up for home Internet service. It should be understood that CBOs who are the “trusted messengers” doing the outreach, assisting households sign up for home Internet service, and delivering the digital literacy training are what has become termed “Digital Navigator” (CETF CBO grantees have been doing the work of Digital Navigators for more than a decade).

Implementation must be at scale to avoid unnecessary administrative costs for the State. Logical scales for collaborative implementation are countywide, regionwide, and statewide. Effective collaborations generally are structured with a coordinating managing partner coupled with experienced "trusted messenger" CBOs that already have established working relationships with the Covered Populations. These kinds of collaboratives must have an "open door" to include all willing partners who are compensated based on performance in achieving Adoptions. It is more important that the willing partners have established working relationships a trusted messengers than previous experience in doing Adoptions. CBOs can be trained in Digital Inclusion to become Digital Navigators. There should be a standardized framework or rubric for measuring Digital Proficiency for all digital literacy training. It is helpful to provide Base Curricula for CBOs and then important to allow innovation for improved content, which is all measured in terms of effectiveness with a standardized framework. With this approach, the overall concept of the California Connect Corps can be launched with centralized State oversight coupled with at-scale collaboratives that engage and support existing CBOs and public agencies doing the work of Digital Navigators. This approach is not only the most inclusive that taps into existing efforts and expertise with accountability for a common outcome (and "Adoption"), but it also is the most cost-effective and efficient to get to implementation sooner rather than later.

Recognizing that there are 2.5M-5.8M households to be reached to achieve Digital Equity in California, there must be complementary "institutionalization strategies" to complement implementation of the Capacity Grant. which harness the authority, reach, and power of other exiting organizations. For example, while today only about 1/3 of the low-income households have children in school, going forward, everyone will go through a school. Schools in low-income neighborhoods and communities must be the priority focus to assist them in implementing brace best practices for the successful integration of technology in teaching and learning coupled with deep parent engagement to improve academic performance. The CETF School2Home Initiative is an example. A serious commitment to institutionalization in this Outcome Area of Education would mean a change in practice for the entire educational system, which requires State leadership.

Likewise, effective institutionalization and integration of Digital Inclusion into the healthcare industry means an intense initiative to optimize the use of Telehealth for improved patient outcomes and overall population health, referred to as "Telehealth For All" Policy.

As referenced in previous comment, Digital Equity cannot be achieved without Affordability. The State of California must have a backstop and back-up plan to the federal Affordable Connectivity Program (ACP). CETF supports immediate extension of ACP through the end of 2024 and then reauthorization and reform to ensure that there is a viable federal program to assist low-income households across the nation. However, California also cannot rely upon the federal government for the only answer to ensure almost 6M economically-disadvantaged households have affordable Internet service and do not live always in danger of being kicked off the Internet if there is a hick-up in Congress. This is especially urgent given the legacy of leadership of the Governor and Legislature to achieve Digital Equity and the passage of the Digital Equity Bill of Rights last year. Thus, CETF supports the State encouraging the Internet Service Providers (ISPs) to continue to offer and affordable subscription that is standardized for eligibility and quality of service to be at least as good as ACP. Most of the existing affordable offers were negotiated as a public benefit from corporate consolidations that continue to be very profitable. Further, if an ISP is being paid with taxpayer or ratepayer dollars as a vendor to the State or is receiving a subsidy for infrastructure deployment, then the ISP should be required to provide their own affordable offer that is consistent with adopted eligibility and service standards. This is the most cost-effective and economically-efficient approach to ensuring into the future that there always will be affordable Internet service for low-income households. There need not be a new State subsidy program, although reform of Lifeline holds promise for expanding access to the Internet.

Since the preparation of the Draft Digital Equity Plan, CETF has begun to pursue a strategy of engaging financial institutions to contribute to a fund for Community Reinvestment Credit (CRA) to help close the Digital Divide. This is based on a report by Rise Economy (formerly the California Reinvestment Coalition). CRA credit for financial institutions could be considered as an additional revenue stream to help close the Digital Divide, promote Digital Inclusion, and achieve Digital Equity.

Another important role for the State is leadership on increasing awareness about available affordable offers. Awareness must be mobilized at scale. The 2023 Digital Equity Survey found that 65% of the ACP-eligible households were not aware of the program or any other affordable offers. The ISPs do not advertise through effective channels, including community and ethnic media, to reach the target populations. Only the State can engage the ISPs in the kind of awareness partnership that is needed to reach the most digitally-disadvantaged residents. In addition, the most effective communication strategy actually is "Direct Notification" by a credible source, such as a public agency that does eligibility determination for the major public assistance programs (Medi-Cal, CalFresh, WIC, National School Lunch Program, Pell Grants, Tribal Assistance Programs) that automatically qualify a household for ACP (and which should be the basis to qualify for an existing ISP affordable offer). The Department of Health Care Services and Department of Social Services have demonstrated the power of Direct Notification. The value of a public awareness advertising program is to increase the receptivity by eligible households such that Direct Notification has higher success rates.

Lastly, it must be recognized that broadband infrastructure is necessary but not sufficient to achieve Digital Equity. With California's bold commitments to construction of high-speed Internet infrastructure coupled with federal BEAD funding, there now is almost $10B allocated for infrastructure. The focus must be on actually getting low-income and digitally-disadvantaged households connected to the Internet and becoming digitally proficient to improve their daily living. CETF has submitted extensive comments in legal briefs in regulatory proceedings and position statements in policymaking. Overall, effective coordination of the $10B in funding for infrastructure requires a focus on driving to the hardest-to-reach areas: (1) rural remote rural communities, including Tribal Lands; and (2) high-poverty urban neighborhoods. In both cases, the market doesn't operate to attract private capital investment and public subsidies are required to deploy the infrastructure. However, there has been too much emphasis on maps instead of a laser focus on getting digitally-disadvantaged households connected with high-quality Internet access. By embracing a strategy of driving to the "hardest-to-reach" and then connecting and upgrading all locations along the path of deployment, the State both assures that the most digitally-disadvantaged households are connected as the first priority and operates as scale economically. The California Department of Technology (CDT) and California Public Utilities Commission (CPUC) can call upon the Regional Broadband Consortia (RBCs), Southern California Association of Governments (SCAG), and San Diego Association of Governments (SANDAG) to work with stakeholders and advocates to reach consensus on Last-Mile Projects that optimize and leverage all the deployment funds to getting residents connected sooner rather than later.

6. Conclusion
The California Emerging Technology Fund (CETF) concurs with the Conclusion.

7. Appendices
The California Emerging Technology Fund (CETF) appreciates the inclusion of all the Appendices in the Draft Digital Equity Plan as well as all the other resources posted on the Broadband For All website.
4833January 25, 2024 at 11:54 amS.P.ResidentLos Angeles900143. Current State of Broadband and Digital Inclusion
I HAD TO THREATEN AND FORCE ATT TO GIVE ME ACCESS TO A WIRED CONNECTION. NO TELECOMM ON THE PLANET WANTS RESIDENTIAL CONSUMERS NOT TO BE WIFI. I WOULD NOT GIVE IN, THE ONLY WAY I GOT THE WIRED CONNECTION THAT THEY TOLD ME WAS NOT POSSIBLE FOR MY SERVICE. THEY LIED, I HAVE A WIRED CONNECTION WITH THE WIFI OFF IN THEIR IP SERVER AND MY SERVICE PORTAL.
4832January 25, 2024 at 11:53 amPolicy DirectorOrganizationThe Children's PartnershipLos AngelesCA1. Executive Summary
Amend goal 3 - language access.
We urge CT to strengthen focus on language access by incorporating directly into goal 3 every time it is listed throughout the plan: “All Californians can access training and support to enable digital inclusion *in the languages Californians speak*.” This comment applies in all places throughout the report where the goals are listed.

Add new objective 2.5 - price disparities.
We urge CDT to add a new objective under goal 2 to eliminate disparities in broadband pricing for similar service, where no significant technological justification for such disparity exists. We recommend referencing the new FCC definition of digital discrimination: “Policies or practices, not justified by genuine issues of technical or economic feasibility, that (1) differentially impact consumers’ access to broadband internet access service based on their income level, race, ethnicity, color, religion, or national origin or (2) are intended to have such differential impact.” (https://docs.fcc.gov/public/attachments/FCC-23-100A1.pdf). This comment applies in all places throughout the report where the objectives are listed.

Add language to “needs and barriers” to access, affordability, and deployment - recognize affordability as a crucial component of access.
In the plan, the term “accessible” is used, but what is meant is “physically available.” We recommend including language in the plan recognizing that affordability is a crucial form of accessibility, not an entirely separate concern. Data clearly show (as referenced in the plan itself) that affordability is the most significant barrier to accessing broadband service.

Add additional “need and barrier” to access - inequitable deployment of broadband infrastructure.
Under needs and barriers to access, we recommend adding inequitable deployment of broadband infrastructure by internet service providers. We recommend referencing the new FCC definition of digital discrimination: “Policies or practices, not justified by genuine issues of technical or economic feasibility, that (1) differentially impact consumers’ access to broadband internet access service based on their income level, race, ethnicity, color, religion, or national origin or (2) are intended to have such differential impact.” (https://docs.fcc.gov/public/attachments/FCC-23-100A1.pdf). This comment applies in all places throughout the report where needs and barriers are listed.

Add additional “need and barrier” to access - funding availability for equitable middle and last mile infrastructure.
The increase in the number of connected homes will only be applicable if middle mile and last-mile network funds are both adequate and equitably distributed to the communities most in need. In 2024-25 California is faced with a budget deficit of at least $37 billion. We are pleased that the Governor’s 24-25 budget proposal includes a $1.5 billion increase for the Middle-Mile Broadband Initiative. However, to address the projected budget shortfall, the Governor’s proposal proposes a delay of $100 million from 2024-25 to 2026-27 for last-mile infrastructure grants at the CPUC and a reduction of $250 million for the Broadband Loan Loss Reserve (BLLR) Fund. We urge you to include language in the plan acknowledging the need for full and adequate funding for these three initiatives, including the associated risks to the plan goals if full funding is not allocated.

Add additional “need and barrier” to affordability - pricing discrimination.
Under needs and barriers to affordability, we recommending adding pricing discrimination by internet service providers. Reference The Markup report (copublished with the Associated Press) which analyzed more than a million addresses across the country and found that AT&T advertises the same price for much slower speeds in higher poverty, less white communities than in wealthy white neighborhoods (https://themarkup.org/still-loading/2022/10/19/dollars-to-megabits-you-may-be-paying-400-times-as-much-as-your-neighbor-for-internet-service); the report from the University of California at Santa Barbara, which analyzed advertised prices at more than 35,000 addresses across the City of Los Angeles and found the same consistent pattern: low-income communities are advertised higher prices for slower service (https://static1.squarespace.com/static/6165cb6ecbf6d70401a212f6/t/645bec1629d79e309c1525c3/1683745815861/UCSB+-+Los+Angeles+Broadband+Pricing+Analysis.pdf); and the California Community Foundation report, which studied 165 addresses and documented clear patterns of Charter/Spectrum offering lower prices and better terms and conditions in wealthy neighborhoods across Los Angeles County (https://static1.squarespace.com/static/6165cb6ecbf6d70401a212f6/t/6345ca9c147af0682276fb3d/1665518251184/Broadband+Pricing+Disparities+Report+-+Oct+2022.pdf). This comment applies in all places throughout the report where needs and barriers are listed.

Add additional “need and barrier” to adoption - language accessibility.
Under needs and barriers to adoption, we recommend adding access to training and support in one’s preferred language. Cross-reference data on people with language barriers that is included on pp. 88-90. This comment applies in all places throughout the report where needs and barriers are listed.

3. Current State of Broadband and Digital Inclusion
Errata - correct missing language access data.
Please note that information under objective 3.4 for people with language barriers (pp. 90-91) includes the wrong information. Data is included here (presumably inadvertently) related to people with disabilities.

Health priority - update language to reframe health beyond health care access and recognize the particularly detrimental and lasting impact of digital inequities on children.
We are pleased that health has been a focus area in the planning process and is prominent in the draft plan.


We recommend updating language to recognize the health impacts of digital inequities beyond those associated with access to health care services. Digital equity is particularly important for health and well-being because it has a compounding effect that starts in childhood. Digital equity has been called a “social determinants echo chamber” and a “super social determinant of health” because digital inequity compounds inequities in other systems, from impeding education to interrupting health care, all the while limiting access to resources that could address adverse social conditions, such as applications for housing and income assistance programs. These social drivers affect an individual at all stages of life, but the effects are particularly significant to the health and ongoing development of children.

Social drivers of health (SDOH) are the social, economic, environmental and other conditions that shape health and well-being. SDOH are structural factors in the places where children and families live, work, play and go to school — such as whether a family has access to healthy foods, livable wages, quality education, neighborhoods free from violence where it is safe to walk and play, affordable housing, clear air and reliable transportation, to name just a few. Evidence shows that approximately 80% of our health outcomes are driven by these social conditions. Medical care, on the other hand, accounts for only about 20% of our health outcomes. Recognizing the ways in which these systems impact the health of our communities is essential to a “whole child” equity approach that recognizes and addresses the various social conditions that shape child health and well-being.
Persistent inequities in access to high-speed internet, adequate devices, and digital education and training have detrimental and lasting effects on our children’s abilities to grow up healthy, to learn and to develop into thriving adults. The deliberate enactment of policies and processes to advance digital equity for BIPOC communities must be prioritized to protect the health and well-being of children. A few of the key barriers related to SDOH that we identified in our 2023 report “Digital Equity: A Key to Children’s Health & Racial Justice” (https://childrenspartnership.org/wp-content/uploads/2023/08/TCP-Digital-Equity-Brief_FINAL.pdf) include:
Telehealth has improved access to care, but BIPOC and Spanish-speaking Californians experience technological, language and other barriers.
BIPOC students are more likely to face barriers to accessing the technology that continues to be needed for effective learning and accessing educational resources.
The lost educational time disproportionately experienced by BIPOC students can lead to lifetime loss of earnings, but greater digital skills can enable employment and higher wages.
Digital barriers prevent families from finding affordable housing and accessing public benefits.

5. Implementation Strategy & Key Activities
Across “key activities” - add specificity, measurable objectives, and timelines.
We urge CDT to strengthen the objectives with more clarity, specificity, and a clear timeline of actionable steps for how the objectives will be addressed. Without a clear, actionable timeline, the plan lacks accountability for the objectives to be met. Other published state digital equity plan drafts have included such timelines, and more specificity including measurable objectives, key performance indicators, short-term targets, and long-term targets. We recommend that this be improved across all key activities.

Add additional “key activity” under 5.1 - prioritized investments.
We urge CDT to add an additional activity under the key activity category 1 (expedite and complete existing Broadband for All infrastructure efforts): “prioritize infrastructure investments in the most underserved and disconnected communities.” Broadband infrastructure deployment needs to prioritize digitally redlined communities, if we want to reach the overarching goal of equitable access for all Californians. Available state and federal funding must be prioritized first where they are needed most. There is abundant research that documents that income and race are the best predictors of broadband access (far and above any rural versus urban split). According to USC and CETF’s recent survey (https://s42263.pcdn.co/wp-content/uploads/2023/12/2023-Statewide-Digital-Equity-Survey-Final-Report.pdf), in cities and rural communities alike, Latinx residents lag behind white residents in broadband connectivity by 10%, Black residents lag behind white residents by 7%, and there is a 25% gap between Native American residents and white residents. Additionally, 19% of low-income people across the State are unconnected or under-connected, compared to just 4% of residents who are not low income. It is critical that we use the facts of these racial and income inequities to drive funds to the least connected communities in every geography across the State - urban, rural, and everything in between.

Add additional “activity” under 5.1 - transparency and community collaboration.
We urge CDT to add an additional activity under the key activity category 1 (expedite and complete existing Broadband for All infrastructure efforts): “increase transparency and community collaboration.” Recently, CDT has strained community trust by making major decisions without engagement of, or even notification of, impacted communities and have obfuscated these decisions by making relevant data impossible to access.

Add additional “activity” under 5.2 - fund efforts to connect and support CBOs.
We urge CDT add an additional activity under the key activity category 2 (convene digital equity stakeholders to strengthen collaboration): “fund efforts to connect and support CBOs.” In addition to existing CDT-led stakeholder engagement efforts, which are minimally-effective at directly engaging the most impacted communities, CDT should fund community-based stakeholders directly to serve as hubs of information sharing and community engagement to guide future decisions and implementation of this plan.

Add additional “activity” under 5.2 - CBO oversight body.
We urge CDT to add additional activity under the key activity category 2 (convene digital equity stakeholders to strengthen collaboration): “establish a new oversight body comprised entirely of CBOs and affected residents to guide implementation of this plan.” This body should be chaired or co-chaired by members of the body, who should have authority to determine the activities, agenda, and direction of the group, with staff support from CDT. This is important to address a key theme from CDT listening sessions to “ensure that communities disproportionately impacted by barriers to digital equity are central to the design, development, and delivery of digital equity programs, and that socioeconomic benefits are captured primarily within these communities. Consult and empower covered populations and other digitally disadvantaged communities to help plan and implement all strategies to achieve digital equity. Those intended to be served must be involved in planning and delivering the services” (p. 21).

Amend and add language under 5.3 - transform data and maps.
We appreciate the focus of key activity 3 on improvements to data and maps. However, we urge CDT to not simply “evolve” the data and maps; if the state seeks to be good stewards of BEAD and other public funds for broadband, then it should seek to “transform” the maps utilizing community-provided data. Municipalities, public entities, and community organizations should get compensated for providing a wide range of data to the CPUC that gives a more holistic picture of the issues driving broadband gaps, so that the state can be more surgical and precise with solutions enabled by historic levels of public funding.

The primary data used to create the currently-available maps is information provided by internet service providers (ISPs), which renders the maps incomplete and not representative of the actual gaps in broadband access.

Under current regulations, fixing inaccuracies of the broadband maps requires the submission of challenges. The arduous nature of these challenges and lack of process transparency are a deterrent for consumers, communities, and cross-sector stakeholders to engage, ultimately weakening the ability of the maps to prioritize the funding and investments in broadband deployment.

Inaccurate data poses a significant obstacle to identifying areas in urgent need, hindering the effective deployment of broadband infrastructure and digital equity programs in the communities that require them most. As efforts are made to improve data systems, we strongly advocate for a heightened focus on accuracy and inclusivity in mapping endeavors. This emphasis is crucial to ensure that the state's digital equity initiatives are grounded in precise information, reaching all underserved communities.
Continued reliance on flawed maps, without swift and substantial corrections, risks perpetuating decades of disinvestment in low-income, predominantly Black and brown communities. This perpetuation exacerbates the digital divide rather than addressing it.
To address this, we recommend timely provision of maps used to determine eligible areas, allowing for a public comment period. This period would afford communities the opportunity to identify excluded areas, offer feedback, and provide data and information that can reinstate those areas in consideration. Furthermore, CDT should uphold transparency in the data collection process, furnishing clear information on how data is gathered, utilized, and how the maps will inform potential funding and project opportunities.

Add language under 5.4 - community-based navigator workforce.
We applaud the inclusion in the plan of the California Connect Corps and digital equity grant programs to expand community-based digital inclusion programs. These initiatives are poised to serve communities in most need, utilizing the established workforce and trusted messengers within the community. The health-related workforce has several community-based providers including community health workers, promotoras, representatives, doulas, peer support specialists, enhanced care management providers, and community support providers that can be leveraged to close digital literacy gaps. We urge CDT to strengthen the language used here to cite which existing anchor-institutions and community-based organizations are providing such digital inclusion services already, or at least how those health care-centered partners will be identified and included in the program— i.e., health care anchor institutions, community health clinics, health-based nonprofit organizations etc.

Amend language of “key activity” 7 - state affordability programs.
Under key activity 7 (promote low-cost offers and the Affordable Connectivity Program, and advocate for a sustainable successor program), recognizing the extremely low likelihood of the federal government re-funding the ACP, we urge CDT to strengthen the plan languge to proactively recommend that the State of California develop a state-level successor program and other policies that promote affordable broadband offerings for low- and moderate income households.

Amend section 5.7 on plan evaluation - strengthen measurable objectives.
Within the annual progress reports on the implementation of this plan, we urge CDT to include measurable objectives, key performance indicators, short-term targets, and long-term targets. For example, we urge CDT to include data-specific data on the covered populations to know who is accessing the programs that are supported by the plan. The need for a more substantial and specific evaluation throughout the 5 years of the plan is essential to addressing and creating actionable changes in bridging the digital divide for Californians. In addition, we propose that evaluations of the plan be conducted and publicly reported after 2 years. This will allow for transparency, continual monitoring of progress towards digital equity, and progress tracking to accurately identify whether the current state digital equity plan is meeting measurable metrics before ultimately achieving the goals of eliminating digital equity disparities for California communities.
4831January 25, 2024 at 11:51 amVP of Government AffairsOrganizationComcastSacramentoCA1. Executive Summary
Comcast strongly supports broadband deployment and adoption initiatives in California and stands ready to further support the State’s efforts. Comcast continues to invest heavily in the State, with investments during the past three years totaling $12.8 billion, including $3.8 billion toward technology and infrastructure improvements like Internet network upgrades. In 2023, Comcast announced investments in rural Fresno and Merced Counties, including expanding to Caruthers, Biola, and Planada (https://california.comcast.com/2023/09/28/comcast-invests-3-6-million-to-bring-xfinity-10g-network-to-rural-community-of-caruthers-california/). Nearly 5.6 million California homes and businesses have access to Xfinity Internet and Comcast Business products and services, including speeds of 1.2 gigabits per second or more available to customers throughout our footprint. Over the past three years, Comcast added and upgraded nearly 10,000 miles of our network to connect homes and businesses and is preparing for the rollout of our next generation 10G network across the United States, including throughout our California service area. This growth is a result of Comcast’s more than $20 billion nationwide investment from 2018 to 2022 in our networks, which now cover more than 60 million U.S. homes and businesses. Given Comcast’s long and proven track record of expanding broadband access and adoption in California, Comcast stands ready to partner with the State in its digital equity efforts through a variety of existing programs that we will discuss throughout our comments.

2. Introduction and Vision for Digital Equity
Barriers to Broadband Adoption. Both longitudinal research and empirical evidence demonstrate that the primary barriers to broadband adoption extend beyond affordability and include perceived relevance and digital readiness, among others.

Perceived Relevance. A significant population of Americans who have not yet adopted home broadband do not recognize the relevance of such connectivity. The National Urban League (“NUL”) Lewis Latimer Plan explains that perceived relevance may be tied to a lack of awareness and understanding of the Internet’s uses and capabilities, in addition to the skills needed to use it. NTIA’s Internet Use Survey data showed that 58 percent of the 21 million offline households indicated no interest in or need to be online. Moreover, a 2021 Pew Research Center survey found that 71 percent of non-broadband users say that they would not be interested in an at-home broadband connection. These numbers help demonstrate why education and outreach to the unconnected and newly connected regarding broadband and its associated benefits is imperative for closing the digital divide.

Digital Readiness. According to the NUL Lewis Latimer Plan, digital readiness is “the sum of the technical skills and cognitive skills people employ to use computers to retrieve information, interpret what they find, and judge the quality of that information” and “the ability to communicate and collaborate using the Internet.” Digital readiness challenges impact different parts of people’s lives, including the use of developing technologies, online educational resources, and telehealth capabilities. While the U.S. workforce has a high demand for digital skills, many workers, especially workers who are members of a racial or ethnic minority group and those with low levels of literacy, lack these skills.

Other Adoption Barriers. Other adoption barriers pertain to information and language, distrust, and structural issues tied to poverty. Information and language barriers may pertain to individuals determining program eligibility, parsing an application process, and setting up devices and services. Addressing language barriers is important for Comcast, which is why Internet Essentials (“IE”) call center agents can help IE applicants in more than 240 languages, in addition to American Sign Language. IE applications are also available in seven languages and materials for IE are available in 16 languages. Distrust may involve skepticism of free services and government programs, as well as uncertainty about additional costs and privacy concerns. Structural barriers may include complicated housing situations, such as recent moves or plans to relocate. Comcast recognizes that just like there is no single solution to addressing broadband adoption, the underlying challenges are also not monolithic.

Bridging the Adoption Gap. Empirical evidence demonstrates that community outreach and engagement – by digital navigators, community-based organizations, community anchor institutions, faith-based leaders, and other trusted voices – is vital to overcoming complex adoption barriers.

To this end, for more than a decade, Comcast has been investing to expand digital equity and inclusion in California, including through community outreach and engagement efforts. Project UP is our comprehensive initiative to advance digital equity and help build a future of unlimited possibilities. Backed by a $1 billion commitment to reach tens of millions of people nationwide, Project UP encompasses the programs and community partnerships across Comcast, NBCUniversal, and Sky that connect people to the Internet, advance economic mobility, and open doors for the next generation of innovators, entrepreneurs, storytellers, and creators (https://corporate.comcast.com/impact/project-up).

3. Current State of Broadband and Digital Inclusion
IE is the largest and most successful broadband adoption initiative in the industry, connecting more than 10 million Americans to broadband Internet at home since launching in 2011. IE is designed to be a wrap-around solution that addresses the main barriers to broadband adoption. IE provides subscribers with access to broadband service at speeds of 50/10 Mbps for $9.95 per month or 100/20 Mbps for $29.95 per month (for IE Plus) with no activation fees and no equipment rental fees for IE and IE Plus, access to millions of Xfinity WiFi hotspots, a wireless gateway delivering in-home WiFi at no additional cost, the ability to obtain low-cost or no-cost computers, unlimited data, and free digital skills training. Notably, while the IE price of $9.95 per month has remained steady since the program launched, speeds for that service have increased seven times, including more than doubling during the early days of the COVID-19 pandemic. Recognizing the critical need for Internet-ready devices in addition to a broadband connection, Comcast has distributed more than 200,000 free and subsidized laptops nationwide. The IE program has been designed to eliminate barriers for financially constrained households and help more families benefit from home Internet access. To become an IE customer, there is no credit check required, no term contract requirement, and customers who do not have a social security number (or prefer not to provide their social security number) may apply with other forms of identification.

Since 2011, 1,968,000 low-income California residents in 492,000 homes have connected to the Internet through IE. The top cities for IE connections include Fresno, Sacramento, Stockton, San Jose, and San Francisco.

Comcast/Xfinity proudly participates in the Affordable Connectivity Program (“ACP”) with all tiers of Internet service the company offers, including two tiers (IE and IE Plus) that are fully covered by the $30 ACP benefit. We hope that the federal government will renew ACP funding and are proud to have co-hosted nearly 900 ACP events nationwide since October 2022. In California, we have partnered with Fresno State Connect Initiative, San Francisco Tech Council (“SF Tech Council”), Catholic Charities, Sacred Heart Community Services, and Solano County Connected as part of our ACP outreach efforts. Beyond connectivity, we work with tens of thousands of partners across the country, including nonprofits and city leaders, to support digital skills training to improve economic mobility. We offer free training through our IE Learning Center: Internet Essentials – Free Internet from Xfinity (xfinity.com), which features hundreds of modules on Internet basics, online safety, digital skills for everyday life, and advanced skill-building (https://www.xfinity.com/learn/internet-service/internet-essentials/learning). The content is curated from partners like Common Sense Media, Goodwill, CNBC, Women in Sports Technology, and more. In addition, Comcast has partnered with several experts, including ConnectSafely, Older Adults Technology Services (“OATS”), and Council for Opportunity in Education, to develop printed digital skills curricula that are distributed to thousands of community partners free of cost. These include several online safety toolkits for seniors and students, discussion guides for parents, and our Jurassic World Science, Technology, Engineering, Arts, and Math (“STEAM”) curricula. Comcast has long invested in nonprofit partners focused on digital skills via the Comcast NBCUniversal Foundation to help provide skills-building, job training, and other career development offerings for the full spectrum of learners, from elementary, middle and high school students to adults.

Locally, these organizations include Fresno State’s Parent University program, Self-Help for the Elderly, Asian Pacific American Community Center (“APACC”), the YMCA of San Francisco, SF Tech Council, Chico’s True North Housing Alliance, and the Parent Institute for Quality Education (“PIQE”), which operates in several cities and counties statewide. Comcast also recently pledged $100,000 in scholarships to students pursuing careers in STEAM at Fresno City College, Clovis Community College, Madera College, Reedley College, and the College of the Sequoias (https://california.comcast.com/2023/10/19/comcast-california-pledges-100000-in-scholarships-to-five-central-valley-community-colleges/).

According to a 2021 study, “Wired and Hired: Employment Effects of Subsidized Broadband Internet for low-Income Americans” published in the American Economic Journal, IE customers make an average of $1,385 more per year and are 8 percent more likely to be employed than those eligible for but not connected through IE (https://www.aeaweb.org/articles?id=10.1257/pol.20190648).

4. Collaboration and Stakeholder Engagement
Project UP encompasses a number of longstanding and new initiatives in collaboration with local communities.

Digital Navigator Programs. Digital navigators are a powerful and proven tool to aid broadband adoption, especially for Covered Populations. Digital navigators are typically hired volunteers or staff from trusted community institutions – such as libraries, social or public service agencies, and community-based organizations – who can assist users in overcoming barriers to adoption in a tailored manner.

Digital navigators can address the relevance of broadband by demonstrating benefits like access to information, telehealth capabilities, and introduction to upskilling programs that serve as pathways to education, employment, and more. A recent Boston Consulting Group (“BCG”) study supported by Comcast surveyed 1,500 people who have participated in programs with digital navigators and found that 65 percent of respondents were able to obtain Internet connectivity or a connected device, and 85 percent of respondents now use the Internet more frequently. The same research demonstrates that the benefits of digital navigators extend beyond individuals obtaining Internet access – almost 50 percent of respondents obtained better health care; more than 40 percent of respondents received support for essentials like food, rent, and housing; and more than one in three respondents found a new job or secured higher incomes. Given the importance of digital navigators, Comcast, in 2022 alone, invested $11.4 million in more than 225 nonprofits to support digital navigator programs across our service areas. Comcast currently partners with organizations in California to create and support digital navigator programs, including Fresno State Connect Initiative, SF Tech Council, and PIQE.

Additionally, investing in digital navigators will provide individuals from all racial/ethnic and educational backgrounds with the opportunity to learn more from members of their own communities about how broadband-connected technology can be relevant to their lives. Research from BCG revealed several other key findings, including that (1) trust and relationship-building are key to reaching disconnected communities; (2) familiar outreach channels are most effective at getting learners in the door; (3) one-on-one attention is often most effective, especially for learning fundamental skills; (4) resource-sharing and local coordination can minimize burdens on individual digital navigators; and (5) digital navigators are the trusted voice on the ground for understanding community needs. These solutions address the main barriers to broadband adoption, as described above, and increase digital opportunity for all Californians.

Digital Skills Programs. As digital navigators play a critical role in helping members of Covered Populations overcome adoption barriers, a related component of successful digital adoption efforts is programming to help people develop digital skills once they are connected. Comcast works with organizations that provide skills building, job training, and other career development offerings for the full spectrum of learners, from high school students to adults. In addition to providing programming support, Comcast often provides funds for devices and other equipment essential for practical learning.

A February 2023 report from the National Skills Coalition and Federal Reserve Bank of Atlanta indicated that 92 percent of jobs available today require digital skills, yet almost one-third of U.S. workers lack opportunities to build these skills. Jobs that require even one digital skill can earn an average of 23 percent more than jobs requiring no digital skills, which translates to an increase of $8,000 in annual income. Developing these digital skills is not only a value add for individual workers, especially for workers of who are members of a racial or ethnic minority group, but a benefit to the larger U.S. economy.

Comcast supports digital exploration initiatives that teach individuals the basic skills needed to increase competency and confidence in using technology, spark interest in technology careers, and prepare individuals for the jobs of the future through early exposure to technology fields, in-school and after-school programming, technology and computer science programs, and soft skills training. In California, this includes Digital NEST, Grail Family Services, Parent University, and the True North Housing Alliance, among others.

Lift Zones. Through Project UP, Comcast, together with nonprofit partners and city leaders, has created more than 1,250 Lift Zones in community centers nationwide, including 154 Lift Zones in California. In 2023, Comcast donated $25,000 to the Boys & Girls Clubs of Oakland to continue elevating Lift Zones hosted at three of their locations, including a focus on career workshops, mentorship, and other digital program supports (https://california.comcast.com/2023/07/07/comcast-donates-25000-to-boys-and-girls-clubs-of-oakland-to-kick-off-lift-zone-elevation/). Along with free Internet connectivity, Lift Zones offer hundreds of hours of free educational and digital skills content. Not only are 50 percent of low-income households in major Comcast markets within walking distance of a Lift Zone, 40 percent of users report that they would not have had Internet access without the Lift Zone, and 58 percent report that the Lift Zone reduces stress for studying, working remotely, and managing online tasks.

Internet Essentials Partnership Program. In addition to IE, the Internet Essentials Partnership Program (“IEPP”) is designed to help accelerate Internet adoption and provides the opportunity for school districts and other organizations to fund and quickly connect large numbers of students and families to broadband access. California organizations participating in IEPP include the Madera Unified School District, Contra Costa College Foundation, Twin Rivers Unified School District, Chico Unified School District, Family Resource Network, and the SF Community Living Campaign.

Other Initiatives: Accessibility. Comcast remains focused on helping members of Covered Populations, including individuals with disabilities. In addition to accessible technology innovations such as the X1 Voice Remote and the Xfinity Adaptive Web Remote, Comcast supports several partner organizations. For example, we partner with the SF Tech Council, an organization focused on tackling digital inclusion gaps for older adults and people with disabilities. SF Tech Council believes that adoption and use of technology helps increase online and in-person connections, improve financial security through employment initiatives, and reduce social isolation. The Comcast NBCUniversal Foundation also recently awarded a $1.3 million two-year grant to Easterseals to expand digital literacy training for young adults with disabilities enrolled in Easterseals employment programs. Students with intellectual and/or developmental disabilities ages 16 to 24 will be trained on how to navigate the Internet, communicate through email, create PowerPoint presentations, prepare resumes, use assistive technology, and more.

6. Conclusion
Comcast encourages California to focus on digital equity efforts that will be the most impactful, including digital navigators, digital skills training programs, and partnerships. Comcast believes that partnerships are paramount to advancing digital equity efforts because closing the digital divide starts at the local level by meeting people where they are and responding to their specific needs. Communities win when the private sector, government, and community organizations join forces to achieve shared goals. To that end, California should create an inclusive framework that allows many organizations to participate directly in grant programs and fosters such participation through partnerships and coalitions. Comcast’s more than a decade of dedicated digital adoption and community engagement efforts demonstrate that the private sector has been a critical partner in facilitating digital equity efforts to date. The implementation of California’s Digital Equity Act should seek to amplify and scale the efforts of these existing successful relationships and ensure that the private sector continues to be a force multiplier for public funding.

Comcast looks forward to continuing to work with the California Department of Technology as it refines and implements its Digital Equity Plan.
4830January 25, 2024 at 11:48 amSpecialist, Policy & OutreachOrganizationCalifornia AfterSchool NetworkSacramentoCA2. Introduction and Vision for Digital Equity
2.2 Alignment with Existing Efforts to Improve Outcomes
EDUCATION
Transforming Schools: Superintendent’s Initiatives details the priorities and initiatives of CDE to transform K-12 public schools by integrating new programs and strategies for students, families, educators, and local education agencies. During the COVID-19 Pandemic, California’s Expanded Learning Programs (including before school, afterschool, summer, and intersession opportunities) collaborated with the school day to ensure families and students had access to technology and connected to their classes. Expanded Learning Programs also created hubs where front-line responders could drop off their children and have them log on to their classes in a safe space and receive support from Expanded Learning staff. Additional information can be found in our brief: A Hub of Community Resilience: California’s Expanded Learning Programs Respond to Crisis A State of the State Brief: December 2020. Currently, California has three funding streams dedicated to ongoing support of Expanded Learning programs, including the After School Education and Safety (ASES) program, the 21st Century Community Learning Centers (21st CCLC) program, and the recently established Expanded Learning Opportunities Program (ELO-P). Local Education Agencies (LEAs), such as School Districts and Charter Schools, are the primary recipients of Expanded Learning apportionments and grants. Many LEAs implement their Expanded Learning programs in partnership with local Community-Based Organizations (CBOs).

DIGITAL LITERACY & INCLUSION
California’s Expanded Learning Programs (including before school, afterschool, summer, and intersession opportunities) served over 980,000 youth in Fiscal Year 2018-19, often engaging students and their families from diverse backgrounds who qualify for free and reduced meals with opportunities to increase their digital literacy skills. Expanded Learning Programs also serve:
Immigrants
Individuals in households below 150% of the federal poverty line
Individuals living in a tribal community
Individuals primarily residing in a rural area
Individuals with disabilities
Individuals with limited English proficiency
LGBTQIA+ individuals
Racial or ethnic minorities
Unhoused individuals
Programs have a history of working with Science, Technology, Engineering, Art, and Math (STEAM), including digital skills, computer, science, cybersecurity, and coding. California ASES Kids Code grants are an example of this. Expanded Learning Programs are crucial partners in this work since they are often the first point of contact with families and the community.
4829January 25, 2024 at 11:45 amP.C.ResidentLos Gatos950332. Introduction and Vision for Digital Equity
Wired infrastructure offers greater capacity, predictable performance, lower maintenance costs, and a longer technological lifetime than wireless technologies. Fiber service is not degraded by line-of-sight issues and is not affected by capacity issues.
4828January 25, 2024 at 11:44 amSpecialist, Policy & OutreachOrganizationCalifornia AfterSchool NetworkSacramentoCA2. Introduction and Vision for Digital Equity
DIGITAL LITERACY & INCLUSION
California’s Expanded Learning Programs (including before school, afterschool, summer, and intersession opportunities) served over 980,000 youth in Fiscal Year 2018-19, often engaging students and their families from diverse backgrounds who qualify for free and reduced meals with opportunities to increase their digital literacy skills. Expanded Learning Programs also serve:
Immigrants
Individuals in households below 150% of the federal poverty line
Individuals living in a tribal community
Individuals primarily residing in a rural area
Individuals with disabilities
Individuals with limited English proficiency
LGBTQIA+ individuals
Racial or ethnic minorities
Unhoused individuals
Programs have a history of working with Science, Technology, Engineering, Art, and Math (STEAM), including digital skills, computer, science, cybersecurity, and coding. California ASES Kids Code grants are an example of this. Expanded Learning Programs are crucial partners in this work since they are often the first point of contact with families and the community.
4827January 25, 2024 at 11:23 amD.W.ResidentOrange928671. Executive Summary
5G has not been proven safe or harmless. It should therefore, never be used as there are many proofs and reports of the damages and harms it has caused. Our government is to protect the people, not harm them and not allow others to harm them.
4826January 25, 2024 at 11:18 amExecutive DirectorOrganizationNextGen CaliforniaSacramentoCA5. Implementation Strategy & Key Activities
NextGen California is pleased to see the State Digital Equity Plan recommend a California Connect Corps as one of the seven key activities the state should undertake to close the digital divide. The NextGen team firmly believes in the power of Digital Navigators to meet Californians where they are and provide the personalized assistance needed to bridge gaps in access, awareness, technical assistance, digital literacy, and utilization of existing programs and resources. Digital navigators are a much needed complement to the digital equity infrastructure — they assist and ensure that community members and community-based organizations (CBOs) are able to take advantage of the new and existing resources that are often designed specifically to meet their needs. We appreciate that the state digital equity plan includes both funding to shore up existing programs and also contemplates piloting new models, such as the California Connect Corps. NextGen would like to see both grant programs coordinated through one entity to ensure that the California Connect Corps adds to and enhances existing capacity.

Digital Navigators is a flexible term that can refer to similar but sometimes distinct activities. Although IT assistance has traditionally not been part of a Digital Navigator’s scope of work, NextGen was heartened to see that the draft plan included IT career training for Digital Navigators in the California Connect Corps so they can provide additional support services to community members. There is another significant benefit as well — it creates a career pathway for Digital Navigators to transition into IT support roles, a job that pays decent wages, is expected to grow in demand, and does not require a four-year degree, although certification is essential. It may be worth considering including device refurbishment as a component of their IT training. Not only does this strengthen the skill set of Corps members, but it also could create a pipeline of free or subsidized devices to distribute to California Connect Corps clients.

NextGen also would like to offer several recommendations to further refine the proposed Connect Corps:

Recommendation 1: Take an integrated statewide approach that ties in with anchor institutions and other like-minded partners

The promise of a California Connect Corps is that the state can be more ambitious, strategic and ultimately impactful in its Digital Navigator programming by taking a coordinated approach. The best way to leverage scarce resources is through a coordinated statewide approach that takes advantage of economies of scale (such as by using a shared training curriculum, programming blueprint, back-office support, help desk infrastructure, partnership network and employer engagement). It enables the program to be more ambitious in its design and partnerships by securing the participation and collaboration of state agencies (ideally California Volunteers, Department of Aging, Labor Agency, etc), anchor institutions (especially K-12 schools, community colleges, community based organizations, and libraries) and employers (to create career pathways for participating Digital Navigators).

For this reason, we urge the California Department of Technology (CDT) to convene an advisory group of public, private, philanthropic, and nonprofit entities to help design the program under an integrated Connect Corps model, potentially with multiple regional and local implementing partners, rather than disparate, stand-alone programs in different localities.

We believe that the best way to achieve this program goal is through a two-tier administrative structure, with one statewide coordinating body working with new and existing local implementing partners in high need areas of the state. This approach blends the benefits of centralized statewide coordination (i.e, efficiency, effectiveness of shared best practices and cost savings through economies of scale) with the benefits of implementation by trusted local partners who know their communities best.

Recommendation 2: Leverage existing expertise

We hope that the Connect Corps will be able to take advantage of both the benefits of statewide coordination and local expertise. The goal should be to enhance, not supplant, existing programs. We envision two ways that existing Digital Navigator programs could complement and/or integrate into the Connect Corps model:
Leverage their experienced Digital Navigators into the Connect Corps infrastructure (for example as trainers, managers, or local coordinators); and/or
Provide additional IT career training to the current digital navigator infrastructure, as well as adhere to the Connect Corps model (further recommendations below)

Recommendation 3: Consider the California Community College system as an institutional home or partner for the California Connect Corps

The California Community College system could make an excellent sponsor for this initiative, in collaboration with CBOs. IT-track community college students have the right profile for the Digital Navigator role. Most, if not all, community colleges offer an IT/Computer Systems track that prepares students for CompTIA A+ certification and beyond. Unlike four year colleges, community colleges specifically prepare students for this certification that allows them to obtain entry-level IT help desk jobs. This provides a strong technical foundation for the California Connect Corps to layer on additional soft skills and Digital Navigator-specific training. Digital Navigators also need to be as diverse as the communities they serve to provide culturally competent, in-language support. The student body of community colleges reflects California’s great diversity. The program also presents a wonderful opportunity for participating students to serve their community in a paid capacity, while earning their IT certification, and gaining invaluable work experience.

Recommendation 4: Prioritize partnerships

The benefit of having statewide coordination is that the program can be more ambitious in its partnerships. We hope that the program is able to take advantage of this by forming partnerships with various anchor institutions (especially libraries, K-12 schools and the community college system), state agencies like the Department of Aging and Cal Volunteers’ College Corps, the California Public Utilities Commission (CPUC), and community-based organizations. In regards to the College Corps program, we recommend adding digital inclusion activities as a fourth pillar of service (alongside climate, educational mentoring and tutoring, and food insecurity) to enable more students to either directly serve in the California Connect Corps, or in other existing digital navigator programs.

Recommendation 5: Meet clients where they are (literally)

Given that the role of a Digital Navigator is to remove barriers to access and utilization of programs targeting underserved populations, we believe the work of Digital Navigators should include robust proactive in-person outreach, in addition to any advertising campaigns (i.e. radio, TV, flyers, etc). This outreach could include tabling at local community events or in high-traffic areas, phone banking, visiting with community centers, and organizing enrollment events for the Affordable Connectivity Program (or with the ACP potentially winding down, other low cost plans) or other public benefit programs in coordination with community-based organizations, anchor institutions, and local, county and state agencies. This outreach should be coupled with on-the-spot assistance whenever possible. NextGen also supports the idea of pop-up help desks that rotate to different anchor institutions and community centers.

Recommendation 6: Provide multi-channel support to address different preferences in high-need areas

In a large state like California, advancing digital equity means striking a balance between the imperatives to offer statewide coverage and in-person services whenever possible. The best way to strike this balance is through in-person operations in high-need communities, and a remote help desk that serves the entire state (hotline, online chat and videoconferencing). We agree with the plan’s recognition of differing individual preferences on the delivery mode, which is why we believe that all delivery modes should be available in high-need areas.

Recommendation 7: Integrate social services enrollment

Community members often have multiple needs across a range of areas that have been left unaddressed. Free tech support or device distribution is often a great way to begin a relationship with underserved individuals and better understand their needs, both tech and non-tech related. To the greatest extent possible, Digital Navigators should be trained to assist clients in online enrollment for social services, ideally through one streamlined portal such as BenefitsCal, as well as providing referrals for additional support. Another possibility would be to hold joint resource fairs or help desks with Digital Navigators and social service providers to provide a one-stop approach to clients.

Partners have found that device give-aways, tied to ACP enrollment (or other similar plans) or completion of basic training, can incentivize engagement with Digital Navigators. It also begins a relationship that allows for Digital Navigators to provide end-to-end support and assistance, tailored to the individual client’s needs. For this reason, NextGen encourages CDT to explore if and how device refurbishment and distribution could be integrated into the California Connect Corps program.

Recommendation 8: Ensure pathways into IT jobs are not dead-ends

The proposed California Connect Corps differentiates itself from most other Digital Navigator programs by offering free IT training to Digital Navigators leading to industry-recognized certification. These IT help desk jobs can be a springboard for underrepresented groups into a career in tech. However, to deliver on this promise, the program must not only offer training but also must work with employers to ensure there is an entry-level IT job on the other side of the Digital Navigator’s service to the community. NextGen was pleased to see mention of supportive services for Digital Navigators, which is another important element to ensure that diverse applicants are able to be successful in these positions as they begin an IT career.

_____

We are encouraged by CDT’s work on this draft plan for how we close the digital divide, but more actionable next steps need to be formulated and communicated with community input. The plan is heavy with aspirations, but lacking in specifics; engaging with digital equity advocates and experts now is more important than ever if CDT is to meet its ambitious goals, and get this right for all Californians. Given the complexity and importance of this initiative, robust stakeholder engagement, including with existing Digital Navigator programs, anchor institutions and beneficiaries, will continue to be crucial to the success of the California Connect Corps. NextGen would strongly suggest that CDT contemplate establishing an advisory council to provide input on the formation, implementation, integration, and oversight of a statewide California Connect Corps network. NextGen looks forward to seeing the vision for a California Connect Corps brought to life. We stand ready to support the initiative however needed to make sure the program delivers on the promise of digital equity.
4825January 25, 2024 at 10:58 amComprehensive Suicide Prevention Program CoodinatorOrganizationCA Dept of Public HealthCA5. Implementation Strategy & Key Activities
Since health is one of the priority outcomes, how will the CDT improve navigation to telehealth and tele-mental health services to patients, providers, and caretakers? In the drafted plan, the CDT will improve access to internet service in community anchor institutions including education, healthcare, workforce and economic development, libraries, and housing. To facilitate access to telehealth and tele-mental health services, the CDT will increase free/affordable access to internet and access to digital literacy/skill training at the community anchor institutions. I would recommend providing guidance and tutorials on how to access to healthcare and mental healthcare services virtually as one of the core components to the digital literacy/skill training curriculum. At the community anchor institutions, I would suggest providing private rooms for patients to connect to their clinician through telehealth and tele-mental health. In addition to providing ongoing access to high-speed broadband, I would highly recommend ongoing support for community anchor institution and literacy/skill training.
4824January 25, 2024 at 10:46 amP.S.ResidentEncinitas920242. Introduction and Vision for Digital Equity
WIRED connection is superior to wireless in all respects, and wireless broadband—especially the basic services offered to low-income families—will NOT solve the digital divide.
Wireless is unreliable and unable to meet the demands of present and future digital communications. Providing funding for rollout of wireless installations will take it away from much safer, reliable, energy-efficient WIRED internet.

• Wireless will set the state back in terms of climate change management because wireless uses a huge amount of energy compared to WIRED broadband.

• Wireless facilities increase fire risk and cyber security risk

• Wireless facilities impact the growing percentage of the population with disabilities related to radiofrequency radiation (RFR) exposure.

• Wired infrastructure offers greater capacity, predictable performance, lower maintenance costs, and a longer technological lifetime than wireless technologies. Fiber service is not degraded by line-of-sight issues and is not affected by capacity issues.
4823January 25, 2024 at 10:45 amManaging DirectorOrganizationValley VisionSacramentoCA1. Executive Summary
Valley Vision, as manager of the Connected Capital Area Broadband Consortium (CCABC) and Capital Region Coalition for Digital Inclusion (CRCDI), is committed to achieving broadband access and adoption, and digital literacy and skills for communities across the Greater Sacramento Region. Beyond our efforts in CCABC and CRCDI, Valley Vision has led direct community efforts to bridge the digital divide, including developing the Capital Region Digital Inclusion Portal (capitalregion.modat.org) and partnerships with the California Emerging Technology Fund (CETF) for advancing Affordable Connectivity Program (ACP) adoption and developing the first elementary School2Home project at Leataata Floyd Elementary School. Regarding ACP this includes hosting several enrollment events with our jurisdictions and CBO partners, helping develop digital navigator programs, tracking ACP enrollment by county and jurisdictions, and collaborating with our congressional delegation to support digital equity programs.

Valley Vision, CCABC, and CRCDI commend the California Department of Technology for its efforts to engage communities across the state in order to develop SDEP. As part of these efforts, Valley Vision co-hosted the Greater Sacramento Region SDEP Workshop on May 11, 2023 with CDT and CPUC, which featured over 150 community participants. We support SDEP’s goals to collectively address the main principles and steps necessary to achieve digital equity and close the digital divide for all Californians.

Through our active efforts of supporting residents, jurisdictions, community based organizations, and providers with broadband deployment and digital equity needs, Valley Vision recommends the following considerations:

Objective 1.4 recognizes the importance of choice for consumers. We support any and all efforts by the State to create increased competition and choice for consumers across the regions in both urban and rural areas. It is vital for consumers to not only have a choice regarding providers, but also broadband technology options, with the availability of both wired and wireless broadband connectivity (along with the necessary infrastructure). In addition to choice, it is essential that each consumer has access to at least one–and preferably all–providers that offer ACP and/or other low-cost programs. In CCABC’s rural communities, many residents eligible for ACP do not have access to providers which offer low-cost program options. The State should support smaller internet service providers to provide these important low-cost services.

Objective 2.3: Currently, ACP will stop accepting applicants February 7th. Valley Vision voiced the importance for continuing ACP during Public Comment at the California Broadband Council meeting on January 24th and appreciate CDT and CPUC’s joint congressional letter in support of ACP, but recommend the State have a strong plan in place to ensure the availability of low-cost internet plans for eligible California residents. This is an essential component of being able to implement SDEP. In supporting adoption efforts, it is important for the State to provide support to consortia, community organizations and local government jurisdictions for assistance in sharing information and leading awareness campaigns related to affordable internet access programs.

Objective 3.1: Valley Vision agrees with increasing the following resources, and recommends supporting these efforts through existing organizations and local government entities, such as County Workforce Boards, in order to establish trusted resources for digital resource training.

We concur with the recommendations outlined by the National Skills Coalition related to Objective 3.4 and 3.5, emphasizing the recommendation for CDT to expand the focus from base-level skills, to intermediate and advanced skills. Along with ensuring workforce-related programs reflect current best practices in the field. The National Skills Coalition presented its Closing the Digital Skill Divide report to CRCDI’s quarterly meeting in June 2023, which found 91% of jobs in California require digital or likely digital skills.

We concur with Southern California Association of Governments’ key recommendations related to section 5.1 Key Activities, in order to ensure all unserved locations are mapped and prioritized.

In closing, Valley Vision, CCABC, and CRCDI recognize SDEP is moving in the right direction to ensure digital equity for all Californians. We thank the State for its continued efforts and the opportunity to provide public comment. We look forward to collaborating with our State partners on implementation of SDEP.
4822January 25, 2024 at 10:42 amD.G.ResidentFort Bragg954373. Current State of Broadband and Digital Inclusion
Broadband has become a necessity on many households. I live in a rural coastal area of Mendocino County, an area with populations concentrated around a few towns connected by roads that are often impassible in winter due to flooding or landslides. Broadband is available in some but not all areas here, and cellular only covers some of the area, principally around the larger towns and not in the areas between them. Landlines are the cornerstone of connectivity in Mendocino County, both for broadband access (via DSL) and for communications. The population demographic here is typically elderly and low-income.

For many, landlines are their only means of communication. Many
do not drive nor own functioning vehicles.
Emergency notifications (official & otherwise) often do
not reach those who have cell phones due to large parts of the County without cell tower coverage, but do reach households with landlines.
For these reasons, maintaining landlines should be the top priority in maintaining
connections to & throughout remote areas, at least until such time as other reliable means are made available,
4821January 25, 2024 at 10:40 amJ.L.ResidentGRASS VALLEY959452. Introduction and Vision for Digital Equity
I don't want wireless. I and many of my family and friends have become hypersensitive to wireless radiation. It is not harmoniously compatible with the electromagnetic systems of our bodies and it creates an increasing amount of discomfort as it disrupts our organisms' functioning. Corporations are given the right to exist by the body politic if they will serve the the public good. When they fail to serve the body sovereign, they no longer have a right to be here.
4820January 25, 2024 at 10:37 amState Network ManagerOrganizationNational Skills CoalitionMillbraeCA1. Executive Summary
Comments to the California Department of Technology (CDT)

National Skills Coalition and our California-based network appreciate the opportunity to provide comments on California’s draft State Digital Equity Plan. NSC fights for a national commitment to inclusive, high-quality skills training so that more people have access to a better life, and more local businesses see sustained growth.

A major policy priority for our coalition is creating and supporting inclusive digital skills policies so that people can access good jobs, and small businesses can hire for in-demand positions. As stakeholders in this important discussion, we welcome the chance to share our experience and observations with the California Department of Technology.

California’s draft Digital Equity Plan (“the Plan”) represents a significant leap forward for the state and will be an invaluable roadmap for the implementation of federal investment over the next few years. However, we are concerned that the Plan does not fully respond to the urgency of the moment with regard to digital skills in particular. As the Plan notes, digital skills underpin each of the other goals that the state has identified regarding broadband adoption, device access and usage, etc. Skills are part of a “virtuous cycle” in which access to technology tools and skills mutually reinforce each other, equipping state residents to achieve their educational, civic, and career aspirations.

Indeed, research has repeatedly shown when people are asked why they want to learn digital skills, they answer: To get a job, or to get a better job. This reality is a cornerstone of the work that digital inclusion providers and advocates have been doing in the Golden State for more than 30 years, and the programs and services that adult education, community college, and workforce development organizations offer in every corner of our state.

The federal Digital Equity Act is a generational investment in meeting this demand. The funding that California is receiving through this legislation will not only help residents get badly needed access to high-speed internet and digital devices, but also equip them with the skills they need to use those tools effectively to achieve their economic and career aspirations. Equipping people with the digital skills they need for the workplace and beyond is an integral part of achieving broader digital inclusion goals.

Recent research from NSC and the Federal Reserve Bank of Atlanta highlights the demand for digital skills in our state. The Closing the Digital Skill Divide report analyzed millions of Help Wanted ads and found that fully 91 percent of jobs in California today require digital or likely digital skills. These numbers hold true across industries and for workers at every level of education and experience.

A crucial finding of this report is the overwhelming demand for frontline, entry-level workers to use technology on the job. Californians need both the foundational, basic skills that are commonly covered in introductory classes, as well as more specialized skills relevant to their particular industry or occupation. Here are just a few examples from major California industries:

-Robotics in the retail, logistics and warehousing, and meatpacking industries

-Content Management Systems (CMS) in the world-renowned entertainment industry within quickly growing advertising, promotions, and marketing sectors

-Scanner, point-of-sale, and other e-commerce technologies in the retail sector

-Safety technologies, blueprint technologies, and other mobile applications in the construction sector

-Industrial Internet of Things (IoT) devices and on-board tractor and harvester software and hardware systems in the agricultural sector

-Cybersecurity in the healthcare, local government, and utility industry sectors


As this research makes clear, today’s digital skills stretch far beyond the traditional image of a white-collar worker sitting at a desktop computer. The jobs in which Digital Equity Act “covered populations” are currently working – and the new jobs they aspire to – require digital skills.

As California implements its federal investments, investing in digital skills will be a crucial element of serving the covered populations outlined in the law -- including rural residents, veterans, low-income individuals, people of color, and people with language or literacy barriers, among others.

Thank you again for the opportunity to submit these comments. Questions about this submission can be directed to Karina Paredes-Arzola at KarinaPA@nationalskillscoalition.org or (415) 624 5140.


Sincerely,


National Skills Coalition

Karina Paredes-Arzola

State Network Manager

KarinaPA@nationalskillscoalition.org



California EDGE Coalition

Anna Alvarado

Policy Director

aalvarado@caedge.org



California Immigrant Policy Center

Edgar Ortiz

Economic Justice Policy Analyst

eortiz@caimmigrant.org



California Opportunity Youth Network

Sean Hughes

Policy Director

seanmichaelhughes@gmail.com



Central Valley Worker Center

Pedro Ramirez

Executive Director

pramirez@valleyworkers.org



SEIU UHW & Joint Employer Education Fund

Tarik Scott

Development Director

tscott@theedfund.org



California’s proposed objectives related to digital skills are necessary but not sufficient. The draft Digital Equity Plan does not go nearly far enough in establishing a vision for what a more digitally skilled California would look like and creating a roadmap to help millions of state residents achieve that vision. Without a more ambitious set of objectives and accompanying measures, California is in danger of losing ground to competitor states that are pursuing more aggressive efforts to upskill and reskill state residents with in-demand digital skills. In particular, Objectives 3.4 and 3.5 could be expanded and strengthened, and a new objective 3.7 should be created.



Objective 3.4 currently reads: “Increase the percentage of Californians who possess basic, intermediate, and advanced digital literacy skills.” This is a valuable and worthy goal. However, the target associated with this objective focuses only on basic skills, which is important but not enough. In addition, the definition of skills that was used in the telephone survey conducted of California residents is fairly elementary and does not take full advantage of earlier work done by Californians and other stakeholders to develop rich taxonomies of digital skills.

It is excellent that California is proposing to use a standardized set of digital skills measures. Having a set of common measures is crucial to providing the CDT and members of the public with easy-to-compare results over time, across different programs and local jurisdictions. However, we recommend that California expand the targets for Objective 3.4 to also include outcomes related to intermediate, applied, and advanced digital skills.



It is vital that these measures be associated with outcomes – that is, observable changes in ability or capacity – and not simply outputs or measures of activities carried out. Outcome measurement allows stakeholders to gauge whether programs are actually helping people achieve intended goals. They can help state leaders identify potential bottlenecks (programs or geographic areas where participants are getting stuck or not flourishing) as well as springboards (programs or areas that are doing an especially good job of helping people advance).



Specifically, we recommend that these common measures include: 1) Number and percentage of individuals who have achieved a measurable digital skill gain, disaggregated by type of gain (foundational/basic, applied/industry-specific, or advanced digital skills) and covered population; 2) Number and percentage of individuals who have attained a quality non-degree credential, disaggregated by covered population; 3) Number and type of digital skills program slots established or expanded, disaggregated by type of training provider (nonprofit organization, higher education institution, worker center, etc.); type of training (foundational/basic, applied/industry-specific, or advanced digital skills); and geographic location (urban, suburban, rural).



CDT should provide flexibility WITHIN these common measures. Specifically, CDT should provide a menu of options for how programs can demonstrate that participants have made a measurable digital skills gain – including pre/post testing, credential attainment, employment promotion/advancement, and other options. This will give providers vital flexibility in designing programs that are responsive to the real needs of people on the ground, without shoehorning all participants into a single type of assessment. Similarly, states should allow providers to report on any type of credential that meets quality guidelines, without “picking winners” by selecting just one credential that all providers must use.



CDT should NOT require the collection of specific data on immigration status. Federal law does not require that Digital Equity Act program participants demonstrate any particular type of immigration status. CDT should follow best practices in the adult education and public health fields by collecting only the minimal amount of Personally Identifying Information needed to demonstrate program impact, and avoiding the collection of any data related to immigration status or other sensitive topics.



We also recommend that CDT collect additional qualitative data from a subset of programs. This data can add richness and depth to the quantitative measures described above, and can point the way to future improvements.



Collecting this data in a limited fashion – perhaps by contracting with an evaluator to conduct interviews with a small percentage of programs – can be a cost-effective way to gather valuable information from: 1) Program participants about what inspired them to enroll in digital skills training and how they have defined success for themselves; 2) Program providers about how they define success in digital skill-building and what they have learned from trying to apply the required measures listed above; and Employers about how they gauge digital skills among jobseekers and workers, and their experiences hiring individuals who have completed Digital

Equity Act-funded training programs.

Objective 3.5 currently reads: Expand the number of members of covered populations hired in broadband infrastructure and technology jobs. The target for this objective is that “There is an increase in the number of individuals who identify as part of a covered population hired for broadband infrastructure and technology jobs.”

Again, this is necessary but not sufficient. We recommend expanding this target by adding detail on specific sub-targets related to each covered population. We also recommend that CDT work with the California Public Utility Commission to establish strong “on-ramps” that connect digital skills training programs to broadband workforce development programs and/or employment in broadband-related jobs.



CDT should ensure that its workforce-related programs reflect best practices in the field, such as contextualized learning, integrated education and training, portable industry-recognized credentials, earn-while-you-learn models, and connections to supportive services such as childcare that allow workers of all backgrounds to persist and succeed. A particularly useful model is industry sector partnerships, which bring together multiple employers along with education and workforce partners to develop employer-informed training programs. These elements are essential to ensure that workers have realistic prospects of attaining local employment when they complete training, and that local businesses can find the skilled workforce they need.



Finally, we recommend that CDT establish an additional Objective 3.7: Increase the use of administrative data to better understand Californians’ digital skills and needs. CDT and other state agencies collect substantial amounts of data in the course of the programs and services they provide. By analyzing a portion of this existing data, California can learn more about how residents are currently accessing state services and where there may be digital inclusion gaps.
4819January 25, 2024 at 10:25 amK.T.ResidentCapitola950101. Executive Summary
Please just improve the wired connections and forget about 5G. Every time we adopt some new technology and go hardcore in that direction we just end up impacting the environment in a new way even if it’s not evident right away or not impacting our immediate surroundings.
Also,

Wireless is unreliable and unable to meet the demands of present and future digital communications. Providing funding for rollout of wireless installations will take it away from much safer, reliable, energy-efficient WIRED internet.
4818January 25, 2024 at 10:22 amAssociate Director, Advocacy and Community EngagementOrganizationAARPPasadenaCA1. Executive Summary
AARP appreciates the opportunity to comment on California’s Draft State Digital Equity Plan (“Plan”), which was issued by the California Department of Technology (CDT) in consultation with the California Public Utilities Commission (CPUC) and the California Broadband Council (CBC). These comments reflect in part AARP’s perspective based on its many years of experience advocating for older adults on various issues. Comments emphasize areas that resonate especially with AARP’s high-speed internet advocacy and identify possible areas for additional emphasis and inclusion in the final Plan.

AARP lauds CDT for the Plan’s comprehensive discussion and analysis of the challenges to and benefits from achieving digital equity as well as for a thoughtful and clearly articulated roadmap for narrowing digital disparities in California. The Executive Summary provides an exceptional overview in a visually appealing manner. This is especially valuable for those unable to read the entire Plan

2. Introduction and Vision for Digital Equity
Comments on Section 2: Introduction and Vision for Digital Equity

AARP supports California’s vision for digital equity: “a California in which all residents have access to high-performance broadband, affordable service and devices, and the training and support necessary to enable digital inclusion for economic and other social benefits.” California’s vision is exemplary as it focuses on long-term outcomes of technology development, rather than attainment of basic skills that may not be sustained by covered populations.

The Plan’s vision holds tremendous promise for the older adults in California. As our society increasingly relies on online services, platforms, and communication means, those lacking reliable access or limited exposure miss out on important opportunities. On page 22, AARP appreciates the Plan acknowledging how digital equity will positively impact educational outcomes in the state. AARP notes that expanded educational opportunities facilitated by greater connectivity can yield personal growth and career advancement benefits for older Californians. Increased access to education opportunities allows older adults to learn a new talent or skill, start a secondary career, and meet like-minded people. Educational outcomes can help older adults maintain their independence, preserve their dignity, and have a positive attitude toward aging.

AARP appreciates the discussion, beginning on page 33, of how health outcomes will improve with better connectivity. As people age, doctor appointments become a bigger part of life. Being responsible for driving a loved one to several appointments a week or to specialists hundreds of miles away can pose a challenge. The hours spent on the road and in waiting rooms add up fast. Telehealth can assist older adults age in place safely and obtain access to state-of-the-art health care. AARP is hopeful that the implementation phase of the Plan will emphasize assisting older adults connecting to health care.

Digital literacy and inclusion are fundamental tenets of digital equity. As technology and Internet-connected devices become more integrated into daily life, there is a tendency to assume that everyone has a certain base level of proficiency. But the reality is that even if California can achieve universal broadband availability, affordability, and device distribution, a lack of digital skills will leave many people unable to benefit from those successes, including countless older adults. AARP appreciates the Plan’s reference to digital literacy and inclusion on page 34. From navigating websites, to using a word processor, to assessing the reliability of information online, digital skills building is fundamental to ensuring equitable access to technology and the Internet and is a key barrier for older adults. AARP suggests the final plan incorporate any high-level successes from the California Department of Aging’s (CDA) “Access to Technology” program and how the state will work with CDA on new programming.

AARP welcomes the discussion, beginning on page 34, of how better connectivity will enhance workforce and economic development outcomes in the state. While older adults may be exiting the workforce more than other covered populations, please consider the need for upskilling or learning technology to supplement retirement/fixed income through entrepreneurship. AARP research has shown small businesses are an important source of jobs for older workers; please find additional information from employment and older workers here - https://www.aarp.org/content/dam/aarp/ppi/2023/4/us-small-business-employment-and-older-workers.doi.10.26419-2fppi.00190.001.pdf

AARP suggests the Plan’s discussion, beginning on page 35, of civic and social engagement include information about how this aspect of older adults’ lives will be enhanced through better connectivity. AARP requests the final Plan include any existing initiatives that tackle social isolation, particularly for older adults. COVID further revealed the detrimental effects of social isolation, especially on certain populations. For more information see: https://www.nytimes.com/2023/09/06/opinion/loneliness-epidemic-solutions.html and https://www.nytimes.com/2023/04/30/opinion/loneliness-epidemic-america.html
https://www.nia.nih.gov/news/social-isolation-loneliness-older-people-pose-health-risks

AARP requests the final Plan state whether the “Share of CA population” in the table on page 45 reflects the share of the entire state or the share of CA covered populations. AARP further suggests the final Plan include a figure # when including tables or visuals within the Plan.

Based on its advocacy in various policy areas such as health and housing, AARP recognizes that high-speed internet access cannot in and of itself solve the many issues relating to various socioeconomic factors, but it is clear access to affordable, reliable high-speed internet access combined with tech-support and digital literacy can contribute to improved education, health, workforce, and civic and social engagement outcomes. If the digital gap is not closed, these disparities will only worsen.


AARP commends CDT for its holistic approach to achieving digital equity and its intention of creating a lasting impact. The objectives and strategies outlined in Section 2.5 are grounded in the key elements of digital inclusion. AARP’s comments on objectives, strategies, and key activities are submitted under Section 5: Implementation.

3. Current State of Broadband and Digital Inclusion
Comments on Section 3: Current State of Broadband and Digital Equity

AARP appreciates the CDT’s comprehensive inventory of digital equity resources. AARP is hopeful CDT will continue to update and make publicly available the asset inventory so that the digital equity community can continue to tap into this valuable resource. AARP commends CDT for developing the Digital Equity Ecosystem Mapping (DEEM) Tool which solicited 322 responses from representatives of Aging Individuals. The DEEM tool helps further build out the state’s existing asset inventory at a more granular regional and local level. On page 61, the Plan notes that CDT intends to update the DEEM tool on an annual basis. AARP notes that the DEEM website states that the tool closes on January 25, 2024. We suggest the website continuously allow for organizations to be added to the asset inventory list, especially given the growing interest in digital equity expected in the coming weeks and months. AARP suggests the DEEM Tool further be expanded to be a more comprehensive data dashboard that might include a comprehensive digital equity atlas that examines the demographic and socioeconomic repercussions of broadband adoption and affordability. The atlas could draw upon a range of data, including datasets centered around environmental justice (low-income and minority populations) and Title VI factors (disabled, older adults, and limited English proficient populations).

The DEEM Tool as a broader data dashboard could further include a digital skills training provider map to help Californians find low-cost or free classes and trainings to improve their digital skills. AARP has been consistently advocating for data gathering, analysis, and reporting for these kinds of purposes and is hopeful that CDT will consider building it into the DEEM Tool.

We appreciate the inclusion of AARP and Older Adults Technology Services (OATS) from AARP within California’s Digital Equity Plan. OATS also runs a technology program for older adults, “Senior Planet from AARP” that is available to all older adults within California. Senior Planet is designed to help older adults aged 60 and older thrive in the digital world, and harnesses technology to change the way we age. Senior Planet operates virtually via SeniorPlanet.org and hosts a National Tech Hotline: 888-713-3495 which is monitored by Senior Planet Trainers from 9am – 5pm EDT, Monday through Friday. Senior Planet also has a licensing program that equips local organizations and community anchor institutions across the country with the tools and curriculum to help older adults access technology and use it to enhance their lives.

The Plan’s presentation and discussion of aging individuals’ barriers and needs, beginning on page 76 is generally consistent with AARP’s experiences. AARP recommends the final Plan show greater emphasis on affordability as a barrier to older adults getting online. Many older adults are living on fixed incomes, which could make the cost of broadband and devices unaffordable. For most, the primary source of income is Social Security Retirement benefit. Regardless of the source of income, many choose to go without high-speed internet service and functional devices when given the choice between internet bills and other life-sustaining costs like medicine or food.

Over 45% of all Affordable Connectivity Program (ACP) are households with a resident 50 or older. That’s over 1.2 million households. As noted in the Plan, ACP continues to be an essential program to help income-challenged households get online. AARP is actively engaged in advocating for continued funding for the ACP or a successor program and welcomes the opportunity to work with the CDT and other partners to increase participation.

AARP also proposes these additions to the Plan to address affordability and the platform that households use to access the internet:

• The Plan could specify that affordability will be a primary criterion for California selection of BEAD subgrantees. The extent to which BEAD recipients offer and publicize affordable low-income and middle-income high-speed internet access services is a critically important factor contributing to progress toward digital equity. In the same vein, AARP recommends that California consider the extent to which BEAD recipients, and indeed, all service providers offer unbundled high-speed internet access.
• The Plan could observe that municipally owned and operated networks can lead to more affordable high-speed internet services than those offered by for-profit companies.
• The Plan could commit to monitoring ACP participants’ form of high-speed internet access (and indeed all residents’ form, because many households that may not qualify for the ACP may nonetheless struggle to pay bills). AARP raises this issue because wireless internet service is distinctly inferior to wireline access. Even where wireline access is an option, residents may nonetheless rely on wireless access (for example, many low-income residents cannot afford both a cell phone and a separate wireline connection to the internet).
• The Plan should ensure the protection of Net Neutrality in access and affordability options

o The United States Administrative Company (USAC) reports that 54.2% of ACP participants subscribe to mobile broadband, 44.9% to fixed broadband (cable, DSL, and fiber), and 0.9% to fixed wireless or satellite. https://www.usac.org/about/affordable-connectivity-program/acp-enrollment-and-claims-tracker/additional-acp-data/, site checked January 13, 2024.
o True digital equity would result in comparable modes of adoption regardless of one’s income and one’s geography. When the quality of internet access (e.g., speed, reliability, technology) varies significantly depending on where a person lives or when it depends on a person’s income, digital equity has not yet been achieved.

AARP submits that some older adults face physical challenges getting online. Disabilities, health issues, and other physical conditions can hinder the use of online technologies. Physical challenges may take the form of conditions that make skills like reading, typing, or scrolling on a mouse difficult, or limited mobility which can, for example, impact one’s ability to drive to a local institution like a community center or library to access broadband and devices if they don’t have access at home.

As noted on page 77, Some older adults need help learning how to use new technology and face barriers navigating some online spaces independently, especially with emergent technologies and increased reliance on the internet for various necessary activities. Lack of confidence in learning new technology can apply to both physical skills, like using facets of a new computer or smartphone (key components, mouse, and keyboard), and non-physical aspects of the technology, like using an internet browser or app.

Among the older adult population, there are varying attitudes about how broadband and devices, or lack thereof, impact their lives. Some are unsure whether increased access to broadband, devices, and digital skills would improve their day-to-day lives or that they are disadvantaged by limited access. AARP agrees with the Plan’s statement that, “Older adults expressed fear of being scammed or taken advantage of when getting online. Many older adults are skeptical about using the internet, especially regarding data privacy and cybersecurity. Those who are interested in the internet want to ensure they navigate the internet safely, and while the need to maintain passwords is recognized, the need to constantly update passwords can be frustrating. Safety and security when online are of importance to older adults, and a significant concern is the threat of being scammed or having data compromised

To further support California’s understanding of digital inclusion barriers older adults face, please explore the following papers:
o Czaja, S. J., Boot, W. R., Charness, N., Rogers, W. A., & Sharit, J. (2018). Improving social support for older adults through technology: Findings from the PRISM randomized controlled trial. The Gerontologist, 58(3), 467-477.
o Purdie, N., & Boulton-Lewis, G. M. (2003). The learning needs of older adults. Educational Gerontology, 29(2), 129-149.
o Tam, M. (2014). A distinctive theory of teaching and learning for older adults: why and why not? International Journal of Lifelong Education, 33(6), 811-820.
o Kamin, S. T., Lang, F. R., & Kamber, T. (2016). Social contexts of technology use in old age. In S. Kwon (Ed.). Gerontechnology: Research, Practice, and Principles in the Field of Technology and Aging (2nd ed., pp. 35 – 56). New York: Springer Publishing Company.

4. Collaboration and Stakeholder Engagement
Comments on Section 4: Collaboration and Stakeholder Engagement

AARP commends CDT for its extensive and multi-faceted outreach. Successful implementation of the Plan depends on maintaining and expanding the impressive level of collaboration and partnerships the Plan reflects. AARP suggests CDT invest sufficient resources to continue in-person solicitation to ensure effective feedback is received from populations not using the internet. Mail surveys, focus groups, roundtables, community partner events are all excellent avenues to foster collaboration and to ensure true progress is achieved throughout the forthcoming grant period and beyond. AARP highly commends CDT for developing an HTML version of the California Digital Equity Plan to be available in over 100 languages and compatible with assistive technology. Providing access to the Plan in languages other than English allows for greater feedback and will result in a richer final Plan. Going forward, AARP encourages CDT to provide as much digital equity information as possible in languages used across the state.

AARP suggests that the final Plan include a figure or framework that visualizes the overlap of covered populations. This will assist the reader with understanding where there are commonalities across covered populations.

Accomplishing the implementation strategy will require identifying the right partners capable of supporting the work necessary to meet the needs of Californians. Collaborating with groups with the capacity to support projects, develop programs, and effectively implement grant funding is essential to ensuring Californians have the access to the necessary to participate in our digital society fully. AARP supports robust interagency coordination, empowering coalitions, community anchor institutions, easy connection with existing digital equity networks, and fostering partnerships (existing and new) as the collaboration path going forward.

5. Implementation Strategy & Key Activities
Comments on Section 5: Implementation

The Plan’s approach to implementation dovetails well with the assets and barriers the Plan identifies and describes in Section 3 and builds off of the partnerships and relationships described in Section 4. The many elements of the plans for implementation appear ambitious yet pragmatic.

AARP supports the Plan’s three goals:

1) All Californians have high-performance broadband available at home, schools, libraries, and businesses.
2) All Californians have access to affordable broadband and necessary devices.
3) All Californians can access training and support to enable digital inclusion.

In Section 3.4, Specific Barriers and Baseline for Covered Populations and Digitally Disadvantaged Communities, the Plan identifies only Goal 2 and 3 for aging individuals. AARP suggests the final Plan include all three goals. Older Californians need and deserve to have high-performance broadband available at home, schools, libraries, and businesses. As the Plan states on page 67, a central barrier to internet access is the lack of available broadband infrastructure and service. For many California residents, businesses, and community anchor institutions, a high-speed internet connection is simply not available at their address. This holds true for older Californians as well, especially those living in rural areas.

Lack of reliable and resilient service can impact older Californian’s ability to receive online government services, engage in distance learning, or benefit from online healthcare services. Older Californians rely on community anchor institutions to access the high-speed internet. Therefore, AARP supports Objective 1.2 and recommends that both a short- and long-term target be developed for increasing the percentage of CAI’s connected to broadband internet service. AARP commends CDT for Objective 1.3 and its target – 100% of Californians have reliable internet service that is adequate for their household and business needs by 2030 – as it is outcome based and will be determined by soliciting what adequate service is from covered populations.

AARP also commends Objective 1.4 and its target – All Californians have access to at least three internet service providers by 2030. Limited ISP options, especially in rural areas, leave residents with only one option. And while service may be available, the speeds may not be fast enough to accommodate the number of individuals using the service at the same time. Consumers, including older adults, want to have options and be able to make their own decision on which provider to use. Individuals can feel stuck or become strategically exploited through price gouging based on the lack of competition. AARP suggests refining Objective 1.4’s target to “All Californians have access to at least three internet service providers that could meet their internet needs and is available within their budget by 2030,” to ensure covered individuals have access to affordable, fast enough internet service.

AARP supports Goal 2 – All Californians have access to affordable broadband and necessary devices – as identified for older adults on page 77. AARP commends Objective 2.3 - increasing the percentage of Californians enrolled in low-cost internet options and subsidies and Objective 2.4 – reducing the average cost that covered populations pay for internet service. Internet subscription costs are unaffordable for many older adult households in California. California’s Statewide Digital Equity Survey found that aging individuals spend on average $85.90/month, higher than other Californians. Actual pricing varies widely beyond that average. When adding car or transportation costs, groceries, health and medical costs, and other living expenses, it can be difficult for residents with limited income to manage an additional bill for broadband. This is one reason why some older residents opt for only a mobile cellular plan instead of a fixed, wired broadband connection. While fixed and cellular services are valuable for connecting Californians to the internet, households with only cellular services are limited in their connection speed and the amount of data they can use. In well-served areas where there are multiple ISPs to choose from, the competitive market can help to keep prices in check, but many locations only have one provider available and have no options if costs are high. AARP suggests the target in Objective 2.1 commit to a certain percentage reduction in those citing costs as the reason for not adopting internet service by 2026. AARP applauds the Plan’s ambitious target for Objective 2.3 to increase the percentage of ACP-eligible households enrolling the program to 99 by the end of 2024. With the uncertainty of the longevity of the Affordable Connectivity Program (ACP), please consider adding an additional tentative target that describes enrollment in low-cost subsidies to Objective 2.3 “Increase the percentage of Californians enrolled in low-cost internet options and subsidies, including the Affordable Connectivity Program.” AARP suggests the target in Objective 2.4 commit to a percentage reduction in average broadband costs for covered populations and a percentage reduction in the number of households citing cost as the reason for not adopting internet service by 2026.

AARP supports Goal 3 – All Californians can access training and support to enable digital inclusion. As mentioned in Section 2, many older adults feel they need help learning how to use new technology and face barriers navigating some online spaces independently, especially with emergent technologies and increased reliance on the internet for various necessary activities. Lack of confidence in learning new technology can apply to both physical skills, like using facets of a new computer or smartphone (key components, mouse, and keyboard), and non-physical aspects of the technology, like using an internet browser or app. Moreover, as the Plan aptly states on page 102, individuals also have trouble navigating online health resources due to a lack of digital skills. AARP commends Objective 3.1 – increasing the availability of digital literacy, cybersecurity, and skills training programs. Find AARP’s insights on how to effectively structure a digital skills program under 3.4 below and 5.1 Key Activities.

Objective 3.2 addresses another important barrier for older adults in California. Technical assistance needed when something goes wrong. Technical assistance for both the device and assistive software is sorely needed and often unavailable for covered populations. Often, when technical assistance is needed, Community Anchor Institutions like libraries are where older adults turn to get help with their devices as no specific technical assistance is available elsewhere. While these institutions may be capable of troubleshooting basic problems, this help is often unpaid and performed by volunteers. In addition to basic technical support for devices, there is a demonstrable need for available, low-cost, assistive software and support. AARP recommends that CDT commit to a firm target for a certain percentage increase in the amount of digital navigation services provided by 2028.

Internet access offers numerous opportunities but comes with significant risks. It is convenient to check bank statements, register for classes, or sign up for a telehealth portal in today’s digital world. However, the ease of access also increases the potential for personally identifiable information to be stolen, for users to be scammed, and for misinformation to spread. Online scams affect people of all ages and is certainly of concern to aging individuals. For example, a recent Pew Report states: “Two-thirds (67%) of adults say they understand little to nothing about what companies are doing with their personal data, up from 59%.” The Report also states: About seven-in-ten Americans are overwhelmed by the number of passwords they have to remember. And nearly half (45%) report feeling anxious about whether their passwords are strong and secure. https://www.pewresearch.org/short-reads/2023/10/18/key-findings-about-americans-and-data-privacy/. AARP supports Objective 3.3 – reduce the percentage of Californians whose concerns for privacy and cybersecurity prevents broadband adoption or effective use. In addition, AARP requests CDT consider a public education campaign with a goal to ensure more Californians can navigate the internet safely and securely. Core components could include partnering with trusted experts to provide low- or no-cost consumer protection training, expanding and amplifying messaging and resources around mental health considerations related to internet use, partnering with sister agencies to utilize existing resources and experts to protect and educate Californian on staying safe online, and educate users about secure networks, cybersecurity tools, privacy settings, and device health.

AARP commends the Plan’s inclusion of Objective 3.4 - Increase the percentage of Californians who possess basic, intermediate, and advanced digital literacy skills. A lack of digital skills increasingly impacts everyday life for older Californians. With the increase of telework/telehealth and as applications, education, and financial services move online, ensuring digital skills programs exist is imperative. Digital skill training will be instrumental in helping residents gain the necessary skills to pursue the opportunities internet access can offer. California has several digital skill training programs and digital navigator programs that serve as best practice models, but universal access to these programs is yet to be available. The ability to access online training allows these programs to be more readily available. However, challenges like funding, staffing, and equipment remain barriers to implementing digital skills programs. As aging individuals acquire digital skills, the relevance and benefit of internet-based applications will become clearer to those who are now on the other side of the digital divide. This Objective could also incorporate social impact digital literacy outcomes, such as social engagement or financial literacy, as well as opportunities to further economic goals. When developing certification and digital skills training programs in California, please consider “why” someone is learning a new skill or tool, as this is just as important as “what” the skill or tool is. This contextualization encourages learners to think about and discuss the relevance of the skills and tools to their lives, as well as their potential, rather than “catching up” to technology. AARP encourages California to conduct interviews with covered populations when designing grant programs certification and state curriculum, so that learners can make their own, informed decisions about how they wish to use a device, platform, or resource to achieve their goals.

Please consider adding an objective within Goal 3 “All Californians can access (free affordable)training and support to enable digital inclusion” that describes an increase in confidence or increase in social connection/s due to program supported digital skills training classes. Monitoring entry to programs only measures outputs of the program and will not describe any progress made by a covered individual “... to enable digital inclusion for economic and other social benefits.”

AARP appreciates the consideration of a digital navigation support program for covered populations. Please note each covered population has different needs and will access technical support as per their own needs and abilities.

As described on page 55, AARP appreciates the inclusion of California’s strategy for Goal 3: Adoption, “Develop statewide digital literacy training framework and certificate programs.” Please ensure older adult digital literacy training framework is designed in consultation with older adults. If possible, use trainers that have experience of working with older adults and/or have lived experience.

AARP requests the final Plan outline how the “statewide digital literacy training platform” described on page 55 will cater to each covered population’s specific needs and how it will be kept up-to-date as technology, methodology and adoption changes.

On page 55, AARP suggests the following revision - Develop statewide digital literacy training framework and certificate programs that are integrated into larger career goals or lifelong learning needs.

5.1 Key Activities

• On Page 114: Section 3, please ensure the data map prioritizes and focuses on underserved, multilingual communities of color.

• On Page 114: Section 4, add to the three primary barriers that beyond signing up for affordable home internet service, affordable computing device, and access to digital literacy training is ongoing technology support. Beyond a one-off class, individuals will still need access to technical support via resources such as in-person or virtual tech coaches or statewide or national toll-free technology support hotlines. As technology evolves, we must also ensure digital literacy is offered in multiple languages. This is also in alignment with goal 3.2 on page 120 to increase access to technical support services for internet-connected devices.

• On page 115: Section 4, add activities focused specifically on telemedicine and fraud prevention.

• On page 115: Section 4, AARP appreciates the inclusion of “Establishment of computer labs/digital literacy training programs at community centers (Senior Centers, Veterans Halls and others).” Considering “Individuals with a language barrier” make up 48% of California’s population, please consider incorporating digital literacy curriculum and training programs to be developed in languages other than English.

• On Page 116: Section 6, ensure the public-facing handbook is age-friendly with thought given to older adults and follows aging individual community anchor institution’s recommendations and best practices for programming.

• On Page 116: Section 6 first bullet point, please ensure the digital literacy leaders include a diversity of experts including organizations experienced with working with older adults.

• On Page 116: Section 6 second bullet point, please ensure extra dollars are provided for the certificate programs for specific demographics as providing digital literacy programming to monolingual older adults can take more time and resources than general digital literacy programming and organizations should not be punished for needing additional time or funding which is in alignment with recognizing the different baselines mentioned on page 121 in section 5.2.

o Also ensure the certificate completion requirements are not too stringent and recognize older adults or people with disabilities may not be able to complete all skills-based competencies especially if there are hearing or visual impairments.

• On Page 116: Section 6 third bullet point, please prioritize low-income monolingual communities of color in the digital inclusion asset mapping.

• On Page 117, develop a back-up plan if the Affordable Connectivity Program (ACP) is not

6. Conclusion
Comments on Section 6: Conclusion

AARP welcomes the opportunity to work with CDT to help California make progress toward its ambitious digital equity goals. AARP recognizes digital equity is related to addressing broader societal issues. High-speed internet access connection will not in and of itself remedy housing, transportation, employment, health and education challenges, but such access is nonetheless an essential element of such efforts. AARP commends CDT on its Draft Digital Equity Plan and respectfully requests our suggestions be incorporated
4816January 25, 2024 at 10:20 amV.K.ResidentGLENDALE912072. Introduction and Vision for Digital Equity
WIRED connection is superior to wireless in all respects, and wireless broadband—especially the basic services offered to low-income families—will NOT solve the digital divide.
4815January 25, 2024 at 10:15 amD.W.ResidentGrass Valley959458. Not Related to Above Sections
Although convenient to have a phone in your pocket or purse, if I had a land line this mobile phone would be gone in a nanosecond.

WIRED connection is superior to wireless in all respects, and wireless broadband—especially
the basic services offered to low-income families—will NOT solve the digital divide.

• Wireless is inferior "dirty" technology, unreliable, and unable to SAFELY meet the demands of present and future digital communications. Provide funding for safer, reliable, energy-efficient WIRED internet, not wireless installations.
• Wireless is unreliable and unable to meet the demands of present and future digital communications. Providing funding for the rollout of wireless installations will take it away from much safer, reliable, energy-efficient WIRED internet.

• Wireless will set the state back in terms of climate change management because wireless uses a huge amount of energy compared to WIRED broadband.

• Wireless facilities increase fire risk and cyber security risk

• Wireless facilities impact the growing percentage of the population with disabilities related to radiofrequency radiation (RFR) exposure.

• Wired infrastructure offers greater capacity, predictable performance, lower maintenance costs, and a longer technological lifetime than wireless technologies. Fiber service is not degraded by line-of-sight issues and is not affected by capacity issues.
4814January 25, 2024 at 10:07 amL.C.ResidentLaguna Hills926532. Introduction and Vision for Digital Equity
Wired infrastructure offers greater capacity, predictable performance, lower maintenance costs, and a longer technological lifetime than wireless technologies. Fiber service is not degraded by line-of-sight issues and is not affected by capacity issues.
4813January 25, 2024 at 10:04 amP.G.ResidentSan Francisco941323. Current State of Broadband and Digital Inclusion
It is imperative to maintain wired connections for internet service. Communities must be able to maintain their local control over placement of these services!
4812January 25, 2024 at 10:02 amConsultantOrganizationPlumas-Sierra TelecommunicationsPortolaCA1. Executive Summary
Thank you for the opportunity to provide comments on the California State Digital Equity Plan. In the Executive Summary, the Plan discusses pairing existing Broadband for All investments with new federal funding. Plumas-Sierra Telecommunications (PST) encourages CDT to ensure that existing, open-access, grant-funded infrastructure is not overlooked in the efforts to complete broadband deployment, and that those existing networks are leveraged and expanded upon with future funding opportunities. Utilizing existing, grant-funded infrastructure will ensure that achieving the goal of providing high-performance broadband services to all Californians is completed in an efficient and cost-effective manner.

PST owns and operates a middle- and last-mile fiber optic network in the rural areas of Plumas, Lassen, and Sierra counties in California and a small portion of Washoe County, Nevada, and has significant experience in owning and operating rural infrastructure. In all the discussions of rural broadband and digital equity, PST has observed that both the cost of operations and maintenance and the expertise and personnel needed for said O&M is never brought up. PST and its parent utility are efficient and experienced, and budget 35% of revenue for O&M. In future planning, O&M should be a higher priority.

In Key Activity 1, the Plan states all entities tasked with building out broadband infrastructure will continue to expedite the 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 services more affordable and provide an opportunity for more local digital navigators to encourage adoption and provide education to "covered populations."

Across the U.S., electric and telephone cooperatives are expanding broadband to their communities. PST is owned by an electric cooperative, Plumas-Sierra Rural Electric Cooperative, and would be delighted to support the creation of additional broadband cooperatives throughout California.

Respectfully submitted,
Plumas-Sierra Telecommunications
4811January 25, 2024 at 9:52 amJ.M.ResidentCarlsbad920092. Introduction and Vision for Digital Equity
A majority of people who do not use this technology are choosing to not use it. There is not enough evidence to show that this technology, especially when deployed at large scale, is safe for humans or other animals.

We've been told that we need to reduce our energy consumption (because of climate, scarcity, etc.), but at the same time, we see our politicians rolling out this "digitalization" agenda which places an incredibly high demand on our energy resources. It doesn't make any sense.

We need to work harder at risk analysis, and we need to engage in a robust cost-benefit analysis whenever these large projects are rolled out. Let things happen organically, and let people choose for themselves if they want to be subjected to massive amounts of wireless radio waves 24/7/365.
4810January 25, 2024 at 9:34 amGroup Program ManagerOrganizationSan Diego CountyCA5. Implementation Strategy & Key Activities
The County of San Diego appreciates the opportunity for public comment on the draft State Digital Equity Plan (SDEP) and recognizes that the State has made significant efforts to learn about our connectivity needs. The County of San Diego’s Comprehensive Broadband Plan (CBP) was released in January 2023. The CBP identifies priority census tracts in unincorporated San Diego, with focus on broadband access, affordability, and adoption for those with low-income households, within historically underserved communities, and in rural and very-high wildfire risk designated areas. The draft SDEP (p.14) lists the following barriers for people who primarily reside in a rural area, which are consistent with the findings in our County’s CBP:

• Infrastructure
• Competition
• Wildfires and disasters
• Isolation and distance from support

Each of these barriers impact access and affordability. To address the barriers identified in the SDEP, we recommend the following strategies and activities:

Consider low-earth orbit satellites and other emerging technology to fill in broadband access gaps in rural areas.

• Broadband grant funding opportunities prioritize fixed fiber connections. But fixed fiber technology was designed for and primarily deployed in urban areas and is not well suited for geographically diverse terrain like in the rural, unincorporated areas of San Diego County. Other technologies need to be explored, such as low-earth orbit satellites, that meet the needs of the rural geography and offer solutions to those that do not have access to fiber.

• There are 37,000 households in the unincorporated County without access to broadband and many live in very-high wildfire risk areas. In an emergency, mobility is key. Our rural communities need to know the location of a fire, get evacuation routes, and receive updates. Offices of education and fire departments are beginning to use low-earth orbit satellites and explore other emerging technologies to improve connectedness and mobility during an emergency. Consider low-earth orbit satellites or microwave internet that meets the SDEP’s broadband speed and reliability requirements.

• To further enhance the SDEP’s objective to increase choices of internet service providers, there also needs to be investments and research of emerging technologies so that Californians, particularly in rural areas, have choices of technology that best meet their immediate needs. One way to address this is to add an objective or expand existing objectives listed in Goal 1 so that all Californians have high-performance broadband available at home, schools, libraries, and businesses.



Encourage and incentivize internet service providers to offer affordable, income-based plans.

• In October 2023, USA Today ranked San Diego as the most expensive place to live in the United States (www.usatoday.com), leaving low-income families in San Diego who need a break financially, unable to qualify to meet the federal poverty standard. Broadband subsidies need to align with similar state subsidy programs such as affordable housing subsidies that factor poverty thresholds and household incomes.

• The federal Affordable Connectivity Program (ACP) was designed as a temporary subsidy that offers monthly internet rates at $30 per month, but is expected to run out of money in April 2024. Even if the federal government decides to extend the program, there is uncertainty among current recipients as to whether they will be able afford to continue internet service once the program is discontinued. While important, a temporary federal program is and cannot be the only solution to affordable broadband access. The SDEP can include activities that develop partnerships with internet service providers and incentivize them to offer affordable plans that are sustainable for our communities in the long term, so that they don’t have to rely on temporary federal assistance.

• Digital Equity Grant funds can be used by the State equitably to fund programs that result in affordable access to broadband. For example, these funds can incentivize internet service providers to demonstrate how they will offer long-term affordable plans for the low-income communities where they will expand broadband infrastructure, should their proposals be awarded. Key considerations could include internet rates relative to income as well as the duration of the affordable plan. This approach can be added as a key activity under the SDEP’s Goal 2: “All Californians have access to affordable broadband and necessary devices.”

We are looking forward to further engagement and partnership with California Department of Transportation on broadband infrastructure and other programs.
4809January 25, 2024 at 9:33 amDirector of Digital EquityOrganizationCounty of Los Angeles | Internal Services Department (ISD)Los AngelesCA5. Implementation Strategy & Key Activities
Key Activities & Digital Equity Programming Activities for Funding Eligibility
• Consider the following digital equity programming activities for State Digital Equity Capacity Program funding eligibility:
• Broadband adoption (e.g., access, affordability, and adoption) efforts
• Community hubs that provide free digital inclusion services (e.g., public Wi-Fi, public access computers, public access printing, etc.) efforts
• Community outreach and engagement activities that promote and enroll covered populations and subpopulations in digital inclusion services efforts
• Cybersecurity and privacy training efforts
• Digital equity coalition planning and implementation efforts at Local and County levels
• Electronic Hazardous Waste (E-waste) services efforts
• Hardware and software technical support efforts
• Internet-enabled device distribution efforts
• Internet-enabled device lending and support efforts
• Local and County digital equity plan development and implementation efforts
• Multilingual and culturally relevant digital literacy and skills training efforts
• Multilingual and culturally relevant digital navigation efforts
• Subgrant funding to community-based organizations (CBOs), Council of Governments (COGs), Local and County governments, higher education institutions, and non-profit efforts
• Workforce development (e.g., career development services, job preparedness training, job search assistance) efforts

Grant Program Development, Implementation, Management, & Evaluation
• Incorporate the following equity-centered and inclusive recommendations for the development, implementation, management, and evaluation of the State Digital Equity Capacity Program:
• Flexibility for collaboration and partnerships on joint grant program applications and proposals (e.g., opportunities for lead partners and supporting partners)
• Flexibility for budget development and eligible expenses (e.g., gift cards and stipends for covered populations and subpopulations)
• Simple and user-friendly State application and proposal submittal portal
• Streamline grant program processes and requirements
• Best practices, resources, and tools for successful grant program applications and proposals
• Equity lens implementation and strategies for not using a “one size fits all” approach
• 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)
• Ongoing technical assistance and training opportunities for national and statewide digital equity models
• Opportunities to share and showcase statewide, regional, local, and grassroots grant programming best practices
• Resources to ease grant program administrative burdens and build organizational staff capacity
• Resources to support community-centered storytelling (e.g., art, articles, dance, interviews, music, photos, quotes, success stories, and videos)
• Standardize metrics and outcomes for statewide data collection
• Equitable data collection using equity indicators:
• Age, disability status, educational attainment, employment attainment, gender and sexual identity, geographic area (e.g., rural, urban), homeownership and housing burden, incarceration status, income, military service status, primary language, race/ethnicity, and zip code
• Tools to showcase statewide digital equity community impact (e.g., interactive real-time online dashboard)
• Use various data collection tools to capture community impact (e.g., questionnaires, real-time forms, pre and post-surveys)

Covered Populations
• Uplift and provide digital inclusion services to subpopulations that are not included (e.g., business owners, micro-business owners, justice-impacted families, refugees, students, undocumented individuals, unhoused individuals, and youth)
• Uplift The Spectrum of Community Engagement to ensure that communities most impacted by the digital divide have voice, power, and ownership in the decision-making and implementation of the SDEP (e.g., include their lived experiences)
• Collaborate with trusted CBOs to engage and provide digital inclusion services to covered populations and subpopulations
• Ensure key engagement barriers are addressed before providing digital inclusion services (e.g., child watch, cultural, economic, language, location, time, and transportation, etc.)

Stakeholder Collaboration, Communications, & Outreach
• 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)
• Establish routine meetings with grantees and subgrantees to share best practices, resources, and lessons learned
4808January 25, 2024 at 9:31 amA.F.ResidentGrass Valley959453. Current State of Broadband and Digital Inclusion
It is VERY IMPORTANT that any further enhancement of technology and internet service to humanity is on a frequencey that DOES NOT harm the human body and it's biological functions. The current frequencies used HARM our biological functions. PLEASE BECOME CONSCIOUS OF THAT AND WORK TOWARDS MAKING BETTER DECISIONS FOR ALL.
4807January 25, 2024 at 9:30 amN.C.ResidentAtascadero934222. Introduction and Vision for Digital Equity
Wired is so much better than wireless. Please do not expand wireless as it is unreliable and is filled with EMF's.Wired infrastructure offers greater capacity, predictable performance, lower maintenance costs, and a longer technological lifetime than wireless technologies. Fiber service is not degraded by line-of-sight issues and is not affected by capacity issues.
4806January 25, 2024 at 9:06 amC.R.ResidentRedondo beach902782. Introduction and Vision for Digital Equity
Wireless is unreliable and unable to meet the demands of present and future digital communications. Providing funding for rollout of wireless installations will take it away from much safer, reliable, energy-efficient WIRED internet.
4805January 25, 2024 at 9:01 amS.F.ResidentSan Diego921172. Introduction and Vision for Digital Equity
Wired connectivity is higher performance, much more secure, and less environmentally polluting because it does not emit biologically harmful wireless radiation.

Eliminating wired connections will force electrosensitive people, about 20% or more of the population, into choosing between their health and being able to participate in telecommunications. Unacceptable and cruel to the most vulnerable populations.
4804January 25, 2024 at 8:57 amDirectorOrganizationEnvironmental Health Advocacy League (ENHALE)MalibuCA1. Executive Summary
The only path to Digital Equity is by means of fulfilling the legally required fiberoptic cable to the premises (FTTP) for all, as was required by federal provisions to have been completed by the year 2014; such that no wireless irradiation shall expose any individual to xenobiotic microwave radiation harm. California is way behind in this schedule, causing harm to all and particularly to certain persons - those with chronic illness and injury-based disabilities, the homeless, and other vulnerable populations. ENHALE works to provide these individuals ways other than microwave radiation to fulfill their communications and other needs. California's failure to have distinguished between wireline and wireless comms in its usage of the term "broadband" has caused harm by some decrement to all people, but particular physical oppression to certain vulnerable groups. California has also perpetrated enormous harm, visually to the landscape, but worse yet to the wild and farm animal populations, to pollinators both birds and insects, and to plants by its insistence on wireless infrastructures and devices, including without limitation the misnamed "smart" grid. Wireless microwave irradiation is physically harmful, insecure, unreliable, and in violation of the 4th Amendment's protection against warrantless surveillance; such irradiation is extremely energy-inefficient and wasteful. California must change from wireless to wireline provision across the board to achieve equity. Thank you.
4803January 25, 2024 at 8:46 amSenior Policy AnalystOrganizationInsure the Uninsured Project (ITUP)SacramentoCA1. Executive Summary
Insure the Uninsured Project (ITUP) values the immense amount of work and engagement that went into developing this plan, in particular as a health policy convener and expert in California, ITUP applauds the inclusion of health care as an essential component and use case in the plan. ITUP appreciates the opportunity to provide feedback on California’s draft State Digital Equity Plan.

If the state wants to address systemic issues driving low adoption, then BEAD funding should be used primarily to support Goals 1 and 2. In particular, if the state achieves objective 1.4, increase the percentage of Californians who have a choice of at least three internet service providers, we believe that will be a solution to objectives 2.1 and 2.4 as communities will see a healthier market competition between providers. As California Community Foundation and the Electronic Frontier Foundation (EFF) have revealed in this policy memo: Internet Service Providers in LA - A Monopoly Story Fact Sheet (calfund.org), having one or two options results in low-quality and unaffordable internet, leading to low adoption rates. We would go a step further with respects to objective 1.4 to say that the state should invest in options that ensure most people have at least one public option, in which public interest usurps profit motive. For example, in EFF’s 2021 paper, Wholesale Fiber is the Key to Broad US FTTP Coverage, a wholesale model - public open access infrastructure leased to providers - was predicted to serve 95% of Los Angeles County and be cost effective.

“When it comes to the availability of internet infrastructure, there are over 450,000 unserved and underserved locations in California.” This data source is based off of the California Public Utilities Commission’s broadband maps. These current maps show who could be served rather than who is actually served. These broadband maps do not accurately report the true number of Californians struggling with lack of broadband and connectivity adoption. To address equitable access, the state needs to either not use maps in making investment decisions, and instead use other tools and resources such as the Socioeconomic Vulnerability Index, or the state needs to make large investments in Key Activity 3: Evolve Broadband and digital equity maps. Not only is it critical to understand whether a household or business has adopted broadband, but it is important to understand how much Californians are utilizing it. There are multiple tools that track such data for public and private entities and make it openly accessible, including Microsoft’s Broadband Interactive Map. ITUP urges the department to utilize multiple tools and resources to curate more accurate and reflective maps of Californians on broadband availability and adoption. These new and evolved maps should include pricing and service offer data in addition to other indicators, such as speed tests, and reliability indicators such as levels of uptime. Accurate broadband maps are essential in achieving digital equity across California as this data will be used to prioritize limited funds available through state investments to close the digital divide for covered populations. The health care ecosystem, especially those serving Medi-Cal members through community clinics and community-based organizations providing direct care to consumers, should play an active role in collecting and using digital barrier information. For example, including questions on broadband access, devices, and digital literacy in health care screenings and intake forms would help to gather this information and data to better understand patients’ digital barriers to accessing health care. This direct source can be used to guide programs and solutions for barriers to broadband and connectivity that are preventing the effective use of telehelath and technology to access care.

ITUP urges the department to strengthen the objectives with more clarity, specificity, and a clear timeline of actionable steps for how the objectives will be addressed. Without a clear, actionable timeline, the plan lacks accountability for the objectives to be met. Other published state digital equity plan drafts have included such timelines, and more specificity including measurable objectives, key performance indicators, short-term targets, and long-term targets.

1. Executive Summary
Comments on Key Activities in Executive Summary

Key Activity 1: Expedite and complete existing Broadband for All infrastructure efforts.
Increasing the miles constructed and increasing the number of internet service providers (ISPs) providing services would potentially allow for more competition which is essential for improving quality and affordability for consumers. However, there needs to be a third-party or additional oversight to ensure accountability that affordable pricing is built in with the additional ISPs in communities providing service. In addition, the increase in the number of connected homes will only be applicable if the last-mile network funds are equitably distributed to the communities most in need. In the Governor’s 2024-25 Budget Proposal, Governor Newsom is faced with a budget deficit of $37.86 billion. To address the projected budget shortfall, the Budget proposes General Fund solutions to achieve a balanced budget which includes:
• Last Mile Infrastructure Grants – A delay of $100 million GF from 2024-25 to 2026-27 for last-mile infrastructure grants at the CPUC.
• Broadband Loan Loss Reserve (BLLR) Fund – A reduction of $250 million GF for the BLLR.
With these delays and reductions towards these grants and funds, the final version of the draft must include the mention of such reductions and adjustments and provide alternative strategies to ensure that last-mile funds are distributed to communities most in need in tandem with the building and completion of the middle-mile network.

Key Activity 3: Evolve broadband and digital equity data and maps.
The current and available California Public Utilities Commission (CPUC) broadband maps and the Federal Communications Commission (FCC) broadband maps are complex and inaccurate. The primary data used to create the maps are mainly based on the information provided by internet service providers (ISPs), which renders the maps incomplete and not representative of the actual gaps in broadband access. Under current regulations, fixing inaccuracies of the broadband maps requires the submission of challenges. The arduous nature of these challenges and lack of process transparency are a deterrent for consumers, communities, and cross-sector stakeholders to engage, ultimately weakening the ability of the maps to prioritize the funding and investments in broadband deployment. As the key activity is listed to “evolve broadband and digital equity data maps”, ITUP urges for more transparency and clear guidance on how the evolution of these maps will be tracked, monitored, and assessed for progress. Examples of how this could be done are the following:
• Inclusion of various data sources such as health care community-anchor institutions, community health clinics and the number of community members they reach etc. would help to illustrate the realities of which communities should be prioritized first;
• Maintaining a publicly accessible data-dashboard with toggle options to switch between calendar years to view the evolution of the maps would be helpful for communities to engage and provide feedback;
• Changing the process of submitting challenges would help increase engagement from communities and help illustrate the realities of communities in need;
• Creating a publicly accessible tracker to increase transparency and communication with the public on what has been done thus far with the broadband maps, at what stage they currently are, and what the next steps are needed to continue improving the accuracies of the maps; and/or,
• Use of a third-party to increase oversight and accountability on the monitoring, assessment and evaluation of the steps used to evolve the maps.
Without mention of key follow-up steps to the creation of such evolved maps, there is no assurance nor accountability that this will be executed with the clear intention of accurately addressing digital equity needs in California.

Key Activity 4: Launch the California Connect Corps and digital equity grant program to expand community-based digital navigation and digital inclusion programs.
ITUP applauds the addition of this grant program. This program is poised to serve communities in most need, utilizing the established workforce and trusted messengers within the community. The health care workforce has several community-based providers including community health workers, promotores, doulas, peer support specialists, enhanced care management providers, and community support providers that can be leveraged to close digital literacy gaps when patients are accessing telehealth and virtual care. ITUP urges strengthening the language used here to cite which existing anchor-institutions and community-based organizations (health and otherwise) are providing such digital inclusion services already, or at least how those health-centered partners will be identified and included in the program—i.e., health care anchor institutions, community health clinics, health-based nonprofit organizations etc. Some of this information can be gathered through various key health state departments including:
• Department of Health Care Services (DHCS) – DHCS administers the Medi-Cal program and is responsible for the health care of 15 million Californians and can outreach to all of them. In addition, they have begun paying health plans to employ/use community health workers, who could be digital navigators for these most vulnerable Californians.
• Department of Social Services (CDSS) – CDSS administers CalFresh (food stamps), in-home supportive services (IHSS), and childcare programs for people with low-incomes.
• California Department of Public Health (CDPH) – CDPH licenses EVERY health facility in CA (see Health and Safety Code Section 1250) – they have the addresses and names of all hospitals (approximately ~ 400), health clinics (approximately ~ 1000 sites), and skilled nursing facilities. They also administer the Women, Infants, and Children Program (WIC).
• Department of Health Care Access and Information (HCAI)—HCAI oversees all hospital building/infrastructure plans, including their “community benefit plans”; they also run workforce programs, including loan repayment for doctors, nurses, etc., as well as are bringing online investment in 25,000 community health workers (would be great if these could be trained to be digital navigators).
In addition, there needs to be more in-depth details, specificity, guidelines, and explanation on the sustainability of such a grant program. Examples of questions to consider in refining such specific and guidelines would be the following:
• Who will be eligible for the grant program first (i.e., those already listed from the Digital Equity Ecosystem Map (DEEM) asset inventory, or will every eligible nonprofit organization submit have to apply?)
• What is the application process for eligible nonprofit organizations to apply for the grant program?
• What will the grant cycles be? Quarterly, bi-annually, annually etc.?
• How will the monitorization, assessment and evaluation of the digital inclusion services be measured?
• Who will be on the board/committee to review applications and what are the criteria in selecting which nonprofit organizations will be granted funding from the CCC grant program?
• What is the process for continuing to receive funding from the CCC grant program? How will applicants have to demonstrate success within their community and how will they track this? What is the process for re-application?

3. Current State of Broadband and Digital Inclusion
Comments on Specific Barriers by Outcome Area – Health

ITUP is pleased to see the inclusion of health care and the commitment of the department to advance digital equity as a super determinant of health. Through ITUP stakeholder engagement, language access in digital tools remains a significant barrier for many in the health care safety net. ITUP urges this section to also be inclusive that language is a barrier for live-synchronous interpretation on virtual care platforms. ITUP urges the department to include the need for digital supports to be language-inclusive for the vastly diverse communities across the state. Minimal live-language interpreters offered during their virtual care appointments is a major barrier to telehealth and virtual care. Not only should there be more written language inclusivity offered, but it should also be inclusive of languages that are exclusively spoken. In addition, ITUP urges the department to strengthen the language to include leveraging existing programs, and investments in health care. Closer collaboration with economic and workforce development agencies to optimize existing programs and investments that can be leveraged for infrastructure deployment, digital literacy, and adoption programs.

5. Implementation Strategy & Key Activities
The implementation plan is particularly lacking in some of the state’s objectives. While we were happy to see the state add objective 1.4, increase the percentage of Californians who have a choice of at least three internet service providers, there was no clear plan or strategy for how and through what time period the state would achieve that objective. We would suggest that the state invest in locally driven public open access middle and last mile models to ensure that most of Los Angeles has at least one public option. This would increase market competition and ensure that an interest not motivated solely by profit is providing solutions to broadband access issues. In addition, ITUP urges the department to include guidance for internet service providers (ISPs) penetrating new markets to have language-inclusivity in outreach materials for consumers.

5. Implementation Strategy & Key Activities
Comments on 5.1 Key Activities

1. Expedite and complete existing Broadband for All infrastructure efforts.

Broadband infrastructure deployment needs to prioritize digitally redlined communities, if we want to reach the overarching goal of equitable access for all Californians. Emphasizing the significance of infrastructure build-out in rural and low-income urban communities is imperative, given the unique challenges these areas face in terms of connectivity.

In order to enhance the timely completion of broadband projects in underserved communities, it is imperative to systematically identify and eliminate barriers that may impede progress. Simultaneously, the establishment of robust accountability mechanisms becomes essential to ensure the expeditious and comprehensive fulfillment of commitments made towards the completion of the Broadband for All infrastructure efforts.

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.

2. Convene digital equity stakeholders to strengthen collaboration

ITUP applauds the addition of this inclusion in the State Digital Equity Plan, however, ITUP urges the State to be more specific about who will be invited to participate in engagement and outreach forums. Inclusion of health care stakeholders will be vital in the process, and these could include health-based nonprofits (i.e., ITUP), the Department of Health Care Services, health care community anchor institutions, digital equity coalitions etc. The outcome area working group co-chairs should also be included in these forums. In addition, having these forums open to the public fosters an environment that is inclusive of all Californians having the opportunity to speak up and share their experiences as the state continues to strengthen community collaboration. Hosting quarterly forum meetings will also allow for continued dialogue and maintenance of relations among the diverse partnerships across the state to continue to address the digital equity needs of Californian communities.

5. Implementation Strategy & Key Activities
Comments on 5.1 Key Activities (continued)

3. Evolve broadband and digital equity data and maps.

The CDT should not simply “evolve” the data and maps; if the state seeks to be good stewards of BEAD and other public funds for broadband, then it should seek to “transform” the maps utilizing community-provided data. Municipalities, public entities, and community organizations should get compensated for providing a wide range of data to the CPUC that gives a more holistic picture of the issues driving broadband gaps, so that the state can be more surgical and precise with solutions enabled by historic levels of public funding.

Inaccurate and inconclusive data poses a significant obstacle to identifying areas in urgent need, hindering the effective deployment of broadband infrastructure and digital equity programs in the communities that require them most. As efforts are made to improve data systems, we strongly advocate for a heightened focus on accuracy and inclusivity in mapping endeavors. This emphasis is crucial to ensure that the state’s digital equity initiatives are grounded in precise information and effectively reaching all underserved communities.

Prioritizing data accuracy and relevancy within this initiative reinforces the groundwork for equitable infrastructure development. Continued reliance on flawed maps, without swift and substantial corrections, risks perpetuating decades of disinvestment in low-income, communities, often the same communities served by the State’s Medi-Cal program. This perpetuation exacerbates the digital divide rather than addressing it.

As has been proven in multiple recent reports from various groups across the country, including the CCF’s pricing discrimination report, the University of California, Santa Barbara, and others, private companies tend to prioritize investments in high-income communities, leaving historically redlined areas with subpar infrastructure, limited options, and higher prices. It would be regrettable for the State to follow a similar trajectory. It is imperative to ensure that every home in underserved communities is accurately represented in data collection efforts.

To address this, we recommend timely provision of maps used to determine eligible areas, allowing for a public comment period. This period would afford communities the opportunity to identify excluded areas, offer feedback, and provide data and information that can reinstate those areas in consideration. Furthermore, the California Department of Technology (CDT) should uphold transparency in the data collection process, furnishing clear information on how data is gathered, utilized, and how the maps will inform potential funding and project opportunities.

5. Implementation Strategy & Key Activities
Comments on 5.1 Key Activities (continued)

7. Advocate for an extension of ACP or a successor program or develop a State-led affordable offering.

ITUP applauds the department for prioritizing affordability for unconnected Californians. However, the current objective appears somewhat vague and lacks emphasis on the crucial need for a long-term program ensuring affordable services. The ongoing advocacy for an extension of the Affordable Connectivity Program (ACP) is set to conclude in April 2024, with new applications freezing February 8, 2024. To enhance this advocacy, we recommend that the CDT’s efforts encompass:
• Engagement with federal representatives to advocate for additional funding for ACP extension,
• Utilize partnerships with broadband service providers, industry associations, community organizations and advocacy groups to collectively work together in advocating,
• Use reputable data to demonstrate the economic, educational, and social benefits resulting from affordable connectivity,
• Lead Public Awareness Campaigns,
• Leverage the departments influence to foster coordination among local and state entities in support of affordable service plan programs, and,
• Build relationships with traditional and social media partners to reach local communities.

5. Implementation Strategy & Key Activities
Comments on 5.7 Approach to Plan Evaluation and Updates

Within the annual progress reports on the implementation of this plan, ITUP urges the department to include measurable objectives, key performance indicators, short-term targets, and long-term targets. For example, ITUP urges the department to include data on the covered populations to understand which communities are engaged in programs that are supported by the State Digital Equity Plan, and which groups are not. The need for a more substantial and specific evaluation throughout the 5 years of the plan is essential to addressing and creating actionable changes in bridging the digital divide for Californians. In addition, ITUP proposes that evaluations of the State Digital Equity Plan be conducted and publicly reported after 2 years. This will allow for transparency, continual monitoring of progress towards digital equity, and progress tracking to accurately identify whether the current state digital equity plan is meeting measurable metrics before ultimately achieving the goals of eliminating digital equity disparities for Californian communities.
4802January 25, 2024 at 8:42 amC.I.ResidentSan Carlos940702. Introduction and Vision for Digital Equity
Wireless will set the state back in terms of climate change management because wireless uses a huge amount of energy compared to WIRED broadband.
4801January 25, 2024 at 8:34 amB.R.ResidentLittle River954566. Conclusion
What can stop seniors having communication cut off? Many don’t know how to use smart phones or computers. How will they have a house phone??
4800January 25, 2024 at 8:28 amS.C.ResidentMonterey Park917552. Introduction and Vision for Digital Equity
Wireless is unreliable and unable to meet the demands of present and future digital communications. Providing funding for rollout of wireless installations will take it away from much safer, reliable, energy-efficient WIRED internet.

Wireless will set the state back in terms of climate change management because wireless uses a huge amount of energy compared to WIRED broadband.

Wireless facilities increase fire risk and cyber security risk

Wireless facilities impact the growing percentage of the population with disabilities related to radiofrequency radiation (RFR) exposure.
4799January 25, 2024 at 8:24 amB.N.ResidentMalibu902652. Introduction and Vision for Digital Equity
For over 15 years I have had my broadband connectivity hard-wired from the modem in my garage, underneath the house via Cat -5, and thence into my office. From there I have a wire from the computer - underneath the house - to the living room, where a computer monitor provides Netflix via Roku. I have NO wireless, because I'm sensitive to it. I don't sit in front of flatscreens in restaurants or doctors offices, nor do I have one in my house. WIRED connection with broadband - which we've already paid for in Los Angeles -is superior to wireless in all respects, You can ask any computer whiz worth his/her salt.

• Wireless will set the state back in terms of climate change management because wireless uses a HUGE amount of energy compared to WIRED broadband.

• Wireless facilities increase fire risk and cyber security risk

• Wireless facilities impact the growing percentage of the population, and the pollinator and avian populations as well.

Disabilities related to radiofrequency radiation (RFR) exposure will be rising, including sperm & egg viability due to searching for signal, I.e "smart" devices in pockets and even diapers! Wireless baby-monitors in yr child's brain. Mothers holding children and scrolling right next to their heads. Alexa, Echo etc can be hacked w. a laser pen from 100 meters. Your children's version (Our most popular and cutest smart speaker with Alexa) "listens" to them and transmits the information. Amazon Sidewalk is going to bridge every bluetooth device in your neighborhood: "The company’s published list of devices includes: Ring Floodlight Camera (2019), Ring Spotlight Cam, Echo (third gen and newer), Echo Dot (third gen and newer), Echo Dot for Kids (third gen and newer), Echo Dot with Clock (third gen and newer), Echo Plus (all generations), Echo Show (all models and generations), Echo Spot, Echo Studio, Echo Input, Echo etc"

Cars, essentially giant moving computers, can be hacked from afar. Driverless taxis in San Francisco can be immobilized w. just a traffic cone on the hood. An essential scene in the new Netflix movie, "Leave the World Behind," produced by Barack and Michelle Obama's company, Higher Ground: The clip finds Julia Roberts’ character walking amongst a sea of white Teslas that have piled up on a country road. When she notices a placard attached to one of them bearing the words “Full Self-Driving Capacity,” communally attracted to each other in a Long Island shut down due to an EMP - or major electromagnetic disturbance. https://highergroundmedia.com/

Please choose the safer and more economical route. Wired infrastructure offers greater capacity, predictable performance, lower maintenance costs, and a longer technological lifetime than wireless technologies. Fiber service is not degraded by line-of-sight issues and is not affected by capacity issues.
4798January 25, 2024 at 8:14 amW.S.ResidentSAN PEDRO907312. Introduction and Vision for Digital Equity
WIRED connection is superior to wireless in all respects, and wireless broadband—especially the basic services offered to low-income families—will NOT solve the digital divide.

Wireless is unreliable and unable to meet the demands of present and future digital communications. Providing funding for rollout of wireless installations will take it away from much safer, reliable, energy-efficient WIRED internet.

Wireless will set the state back in terms of climate change management because wireless uses a huge amount of energy compared to WIRED broadband.

Wireless facilities increase fire risk and cyber security risk

Wireless facilities impact the growing percentage of the population with disabilities related to radiofrequency radiation (RFR) exposure.

Wired infrastructure offers greater capacity, predictable performance, lower maintenance costs, and a longer technological lifetime than wireless technologies. Fiber service is not degraded by line-of-sight issues and is not affected by capacity issues.
4797January 25, 2024 at 7:51 amS.K.ResidentFairfax949302. Introduction and Vision for Digital Equity
2. Introduction and Vision for Digital Equity
WIRED connection is superior to wireless in all respects, and wireless broadband—especially the basic services offered to low-income families—will NOT solve the digital divide.

Wireless is unreliable and unable to meet the demands of present and future digital communications. Providing funding for rollout of wireless installations will take it away from much safer, reliable, energy-efficient WIRED internet.

Wireless will set the state back in terms of climate change management because wireless uses a huge amount of energy compared to WIRED broadband.

Wireless facilities increase fire risk and cyber security risk

Wireless facilities impact the growing percentage of the population with disabilities related to radiofrequency radiation (RFR) exposure.

Wired infrastructure offers greater capacity, predictable performance, lower maintenance costs, and a longer technological lifetime than wireless technologies. Fiber service is not degraded by line-of-sight issues and is not affected by capacity issues.
4796January 25, 2024 at 7:49 amM.L.ResidentSan Diego921542. Introduction and Vision for Digital Equity
WIRED connection is superior to wireless in all respects, and wireless broadband—especially the basic services offered to low-income families—will NOT solve the digital divide.

Wireless is unreliable and unable to meet the demands of present and future digital communications. Providing funding for rollout of wireless installations will take it away from much safer, reliable, energy-efficient WIRED internet.

Wireless will set the state back in terms of climate change management because wireless uses a huge amount of energy compared to WIRED broadband.

Wireless facilities increase fire risk and cyber security risk

Wireless facilities impact the growing percentage of the population with disabilities related to radiofrequency radiation (RFR) exposure.

Wired infrastructure offers greater capacity, predictable performance, lower maintenance costs, and a longer technological lifetime than wireless technologies. Fiber service is not degraded by line-of-sight issues and is not affected by capacity issues.
4794January 25, 2024 at 7:18 amL.B.ResidentSan Mateo944042. Introduction and Vision for Digital Equity
WIRED connection is superior to wireless in all respects, and wireless broadband—especially the basic services offered to low-income families—will NOT solve the digital divide.
2. Introduction and Vision for Digital Equity
Wireless is unreliable and unable to meet the demands of present and future digital communications. Providing funding for rollout of wireless installations will take it away from much safer, reliable, energy-efficient WIRED internet.

Wireless will set the state back in terms of climate change management because wireless uses a huge amount of energy compared to WIRED broadband.

Wireless facilities increase fire risk and cyber security risk

Wireless facilities impact the growing percentage of the population with disabilities related to radiofrequency radiation (RFR) exposure.

Wired infrastructure offers greater capacity, predictable performance, lower maintenance costs, and a longer technological lifetime than wireless technologies. Fiber service is not degraded by line-of-sight issues and is not affected by capacity issues.












Reply, Reply All or Forward
4793January 25, 2024 at 7:18 amS.M.ResidentLOS ANGELES900662. Introduction and Vision for Digital Equity
WIRED connection is superior to wireless in all respects, and wireless broadband—especially the basic services offered to low-income families—will NOT solve the digital divide.

Wireless is unreliable and unable to meet the demands of present and future digital communications. Providing funding for rollout of wireless installations will take it away from much safer, reliable, energy-efficient WIRED internet.

Wireless will set the state back in terms of climate change management because wireless uses a huge amount of energy compared to WIRED broadband.

Wireless facilities increase fire risk and cyber security risk

Wireless facilities impact the growing percentage of the population with disabilities related to radiofrequency radiation (RFR) exposure.

Wired infrastructure offers greater capacity, predictable performance, lower maintenance costs, and a longer technological lifetime than wireless technologies. Fiber service is not degraded by line-of-sight issues and is not affected by capacity issues.
4792January 25, 2024 at 7:11 amK.S.ResidentCathedral City922341. Executive Summary
Broadband for all is necessary in the 21st century and individuals should not be limited in their lives because of a lack of access to the internet. We live in a digital age and should all have the opportunity to be connected without having to worry about being able to afford it.
4791January 25, 2024 at 7:06 amSenior Vice President, Business Development, StrategyOrganizationFrontier CommunicationsCA1. Executive Summary
Frontier Communications applauds California’s long-standing efforts to close the digital divide throughout the state and appreciates its continued work to ensure that all Californian’s have the connectivity and skills needed to fully engage in our increasingly digital society. The State’s Digital Equity Plan (SDEP) clearly identifies the numerous barriers that need to be overcome to satisfy California’s Broadband for All goals. Frontier hopes to continue to partner with the state in pursuit of its Broadband for All goals.

In California, serving rural communities is central to Frontier. We serve some of the most rural and hard to serve areas of the state and have worked to ensure phone, internet, and high-speed broadband is available in the communities we serve. In 2021, Frontier launched a major self-financed initiative—Building Gigabit America—to bring fiber to the premises to more homes and businesses. In 2022, we deployed fiber past 1.2 million locations across our footprint and we are on track to pass a comparable amount in 2023. In California, we have heavily invested in the state and fiber-enabled more than 2 million locations to date.

Further, since 2016, we have worked closely with the California Emerging Technology Fund (CETF) to engage communities and increase internet adoption rates. We know that strong partnerships such as ours with CETF and the communities we serve are also important for ensuring state and federal funding reach communities with the highest need. We are confident that, working together and through a multi-vectored approach, we can make meaningful progress in overcoming the barriers of Access, Affordability and Adoption.

Thank you for allowing us to partner with the State and the Broadband for All team to bring fiber Broadband to the rural communities we serve in California.

Additionally, please amend one missing piece of information within the document in
Appendix J. Frontier Communications does participate in ACP (Affordable Connectivity Program).

Sincerely,

Allison M. Ellis
SVP, Business Development, Strategy
AE4862@ftr.com | 240-353-4702 | Durham, NC
Frontier Communication

7. Appendices
Frontier Communications:
Please amend one missing piece of information within the document in
Appendix J. Frontier Communications does participate in ACP (Affordable Connectivity Program).
4790January 25, 2024 at 7:02 amK.F.ResidentRoseville956781. Executive Summary
END 5-G - EMFs are DEADLY!
WIRED connection is superior to wireless in all respects, and wireless broadband—especially the basic services offered to low-income families—will NOT solve the digital divide.

Wireless is unreliable and unable to meet the demands of present and future digital communications. Providing funding for rollout of wireless installations will take it away from much safer, reliable, energy-efficient WIRED internet.

Wireless will set the state back in terms of climate change management because wireless uses a huge amount of energy compared to WIRED broadband.

Wireless facilities increase fire risk and cyber security risk

Wireless facilities impact the growing percentage of the population with disabilities related to radiofrequency radiation (RFR) exposure.

Wired infrastructure offers greater capacity, predictable performance, lower maintenance costs, and a longer technological lifetime than wireless technologies. Fiber service is not degraded by line-of-sight issues and is not affected by capacity issues.
4789January 25, 2024 at 6:58 amK.B.ResidentCalabasas913021. Executive Summary
California does not need a digital equity plan. We do not need another huge and expensive government program at this time of budget deficits. This should not be the top priority of the state. Let’s simplify our lives rather than make them more complicated. If a person wants to prioritize a phone, that person can choose to do that. We do not need to choose for that person. Please don’t create a whole infrastructure at a time when we need to slim the budget and set practical priorities, such as securing the infrastructure we already have.
Sincerely, Kathy Berkowitz
4788January 25, 2024 at 6:47 amR.A.ResidentHealdsburg954481. Executive Summary
Our rural area is not served by internet providers but they claim they do with current service maps. Our only WiFi choice is satellite and is very expensive and too slow to stream.
We also live with no cell service.
4787January 25, 2024 at 5:10 amCEOOrganizationKeep Cell Antennas AwayElk GroveCA2. Introduction and Vision for Digital Equity
Other than very few exceptions the State should promote and provide funding for internet connections which operate through wires, cables, and other physical means. Coaxial cables, Ethernet cables, etc. These direct connections have the advantage of being faster, more secure, and more reliable than any other. They are also safer, as they do not expose the end user and everybody in the vicinity to pulsed, modulated, microwave electromagnetic radiation. There is in the law, and I believe this is a requirement for BEADS grants, a requirement that each project must be capable of 100 mbps upload and 100 mbpls download speeds. Only wired internet connections are capable of this. One purpose of providing internet access to lower income communities, we have heard, is so that children can do their homework with it. Homework is necessary but where is a child most likely to do his or her homework? Where he or she is stationary or out and about, let's say socializing with friends? Obviously the former. There are probably fewer than ten (10) children in California who do their homework while they are out with their friends. The rest, 99.999% of them, do their homework while they are stationary. A wired internet connection can connect either a laptop, desktop or mobile phone to the internet. A wireless internet connection can too, but students do not do their homework while out on the move, and so wireless does not provide ANY benefit to education, while hard wired does. California wants to close the "digital divide" and to do so it must understand how and why the digital divide was created and who created it. Given a huge state with 40 million residents and a wide variety of cities and rural areas with different socioeconomic profiles and population densities, the wireless carriers chose to provide internet service where it was most profitable ONLY; namely, those areas where they could inexpensively reach a LOT of people who could afford their services. Some areas did not fit this profile and so the industry chose not to provide their services there. Repeated attempts by the State to address this situation by giving more money and more options and even zoning authority to wireless companies has failed to change this. The reason is nothing has changed the underlying economics. When the State finally realizes that the industry created the digital divide, and did so for financial reasons, the State will finally begin to make progress closing the digital divide. Wireless radiation from cell antennas has specific harms which wired connections do not. According to literally thousands of studies long term exposure to the radiation from cell towers and cell antennas, known as pulsed, modulated, microwave electromagnetic radiation, aka radio frequency radiation (RF) or electromagnetic fields (EMF), causes significant adverse health effects in humans. The radiation affects the central nervous system, causing insomnia, tinnitus, fatigue, headaches, radiation sickness, and adverse effects on sleep, memory, learning, perception, motor abilities, prenatal and reproductive health, and children’s health. Radiation health effects also include reproductive problems and neurological problems that span from effects on memory to motor abilities, DNA damage and cancer. 1

Some of these health effects and the studies supporting them are on Dr. Moskowitz’s website saferemr.com. Joel M. Moskowitz, Ph.D., Moskowitz is the Director, Center for Family and Community Health, School of Public Health, at the University of California, Berkeley.
According to a ruling by the U.S. Court of Appeals for the D.C. Circuit 1 the FCC has been ignoring thousands of pages of studies since 1996, substantial evidence 2 of significant harm to human health from microwave radiation at levels allowed by the FCC’s “maximum permissible exposure guidelines".
ENVIRONMENTAL HEALTH TRUST, ET AL., No. 20-1025, consolidated with CHILDREN'S HEALTH DEFENSE, ET AL., No. 20-1138 v. FEDERAL COMMUNICATIONS COMMISSION AND UNITED STATES OF AMERICA, Decided August 13, 2021. In other words according to this federal court of appeals the federal government is ignoring health effects studies since 1996.


Over 230 scientists from more than 40 countries have expressed their “serious concerns” regarding the ubiquitous and increasing exposure to EMF generated by electric and wireless devices already before the additional 5G roll-out. They refer to the fact that ”numerous recent scientific publications have shown that EMF affects living organisms at levels well below most international and national guidelines”. Effects include increased cancer risk, cellular stress, increase in harmful free radicals, genetic damages, structural and functional changes of the reproductive system, learning and memory deficits, neurological disorders, and negative impacts on general well-being in humans. Damage goes well beyond the human race, as there is growing evidence of harmful effects to both plants and animals.

https://emfscientist.org/index.php/emf-scientist-appeal

The EUROPA EM-EMF Guideline 2016 states that ”there is strong evidence that long-term exposure to certain EMFs is a risk factor for diseases such as certain cancers, Alzheimer’s disease, and male infertility…Common EHS (electromagnetic hypersensitivity) symptoms include headaches, concentration difficulties, sleep problems, depression, lack of energy, fatigue, and flu-like symptoms.”

https://www.ncbi.nlm.nih.gov/pubmed/27454111

An increasing part of the European population is affected by ill health symptoms that have for many years been linked to exposure to EMF and wireless radiation in the scientific literature. The International Scientific Declaration on EHS & multiple chemical sensitivity (MCS), Brussels 2015, declares that: “In view of our present scientific knowledge, we thereby stress all national and international bodies and institutions…to recognize EHS and MCS as true medical conditions which acting as sentinel diseases may create a major public health concern in years to come worldwide i.e. in all the countries implementing unrestricted use of electromagnetic field-based wireless technologies and marketed chemical substances… Inaction is a cost to society and is not an option anymore… we unanimously acknowledge this serious hazard to public health…that major primary prevention measures are adopted and prioritized, to face this worldwide pan-epidemic in perspective.”

http://www.ehs-mcs.org/en/

​ Precautions
The Precautionary Principle (UNESCO) was adopted by EU 2005: ”When human activities may lead to morally unacceptable harm that is scientifically plausible but uncertain, actions shall be taken to avoid or diminish that harm.”

http://eur-lex.europa.eu/summary/glossary/precautionary_principle.html

http://www.precautionaryprinciple.eu/

Resolution 1815 (Council of Europe, 2011) ”Take all reasonable measures to reduce exposure to electromagnetic fields, especially to radio frequencies from mobile phones, and particularly the exposure to children and young people who seem to be most at risk from head tumours…Assembly strongly recommends that the ALARA (as low as reasonably achievable) principle is applied, covering both the so-called thermal effects and the athermic [non-thermal] or biological effects of electromagnetic emissions or radiation” and to ”improve risk-assessment standards and quality”.

http://assembly.coe.int/nw/xml/XRef/Xref-XML2HTML-en.asp?fileid=17994

Europe recognizes and acknowledges the large body of scientific evidence showing health harms from exposure to pulsed, modulated, microwave electromagnetic radiation, the kind wireless cell antennas provide.

As shown earlier, according to a federal appeals court ruling the U.S. government, namely the Federal Communications, the non health and safety agency which was given the authority to create radiation limits, has been ignoring scientific evidence of health hazards since 1996.

California need not be limited by the industry serving, industry driven, anti-scientific corruption of the FCC. California can and should stand up and do what is right for all Californians, which is protect our health from known health hazards and implement the precautionary principle.

When a cable or wire brings internet service into a home there is no radiation and no health hazard. When a cell antenna brings it in there is radiation and there are many health hazards. Furthermore the residents have no ability to turn the radiation off or down. We can turn off the wifi in our homes. We can turn off our cell phones at night. But we cannot turn off or down the cell antenna mounted on a light pole in the public right of way. For this reason wired internet access is far superior to wireless.

Passed in 2019, the the City of Elk Grove wireless communications facilities ordinance protects homes from having a cell antenna on a light pole right in front of the front yard. I call this the "front yard rule" and it prevents or minimizes the irresponsible placement of cell antennas.

“No small cell wireless communication facility shall be located immediately adjacent to, nor immediately across the street from, a front yard of any residential dwelling.”

(EGMC 23.94.050 (A)(6)(b)) (Ordinance 19-2019)

My estimate is that this provision has protected over 90% of homes in Elk Grove from having a cell antenna right in front of the front yard, transmitting microwave radiation into the home.


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4784January 25, 2024 at 2:41 amK.B.ResidentPetaluma949751. Executive Summary
WIRED connection is superior to wireless in all respects.
Wireless broadband, especially when used for the basic services offered to low-income families will NOT resolve the digital divide.

• Wireless is an inferior "dirty" technology, unreliable, and unable to SAFELY meet the demands of present and future digital communications. Please provide funding for safer, reliable, energy-efficient WIRED internet, not wireless installations.
• Wireless is unreliable and unable to meet the demands of present and future digital communications. Providing funding for the rollout of wireless installations will take it away from much safer, reliable, energy-efficient WIRED internet.

• Wireless will set the state back in terms of climate change management because wireless uses a huge amount of energy compared to WIRED broadband.

• Wireless facilities increase fire risk and cyber security risk

• Wireless facilities impact the growing percentage of the population with disabilities related to radiofrequency radiation (RFR) exposure.

• Wired infrastructure offers greater capacity, predictable performance, lower maintenance costs, and a longer technological lifetime than wireless technologies. Fiber service is not degraded by line-of-sight issues and is not affected by capacity issues.
4781January 25, 2024 at 1:06 amJ.W.ResidentCarson907451. Executive Summary
Please give us fiber to the home. Anything less deprives the people.
4780January 25, 2024 at 12:41 amB.K.ResidentAlbion954103. Current State of Broadband and Digital Inclusion
We use wifi from satellite, which is slow and frequently interrupted. For telemed appointments or Zoom, I have to call in on my landline phone. (Verizon, US Cellular, and AT&T say they don't cover this area for mobile phones). I'm really looking forward to the "last mile" wired connection.
4779January 24, 2024 at 11:56 pmJ.Y.Resident913202. Introduction and Vision for Digital Equity
I endorse this statement:
WIRED connection is superior to wireless in all respects, and wireless broadband—especially the basic services offered to low-income families—will NOT solve the digital divide.

Wireless is unreliable and unable to meet the demands of present and future digital communications. Providing funding for roll-out of wireless installations will take it away from much safer, reliable, energy-efficient WIRED internet.

• Wireless will set the state back in terms of climate change management because wireless uses a huge amount of energy compared to WIRED broadband.

• Wireless facilities increase fire risk and cyber security risk

• Wireless facilities impact the growing percentage of the population with disabilities related to radiofrequency radiation (RFR) exposure.

• Wired infrastructure offers greater capacity, predictable performance, lower maintenance costs, and a longer technological lifetime than wireless technologies. Fiber service is not degraded by line-of-sight issues and is not affected by capacity issues.
4778January 24, 2024 at 11:51 pmC.M.ResidentOakland946101. Executive Summary
Goal 1: 'High performance broadband' - I may have missed but didn't see a clear definition of this. Could be confusing for communities to know what this means. Maybe add a line that defines it.

1. Executive Summary
Goal 2: I didn't see a specific call out regarding devices. It is addressed later, but not a call out in Goal 2. Devices need to be relevant and usable for a current and at least a few future years; eliminate the monthly fee (if there is a monthly fee, it is lease-to-own); establish and upgrade or trade-in program. This may not all be in Goal 2. but didn't see devices addressed there.

1. Executive Summary
Strategies and Implementation: Not sure if it I missed but satellite and other options should be considered as an option, especially where trenching is not an option.

2. Introduction and Vision for Digital Equity
Page 34, mid-page. Tech Exchange has been around for 29 years doing this work, longer than many, especially in Oakland, Bay Area and South Bay. It seems only fair to add them to that list

2. Introduction and Vision for Digital Equity
Page 36: I saw disaster recovery in reference to wildfares and for tribal communities, but perhaps to expand to be address in all communities. After all, Internet, when powered, will be a critical component in regards to disaster recovery of any type. For example, Oakland has Communities of Oakland Respond to Emergencies (CORE) ..."is a free emergency preparedness and response training program of the Oakland Fire Department. CORE provides free emergency preparedness training for individuals, neighborhood groups and community‐based organizations in Oakland." With climate change and more, this will only increase across the state and the Internet will likely be an important backbone to support. So addressing Disaster Recovery as a component would be ideal.

2. Introduction and Vision for Digital Equity
Page 51, Objective 3.5: Is there a target percentage? Will there be goals for vendors to achieve toward the target
percentage?

2. Introduction and Vision for Digital Equity
Page 54, Strategies for Goal 1 - Access: Regarding broadband infrastructure, should be resilient and future forward. Don’t want to ‘outgrow’ and have to start again.

2. Introduction and Vision for Digital Equity
Page 54, Goal 2: Use social media where possible for advertising. Also ads on vendor partner websites.
4777January 24, 2024 at 11:42 pmS.T.ResidentOakland946091. Executive Summary
My name is Sarah Turley and I am a high schooler on the Youth Commission for the City of Oakland representing district 1.
I am writing to ensure that students living in underserved Oakland communities receive access to affordable, fast internet. Currently, the map being used by the state marks Pleasanton neighborhoods with median HH incomes of over six figures as having more need than neighborhoods like West Oakland with a median HH income of $21k. Following this map will contribute to 21st-century redlining. There are over 35 thousand people in Oakland living unconnected to the internet. Even for those who have internet connection it is often unreliable if you are living in certain areas.
During covid when jobs and school went online, my family and our neighbors had to share the wifi for a total of 8 people. Paired with my school loaned chromebook, it was incredibly slow and doing school on zoom was impossible. To combat this my school gave out hotspots but even then the hotspot was incredibly unreliable. Many of my classmates were in similar situations. Even after distance learning, fast, affordable wifi and hotspots are a necessity to succeeding in school. Providing more broadband internet in Oakland would help so many students and the State of California must act now to change the maps and re-evaluate where funding is distributed.
4776January 24, 2024 at 11:41 pmT.W.ResidentAlbion954103. Current State of Broadband and Digital Inclusion
My land line was out for 1/2 December & 1/2 January, 2023/24. I/m 87 years old & have balance issues. My nearest neighbor is a 25 min. walk away. I've gone to both U.S. Cellular & Verizon, the only companies that serve my area, but they say they don't serve my address. My neighbor can stand on my porch and make a phone call using U.S.Cellular. I wonder if it's because I'm wanting service through the Government APC connectivity program. But that rant is beside the point. What is really needed in our rural area is wired internet & phone service, that covers every household, & not iffy wireless service that's hit or miss.
4775January 24, 2024 at 11:23 pmO.K.ResidentSanta Rosa954041. Executive Summary
I am an author and definitely believe in using the internet to do research in my writing. However, I would prefer wired connectivity instead of wireless. Having written a book about wireless Smart Meters and their harmful pulsed radiation causing health problems and also fire hazards, and also a second book about 5G and the huge amount of radiation that is coming from it, I strongly believe and recommend wired connections for as many broadband services as possible.
I know of many people who are EMF sensitive and cannot be around wireless devices without having serious health reaction, including headaches, heart palpitations, ringing in their ears, some even develop seizures, and some develop cancer. Wi-Fi is especially hard on young children. Schools that are installing it for every classroom are finding young children are developing some of the same above-mentioned health problems.
I would suggest that you offer instead wired broadband service. Wired connection is superior to wireless in all respects. It is safer, more reliable, and energy-efficient. Wireless uses a huge amount of energy compared to wired broadband. Wireless facilities also increase fire risk and cyber security risk. Wired infrastructure offers greater capacity, predictable performance, lower maintenance costs, and a longer technological lifetime than wireless technologies. Fiber service is not degraded by line-of-sight issues as is often with wireless, nor is it affected by capacity issues. For all of these reasons, please consider using wired broadband services. Thank you.
4774January 24, 2024 at 11:22 pmR.G.ResidentVenice902912. Introduction and Vision for Digital Equity
WIRED connection is superior to wireless in all respects, and wireless broadband—especially the basic services offered to low-income families—will NOT solve the digital divide.

Additional points:
• Wireless is unreliable and unable to meet the demands of present and future digital communications. Providing funding for rollout of wireless installations will take it away from much safer, reliable, energy-efficient WIRED internet.

• Wireless will set the state back in terms of climate change management because wireless uses a huge amount of energy compared to WIRED broadband.

• Wireless facilities increase fire risk and cyber security risk

• Wireless facilities impact the growing percentage of the population with disabilities related to radiofrequency radiation (RFR) exposure.

• Wired infrastructure offers greater capacity, predictable performance, lower maintenance costs, and a longer technological lifetime than wireless technologies. Fiber service is not degraded by line-of-sight issues and is not affected by capacity issues.
4773January 24, 2024 at 11:04 pmB.H.ResidentSherman Oaks914032. Introduction and Vision for Digital Equity
WIRED connection is superior to wireless in all respects, and wireless broadband—especially the basic services offered to low-income families—will NOT solve the digital divide.


• Wireless is unreliable and unable to meet the demands of present and future digital communications. Providing funding for rollout of wireless installations will take it away from much safer, reliable, energy-efficient WIRED internet.

• Wireless will set the state back in terms of climate change management because wireless uses a huge amount of energy compared to WIRED broadband.

• Wireless facilities increase fire risk and cyber security risk

• Wireless facilities impact the growing percentage of the population with disabilities related to radiofrequency radiation (RFR) exposure.

• Wired infrastructure offers greater capacity, predictable performance, lower maintenance costs, and a longer technological lifetime than wireless technologies. Fiber service is not degraded by line-of-sight issues and is not affected by capacity issues.
4772January 24, 2024 at 10:49 pmW.T.ResidentHalf Moon Bay940192. Introduction and Vision for Digital Equity
WIRED connections are superior to wireless in all respects! Wireless broadband is NOT a solution!

Wireless is unreliable, uses more energy, is prone to hacking, is making people sick and there are NO established levels for safety (because it is NOT safe), and the grid can easily be taken out by solar flares and EMPs. THIS WEEK radio blackouts were created due to solar flares which are becoming more frequent. Stick to wired connections!
4771January 24, 2024 at 10:27 pmE.N.ResidentCastro Valley945462. Introduction and Vision for Digital Equity
Wired internet connections are safer, more reliable and more energy efficient than wireless. Wireless uses much more energy than wired. For the sake of climate change, then, wired is the best and only reasonable choice. Wireless infrastructure will not solve the digital divide; it has less capacity, costs more to maintain, and has a shorter lifespan than wired. Finally, blanketing unconnected areas with wireless broadband will greatly increase the RF radiation everyone is subject to, with no rural areas to 'escape' to. This will increase the likelihood of more people finding themselves sensitive and reactive to RF radiation, as I have. All of my household's internet connections are wired. Please give serious consideration to implementing wired connectivity. Thank you.
4770January 24, 2024 at 10:07 pmDirector of Government OutreachOrganizationEnvironmental Health Trust5. Implementation Strategy & Key Activities
We thank the California Department of Technology (CDT) and affiliates for considering our comments on the California Digital Equity Plan.1 The Environmental Health Trust (EHT) is a not-for-profit scientific think tank that promotes a healthier environment through research, education and policy.2

EHT shares the vision of CDT, “A California in which all residents have access to high-performance broadband, affordable service and devices, and the training and support necessary to enable digital inclusion for economic and other social benefits.”3 Digital equity initiatives focus on communities with technology access disparities who oftentimes also experience disparities in environmental, social and health justice. We submit that a responsible digital equity plan must consider the quality, sustainability and upgradability of the technology being introduced and also their impact on the environment and health to ensure continuity into the future.

The five objectives of CDT are: “1. The availability of, and affordability of access to, fixed and wireless broadband technology; 2. The online accessibility and inclusivity of public resources and services; 3. Digital literacy; 4. Awareness of, and the use of, measures to secure the online privacy of, and cybersecurity with respect to, an individual, and; 5. The availability and affordability of consumer devices and technical support for those devices.”

We urge the CDT to favor wired connections all the way to the end user where feasible in these communities and not wireless infrastructure which will not meet future connectivity needs, harm the environment and the health of residents and create another digital divide in just a few years.

Wired connections are superior to wireless:
1. Scientific and policy documentation on human health and environment supporting the use of wired versus wireless broadband
2. Performance, scalability, cybersecurity and competition
3. Energy efficiency
4. EHT Recommendations

1. Scientific and Policy Documentation on Human Health and Environment Supporting the Use of Wired versus Wireless Broadband

The scientific evidence4 is adequate to support strong public health policies to reduce wireless radiation, especially for children and vulnerable populations. A growing body of scientific evidence of wireless radio frequency (RF) radiation at levels far below FCC limits is showing evidence of cancer,5 increased oxidative stress,6 genetic damage,7 structural and functional changes of the reproductive system,8 memory deficit,9 behavioral problems10, and neurological impacts.11

A study by U.S. Army and Air Force Research Laboratories found that high powered pulsed microwave exposures could reach the same threshold pressures of explosive blast brain and football head impact injuries even at levels considered “safe” and compliant with current FCC RF limits.12

However, despite these health issues, wireless technologies are often put forward as the solution to bridge the digital divide and connect the unconnected. Thus, vulnerable populations often end up receiving significantly increased exposure of radiofrequency radiation, an emerging environmental justice issue.

Research shows that the environmental levels of radiofrequency radiation (RFR) that people are exposed to have increased with the densification of cell tower networks closer to where people live, work and play and levels are highest in urban areas.13 Studies show a 70x increase14. Cell towers are often disproportionately placed in neighborhoods with higher numbers of minorities and students needing free and reduced meals.15 In Montgomery County, for example, cell towers are overwhelmingly placed in schools with higher numbers of minorities, english as a second language students, and those who subscribe to free and reduced lunch rates.16 Parents in schools with a higher white and more affluent population have organized and successfully fought off the towers.17

Cell antennas are being put up in front of apartments and renters are not being informed nor are they a part of the decision making process. Low income families and renters have less ability to move or mitigate exposures. Health care inequalities will further exacerbate health inequities as people in under-resourced communities will receive unequal care for the damages from exposure to RFR.

Policies to fasttrack 5G and wireless technology are pushed to fix the digital divide despite evidence indicating it could exacerbate the digital divide. In June 2020, the U.S. the Government Accountability Office (GAO) released a report on 5G which concluded that 5G may “worsen” the digital divide. The experts the GAO convened stated that “5G deployment would likely exacerbate disparities in access to telecommunications services, known as the ‘digital divide.’”

Expert Recommendations on Technology Safety

Recommendations of the United States Government Accountability Office

According to a 2012 Government Accountability Office (GAO) Report titled “Telecommunications: Exposure and Testing Requirements for Mobile Phones Should Be Reassessed”18 it is stated that “By not formally reassessing its current limit, FCC cannot ensure it is using a limit that reflects the latest research on RF energy exposure…” and that “Some consumers may use mobile phones against the body, which FCC does not currently test, and could result in RF energy exposure higher than the FCC limit.” This report resulted in two recommendations made to the FCC:

Recommendation 1: “The Chairman of the FCC should formally reassess the current RF energy exposure limit, including its effects on human health, the costs and benefits associated with keeping the current limit, and the opinions of relevant health and safety agencies, and change the limit if determined appropriate.”

Recommendation 2: “The Chairman of the FCC should reassess whether mobile phone testing requirements result in the identification of maximum RF energy exposure in likely usage configurations, particularly when mobile phones are held against the body, and update testing requirements as appropriate.”

According to the GAO report “Despite many years of consideration, FCC still has no specific plans to take any actions that would satisfy our recommendations. Accordingly, we are closing the recommendations as not implemented.”

The American Academy of Pediatrics

The American Academy of Pediatrics (AAP) has written several letters to the FCC calling on them to update wireless safety limits to protect children 19stating that, “Current FCC standards do not account for the unique vulnerability and use patterns specific to pregnant women and children. It is essential that any new standard for cell phones or other wireless devices be based on protecting the youngest and most vulnerable populations to ensure they are safeguarded throughout their lifetimes.”

In response to the National Toxicology Program animal study findings of cancer and DNA damage20 from cell phone radiation, the AAP also issued the cell phone safety tips specifically for families21 to reduce exposure to wireless radiation including, “If you plan to watch a movie on your device, download it first, then switch to airplane mode while you watch in order to avoid unnecessary radiation exposure.”

The American Academy of Pediatrics states of cell towers22 that, “An Egyptian study confirmed concerns that living nearby mobile phone base stations increased the risk for developing: Headaches, Memory problems, Dizziness, Depression, Sleep problems”

The California Department of Health

The California Department of Health released an advisory on how to reduce cell phone radiation23 stating children may be more at risk and “Although the science is still evolving, some laboratory experiments and human health studies have suggested the possibility that long-term, high use of cell phones may be linked to certain types of cancer and other health effects.” Recommendations include, "Parents should consider reducing the time their children use cell phones and encourage them to turn the devices off at night.”

The Santa Clara Medical Association

The Santa Clara Medical Association Best Practices for Technology in schools24 recommends reducing Wi-Fi exposure and restricting cell towers near schools.

California Medical Association

In 2014, the California Medical Association passed two resolutions regarding wireless standards: 1. To “support efforts to reevaluate microwave safety exposure levels associated with wireless communication devices, including consideration of adverse non-thermal biologic and health effects from non-ionizing electromagnetic radiation used in wireless communications”; and 2. To “support efforts to implement new safety exposure limits for wireless devices to levels that do not cause human or environmental harm based on scientific research.”

Recommendations of the New Hampshire State Commission on 5G Health and Environment

In 2019 the New Hampshire government passed House Bill 522 “An act establishing a commission to study the environmental and health effects of evolving 5G technology.”25 The Commission released its Final Report on Commission to Study the Environmental and Health Effects of Evolving 5G Technology26 in 2020 with findings that safety assurance for wireless technology “come into question because of the thousands of peer-reviewed studies documenting deleterious health effects associated with cellphone radiation exposure.” In its report the Commission issued 15 recommendations:

1. Support statewide deployment of fiber optic cable connectivity with wired connections inside homes.
2. New Hampshire schools and libraries should replace Wi-Fi with hardwired connections.
3. Require setbacks for new wireless antennas from residences, businesses, and schools.
4. New Hampshire health agencies educate the public on minimizing radiofrequency radiation (RFR) exposure with public service announcements on radio, television, and print. “Warnings concerning the newborn and young as well as pregnant women”
5. Establish RFR free zones in commercial and public buildings
6. New measurement protocols needed to evaluate high data rate, signal characteristics associated with biological effects and summative effects of multiple radiation sources.
7. RFR signal strength measurements for cell sites should be done by independent contractors.
8. NH professional licensure to offer education so home inspectors can include RFR intensity measurements.
9. Warning signs to be posted in commercial and public buildings.
10. State should measure RFR and post maps with measurements for the public.
11. Require 5G structures to be labeled for RFR at eye level and readable from nine feet away.
12. Engage agencies with ecological knowledge to develop RFR safety limits that will protect the trees, plants, birds, insects, and pollinators.
13. Under the National Environmental Policy Act, FCC should do an environmental impact statement as to the effect on New Hampshire and the country as a whole from 5G and the expansion of RF wireless technologies.
14. Cell phones and wireless devices should be equipped with updated software that stops cell phones from radiating when positioned against the body.
15. A resolution to US Congress to require the FCC to commission an independent health study and review of safety limits.

The Connecticut Department of Public Health

The Connecticut Department of Public Health states in its FAQs on Cell Phones that it is “wise” to reduce cell phone radio frequency to one’s brain.27

The North Carolina Public Health Department

The North Carolina Public Health Department lists the full cancer findings of the NTP study28, the FDA stance and also the American Academy of Pediatrics recommendations to reduce cell phone radiation stating “there is some concern that exposure to non-ionizing radiation, also called radio frequency radiation, that is emitted by cell phones may result in an increased risk of cancer or other health effects”

The Maryland State Children’s Environmental Health And Protection Advisory Council

The Maryland State Children’s Environmental Health And Protection Advisory Council, whose 19 member Commission includes experts in public health, pediatricians, state health and environment agencies and legislators issued a report recommending reducing wireless exposure to children in schools and homes.29

Scientists With Expertise in Electromagnetic Radiation

Numerous medical groups have called for policies to reduce children’s exposure30. For example, the EMF Scientists are over 259 scientists from 41 countries who have peer-reviewed publications on electromagnetic fields who made a 2015 appeal to the United Nations31 and all member States in the world to encourage the World Health Organization “to exert strong leadership in fostering the development of more protective EMF guidelines, encouraging precautionary measures, and educating the public about health risks, particularly risk to children and fetal development.”

With several California Medical entities and numerous additional expert recommendations in mind we recommend that the Digital Equity Plan opt for and prioritize wired connections. The use of wired technology decreases the need for wireless and will help reduce environmental levels of wireless radiation.

Scientific Research on Wireless Impact to Health and Environment

Wireless radiation cannot be considered safe and FCC limits are inadequate to address long term health effects from daily exposure to wireless radiation. As stated by the EPA, FDA, and Department of Interior, current FCC guidelines address heating effects of short term exposures only.32 Current FCC human exposure guidelines are unchanged since 1996 and were based on now antiquated limits developed by ANSI/IEEE C95.1-1992 and NCRP’s 1986 Report. These limits identified the level of adverse effects based on studies which exposed a few monkeys and rats to RF radiation for less than one hour, more than 40 years ago. They do not consider the biological effects of non-thermal or long-term low-level exposures of radiofrequency radiation documented in the scientific literature.33 Current guidelines also do not consider the documented effects of modulations and pulsation on living cells. As the DC Circuit recognized, these antiquated studies are a far cry from properly assessing the health and environmental impacts of modern technology and ubiquitous wireless devices.

No federal agency with health or science expertise has evaluated the comprehensive body of scientific research on the human health and environmental impacts of wireless radiation. An ever growing body of scientific evidence documents adverse effects from RF radiation at exposure levels well below FCC limits34 with research findings that include cancer, the induction of oxidative stress, epigenetic effects, impacts to neurotransmitters, memory, brain development and damage to the immune, endocrine, hematological and reproductive system. Further, studies have found impacts to tree canopy, plant growth, pollinator health and the orientation, migration and breeding of wildlife.35 The science clearly indicates that wireless networks create harmful interference in humans as well as flora and fauna. Attachments 2 and Attachment 3 below document the significant body of scientific evidence indicating adverse effects to humans and the environment from radiofrequency exposure.

Neither FCC, nor the Food and Drug Administration (FDA), have yet to address their responsibilities to ensure public health and environmental protection. The FCC has not responded to the August 13, 2021, U.S. Court of Appeals for the District of Columbia Circuit ORDER in Environmental Health Trust et al. v. FCC, 2021 wherein the court ordered the FCC to “address the impacts of RF radiation on children, the health implications of long-term exposure to RF radiation, the ubiquity of wireless devices, and other technological developments that have occurred since the Commission last updated its guidelines, and…the impacts of RF radiation on the environment.” The Court also ordered the FCC to “provide a reasoned explanation for its decision to retain its testing procedures for determining whether cell phones and other portable electronic devices comply with its guidelines.”

Further, as documented in Attachment 1 on Regulatory Gaps, there are no federal agencies with health and science expertise engaged in activities related to reviewing the science on health effects of rising environmental RF levels from network infrastructure.


2. Performance, Scalability, Cybersecurity and Competition

Despite efforts made to fund broadband expansion, according to the California Digital Equity Plan, “there is a persistent digital divide in California. One in five residents lacks access to reliable, high-speed broadband, affordable internet service and devices, and the training and skills to use them.” and “Although 91% of Californians are connected to broadband service, only 62% report that their service is reliable for their household needs.”

Performance and Scalability

While wireless infrastructure promises faster and cheaper deployment, it is no match for the performance of fiber infrastructure and ends up being costlier in the long run to maintain and upgrade.36 The poor performance metrics of wireless infrastructure costs our states billions of dollars when residents and businesses are held up by unreliable service, low speeds, and issues with cybersecurity37 and privacy.

Baseline speed requirements of 100/20Mbps (download/upload) can be achieved with current cable infrastructure, the kind that already exists for most homes and businesses. 5G wireless infrastructure offers speeds similar to what cable currently provides38 and is limited in its capacity to reliably offer faster upload speeds, unreliably peaking at just 50 Mbps when standing near the transmitter. Using funding for wireless infrastructure will put communities in another digital divide in just a few years when bandwidth demands increase with future technology demands.

Baseline speeds for fiber infrastructure is 1000/1000 Mbps (download/upload) far surpassing wireless speeds at its minimum performance capabilities. Currently cities that have adopted all fiber networks are seeing speeds of 10,000/10,000 Mbps with the capabilities of upgrading to Terabyte symmetrical speeds and quantum technology. Chattanooga, Tennessee adopted fiber to the premises 12 years ago with symmetrical speeds of 1000 Mbps and has now upgraded to 10 Gbps (or 10,000 Mbps) symmetrical speeds by simply replacing the software and keeping all the fiber intact.39 Fiber upgrades cost a fraction of wireless infrastructure upgrades. These savings will be passed down to underserved communities that need it the most. That is why it is critical to invest in a superior infrastructure, that is fiber, now which will pay off in the future.

The pandemic shutdowns forced large families to work and school from home and it was a quick lesson on the imperative need for fast, reliable internet that not only allowed us to quickly download information but to also have fast upload speeds so that multiple family members can have online video calls at the same time.
Wireless infrastructure fails in allowing multiple users on the same network to reliably have online video meetings at the same time.

Wireless infrastructure fails during inclement weather or when the path of the signal is obstructed. Fiber and current cable infrastructure can reliably offer superior service without these challenges.

Cybersecurity

While it is important to teach residents cyber safety it is equally important to harden the infrastructure to keep out bad actors. Wireless broadband presents a major cybersecurity risk. Individuals, institutions and businesses have suffered great losses as wireless signals are easily accessible to hackers.40 Fiber and current cable infrastructure can reliably offer superior service without these challenges.

Competition

The quality of broadband will make or break the ability for these communities to compete with the rest of the United States and the world.41 Other countries have recognized the importance of fiber optics all the way to the premises and have invested heavily to reach 100% penetration, ensuring that even rural communities42 with unfavorable terrain have fiber. As of 2019 - 92% of China’s internet users had fiber all the way to the home.43 62% of homes in the European Union 39 bloc nations have fiber to the premises.44 United Arab Emirates, Qatar, Singapore and Hong Kong all have higher than 90% penetration of fiber all the way to the premises while Iceland, Spain and Portugal are catching up at 76.8%, 73.5% and 71.1% respectively. 45 The US, on the other hand, stands at 16.39% penetration of fiber to the premises and ranked 30th among Organization for Economic Co-operation and Development countries, as of 2020. 46

Energy Efficiency

According to IEEE Magazine, 5G base stations are expected to consume roughly 3 times the power of 4G base stations and more 5G base stations are required to cover the same area.47 Energy consumption is expected to increase by 61 times from 2020 to 2030 with 5G.48 Adding more strain on electric grids, especially when we have not fully moved to renewable energy, will further exacerbate carbon emissions.

According to countries that have already installed fiber to the homes (FTTH), like China and Spain, fiber is 85% more energy efficient than copper yielding a saving of 208GWh which represents a reduction of 56,500 tons of CO2 emissions. One study done by the Federal Environment Ministry of Germany and the German Environment Agency found that video transmission through fiber optics is nearly 50 times more energy efficient than wireless.49 Research on whole network level assessments of the operational energy use implications of 5G warns “Energy-intensive user practices contribute to ever-growing levels of data traffic, and counteract 50the energy-saving potential of 5G efficiency improvements.”51 Promoting technology that increases carbon pollution in already disadvantaged neighborhoods will further exacerbate environmental and social injustices.

4. EHT Recommendations

Recommendation 1: Individuals such as those with EMF related disabilities and vulnerable populations like children, pregnant women, the sick and elderly should have equal access to safe wired (wireless radiation free) technology.

The California Digital Equity vision is “A California in which all residents have access to high- performance broadband, affordable service and devices, and the training and support necessary to enable digital inclusion for economic and other social benefits.” There is a segment of the population that has developed or will develop microwave sickness, a debilitating reaction to electromagnetic fields including RFR. Microwave sickness is well documented in the medical literature. 52 53 Electromagnetic related disability is recognized by the US government and multiple other entities.54 In addition, certain segments of the population are more vulnerable to radiofrequency impacts, including children, pregnant women, the sick and the elderly.55

The goal of CDT is to provide connectivity to all Americans, regardless of disability status or age. Wired internet connections can safely and more effectively provide internet connectivity without the risks to individuals especially those with electromagnetic disabilities and vulnerable populations. This is in line with the expert recommendations cited above to provide fiber optics connectivity to all premises and hardwired connections all the way to devices, including replacing Wi-Fi with hardwired connections.

Recommendation 2: Communities with digital disparities should have access to reliable, affordable and cybersecure wired infrastructure all the way to the end user to ensure sustainability and affordability into the future as bandwidth demands increase.

Objective 1.3 is to “Increase the percentage of Californians who report that their internet service is reliable.” Objective 2.1 is to “Decrease the percentage of Californians who cite cost as the primary barrier to internet service.”
Objective 2.2 is to “Reduce the average cost that covered populations pay for internet service.” Objective 3.3 is to “Reduce the percentage of Californians whose concerns for privacy and cybersecurity prevent broadband adoption or effective use.”

Having wireless infrastructure especially in disadvantaged areas will ultimately be more costly as more funds will be required to upgrade all the infrastructure when bandwidth demands increase.56 These costs will be passed down to disadvantaged communities that can least afford them. Upgrades will take longer in disadvantaged neighborhoods and threaten to put the residents in another digital divide when substandard infrastructure cannot keep up with the demands. This will be devastating to these communities especially after residents have become dependent on the technology for their everyday needs.

While wired infrastructure costs more initially to install it provides superior performance, cybersecurity, and energy efficiency that will be sufficient for communities for a much longer time than wireless infrastructure.57 In the future maintenance and upgrade costs of fiber will be a fraction of the price of maintaining and upgrading wireless infrastructure. These savings will be passed down to the communities that most desperately need them.

Furthermore, Californians are rightfully concerned about cybersecurity and privacy with 42% citing “concerns over privacy barriers to home internet.” While it is important to teach residents how to keep their information safe, it is equally important to harden the infrastructure with wired connections so that bad actors are less able to tap into wireless information floating in the air. Hacking into wireless infrastructure has cost our state billions of dollars and cost residents irreparable damage to privacy with their information posted all over the internet without their permission.

Recommendation 3: “Goal 3: All Californians can access training and support to enable digital inclusion.” and all of its objectives should include education on the impacts of RF exposure on humans, especially children, pregnant women, the sick and the elderly and ways to mitigate these impacts.58

Environmental Health Trust has developed public health fact sheets and educational resources to communicate all the ways to reduce everyday wireless exposures.59 These educational resources are free and should be included in the California Digital Equity Plan as part of the education plans in Goals 3.

Also, broadening the definition of stakeholders to include a wider range of groups including public health and environmental health organizations such as Environmental Health Trust as well as community groups and organizations. More outreach needs to be done with the American public so they understand this issue and can participate in the process.

Recommendation 4: We recommend that wired networks be installed instead of wireless access points. In addition, wired computers and associated equipment, along with training should be provided to communities so they can learn how to use wired computers and technology.

The first objective of the Digital Equity Plan is “The availability of, and affordability of access to, fixed and wireless broadband technology.” We recommend against wireless broadband technology and instead recommend wired networks whenever possible. For example, in a library each desk can be equipped with an ethernet connection and adapters, same with schools.

If Wi-Fi or wireless systems are to be installed then proper RFR measurements should be taken and publicly posted on maps so the RF radiation measurements may be accessed by all individuals concerned with wireless radiation exposure, especially those with electromagnetic sensitivity. We also recommend that proper signage be posted on all locations with Wi-fi hotspots and other wireless transmitters, visible at least 9 feet away, so that individuals with electromagnetic sensitivities may be alerted prior to high exposure. Full transparency is needed regarding RF exposures.

Recommendation 5: Internet Service Providers must compete on safety and cybersecurity. With the Digital Equity Objective 1.4 to “increase the percentage of Californians who have a choice of at least three internet service providers.” it is critical that these services are being provided through a wired connection.

The worst case scenario is to have 3 or more cell towers in one community putting residents at risk of overexposure to radiofrequency radiation. See the Regulatory Gaps cited in Attachment 1 below showing that no agency is measuring exposure and ensuring the safety of ubiquitous and ever increasing wireless radiation. This puts residents who already face environmental and health inequities at increased risk.

ATTACHMENT 1: Today’s Regulatory Gap Regarding Radiofrequency Bioeffects ATTACHMENT 2: Radio-frequency Radiation Impacts on the Environment ATTACHMENT 3: Radio-frequency Radiation Impacts on Human Health ATTACHMENT 4: Legal and Liability Issues of Wireless


We are happy to meet with and provide the CDT and affiliates with more information and resources.

Sincerely,
Theodora Scarato
Executive Director Environmental Health Trust
Theodora.scarato@EHTrust.org

Rola Masri
Director of Government Outreach Environmental Health Trust
RolaMasri@EHTrust.org

ATTACHMENT 1: Today’s Regulatory Gap Regarding Radiofrequency Bioeffects

Although the public and elected officials assume that federal agencies are engaged in RF activities to ensure public health and environmental protection, this is inaccurate. FCC RF exposure limits are guidelines only, as they are not federally developed safety standards60 whereby agencies reviewed the totality of scientific evidence, performed risk analysis and identified a level of adverse effect to base an exposure limit on that would ensure adequate public protection. A review of federal agency involvement indicates minimal research and oversight activities along with serious regulatory gaps including but not limited to:

Issues related to the FCC’s 1996 limits.
● RF guidelines were designed for humans, not animals or plants, and only for effects of high intensity short term acute exposures. The limits were not designed to protect against effects of long term exposure.
● There is no periodic or ongoing transparent evaluation of current scientific research to ensure FCC limits are adequate (no hazard evaluation, quantitative risk assessment of the totality of science including impacts to brain development, reproduction or immune system) by any federal agency with health and safety expertise.

Issues related to transparency, monitoring, data gathering and oversight.
● There is no federal registry for all wireless facility sites, macro cell towers, and 5G/4G “ small cell” wireless facilities.
● There is no measuring, monitoring or mapping program for environmental RF levels.
● There is no post market surveillance program nor public/industry reporting system to gather data on health and environmental impacts.

Issues related to compliance
● There is no oversight and enforcement program in place to ensure RF emissions from network antennas and devices are compliant.
● Current industry-generated or commissioned pre-construction reports and post-construction testing are largely inadequate, if not inaccurate, in large part because the modeling protocols and programs have not been validated for real world accuracy.
● There are no up-to-date, minimum standards for preparing RF compliance reports, studies and evaluations nor quality control.
● As of June 2023, FCC has not issued updated guidance on how to comply with RF rules, which includes newly licensed frequencies and services, since 1997. The existing guidance, Evaluating Compliance with FCC Guidelines for Human Exposure to Radiofrequency Electromagnetic Fields (FCC OET 65 (1997),61 which provides assistance in determining whether proposed or existing transmitting facilities, operations or devices comply with limits for human exposure to radiofrequency (RF) adopted by the Federal Communications Commission (FCC) rules, is outdated. Independent inspectors, informed by up-to-date guidance, should be required to carry out on-the-ground measurements post antenna deployments to verify compliance with human exposure limits.
● Field compliance reports taking actual measurements can reach different conclusions depending on, for exam
4769January 24, 2024 at 10:03 pmR.D.ResidentPenn Valley959462. Introduction and Vision for Digital Equity
WIRED connection is superior to wireless in all respects, and wireless broadband—especially
the basic services offered to low-income families—will NOT solve the digital divide.

• Wireless is inferior "dirty" technology, unreliable and unable to SAFELY meet the demands of present and future digital communications. Provide funding for safer, reliable, energy-efficient WIRED internet, not wireless installations.
• Wireless is unreliable and unable to meet the demands of present and future digital communications. Providing funding for roll out of wireless installations will take it away from much safer, reliable, energy-efficient WIRED internet.

• Wireless will set the state back in terms of climate change management because wireless uses a huge amount of energy compared to WIRED broadband.

• Wireless facilities increase fire risk and cyber security risk

• Wireless facilities impact the growing percentage of the population with disabilities related to radiofrequency radiation (RFR) exposure.

• Wired infrastructure offers greater capacity, predictable performance, lower maintenance costs, and a longer technological lifetime than wireless technologies. Fiber service is not degraded by line-of-sight issues and is not affected by capacity issues.
4768January 24, 2024 at 10:00 pmJ.L.ResidentFairfax949302. Introduction and Vision for Digital Equity
I support FIBER and WIRED connectivity.

WIRED connection is superior to wireless in all respects, and wireless broadband—especially the basic services offered to low-income families—will NOT solve the digital divide.

I am someone with the ADA recognized disability of electrical sensitivity- in my case, being around wireless devices gives me headaches, tremors, and prevents me from sleeping. I have to make huge sacrifices in where I live and work to protect my health and sleep. Many people struggle with this sensitivity and health issue, which can be made worse by other health issues, such as auto immunity and mold, etc. You need to consider the impact on everyone, including those whose health is most fragile and at risk.

In addition, all of the following are reasons to focus away from more wireless as the solution and to choose fiber and wired connections :

Providing funding for rollout of wireless installations will take it away from much safer, reliable, energy-efficient WIRED internet.

• Wireless will set the state back in terms of climate change management because wireless uses a huge amount of energy compared to WIRED broadband.

• Wireless facilities increase fire risk and cyber security risk.

• Wireless facilities impact the growing percentage of the population with disabilities related to radiofrequency radiation (RFR) exposure.

• Wired infrastructure offers greater capacity, predictable performance, lower maintenance costs, and a longer technological lifetime than wireless technologies. Fiber service is not degraded by line-of-sight issues and is not affected by capacity issues.

• Wireless is unreliable and unable to meet the demands of present and future digital communications.
4767January 24, 2024 at 9:59 pmL.C.ResidentLos Angeles900661. Executive Summary
WIRED connection is superior to wireless in all respects, and wireless broadband—especially the basic services offered to low-income families—will NOT solve the digital divide.
4766January 24, 2024 at 9:28 pmT.F.ResidentGrass Valley959493. Current State of Broadband and Digital Inclusion
Fiber service is not degraded by line-of-sight issues and is not affected by capacity issues.

Wired infrastructure offers greater capacity, predictable performance and lower maintenance costs, than wireless technologies.
4765January 24, 2024 at 9:16 pmGovernment Affairs & Policy AssociateOrganizationTarana Wireless, Inc.MilpitasCA2. Introduction and Vision for Digital Equity
Tarana Wireless is pleased to have the opportunity to provide comments on the California Department of Technology’s California State Digital Equity Plan (SDEP). These crucial digital equity initiatives are imperative to ensure California realizes the maximum benefit of the unprecedented investment in broadband service from the Infrastructure Investment and Jobs Act, allowing all Californians to reap the impactful benefits of access to reliable high-speed broadband internet. This sentiment is further echoed by Governor Newsom’s signing of the Digital Equity Bill of Rights (AB 414, 2023), which establishes a framework of commitment, making it the policy of the State of California to ensure that broadband is sufficient, equitable, accessible, affordable, reliable, and ubiquitous for all Californians. The SDEP appropriately recognizes and harmonizes its aims and goals with California’s Broadband for All Action plan, a result of Governor Newsom’s Executive Order (N-73-20). Synergizing the once-in-a-generation BEAD effort with existing state programs can ensure that California is truly on the path to closing the digital divide for all California communities.

The SDEP clearly defines digital equity as ensuring that all Californians have access to the technology and digital skills necessary for full participation in modern society. A prerequisite for this is reliable high-speed broadband service. Goal 1 of the State Digital Equity Plan, stating “All Californians have high-performance broadband available at home, schools, libraries, and businesses” (SDEP, pg. 66), acknowledges that Digital Equity cannot be achieved until every Californian has access to broadband. This sentiment is further emphasized in the strategic objective to ensure the “availability of, and affordability of access to, fixed and wireless broadband technology” (SDEP, pg. 46). The $1.86 billion BEAD allocation presents a once-in-a-generation opportunity to ensure that all Californians have access to reliable broadband by 2028, laying the foundation for crucial digital equity initiatives.

With this in mind, we encourage the next draft of the SDEP to reflect the BEAD Initial Proposal, particularly Volume II, which outlines the CPUC’s strategy for utilizing California’s finite BEAD allocation. While the current draft of the SDEP references the Five-Year Action Plan prepared by the CPUC, Volume II contains troubling language that jeopardizes the crucial foundational goals of California’s Digital Equity plan.

While Volume II makes numerous references to the goal of universal service, aligning with Goal 1 of the SDEP, the language in Volume II related to subgrantee selection indicates that the CPUC will prioritize fiber over California families. Volume II troublingly states, “In the event that BEAD funds are insufficient to deliver fiber to all locations, the CPUC will prioritize projects to serve unserved and underserved locations located in high-poverty and persistent poverty counties, consistent with the BEAD NOFO, as well as projects to serve locations on Tribal lands” (Vol. II, pg. 40). Moreover, even with the best estimates from internal modeling, the CPUC admits that “Given the unpredictability of fiber construction costs during the BEAD timeline and considering the challenges to reach many extremely remote locations in some parts of California, the costs to deploy fiber to all unserved and underserved locations may exceed available BEAD resources” (Vol. II, pg. 26). Allocating funds to a specific technology to the detriment of unserved/underserved families would impede achieving the primary goal of ensuring all Californians have access to reliable broadband. As the Digital Equity Plan notes in Section 5, it is crucial to develop and promote alternative technology solutions - which meet and preferably exceed the state and federal goals for high speed (100/20 Mbps) and low latency (100ms or less) - as some communities cannot wait for broadband infrastructure to be built out (SDEP, pg. 113). Timely deployment of high-speed broadband is critical to ensuring the next generation of Californians is not hampered due to a lack of broadband access. The BEAD program, if executed prudently by employing all available technologies, can ensure all Californians are on the winning side of the digital divide.

While the SDEP recognizes the crucial role that fixed wireless broadband technologies can play in bridging the digital divide, Volume I of the CPUC’s Initial Proposal contains outdated information on the current state of the technology, while conflating "cellular/mobile wireless with legacy fixed wireless, while completely ignoring next generation Fixed Wireless Access (ngFWA) technologies which are proven in addressing all of the technology concerns of legacy fixed wireless (Please read the recent analysis/article by the highly respected analysts at Dgtl Infra from January 5th (link). Instead, the CPUC's Initial Proposal Volume 1 inaccurately writes “In fixed wireless networks, service performance can be affected by a customer’s proximity to a base station, the capacity of the cell site, the number of other users connected to the same cell site, the surrounding terrain, and radio frequency interference. Additionally, fixed wireless networks require a clear line-of-sight. Therefore, obstructions, such as trees, can block radio signals and impact the reliability of fixed wireless networks. Poor weather conditions, including rain, can affect the availability and quality of a customer’s fixed wireless service” (Vol. 1, pg. 9). This misunderstanding of fixed wireless technology as a whole serves as the basis for the CPUC to not fully consider the role that alternate technologies can and do play in providing reliable broadband service. This tenuous grasp of the landscape of fixed wireless technologies/services is deeply troubling and leads to poor policy/programmatic choices that negatively impact California's ability to achieve universal service. This apparent disconnect between the Initial Proposal and SDEP raises concerns that these parallel efforts may be disjointed.

Affordability is a key issue that the SDEP repeatedly raises as a barrier for under-resourced communities to access reliable broadband service. While the CPUC has provided scoring criteria designed to incentivize BEAD project applications to offer affordable broadband service plans (Vol. II, pg. 35), Tarana Wireless is concerned by the absence of a specified timeframe within the Affordability component of the Scoring Criteria for Priority Broadband Projects and Non-Priority Broadband Projects. This lack of clarity leaves the commitment to offer an economically affordable broadband plan open to potential abuse by providers. There is a risk that a provider might pledge to provide a low-cost broadband plan solely to secure a project bid, only to shift to market-rate pricing after project completion and subscriber sign-ups. This scenario could unfairly impact consumers, especially if the provider adjusts pricing to levels beyond the means of the homes and families in the area. This apparent gap in the BEAD program's strategy to deploy affordable broadband impinges on the affordability efforts contained within the SDEP. Reconciling this issue in the context of digital equity is of vital importance.


Keeping the SDEP grounded in the Initial Proposal drafted by the CPUC and submitted to the NTIA is an important step to ensure the critical foundational equity work that will be undertaken by the California Department of Technology reflects the BEAD effort. Without achieving universal service, California will not be able to undertake the plans described in the SDEP and cannot make the impact needed in the most vulnerable and under-resourced communities. The SDEP and BEAD Initial Proposal must complement each other to capitalize on this once-in-a-lifetime investment. Considering this year's projected $68 billion budget shortfall faced by California, future financing for similar broadband efforts cannot be guaranteed. What can be guaranteed, however, is that a BEAD Plan by the CPUC that aligns with the appropriate and clearly stated goal of the California Department of Technology’s California State Digital Equity Plan (SDEP), can ensure that every unserved and underserved family and location in California is equipped with affordable, reliable, high-speed, low latency broadband in a cost-effective and time-efficient manner.
4764January 24, 2024 at 8:50 pmExecutive DirectorOrganizationCalifornia For Safe TechnologyLos Altos HillsCA2. Introduction and Vision for Digital Equity
Dear Members of the California Department of Technology,

I am writing to express our organization's concerns and advocate for a prioritized focus on WIRED broadband infrastructure over wireless solutions, particularly in the context of addressing the digital divide and ensuring reliable and efficient internet access for all Californians.

The primary point I emphasize is WIRED connections' superiority over wireless options. While wireless broadband may seem like a viable solution, especially for low-income families, relying on wireless technology will not bridge the digital divide. WIRED connections offer numerous advantages over wireless, and allocating resources for wireless installations will divert attention from the safer, more reliable, and energy-efficient WIRED internet.

Here are some key points to consider:

1. Reliability and Performance: Wireless connections are inherently unreliable and struggle to meet the increasing demands of digital communications. Investing in wireless infrastructure may compromise the quality and reliability of the services provided to a community.

2. Energy Consumption: Wireless technology consumes a substantial amount of energy, contributing to environmental concerns and setting the state back in terms of climate change management. Prioritizing WIRED broadband can align with California's commitment to sustainable and energy-efficient solutions.

3. Safety Concerns: Wireless facilities pose fire risks and increase cybersecurity vulnerabilities. Prioritizing WIRED infrastructure can mitigate these risks, ensuring a safer and more secure digital environment.

4. Health Implications: The growing percentage of the population with disabilities related to radiofrequency radiation (RFR) exposure is a significant concern. The number of phone calls we receive from individuals concerned and suffering serious health issues due to exposure to wireless radiofrequency has grown exponentially in the last couple of years. Emphasizing WIRED connections can contribute to minimizing health-related risks associated with wireless technologies.

5. Capacity and Longevity: WIRED infrastructure, especially fiber service, offers greater capacity, predictable performance, lower maintenance costs, and a longer technological lifetime compared to wireless technologies. Line-of-sight issues do not hinder fiber service and remain unaffected by capacity challenges.
I urge the California Department of Technology to carefully consider the long-term implications and prioritize the implementation of WIRED broadband infrastructure to ensure equitable, reliable, and sustainable internet access for all residents of California.

Thank you for your attention to this matter.

Sincerely,
Cheryl Mathews
cmathews4@me.com
Executive Director
California For Safe Technology
https://www.ca4safetech.org/
4763January 24, 2024 at 8:46 pmA.F.ResidentGrass Valley959492. Introduction and Vision for Digital Equity
Wireless is unreliable and unable to meet the demands of present and future digital communications. Providing funding for rollout of wireless installations will take it away from much safer, reliable, energy-efficient WIRED internet.
Wireless facilities impact the growing percentage of the population with disabilities related to radiofrequency radiation (RFR) exposure.
4762January 24, 2024 at 8:42 pmCo-founder , PresidentOrganizationAnewVista Community ServicesRedwood CityCA5. Implementation Strategy & Key Activities
In this digital equity plan, a lot of information is focused on the organizational level. However, it lacks a section focused on individuals. There is some mention of delivering programs in the languages spoken by the constituents.

Our organization AnewVista Community Services https://www.anvcs.org a 501 © (3) has been serving older adults with Digital literacy programs for the last 4 years and has seen some remarkable need for the continuity of programs/events/classes and access to experts in an open and welcoming environment, in-person, online, and remote specialized for senior’s unique needs. Instilling a sense of curiosity, getting the seniors to want to pull the information rather than being forced into tech world works from our experience in serving more than 2000 seniors.


Compliance with online classes can be very high, especially for aging adults. It may require some help and training initially.

There is a need of state state-wide efforts to address an individual. It has to be all means (Website/Social Media/Print Media).
There has to be an easy and simple approach to services about Digital Literacy and Broadband Access programs.

Even on https://connectedca.org/ there is no way to find the services.

Access to broadband and internet adoption are social determinants of health, especially for aging adults/senior citizens. And it is not just by handing a device for free or giving low-cost broadband we achieve the digital equity. For one to adopt technology especially older adults need to have a safe space, a community, and easy access to tech support on a continuous basis.

For implementation, the first step is access and awareness of the programs:
Is there a simple, easy-to-use tool/website where an individual or a senior citizen can find services about digital literacy or low-cost broadband?
Is there a tool/website enabling collaborators where Digital Literacy providers can find the Organizations that can benefit from their programs and vice versa? Collaboration and partnerships are key for the impact we are seeking with the digital equity plan. Enabling collaboration in a structured way by the state plan is key.

ANVCS.org is a non-profit providing tech skills to seniors and their communities. Tech skills are developed through a competency journey through a combination of live classes, 1-on-1 office hours, and in-home tech support. ANVCS.org is headquartered in Silicon Valley, California with funding from donors; local, state, and national grants; along with community contracts for in-person services. For more information visit: https://ANVCS.org

1. Executive Summary
Comments on Goal 1
Goal 1 on increasing broadband is admirable but limiting usage to infrastructure of broadband is limiting due to infrastructure costs, assumptions of home living as well as linked to goal 2 of increasing the population of tablets and computers. The installation of broadband into a home includes the physical installation and installing a fiber or copper cable (DSL, Cable...) into the home as well as the installation of a modem/router which adds to recurring costs and creates the need for maintenance and support. Meanwhile, with the advent of 5G and future technology, home broadband can be installed without a physical installation, From a cost/complexity perspective and having more smartphones available for the consumer than desktops and tablets is it better to pursue wireless data connections to be more prevalent then pushing physical installations into the home of unknown status?
4761January 24, 2024 at 8:20 pmR.D.ResidentCASPAR954203. Current State of Broadband and Digital Inclusion
Landlines are essential in Mendocino County. Our county is wooded, rural, with few freeway miles and population centered in three primary locations. One primary traffic artery north-south, and most other roads only two lane, subject to environmental closure. Most of our population is low income & elderly people are the
main demographic. For most residents a landline is the only means of communication. Too many of the county population do not drive nor own functioning vehicles. Highway 1 is the only road between bridges in an earthquake/tsunami-prone area. We have had wildfires and winter weather always brings power failures for large sectors of the County, often for days at a time. Rainstorms often disable cell towers for days. Internet connectivity is often sketchy. Emergency notifications (official & otherwise) often do not reach those who have cell phones. Predictably, rapid climate change will increase & intensify fire & weather incidents.
Please maintain landlines as a priority for connections in our remote area.

Ray Duff
4760January 24, 2024 at 8:14 pmOwnerOrganizationIt Starts With ImageSan BernardinoCA1. Executive Summary
Our aim is to help close the digital divide. We are excited the “Vision” is becoming a reality
A California in which all residents have access to high-performance broadband, affordable service and devices, and the training and support necessary to enable digital inclusion for economic and other social benefits.
We have still aways to go! Together we can close the digit divide.
4759January 24, 2024 at 7:30 pmFounderOrganizationOur Voice: Communities for Quality EducationResedaCA1. Executive Summary
Our Voice: Communities for Quality Education, an L.A.-area nonprofit organization that helps Latino and Indigenous immigrant families access and use 21st Century technologies to advocate for a high-quality public education, values the opportunity to provide feedback regarding California's draft State of Digital Equity Plan.

Executive Summary
California's plan to address systemic issues that impact low adoption, while laudable, must focus BEAD funding and support on Goals 1 (high-performance broadband), and 2 (affordable broadband). Each Friday, Our Voice hosts presenters on Zoom and Facebook Live, who bring essential information to Latino and Indigenous immigrant low-income families throughout L.A. County. For the last three years, we've seen families become increasingly frustrated by faulty, unreliable, internet that bumps them out of meetings prompting them to constantly sign back in. Each time this happens, families miss key points about mental health, tenants, rights, education, health, and much more. It also affects those of us who work to help families access critical resources. Our families express great frustration at the high-cost of internet, which they cannot afford, and poor service connections.

Most of Our Voice's members are low-resource families for whom internet services are unaffordable and unreliable. For this reason, we believe that achieving objective 1.4, "increase the percentage of Californians who have a choice of at least three internet service providers," is critical in order to reach objectives 2.1 (decrease cost as a barrier) and 2.4 (reduce average cost for covered populations). We believe that market competition between providers is key if the state is to reach its cited goals and objectives. It is also time to have a public option for families in California.

Lastly, we ask the state to adopt tools to track data that reflect the true needs of the people of California. Too many communities have been left out of maps made available by private internet service providers.
4758January 24, 2024 at 7:26 pmCity Council MemberOrganizationCity of AvalonAvalonCA3. Current State of Broadband and Digital Inclusion
Please consider including cities like ours (Avalon) which by every definition are rural yet do not fall under a rural county (LA). Please consider citing what price range is considered “affordable” based on verified speeds not self-reported speeds. Please consider increasing the ACP income threshold based on the information you’ve included. Please consider the ultimate goal of end to end coverage. It is quite challenging to be paying some of the highest rates for broadband in LA County (highest in the Gateway Cities COG) yet to have unreliable service that is subject to microwave interruptions, blips or dips in service, weather related interruptions (wind, moisture, high heat, extreme cold, high seas) and physical geographic challenges (canyon walls, reflective ocean waves) all of which impact speeds to be less than promised/paid for. A full and broad solution is needed just for us to catch up to the rest of California.
4757January 24, 2024 at 7:04 pmH.D.ResidentGrass Valley959452. Introduction and Vision for Digital Equity
WIRED connection is superior to wireless in all respects, and wireless broadband—especially the basic services offered to low-income families—will NOT solve the digital divide.

• Wireless is unreliable and unable to meet the demands of present and future digital communications. Providing funding for the rollout of wireless installations will take it away from much safer, reliable, energy-efficient WIRED internet.

• Wireless will set the state back in terms of climate change management because wireless uses a huge amount of energy compared to WIRED broadband.

• Wireless facilities increase fire risk and cyber security risk

• Wireless facilities impact the growing percentage of the population with disabilities related to radiofrequency radiation (RFR) exposure.

• Wired infrastructure offers greater capacity, predictable performance, lower maintenance costs, and a longer technological lifetime than wireless technologies. Fiber service is not degraded by line-of-sight issues and is not affected by capacity issues.
4756January 24, 2024 at 7:03 pmE.F.ResidentLittle River954563. Current State of Broadband and Digital Inclusion
The cellular connectivity where I live is sporadic.. sometimes it is ok and sometimes it does not function.
I have a landline phone using AT&T as my provider in order to have reliable phone service , particularly in a personal emergency, in a disaster situation and in times when the PG&E lines do not function which results in no electricity.
In the latter case, , my cell phone loses its charge and so cannot function.
I need AT&T to maintain service on their underground lines to insure that my need for phone service is met at the above times especially when my life depends on it.
I also want to speak for people here on the Mendocino Coast who cannot speak for themselves and need this AT&T service in normal times and when their lives depend upon it for their survival. Please require AT&T to service their underground lines so that people like me where cellular connectivity is sporadic and unreliable have phone service, especially in an emergency. I hope you will do this.
And I wonder if you will be sued if you do not require AT&T to maintain their underground lines and as a result there is
loss of life or serious injury because you did not require this necessary maintenance.
4755January 24, 2024 at 6:57 pmJ.V.ResidentFort Bragg954371. Executive Summary
Wired broad band would be immensilly preferable to the satellite wifi I have now. The EMF radiation in my neighborhood effects my body & mind.
4754January 24, 2024 at 6:42 pmG.K.ResidentSanta Maria934551. Executive Summary
This is a well thought out and organized plan. I encourage the implementation to start as soon as practical. I too would like higher internet speeds and lower provider costs. There seems to be a lack of competition in my area. I look forward to having the goals met.
4753January 24, 2024 at 6:20 pmC.F.ResidentRough and Ready959751. Executive Summary
My physician wants me to have a wired connection. My expensive wireless connections are not reliable, leaving me without a phone.

For me, wired connection is superior to wireless in all respects:

We already paid for it on our phone bills. We want WIRED LAND LINES. Why are the wireless companies forcing digital on us. They have done not ONE study on the health of these digital wireless.

Fiber service is not affected by problematic line-of-sight and/or capacity issues.

Wired infrastructure offers greater capacity, predictable performance, lower maintenance costs, and a longer technological lifetime than wireless technologies.

Wireless facilities increase fire and cyber security risks, and impact the growing percentage of the population with disabilities related to radiofrequency radiation (RFR) exposure.

Energy consumptive, EXPENSIVE wireless is unreliable and unable to meet the demands of current digital communications.

Rollout of wireless installations will divert needed funding from much safer, reliable, energy-efficient WIRED internet.

I paid AT&T for Wired service. They never gave it to me (as confirmed by local At&T lineman.) Yet they charged me $500 and tried to wreck my credit for not paying them. (I had Verizon the whole time/) The At&T lineman came and checked my house, and advised me to take it to the CPUC, where finally it was resolved in the office of the president of AT&T. Don't let this company rip us off.

I want a landline. NOW. Or give me back all the phone tax money you have charged me all these years.

I am hyper sensitive to 5G. I do not want 5. I want a real landline.
4752January 24, 2024 at 6:15 pmN.C.ResidentBurbank915052. Introduction and Vision for Digital Equity
WIRED connection is superior to wireless in all respects, and wireless broadband—especially the basic services offered to low-income families—will NOT solve the digital divide.
4751January 24, 2024 at 6:05 pmL.B.ResidentSherman Oaks914032. Introduction and Vision for Digital Equity
WIRED connection is superior to wireless in all respects, and wireless broadband—especially the basic services offered to low-income families—will NOT solve the digital divide.

• Wireless is unreliable and unable to meet the demands of present and future digital communications. Providing funding for rollout of wireless installations will take it away from much safer, reliable, energy-efficient WIRED internet.

• Wireless will set the state back in terms of climate change management because wireless uses a huge amount of energy compared to WIRED broadband.

• Wireless facilities increase fire risk and cyber security risk

• Wireless facilities impact the growing percentage of the population with disabilities related to radiofrequency radiation (RFR) exposure.
4750January 24, 2024 at 6:03 pmR.P.Resident959592. Introduction and Vision for Digital Equity
WIRED connection is superior to wireless in all respects, and wireless broadband—especially the basic services offered to low-income families—will NOT solve the digital divide.



Additional points:

• Wireless is unreliable and unable to meet the demands of present and future digital communications. Providing funding for rollout of wireless installations will take it away from much safer, reliable, energy-efficient WIRED internet.


• Wireless will set the state back in terms of climate change management because wireless uses a huge amount of energy compared to WIRED broadband.

• Wireless facilities increase fire risk and cyber security risk

• Wireless facilities impact the growing percentage of the population with disabilities related to radiofrequency radiation (RFR) exposure.

• Wired infrastructure offers greater capacity, predictable performance, lower maintenance costs, and a longer technological lifetime than wireless technologies. Fiber service is not degraded by line-of-sight issues and is not affected by capacity issues.
4749January 24, 2024 at 6:02 pmV.R.ResidentLos Angeles900642. Introduction and Vision for Digital Equity
Please consider the following information.
WIRED connection is superior to wireless in all respects, and wireless broadband—especially the basic services offered to low-income families—will NOT solve the digital divide.

• Wireless is unreliable and unable to meet the demands of present and future digital communications. Providing funding for rollout of wireless installations will take it away from much safer, reliable, energy-efficient WIRED internet.

• Wireless will set the state back in terms of climate change management because wireless uses a huge amount of energy compared to WIRED broadband.

• Wireless facilities increase fire risk and cyber security risk

• Wireless facilities impact the growing percentage of the population with disabilities related to radiofrequency radiation (RFR) exposure.

• Wired infrastructure offers greater capacity, predictable performance, lower maintenance costs, and a longer technological lifetime than wireless technologies. Fiber service is not degraded by line-of-sight issues and is not affected by capacity issues.
4748January 24, 2024 at 5:37 pmS.P.Resident954608. Not Related to Above Sections
Please don’t end land lines. I need my land line as cell phone reception is very poor in my area.
I need this phone to connect with the Mendocino Volunteer Fire Department, and the 911 emergency department. My land line is a life saving device, and is extremely necessary for me.
4747January 24, 2024 at 5:35 pmL.H.ResidentMendocino954602. Introduction and Vision for Digital Equity
Landlines are the cornerstone of connectivity in Mendocino County. This county is a huge land mass with population concentrated around a few centers connected by a few marginally maintained roads vulnerable to weather, fire, & seismic events. Low income & elderly people are the main demographic in my remote rural stretch at the edge of the Pacific Ocean. For many, landlines are their only means of communication. Many do not drive nor own functioning vehicles. Highway 1 is the only road between bridges in an earthquake/tsunami-prone area. Wildfires & intense storms often disable cell towers for days. Internet connectivity is often sketchy. Emergency notifications (official & otherwise) often do not reach those who have cell phones. Predictably, rapid climate change will increase & intensify fire & weather incidents.
I urge that maintaining landlines be top priority in maintaining connections to & throughout remote areas.
4746January 24, 2024 at 5:28 pmPlanning SupervisorOrganizationSouthern California Association of Governments (SCAG)Counties of Imperial, Los Angeles, Orange, Riverside, San Bernardino, and VenturaCA5. Implementation Strategy & Key Activities
Key Activities & Digital Equity Programming Activities for Funding Eligibility
A key aspect of the Southern California Association of Government’s (SCAG) strategy to overcome the digital divide has been the promotion of subsidy programs like the Affordable Connectivity Program (ACP). This program has played a significant role in the SCAG region by providing subsidized Internet to those on Federal assistance. With over 1.6 million households enrolled, the success of the ACP is evident. However, with the expected depletion of ACP funds by spring 2024, we emphasize the need for a successor program to continue supporting these households and to extend affordable Internet access to more residents.

Stakeholder Collaboration, Communications, & Outreach
SCAG recognizes, as does the State Digital Equity Plan (SDEP), the pivotal role of Local leaders and community-based organizations (CBOs) in promoting digital inclusion. These groups are intimately connected with their communities and are trusted sources of information and guidance. It is essential that solutions are driven at both regional and Local levels by these key stakeholders.

Goal 3: All Californians can access training and support to enable digital inclusion
SCAG endorses the SDEP’s objectives, particularly in areas of training for digital inclusion (as outlined in Goal 3). With the increasing number of households gaining Internet access, expanding digital literacy, cybersecurity, and skills training programs is crucial. These initiatives are vital in equipping residents to navigate and thrive in an increasingly digital world.
4745January 24, 2024 at 5:26 pmChief Executive OfficerOrganizationSoutheast Community Development Corporation (SCDC)Bell GardensCA5. Implementation Strategy & Key Activities
Overview
SCDC serves the following communities in Southeast Los Angeles County (e.g., City of Bell, City of Bell Gardens, City of Maywood, City of Cudahy, City of South Gate, City of Huntington Park, City of Vernon, City of Lynwood, unincorporated Walnut Park, unincorporated Florence-Firestone, zip codes: 90201, 90280, 90255, 90001, 90002, 90051, 90270, 90058, 90270, 90058).

Key Activities & Digital Equity Programming Activities for Funding Eligibility
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 (e.g., robotics, coding, computer-aided drafting), and store large have access to computers with the capacity to engage in these tasks that lead to future STEM careers.

Grant Program Development, Implementation, Management, & Evaluation
Startup funds should cover the cost of needed equipment to begin the grant work and at least 50% of the cost of staffing. For example, startup funds for a computer lab and digital literacy should include the cost of the computer lab equipment, marketing materials, and at least 50% of the cost of staffing. By doing this, small non-profits that serve communities in need will be able to participate in grant funding opportunities.

Covered Populations
Include micro businesses when planning digital literacy, broadband adoption, and access to high-speed Internet.

Stakeholder Collaboration, Communications, & Outreach
For the purpose of marketing and outreach efforts, partner with schools, cities, counties, community-based organizations (CBOs), influencers, etc. to use their social media, quarterly publications, place banners in high-traffic corridors, and table at large community events.

Goal 3: All Californians can access training and support to enable digital inclusion
To meet the 3 goals, we will need to leverage resources. College students who are paid to work as fellows through the College Corp may be placed with non-profits or CBOs to teach digital literacy training to parents and seniors. Cities and the County of Los Angeles at times have unused or underused space that at times CBOs may request to use to provide digital literacy classes or services. Please create a list to let us know where these locations exist. Digital literacy is a need for senior citizens and youth (e.g., 2nd grade to 24-years). Pay for fees to get folks certified in technology skills.
4744January 24, 2024 at 5:24 pmManager of Natural Resources & SustainabilityOrganizationSan Gabriel Valley Council of Governments (SGVCOG)MonroviaCA5. Implementation Strategy & Key Activities
Key Activities & Digital Equity Programming Activities for Funding Eligibility
Does broadband adoption in current anticipated activities for adoption include actual broadband infrastructure deployment? If not, can it include it? Infrastructure deployment can be expensive, and if that’s mentioned, that could add flexibility to how program funds are used. How can the State merge existing capacity-building programs such as the CivicSpark or Climate Action Corps programs with the proposed California Connect Corps? Broadband accessibility and digital equity also become a climate and resiliency issue for some communities, especially those that are unserved or underserved working on housing and homelessness, wildfires, natural disasters, etc. How might the State work with Local, regional, and metropolitan agencies in coordinating and deploying Last Mile programs to not only connect to the Middle-Mile Broadband Initiative (MMBI) but also to encourage broadband deployment equitably and cost-effectively? How might the statewide asset inventory be a common resource that also includes unhoused populations?

Grant Program Development, Implementation, Management, & Evaluation
What does flexibility look like for agencies that want to have a joint partnership/collaboration? Does this act put them more at an advantage in receiving funding? What reference point will the State keep in mind in terms of an equity lens for implementation and strategies? How will the State accommodate populations that live in rural areas or are experiencing homelessness?

Covered Populations
Why are these subpopulations not included (e.g., business owners, justice-impacted families, refugees, students, undocumented individuals, unhoused individuals, and youth)? How can we include these marginalized and hard-to-reach groups to further their access to the Internet equitably and inclusively?

Closing Gaps, Additional Funding, & Sustainability
Sustainable funding sources are important. Perhaps there can be a Revolving Loan Fund (RLF) to help finance big capital projects related to broadband expansion and infrastructure like other utility projects for energy and water.

Stakeholder Collaboration, Communications, & Outreach
Can another priority outcome area include public safety such as (e.g., cases during natural disasters/emergency events like wildfires)?
4743January 24, 2024 at 5:23 pmDirector - Emerging Technologies & Collections DivisionOrganizationLos Angeles Public Library (LAPL)Los AngelesCA5. Implementation Strategy & Key Activities
Key Activities & Digital Equity Programming Activities for Funding Eligibility
Immediate Hotspot Access: Los Angeles Public Library’s (LAPL) Tech2Go Program faced a significant challenge when Federal funding for these hotspots expired, leading to the cutoff of over 7,000 hotspots. Given their importance in providing immediate access to vital services, LAPL proposes that funding eligibility criteria consider supporting initiatives like the Tech2Go Program to ensure immediate hotspot access for our communities. Digital Asset Mapping: In collaboration with the City of Los Angeles, a Digital Asset Map is being developed to assist Angelenos in locating the nearest physical access points to Wi-Fi and hotspots. This tool will significantly aid residents in finding essential connectivity resources. LAPL recommends that efforts related to digital mapping and asset location be included in the funding eligibility criteria to strengthen the digital inclusion infrastructure.

Grant Program Development, Implementation, Management, & Evaluation
Language Access: In a State with over 200 languages spoken, providing documents in various preferred languages is vital.

Covered Populations
Key Area to Address: Individuals with a language barrier (including individuals who are English learners and have low levels of literacy).
Response: In promoting digital equity, special attention should be given to individuals with language barriers and low literacy levels. To address this, we advocate for the inclusion of multilingual and culturally relevant training programs. These efforts align with LAPL's commitment to digital literacy and the Cybernauts Program's success in bridging the digital divide among diverse populations.

Closing Gaps, Additional Funding, & Sustainability
Key Area to Address Greater funding sources and sustainability (e.g., Federal, State, regional, Local, philanthropy, and private).
Response: Achieving sustainability in digital equity initiatives requires a diversified funding approach, including State, Local, and private sector partnerships. We recommend exploring opportunities for cross-sector collaboration and funding.
Additionally, we stress the need for streamlined communication strategies to inform Local governments and stakeholders of the rapidly changing infrastructure landscape and its benefits to Angeleno households.

Stakeholder Collaboration, Communications, & Outreach
Key Area to Address: Greater community awareness.
Response: To enhance community awareness, effective communication strategies should be in place. Local governments must work collaboratively to ensure that residents are well-informed about the evolving digital infrastructure landscape. This includes rapid communication of changes and their potential impact on households.

Goal 1: All Californians have high-performance broadband available at home, schools, libraries, and businesses
Key Area to Address: Easier funding or grant allocation process to support the cost of high-speed Internet for anchor institutions.
Response: The LAPL, one of the largest library systems in the United States, is currently providing 100 gigabytes (GB) of high-speed Internet access at all our libraries. However, the cost is very high, and relying on the annual Schools and Libraries Program (E-Rate) application process to acquire funding discounts is extremely complicated and challenging. It requires hiring external E-rate consultants and the amount of administrative work on library staff involved is tremendous. Not to even mention the technical side of supporting this high-speed network. There should be an easier process to acquire these fundings, rather than putting extra burden on the administrative side of workload.
4742January 24, 2024 at 5:21 pmAssistant Director, Technology Innovation & OutreachOrganizationLos Angeles County Office of Education (LACOE)DowneyCA5. Implementation Strategy & Key Activities
Covered Populations
The State Digital Equity Plan (SDEP) is moving California towards broadband access for all, however, there are a few concerns. The first of which is the covered population. We would like to see that all TK-12 students are also covered under the SDEP. Many students are denied broadband access that is beyond their control such as not having a social security number.

Goal 1: All Californians have high-performance broadband available at home, schools, libraries, and businesses
Further, we believe that it is also important to provide access to individuals who may not have the traditional means of broadband access and provide this access using a hotspot or other access to reliable Internet. Additionally, the formula for covered individuals living at or below the Federal Poverty Income Level needs to be adjusted for the cost of living in the State of California.

Goal 3: All Californians can access training and support to enable digital inclusion
In addition, the emphasis on digital literacy and education cannot be understated. Providing individuals broadband access is one thing, however, understanding how to navigate the Internet, utilizing web-based platforms, and understanding how to safely protect oneself when traversing the Internet is another. It is important to establish partnerships with educational institutions and organizations to provide adequate training and resources for individuals who obtain broadband access.
4741January 24, 2024 at 5:19 pmR.J.ResidentVentura930032. Introduction and Vision for Digital Equity
WIRED Connection is superior to wireless in all respects, and wireless broadband - especially the basic
services offered to low-income families - will NOT solve the digital divide.
4739January 24, 2024 at 5:18 pmResident Services Manager, Strategic InitiativesOrganizationHousing Authority of the City of Los Angeles (HACLA)Los AngelesCA5. Implementation Strategy & Key Activities
Key Activities & Digital Equity Programming Activities for Funding Eligibility
Increase the number of Internet Service Providers (ISPs) servicing low-income, urban communities, particularly surrounding affordable and public housing developments, to stimulate an increase of affordable Internet service options for residents, small businesses, and non-profits. Advocate for the extension of the Affordable Connectivity Program (ACP) beyond April 2024 or alternative sources of public subsidies for low-income and public housing residents.

Grant Program Development, Implementation, Management, & Evaluation
Resources for STEAM programming at affordable and public housing computer labs and open spaces. Cross-sector engagement between affordable and public housing developments and philanthropic parties to ensure housing entities are aware of prospective funding trends related to digital equity.

Covered Populations
Specific support for individuals requiring mental health support.Tailored strategies for families experiencing trauma (e.g., domestic violence, human trafficking, gangs). Support for foster care youth.

Closing Gaps, Additional Funding, & Sustainability
Long-term funding for continuity of programming, funding insecurity, retention of participants and staff, collaboration, investment, and increased impact.

Stakeholder Collaboration, Communications, & Outreach
Affordable and public housing (e.g., application for housing, Section 8, asset management sites) to be included in cross and multi-sector collaboration.

Goal 1: All Californians have high-performance broadband available at home, schools, libraries, and businesses
Increase the percentage of Californians who are connected to reliable broadband Internet service and equipment at affordable and public housing developments for educational, health, employment, and skill development.

Goal 2: All Californians have access to affordable broadband and necessary devices
Access to subsidies for equipment: smartphones, home computers, tablets, and printers.

Goal 3: All Californians can access training and support to enable digital inclusion
Reduce the percentage of youth who are experiencing online and/or social media bullying via training, communication, or online campaigns for parents and youth.
4738January 24, 2024 at 5:16 pmLegislative Affairs SpecialistOrganizationCommunity Clinic Association of Los Angeles County (CCALAC)Los AngelesCA5. Implementation Strategy & Key Activities
Covered Populations
The Community Clinic Association of Los Angeles County (CCALAC) would like to highlight the covered population of youth and older adults. Our key consideration is that community-based organizations (CBOs) serve communities and patients encompassing all demographic characteristics already listed.

Closing Gaps, Additional Funding, & Sustainability
The primary challenges health center patients face in adopting video telehealth (as reported by health centers in May 2020) include access to technology; ease of use of the technology; Internet bandwidth; and language/literacy barriers. Awareness of the availability of telehealth and privacy concerns were ranked much lower. CCALAC member health centers would likely engage in future opportunities to receive technical assistance training centered on enhancing digital literacy among their staff and the communities they serve.

Stakeholder Collaboration, Communications, & Outreach
CCALAC’s Health Information Technology division supported a Telehealth Assistance Program to support members with implementing telehealth in 2020, and in 2022 developed and provided member health centers with a digital divide toolkit to help health center staff in assessing patients’ needs and direct them to programs and resources.Improving digital literacy awareness among both health center patients and staff is a priority for our members.

Goal 3: All Californians can access training and support to enable digital inclusion
Training and support opportunities to enhance cyber security awareness and digital literacy would benefit health centers. CCALAC would disseminate information, resources, and training opportunities centered on digital equity to our members to assist in meeting the needs of health center patients and staff regarding accessing broadband and devices and utilizing adapting technologies.
4737January 24, 2024 at 5:13 pmCity EngineerOrganizationCity of RosemeadRosemeadCA5. Implementation Strategy & Key Activities
Key Activities & Digital Equity Programming Activities for Funding Eligibility
Will there be technical assistance in the establishment of the digital equity programs, funding eligibility, and a funding application? For a small city with limited staff, human resources would be a major challenge in taking on this great endeavor.

Grant Program Development, Implementation, Management, & Evaluation
Will there be technical assistance in the establishment of the digital equity programs, funding eligibility, and a funding application? For a small city with limited staff, human resources would be a major challenge in taking on this program.

Covered Populations
On inclusion, the City of Rosemead (City) has significant non or limited English speakers. In addition, a lot of this population are seniors. Some of them may not have ready transportation to travel to training centers. Would there be training in multiple languages and transportation support?

Closing Gaps, Additional Funding, & Sustainability
The program needs a long-term plan and funding to support infrastructure and training. As well as administrative support to manage the program.
4736January 24, 2024 at 5:11 pmGeneral Manager/Principal AnalystOrganizationCity of Pico RiveraPico RiveraCA1. Executive Summary
Key Activities & Digital Equity Programming Activities for Funding Eligibility
The quality of Internet or broadband needs to be defined to contain specific speeds megabits per second (Mbps) and reliability. Support the California Connect Corps (CCC) to conduct Local outreach. “High performance” needs to be defined by clearly quantifying speeds Mbps and reliability (p. 119 – Goal 1). Continue to promote low-cost offers and the Affordable Connectivity Program (ACP) or a sustainable solution ensuring accessible and affordable Internet service. Fund educational workshops and outreach that entail testing Internet speed, reporting poor Internet quality, and steps to resolve Internet quality issues.

Closing Gaps, Additional Funding, & Sustainability
Local governments have limited resources, and broadband has traditionally been a State and Federal government affair. Local governments need dedicated funding or State resources to implement efforts related to the State Digital Equity Plan (SDEP).

Stakeholder Collaboration, Communications, & Outreach
Establish working groups like the Council of Governments (COGs) to collaboratively implement broadband equity programs. Assign a representative to work directly with Local governments to inform, update, and support broadband equity initiatives and programs.

Goal 1: All Californians have high-performance broadband available at home, schools, libraries, and businesses
Objectives 1.3 and 1.4 are high priorities for the Pico Rivera community. While approximately 88-90% of households have a broadband Internet subscription, the significant concerns are having access to competitive rates, reliability, and speeds.

Goal 2: All Californians have access to affordable broadband and necessary devices
Costs should be consistent and fair. Two independent studies, including those from the University of California Santa Barbara (UCSB), have demonstrated that Internet Service Providers (ISPs) charge higher rates to low-income areas for lower-quality service than in affluent areas.
4735January 24, 2024 at 5:09 pmInnovation & Environmental ManagerOrganizationCity of PalmdalePalmdaleCA5. Implementation Strategy & Key Activities
Key Activities & Digital Equity Programming Activities for Funding Eligibility
Promote the use of inclusive apprenticeships throughout network development. Local governments and community-based organizations (CBOs) can support the development of apprenticeship pipelines. In addition, partners can ensure that participants have wrap-around services and/or pre-apprenticeship training to support their success.Evolve broadband and digital equity data and maps. As mapping tools are refined, it would be beneficial for there to be data summaries and visualization tools for political boundaries, e.g., city borders. This would help Local governments to analyze access and adoption in their jurisdictions. Current maps focus mostly on Census blocks or tracts and make it difficult for a community to accurately assess the data for Internet access, device access, and digital literacy competency. Ensure new broadband infrastructure is resilient to wildfires and disasters. Create a best practice guide for communities that are implementing their own infrastructure on how to make broadband and other connectivity services resilient. Convene digital equity stakeholders to strengthen collaboration. Consider organizing regional conferences or workshops annually to strengthen regional collaboration (and/or work with regional entities that may be planning these types of efforts with funding and programming support).

Grant Program Development, Implementation, Management, & Evaluation
To increase equitable access to grant funding, the State should look into consideration of a pre-application technical assistance program. This could provide free application support for Local governments or other disadvantaged organizations who may not have the resources, experience, or capacity to complete a competitive grant application. We suggest that the State utilizes standard data and mapping tools for the application process to ensure that applications are judged equitably. Ensure that grants are open for enough time for partnerships to be developed and programs to be designed. Ideally, grant opportunities would be open for at least 3 months but not less than 2 months.

Covered Populations
Undocumented individuals should be included in the covered populations. Undocumented individuals face unique challenges related to the digital divide, such as fear or distrust that prevents people from accessing Internet assistance and digital equity programs.

Stakeholder Collaboration, Communications, & Outreach
We suggest that the State creates a media toolkit for promoting programs to the press and a communications guide to help quickly and effectively develop public engagement materials, including presentation decks, social media graphics, and printable flyers that cities can utilize.

Goal 2: All Californians have access to affordable broadband and necessary devices
In addition to a lack of awareness, low-income households experience other barriers to accessing low-income Internet programs. Other factors such as poor credit history and previous past-due bills with the company can restrict eligibility. Furthermore, low-cost Internet plans may be time-limited, which may cause unforeseen rate increases.

Goal 3: All Californians can access training and support to enable digital inclusion
There should be a bullet point that emphasizes Increasing the availability of digital literacy programs that are offered in multiple languages.
4734January 24, 2024 at 5:07 pmBuilding & Planning DirectorOrganizationCity of MaywoodMaywoodCA5. Implementation Strategy & Key Activities
Key Activities & Digital Equity Programming Activities for Funding Eligibility
Our City’s biggest focus and input is improving broadband access and providing technology education to our low-income, predominantly Hispanic community. We believe it is crucial for bridging the digital divide and promoting equal opportunities. Here are a few key strategies that may help with the broadband endeavor. Advocate for improved broadband infrastructure in our communities. Collaborate with Local government agencies and Internet Service Providers (ISPs) to expand and enhance broadband connectivity.

Grant Program Development, Implementation, Management, & Evaluation
Develop educational materials and resources in both English and Spanish to cater to the linguistic diversity of our communities. Remember that community involvement and tailoring initiatives to the specific needs of the population are essential for the success of such programs. Additionally, seeking support from Local authorities, businesses, and non-profit organizations can help sustain and expand these efforts.

Goal 3: All Californians can access training and support to enable digital inclusion
Organize digital literacy workshops and training sessions for residents to enhance their computer and Internet skills. Partner with Local schools, libraries, and community organizations to host these programs.
4733January 24, 2024 at 5:05 pmAssistant Executive DirectorOrganizationCity of Los Angeles | Department on DisabilityLos AngelesCA5. Implementation Strategy & Key Activities
Covered Populations
Barriers reported by people with disabilities including inadequate accessible hardware and software, lack of availability of training on using hardware and software, and lack of accessibility of online services, are all consistent with the City of Los Angeles Department on Disability’s (DOD) understanding of barriers experienced by City of Los Angeles constituents. For aging individuals (60+), DOD has observed that many people who fall into this category would benefit from assistive technology but are unaware of it and do not consider themselves as having a disability, so they are not necessarily seeking disability-related resources to help them access the Internet. A campaign to make this covered population aware of assistive technology (which is often built into software) and how to use it, would likely be beneficial. "Advance universal design to ensure accessibility and assistive technology for everyone": consider adding a reference to meeting digital accessibility requirements (a reference to the Web Content Accessibility Guidelines, or other regulatory standards) to make clear that there are minimum compliance requirements. Reference to Universal Design as a mechanism to ensure accessibility is good, but not enough to ensure access for people with disabilities."Develop all informational materials and awareness media in-language and in-culture": ensure that "in-culture" includes disability culture. Ensure digital navigators, non-profits funded through the California Connect Corps grant, State agencies delivering State-managed digital inclusion programs, and other similar entities are trained on digital accessibility principles, concepts, and requirements, as well as how to effectively work with people with various types of disabilities.
Ensure all digital inclusion tools and best practices are accessible to and inclusive of people with disabilities.

Stakeholder Collaboration, Communications, & Outreach
Consider engaging the California Foundation for Independent Living Centers (CFILC) as a statewide partner. Recommend engaging additional service providers who work directly with the disability community to serve as trusted/credible messengers, digital navigators, and other roles to support the implementation of the State Digital Equity Plan (SDEP).

Goal 3: All Californians can access training and support to enable digital inclusion
Recommend updating this priority outcome area to include specific assurances that digital literacy and skills training and technical support are accessible to and usable by people with disabilities. If using community-based instructors, these instructors will need training and tools to ensure people with disabilities, including those who use assistive technology, have equitable access to the services they provide. Consider developing an accessible curriculum for use by community-based instructors that meet disability access requirements and consider specifically recruiting community-based instructors with disabilities who are familiar with digital accessibility and assistive technology.
4732January 24, 2024 at 5:04 pmDeputy Director for Strategic Partnerships & PlanningOrganizationCity of Los Angeles | Department of AgingLos AngelesCA5. Implementation Strategy & Key Activities
Key Activities & Digital Equity Programming Activities for Funding Eligibility
Provide funding to allow expansion of digital public access for older adults, especially at aging network sites. Digital devices and digital literacy/training should be an allowable activity funded by the grant.

Grant Program Development, Implementation, Management, & Evaluation
Application for the grant should be limited to one City department, that will serve as the grant manager and allocate funding to allied/partner departments to deliver activities and goals of the State Digital Equity Plan (SDEP).

Covered Populations
Populations covered under the SDEP include most of the populations covered by the City of Los Angeles Department of Aging (LADOA) programs and services, which are individuals 60+ with emphasis on targeting those whose income is at or below 150% of the Federal Poverty Level, members of a racial or ethnic minority group, or those that have low English proficiency. Family caregivers who are providing care to those with disabilities should also be considered as part of the covered population since they may need digital access to support those charged under their care.

Closing Gaps, Additional Funding, & Sustainability
Ensure there is adequate funding to support ongoing equity inclusion engagement, outreach, and digital literacy beyond the initial launch of the program.

Stakeholder Collaboration, Communications, & Outreach
Since the issue being addressed is digital equity, using exclusively digital media will not be an effective tool for communicating progress or updates to stakeholders. This constituency will be more comfortable with a combination of printed, in-person, and digital media. Therefore, the best way to disseminate information or maintain communication is to partner with community-based organizations (CBOs) with an existing relationship with the stakeholders. Through our experience, this has been the most effective way of communicating with those who are experiencing a digital divide.

Goal 1: All Californians have high-performance broadband available at home, schools, libraries, and businesses
Having a choice of Internet Service Providers (ISPs) would be great for consumers as it gives them a choice of which service provider to sign up with and it also promotes vendors to improve or maintain their service level (e.g., reliability, high performance, etc.). to stay competitive with other providers. Additionally, if broadband can be made available at various points of interest throughout the City, this will allow the older adult population to get out of their homes, promoting exercise and avoiding isolation and institutionalization.


Goal 2: All Californians have access to affordable broadband and necessary devices
The aging population is the fastest-growing demographic in those experiencing homelessness or those who are unhoused. Given the choice of becoming unhoused or paying for Internet/broadband, this constituency will prioritize housing. A low-cost option is not enough; therefore, an option for free Internet/broadband is available to those who are financially eligible.


Goal 3: All Californians can access training and support to enable digital inclusion
LADOA partnered with the California Department of Aging to distribute iPads to seniors who did not have mobile devices at home. Additionally, the senior participants were provided with a digital literacy training curriculum via virtual meetings, one-on-one interaction, and group sessions. These sessions covered areas including account setup, using social media apps and other Internet applications, cybersecurity best practices, and provided technical assistance. One of the challenges we found was that due to seniors living on a fixed income, paying for full-cost Internet services was untenable in the long run. Additionally, with access to mobile devices and the Internet, it became critical to make seniors aware of the cybersecurity threats that constantly seek to steal/compromise sensitive/confidential information. Also, overreliance on social media to connect with others digitally did not fully address the social isolation seniors continue to face. For our population, digital literacy training is available through one of our partners. They can receive one-on-one or in-class training. Training can be provided in several different languages and classes vary from beginner to advanced training.
4731January 24, 2024 at 5:02 pmDigital Equity & Economic Inclusion OfficerOrganizationCity of Long BeachLong BeachCA5. Implementation Strategy & Key Activities
Key Activities & Digital Equity Programming Activities for Funding Eligibility

Interim Alternative Technology Solutions
The State Digital Equity Plan (SDEP) advocates for “interim alternative technology solutions” for communities that cannot wait for broadband infrastructure to be built out. The City of Long Beach (City), via its community-created Digital Inclusion Roadmap (Roadmap), recommends the following interim technology solutions for communities not immediately able to access broadband connectivity: Free Internet: the SDEP highlights the need for low-cost Internet but does not reference access to free Internet services. Per our community engagement, many community members will not be able to pay any cost for the Internet and will only be connected if the Internet services are free. Hotspots: With that in mind, hotspots are still valuable short-term solutions to connect community members immediately to the critical resources available via the Internet. Lending at Libraries: Public libraries are community resources, usually conveniently located within a 15-minute walk for most communities. It is critical that we still consider that we use these as hubs for digital inclusion resources. Chromebook and hotspot lending services have proven to be successful at the Long Beach Public Library and need further investment and development. Apartment Wi-Fi: The SDEP should consider landlords and other housing providers as important stakeholders. Outfitting an apartment with the Internet is a solution that maximizes collective impact. Wi-Fi in Public Spaces The community-created Roadmap specifically highlights the importance of quality Wi-Fi in public spaces like parks, transit stops, City halls, and other public spaces. Every public space should be a place where residents can access Internet resources.
Recently the U.S. Department of Housing and Urban Development (HUD) awarded the City a grant to install public Wi-Fi in four new park locations. This is particularly important for residents who are experiencing homelessness or who are precariously housed. The SDEP should reflect similar investments.

Covered Populations
The City, via the Long Beach Values Act, has made a deliberate investment in undocumented people to support them with City services and on the pathway toward economic investment. California has a large undocumented population and digital inclusion resources should be tailored for this specific population that is disproportionately lower income and has a lower trust in government than other groups. Relatedly, emphasis on language access and language equity is important so that digital literacy courses and technical support are provided in preferred languages. In 2023, the City, locking arms with the City of Long Angeles, declared an emergency on homelessness, diverting City staff and resources to focus on this critical emergency. Unhoused individuals have different needs than other people in the digital divide, often needing access to the Internet on their smartphones to navigate bureaucratic housing resource processes. This makes them as unique of a population as people who are currently incarcerated. Unhoused individuals should be one of the priority populations.

Closing Gaps, Additional Funding, & Sustainability
Consumer Advocacy: The City’s Roadmap community-prioritized strategies highlighted the need for community members to have the option to resolve issues or problems they are having with Internet Service Providers (ISPs). The City recommends that the State create a process by which they will implement the Federal Communications Commission’s (FCC) new rule on Broadband infrastructure deployment and the provision of broadband Internet access services. The FCC has said it intends to launch investigations into complaints and allegations filed through the informal complaint process or otherwise brought to the FCC’s attention, including from State, Local, and Tribal governments, and to pursue remedies and penalties where it determines a violation has occurred. The State complies with and implements the FCC’s new rule.

Goal 1: All Californians have high-performance broadband available at home, schools, libraries, and businesses
It is important to provide computing devices and digital literacy resources that are appropriate for small businesses. In the City, we led a device distribution of Chromebooks and hotspots for residents and small businesses. Feedback from this program indicated that businesses could not run crucial business applications on these devices and instead needed Microsoft Windows Operating System or MAC OS (macOS). This was due to digital literacy gaps and limited functionality when using the Microsoft Office web version.
4730January 24, 2024 at 5:01 pmManagement AnalystOrganizationCity of El MonteEl MonteCA5. Implementation Strategy & Key Activities
Key Activities & Digital Equity Programming Activities for Funding Eligibility
The State Digital Equity Plan (SDEP) does a great job of highlighting the 7 key activities for implementing the plan, but activities 2, 3, 5, and 6 need further clarification. Is there any existing example that can be used to further evaluate each key strategy? How will the effectiveness of implementing each key strategy be measured?

Grant Program Development, Implementation, Management, & Evaluation
Consider existing regional efforts for implementing broadband. When will the State Digital Equity Capacity Grant Notice of Funding Opportunity (NOFO) be released? How long is the deadline to apply for this program? Have there been any preliminary steps taken to notify Californians about this project?

Covered Populations
Consider including transitional-age youth in the covered populations. Consider individuals experiencing homelessness in the covered populations.

Closing Gaps, Additional Funding, & Sustainability
Increase opportunities for Local organizations and municipalities to partner with private entities to expand access to affordable broadband and foster those relationships. Continued coordination throughout the implementation process.

Stakeholder Collaboration, Communications, & Outreach
Implement additional curriculum for understanding basic digital literacy skills. How will implementation occur in the priority outcome areas? Will the community engagement effort be phased out to target each priority outcome area? How will engagement reach unincorporated areas? Will specific entities be collaborating with rural areas? Increase marketing and promotion to keep the momentum going. (e.g., run ads on already existing social media platforms to keep Californians engaged). Conduct briefings with existing organizations to assist with convenings and communications across multiple agencies.

Goal 1: All Californians have high-performance broadband available at home, schools, libraries, and businesses
Increase Local and regional engagement efforts to provide resources and information.
Increase the number of broadband infrastructure open to the public, especially during night hours.
Decrease the percentage of Californians that have no access to broadband available at home.

Goal 2: All Californians have access to affordable broadband and necessary devices
Increase the availability of broadband-connected devices to provide better opportunities for receiving access to training. Increase the availability of various low-cost Internet options and subsidies. Oftentimes, these programs are first come first served basis, putting others on waiting lists to receive benefits.

Goal 3: All Californians can access training and support to enable digital inclusion
To understand the need for broadband regionally, there should be questions added to the Census to collect more information on a Local level. Increase engagement efforts in senior homes to ensure training is accessible for all Californians. Implement diverse multilingual training opportunities to enhance equity in accessing training.
4729January 24, 2024 at 4:59 pmAssistant to the City ManagerOrganizationCity of DuarteDuarteCA5. Implementation Strategy & Key Activities
Key Activities & Digital Equity Programming Activities for Funding Eligibility
Get equity data and maps that are comprehensive and accurately represent underserved communities, outreach for needs assessments should go beyond social media and online surveys.
Any regional initiatives to evolve equity maps should take a multi-faceted approach to ensure communities that are underrepresented receive a platform. This could also mean deferring to city maps, or expertise from Local governments that are closest to its communities.

Grant Program Development, Implementation, Management, & Evaluation
The County of Los Angeles (County) should take the lead for any regional approach to applying for and receiving grants. The Council of Governments (COGs) may be a useful resource to compartmentalize grant funding, as is the case with Measure H funds, for example. A County-led approach when implementing grant funds would also be helpful, as cities can leverage County vendors and contractors to bring broadband efforts to underrepresented communities.

Covered Populations
Outreach and education for covered populations should be easily accessible through prominent languages other than English and other accessibility measures to ensure there aren’t any communication barriers.

Closing Gaps, Additional Funding, & Sustainability
An emphasis on a regional approach in this focus area will be extremely important to have greater influence when seeking grants, avoiding redundancies, and coordinating with neighboring cities to create a holistic broadband network.

Stakeholder Collaboration, Communications, & Outreach
Due to the dynamic and rapidly changing environment, regular updates in the form of newsletters, digests, and other summaries are essential for cities to concentrate valuable information in one easily digestible piece.

Goal 1: All Californians have high-performance broadband available at home, schools, libraries, and businesses
A strategy that emphasizes cities leveraging the County Internal Services Department (ISD) master services agreement for several pre-qualified firms to deploy a community broadband network more quickly in heavily underserved would be an effective way to build out the County’s broadband network.

Goal 2: All Californians have access to affordable broadband and necessary devices
Leveraging ISD’s master services agreement for several pre-qualified firms to deploy a community broadband network more quickly in heavily underserved would assist cities with communities that have historically been served by one service provider.
4728January 24, 2024 at 4:58 pmChief Information OfficerOrganizationCity of Culver CityCulver CityCA5. Implementation Strategy & Key Activities
Key Activities & Digital Equity Programming Activities for Funding Eligibility
Facilitate opportunities for municipalities to partner with Local school districts to advance the availability of broadband to school-aged children (K-12). Develop programs that promote digital literacy in schools, libraries, senior centers, and community program facilities.

Grant Program Development, Implementation, Management, & Evaluation
To assist cities with being prepared and understanding funding opportunities, provide a matrix of available funding which provides the granting agency, website for more information, and general qualification parameters.

Covered Populations
Leverage Local Geographical Information System (GIS) programs to obtain accurate demographic maps to better identify the covered populations based on prioritized needs. Establish a standard survey for assisting with categorizing and establishing broadband needs. Establish clear parameters for determining where digital inequities exist. Establish strategies toward facilitating connectivity options for the unhoused community.

Stakeholder Collaboration, Communications, & Outreach
Provide a monthly email to agency contacts that provide updates/funding opportunities and resources.

Goal 1: All Californians have high-performance broadband available at home, schools, libraries, and businesses
Establish clear targets for each of these goals. A baseline must first be established to accurately track performance.

Goal 2: All Californians have access to affordable broadband and necessary devices
Establish clear targets for each of these goals. A baseline must first be established to accurately track performance.
4727January 24, 2024 at 4:55 pmInformation Services OfficerOrganizationCity of ClaremontClaremontCA5. Implementation Strategy & Key Activities
Closing Gaps, Additional Funding, & Sustainability
In many other Federal grants, we find that we have first-time monies for a lot of these things. The sustainability of those funds is not there, as we saw with previous funds in the past. Make sure there are maintenance costs included for sustainability.
4726January 24, 2024 at 4:54 pmEconomic Development ManagerOrganizationCity of ArcadiaArcadiaCA5. Implementation Strategy & Key Activities
Stakeholder Collaboration, Communications, & Outreach
There needs to be an expanded conversation on workforce and economic development, especially as it relates to businesses that may need access to broadband services that currently have few options. The entire State Digital Equity Plan (SDEP) centers on under-connected residents, and there is very little discussion regarding under-connected businesses. Should they be targeted as part of a covered population? Although there is a reference to workforce development opportunities within the broadband industry to economically uplift under-connected residents, there is not much thought on how businesses can benefit or the need to address their uneven access to broadband.
These businesses are the engines of our Local economy, and their success will help fulfill the objectives of many of the goals of the SDEP.
4725January 24, 2024 at 4:54 pmCo-coordinatorOrganizationNapa Neighborhood Association for Safe TechnologyNapaCA2. Introduction and Vision for Digital Equity
We are providing public comment on behalf of residents in Napa County.
We would like to see all residents have access to safe, fast, reliable, and secure communications and that means WIRED connection. Wired broadband is superior to wireless in all respects, and wireless broadband—especially the basic services offered to low-income families—will NOT solve the digital divide. Not only is wired connection better for people, it is better for the environment as well. It is safer for the flora and fauna by not exposing them to radio frequency radiation, more energy efficient, and poses less of a fire risk, which are all critical issues facing people and our planet. Please make the wise decision of steering the conversation and decision making toward wired broadband for true equity, and social and environmental responsibility.

Additional points:
• Wireless is unreliable and unable to meet the demands of present and future digital communications. Providing funding for rollout of wireless installations will take it away from much safer, reliable, energy-efficient WIRED internet.

• Wireless will set the state back in terms of climate change management because wireless uses a huge amount of energy compared to WIRED broadband.

• Wireless facilities increase fire risk and cyber security risk

• Wireless facilities impact the growing percentage of the population with disabilities related to radiofrequency radiation (RFR) exposure.

• Wired infrastructure offers greater capacity, predictable performance, lower maintenance costs, and a longer technological lifetime than wireless technologies. Fiber service is not degraded by line-of-sight issues and is not affected by capacity issues.
4724January 24, 2024 at 4:52 pmCommunity Development DirectorOrganizationCity of AlhambraAlhambraCA5. Implementation Strategy & Key Activities
Key Activities & Digital Equity Programming Activities for Funding Eligibility
Update maps and coverage resources. Evolve broadband and digital equity data and maps.
4723January 24, 2024 at 4:49 pmA.W.ResidentLittle River954563. Current State of Broadband and Digital Inclusion
I understand that broadband is not available to the Woods community where I reside. It is through a cable company if one has the funds to have it. Not all properties in the Woods can access the cable.
4722January 24, 2024 at 4:49 pmOperations ManagerOrganizationCalifornia State University, Dominguez Hills (CSUDH)Carson, CACA5. Implementation Strategy & Key Activities
Key Activities & Digital Equity Programming Activities for Funding Eligibility
Create a comprehensive database or platform that lists all Infrastructure Investment and Jobs Act (IIJA)/ Bipartisan Infrastructure Law (BIL) programs e.g., Middle-Mile Broadband Initiative (MMBI), Last Mile, Broadband Equity Access and Deployment Program (BEAD), Digital Equity Act Programs (DEA), etc. recipients alongside their respective State Digital Equity Plan (SDEP) deliverables. This will help track progress and identify potential overlaps or gaps. Establish clear reporting requirements (e.g., implement standardized reporting mechanisms for IIJA/BIL grantees, outlining their progress and achievements in fulfilling SDEP). Implement a shared communication platform where grantees can showcase their successes, share best practices, and address any challenges related to the SDEP implementation. Utilize a collaborative platform (e.g., Slack, Microsoft Teams, Google Workspace, etc.). Workforce Readiness provided in BEAD Volume II, how will this work in concert with the SDEP and regional plans e.g., Los Angeles County Economic Development Corporation (LAEDC), Los Angeles High Road Transition Collaborative (LAHRTC), and California Jobs First (CJF)? Align efforts to add value to long-term economic development goals. Build a universal training program for digital navigation, literacy, and skills training led by the U.S. Department of Education (ED). Promote programs that provide communities with funding, education, and support for deploying innovative high-speed Internet solutions, ensuring independence from unreliable or outdated infrastructure.

Grant Program Development, Implementation, Management, & Evaluation
Maximize impact by transitioning from planning to action. Invest directly in the adoption phase with digital inclusion programs with proven effectiveness, leveraging the planning and infrastructure built through the BEAD and DEA Grant Programs. Allocate unutilized BEAD and DEA Grant Program funds to support further innovations through competitive initiatives. Offer a hybrid model, combining regional agencies with a central oversight body to balance Local expertise with State-level standardization and accountability when accessing and applying for funds. Recommend the State manage grant applications, funding distribution, and National Telecommunications and Information Administration (NTIA) reporting requirements, allowing Local entities to handle on-the-ground program execution, participant outreach, and service delivery utilizing resources effectively.

Covered Populations
Ensure that communities disproportionately impacted by barriers to digital equity are central to the design, development, and delivery of digital equity programs, and that socioeconomic benefits are captured primarily within these communities. Consult and empower covered populations and other digitally disadvantaged communities to help plan and implement all strategies to achieve digital equity. Those intended to be served must be involved in planning and delivering the services.
From an education perspective, add a priority group that includes “student parents”. Student parents are students attending any educational institution while simultaneously raising a child (or children). They come from diverse backgrounds and face unique challenges in balancing their academic pursuits, family obligations, and personal needs.

Closing Gaps, Additional Funding, & Sustainability
Expand, prioritize, and develop a sustainable framework for existing grantees of previous programs e.g., Connecting Minority Communities Program (CMC), California Advanced Services Fund (CASF), Last Mile, etc.Utilize the Digital Equity Ecosystem Map (DEEM) to overlay the BEAD-identified priority areas with organizations offering digital inclusion programs, such as affordability initiatives and digital literacy training, facilitating a streamlined review process for funded areas and their associated support services. For example, see the California State University, Dominguez Hills (CSUDH) Broadband Map Layers (arcgis.com) with designated CSUDH CMC partners: Broadband Map Layers (arcgis.com). Investigate the gap between CASF and Last Mile Program funding for Local municipalities and its tangible contributions to advancing digital equity. With the Affordable Connectivity Program (ACP) set to expire, a significant funding gap exists in addressing Internet affordability challenges beyond the Lifeline Program’s scope. It is crucial to develop alternative or supplementary funding mechanisms to prevent potential service disruptions and ensure continued access for those in need.

Stakeholder Collaboration, Communications, & Outreach
We recognize the commendable collaborative effort regarding IIJA/BIL program communication across various entities. However, concerns exist about information overload for the intended beneficiaries. Perhaps exploring a centralized or coordinated dissemination strategy could enhance the effectiveness of reaching the target audience. A one-stop-shop platform that tells applicants not only if qualified for financial aid, but also connects applicants directly to relevant digital inclusion programs, housing programs, subsidized childcare options, and mental health resources, all in one place. Raise awareness and visibility of State-mandated or approved consortia so Local organizations can effectively align with the appropriate entity. Set guidelines that ensure their strategic approach or plan aligns with the BEAD, DEA, SDEP, regional efforts led by Southern California Association of Governments (SCAG) and California Community Foundation (CCF), Local/County-mandated coalitions e.g., LAEDC and UNITE-LA that lead Los Angeles Digital Equity Action League (LA DEAL) Consortium. It remains unclear who the designated entity is to support IIJA/BIL.

Goal 1: All Californians have high-performance broadband available at home, schools, libraries, and businesses
Baseline measures or reporting, in general, should be designed to critically assess and transparently reflect the diverse experiences and needs of the community we serve. Find the balance between quantitative measures and embrace qualitative methods that capture the lived experiences and stories of community members. The potential use of QuantCrit or the quantitative critical theory approach may be a good reference point to support reporting metrics.

Goal 2: All Californians have access to affordable broadband and necessary devices
With the ACP set to expire, a significant funding gap exists in addressing Internet affordability challenges beyond the Lifeline Program’s scope. It is crucial to develop alternative or supplementary funding mechanisms to prevent potential service disruptions and ensure continued access for those in need.

Goal 3: All Californians can access training and support to enable digital inclusion
The baseline is not currently available from SDEP under objective 3.1. Develop a sustainable framework and integrate digital inclusion strategies into current programs and services. For example, in the California State University System (CSU) e.g., CSUCCESS, CAConnect Corps, and Governor’s Compact.
4721January 24, 2024 at 4:47 pmProgram ManagerOrganizationPublic Advocates OfficeCA1. Executive Summary
Digital Equity Plan Public Comments of the Public Advocates Office

NOTE: A fully cited, version of these comments on letterhead were submitted to Director Liana Bailey-Crimmins and Deputy Director of Broadband and Digital Literacy Scott Adams

Dear Director Bailey-Crimmins and Deputy Director Adams:
The Public Advocates Office at the California Public Utilities Commission (Cal Advocates) submits these comments to the California Department of Technology’s (CDT) Digital Equity Plan. Cal Advocates is the state-appointed independent consumer advocate at the California Public Utilities Commission (CPUC). Our goal is to ensure that all Californians have affordable, safe, and reliable utility services while advancing the state’s environmental goals.
A key policy priority for Cal Advocates is to ensure universal access to affordable, high-quality broadband internet service (broadband). A broadband connection is an essential necessity to work and learn remotely, address vital healthcare needs, engage in civic activities, and connect with loved ones. Yet, this service is not available to all. Households and communities that are low-income, disadvantaged, and historically marginalized continue to be left behind. Cal Advocates supports the California Department of Technology’s (CDT) efforts to realize the Draft State Digital Equity Plan’s (the Plan) vision of “a California in which all residents have access to high-performance broadband, affordable service and devices, and the training and support necessary to enable digital inclusion for economic and other social benefits”.
Cal Advocates recommends the following two revisions to the Plan to further broadband affordability and promote equitable infrastructure investments that benefit the most vulnerable covered populations.
1) State-subsidized Broadband Infrastructure Projects should Require Low-Income Broadband Plans
The Plan correctly identifies the importance of broadband affordability within Goal 2. Furthermore, Objectives 2.1 and 2.4 are correctly designated as measurable outcomes that can be compared to a baseline starting value. However, the Plan lacks concrete paths to ensure achievement of the targets associated with Objectives 2.1 and 2.4, which are necessary for a topic as complex as broadband affordability. The Plan’s most granular recommendations for achieving these targets are in its Key Activities. However, not a single Key Activity addresses the root causes of the lack of broadband affordability - the broadband prices set by Internet Service Providers.
The only mention of affordability in the Key Activities section appears in Key Activity 7, which focuses on promoting the Affordable Connectivity Program (ACP). Because relying on a limited-fund, short-term federal program does not guarantee the affordability of broadband service in California over the long term, Cal Advocates urges CDT to add additional affordability measures to the Plan. Additional affordability measures are needed because the Federal Communications Commission (which was designated by Congress in the Infrastructure and Jobs Act of 2021 (IIJA) to establish rules for the Program) issued an Order which mandates the “wind down” of the ACP. Consistent with previous research which concluded that the ACP would run out of funds in early 2024, the Order formally ends the processing of new ACP enrollments after February 7, 2024, and projects funds will run out in April, after which households enrolled in ACP will no longer receive subsidies. While Congress could approve successor programs, any such program would be subject to the same long-term viability concerns.
Even if the ACP had sufficient funds and continued, relying exclusively on the ACP to ensure affordability would remain problematic. The ACP is extremely limited in its capacity to promote “affordability” for vulnerable households. The ACP provides a monthly discount of up to $30 (and up to $75 in tribal areas) off the cost that an Internet Service Provider charges. However, there is no upper bound on the cost that Internet Service Providers charge ACP-eligible customers for broadband service. For example, while low-income customers in the Foresthill Telephone Company’s service area may receive a $30 discount, the underlying price for a 100 Megabit per second (Mbps) broadband service is $135 per month. Based on evidence in the record of the CPUC’s Broadband Infrastructure Deployment Proceeding (R.20-09-001), the maximum that would be affordable to a low-income household is $15 per month. Thus, even with an ACP discount, the monthly cost for Internet may not be affordable to a low-income household.
California is investing billions of dollars in broadband infrastructure digital inclusion efforts. To achieve the Plan’s vision, these investments must result in affordable broadband for the most vulnerable covered populations. Neither the ACP, nor any hypothetical successor programs, is sufficient to ensure the affordability of broadband services if the price of broadband exceeds the discounts offered by more than $15 per month. Indeed, for low-income households in areas with high service costs, billions of dollars in public investment could actually exacerbate the existing digital divide – because Internet Service Providers may need or elect to charge high prices to serve areas with no other wireline broadband options.
Rapidly emerging broadband deployment and digital inclusion programs represent a major opportunity to take a step in the right direction. As a starting point toward guaranteeing broadband affordability, all current and future state-subsidized broadband infrastructure projects instituted by CDT and the CPUC should require low-income eligible broadband plans: (1) include upper bounds on the cost of broadband charged to low-income households and (2) use a geographically specific definition of low-income eligibility based on the California Department of Housing and Community Development Income limits (as is done in the CPUC’s Environmental and Social Justice Action Plan). This will ensure that all broadband infrastructure deployed with public dollars will support broadband services that are affordable to the people who desperately need them.

2) Covered Populations within Communities that have been Historically Left Behind Should be Prioritized for Broadband Deployment and Adoption Efforts
The historic broadband investment achieved by California’s “Broadband for All Act,” while momentous, is not the first time the California Legislature aimed to close the “digital divide.” During the 1999-2000 legislative session the Legislature adopted a resolution adopting the goal of eliminating the “digital divide.” Attempts to close the digital divide (more accurately, disparities in broadband deployment, affordability, and adoption) have been a statutory priority for over two decades. Current broadband investments must prioritize communities who have been excluded from prior efforts due to structural inequities.
While the Plan correctly identifies the price of broadband as the number one barrier preventing covered populations from subscribing to broadband service and correctly identifies the need to focus on covered populations, the Plan does not go far enough to extend the benefits of broadband deployment and adoption subsidies to those communities who have been excluded from prior investments (both broadband and otherwise).
The Plan’s focus on Covered Populations should be sharpened to prioritize the Covered Populations in the most vulnerable communities. This includes communities where broadband service providers have historically underinvested, disadvantaged communities, Tribal areas (both federally recognized and not federally recognized), and migrant worker communities. Cal Advocates urges the CDT to state in its final State Digital Equity Plan that both its own digital inclusion efforts and broadband deployment programs including the California Broadband Equity Access and Deployment Program (BEAD), must prioritize these historically redlined and disadvantaged communities.
Conclusion
Cal Advocates urges the California Department of Technology in coordination with the CPUC to include additional measures for broadband affordability that prioritize the most vulnerable communities in California’s broadband equity efforts. By doing so, we will ensure that the historic broadband programs of today correct and make progress towards achieving digital equity.
Sincerely,
Ana Maria Johnson
Program Manager – Communications and Water Policy Branch
Public Advocates Office
4720January 24, 2024 at 4:45 pmP.M.ResidentMcKinleyville955192. Introduction and Vision for Digital Equity
I urge you to provide WIRED connections as you attempt to bring connectivity to disadvantaged households. WIRED connections are superior in every technological way, and do not cause the physical illnesses that are associated with EMF exposure.
4718January 24, 2024 at 4:34 pmJ.P.ResidentPasadena911071. Executive Summary
Please don't have wireless only
4717January 24, 2024 at 4:01 pmK.G.ResidentSan dimas917731. Executive Summary
WIRED connection is superior to wireless in all respects, and wireless broadband—especially the basic services offered to low-income families—will NOT solve the digital divide.

Additional points:
• Wireless is unreliable and unable to meet the demands of present and future digital communications. Providing funding for rollout of wireless installations will take it away from much safer, reliable, energy-efficient WIRED internet.

• Wireless will set the state back in terms of climate change management because wireless uses a huge amount of energy compared to WIRED broadband.

• Wireless facilities increase fire risk and cyber security risk

• Wireless facilities impact the growing percentage of the population with disabilities related to radiofrequency radiation (RFR) exposure.

• Wired infrastructure offers greater capacity, predictable performance, lower maintenance costs, and a longer technological lifetime than wireless technologies. Fiber service is not degraded by line-of-sight issues and is not affected by capacity issues.
4716January 24, 2024 at 3:49 pmDirector of LibrariesOrganizationCity of San JoseSan JoseCA1. Executive Summary
The Plan should identify strategies to address all gaps – both rural and urban. It is concerning that urban areas will not receive sufficient funding to achieve access deployment equity. As affordability is the top barrier for all populations in the state, the Plan should establish a strategy to focus on what the state can directly control, instead of full reliance on federal programs, including the Affordable Connectivity Program.

Access – Pg 11 –The Digital Equity Plan (Plan) identifies that California has over 450,000 unserved and underserved locations. The City concurs that serving these locations is the first step in achieving the state’s Broadband for All vision. However, the programs identified in the Plan are insufficient to close this gap, which the state also recognizes, including the state’s Middle-Mile Broadband Initiative (MMBI) and CPUC’s last mile programs as well as the Federal Infrastructure Investment and Jobs Act funding, including the Broadband Equity, Access, and Deployment Program (BEAD). It is perhaps a consequence of the insufficiency of the current combination of state and Federal funding that California’s urban population centers are not prioritized in the Plan. However, the Plan is intended to establish the state’s path to achieve Broadband for All, and therefore needs to identify strategies to address all gaps – both rural and urban. As this Plan identifies that affordability is a leading barrier to adoption for all communities, including and especially in urban areas, but this plan does not discuss or even consider strategies to replace or replicate the Affordable Connectivity Plan (ACP) or a similar approach to address affordability.

The state’s broadband availability maps used in the California Public Utilities Commission’s (CPUC’s) last mile program and the state’s BEAD 5-year planning suggest that only 1% of locations in San Jose are unserved or underserved. While the Plan acknowledges the need for improved map accuracy, the state’s existing maps, which have been used to create the Plan, preclude San Jose and other urban centers from investment and grant eligibility because the maps focus on infrastructure availability alone. This contrasts sharply with the reality that over 12% of San Jose households remain either unconnected or under-connected based on the 2018-2022 American Community Survey (ACS) 5-Year estimates. The ACS estimates provide more comprehensive insight into digital equity gaps because it measures broadband adoption and is not exclusive to availability of broadband infrastructure like the state’s maps. Further, the draft (September 2023) MMBI map deprioritized the state middle mile deployment in urban regions including the Bay Area and Los Angeles by relegating them to Phase 2 for which funding and implementation is uncertain. These exclusions mean that San Jose and similar urban areas will not receive sufficient funding to achieve deployment equity and may have to rely on existing broadband technologies and networks, in some cases outdated or non-existent, and remain unaffordable. This will slow down progress in connecting more households and hinder the state’s achievement of its Broadband for All vision.

Affordability – Pg 11 – Comment: City concurs that cost is the top barrier to digital equity for all populations throughout the state. The Plan rightly points out the administrative burdens of the ACP which the Federal Communications Commission (FCC) should work to reduce if ACP or a successor continue. However, the Plan should focus on what the state can directly control. The Plan should establish targets for the state to reduce the administrative burdens of its LifeLine program and to maximize participation in it. Regarding the ACP, the instability of the program is of great concern and is outside of the state’s control. The Plan’s reliance on the ACP or successor federal subsidy to achieve the Plan’s targets is understandable, given the program’s multi-year success and bipartisan support to continue the program. The City has also advocated for its continuation along with the state. Nonetheless, the Plan should recognize that the ACP may end, or its structure and eligibility modified, in 2024 or within the initial five years contemplated by the Plan. Thus, the Plan should anticipate the challenges this would present and seek to mitigate them. To this end, the Plan should establish state-led supports to address affordability as well as specify strategies the state will employ to minimize adoption regression immediately upon FCC announcement of a date for stopping new enrollments in the ACP or Congress passes new program structures.

2. Introduction and Vision for Digital Equity
The plan should incorporate the most recent data to establish accurate baselines as has been done for most objectives relying on the 2023 Statewide Digital Equity Survey data. However, Object 1.4 relies on outdated data from the 2018 CPUC competition report. Since the CPUC already collects both deployment and subscription data annually, as codified in Public Utilities Code Sections 281(b)(4), 281.6 and 5895, updating a competition analysis is both necessary and achievable.

Typo
Page 49; Objective 2.3. states “Target: Nienty-nine percent” but should be Ninety percent.

3. Current State of Broadband and Digital Inclusion
**Grant cities digital equity data access to enhance local planning**

The state should, at minimum, provide cities and other subdivisions of the state full access to all raw data collected related to broadband and digital equity, including from surveys and state oversight of BEAD broadband infrastructure deployments, broadband service costs, and delivered broadband speeds. This data is essential for local entities to track progress, make decisions, and plan effectively. Open data access increases transparency and collaboration between government levels, improving local services and results.


**Streamline the state data map in alignment with the FCC's updates to ensure robustness and currency**

The plan correctly recognizes the ongoing issue of data granularity and accuracy as a critical barrier that needs prioritized attention. We commend the commitment of the California Department of Technology (CDT) and CPUC to advance data collection methods and foster cooperative relationships with stakeholders at both state and local levels. It is crucial for the state to also coordinate with federal agencies to align these efforts. The FCC updates both fabric location and service availability data every six months. This frequent and detailed collection makes the federal data preferable for many groups, underscoring the need for state data to be equally robust and current. Specifically, the state broadband map should be updated every six months, ideally within one month following the FCC’s update. This ensures that state data remains current and aligns closely with federal data timelines. A more effective approach would be to work collaboratively with the FCC to integrate state-verified data directly into the FCC’s map. This unified approach helps streamline data management and eliminates discrepancies between state and federal data.


**Need for more granular data collection on broadband service pricing**

Beyond the availability of services, obtaining precise pricing information is crucial. The state’s 2023 Statewide Digital Equity Survey indicates a gap in baseline data collection, which overlooks important factors such as speeds, subsidies, and bundled services. This lack of information makes it difficult to compare services and determine how affordable they are. When publishing the annual affordability report, the CPUC should concurrently provide the underlying data with greater granularity. Specifically, details should be available at the census-tract level instead of the broader Public User Microdata Area (PUMA) level. Census tracts, which are smaller and more specific geographic units, allow for a localized analysis of the data.


Citation omitted:
A direct electronic link is needed for citing slides of ‘Digital Equity Needs Assessment and Asset Inventory for the State of CA, August 28, 2023’.

4. Collaboration and Stakeholder Engagement
**Partner with cities that have established Digital Equity programs, especially San Jose, to leverage their successful digital skill models and learning resources**

In developing a statewide digital skills curriculum and platform, it is crucial to collaborate with cities that have established Digital Equity programs. City of San Jose, for instance, has already crafted high-quality digital skill programming standards and curricula. San Jose’s experience and expertise in implementing digital skills frameworks over many years make it an essential partner in this initiative. The state should specifically and directly engage with San Jose, leveraging its successful models and learning resources.

5. Implementation Strategy & Key Activities
**The Plan inadequately addresses the sustainability of funding**

The Plan currently falls short in detailing strategies for sustaining and building new funding streams after the exhaustion of temporary sources like the ACP subsidies and federal government grants, both Capacity and Competitive grants. Additionally, the Plan does not address the sustainability and revenue sources for existing state programs, including details on the origins of funding and the anticipated longevity of these financial resources. To address these gaps, the Plan needs a comprehensive exploration of existing and potential new revenues and resources. It should clearly identify specific actions, partnerships, or policies that will be implemented to ensure a steady flow of resources to meet ongoing needs. As an example of the instability of the Plan’s funding strategy while this Plan has been in review the Governor has announced a substantial budget reduction target which eliminates a significant portion of broadband grant money to libraries. This action undermines the stated strategy of leveraging existing State programs and underscores the need for a strategy that focuses on existing and new revenue sources.
The Plan highlights the need for private investment through public/private partnerships. It is important to empower local governments with the necessary negotiation authority to effectively partner with the private sector. This includes strategically leveraging assets such as the right of way, recognizing these valuable resources in fostering collaborative growth and investment.


**Funding channel for local governments is needed**

The fundable activities in Section 5.1.4 should include more than just the local digital equity planning; funding opportunities should also cover the implementation phases within local governments.
Local governments recognize their communities’ specific needs. They require a dedicated funding channel now more than ever, especially now that one-time COVID-related funding supports are gone. Establishing this new funding channel is crucial for efficiently planning and implementing local digital equity initiatives effectively. Local governments with mature digital equity programs, like San Jose, facilitate the direct provision of digital empowerment services and bolster partnerships with local Community Based Organizations (CBOs). Existing funding structures, like the California Advanced Services Fund (CASF) Adoption Account, are inadequate and do not support local governments. They do not accommodate the varied needs of diverse communities and their funding cycles are often misaligned with the operational timelines of local governments.
The Plan should include a structured framework for such funding channel, designed to create a balanced and transparent process that allows for both local autonomy and state oversight to ensure alignment with state objectives. Fund distribution criteria should focus strictly on the digitally disadvantaged population and require coherent alignment between local and state digital equity plans.


**Emphasize on long-term outcomes, pivoting away from temporary measures like short-term internet access and loaned devices from the pandemic era.**

The Plan should emphasize assurance of long-term outcomes and strengthen both existing and new initiatives to guarantee sustainable access and improvement of digital skills. The Plan should evaluate and improve short-lived solutions, such as those providing temporary internet access or loaned devices only for a duration of a grant. These temporary solutions played a crucial role as emergency responses during the early years of the pandemic (2020-2022), offering immediate relief in a time of unprecedented need. However, they create a cycle of dependency and can be counterproductive in the long run. When the funding concludes, individuals often find themselves back to having no connectivity or access to digital devices. The Plan should pivot towards solutions that feasibly sustain a household’s connection in perpetuity. Strategies for post-grant support should be integral, ensuring that individuals retain connectivity and access to devices even after the funding concludes.


**Attention is needed to improve the broadband service for the incarcerated population.**

While the City of San Jose does not manage county jails or corrections facilities, the clear impact of the lack of affordable connectivity and digital access to incarcerated individuals and their families deserves attention. While progress has been made in eliminating fees for voice and video calls, additional support and attention is required to improve the broadband service levels at corrections facilities. Without improvement to the quality of service, incarcerated individuals will continue to lose access to critical training and rehabilitation assets and remain disconnected from their families.


**Broadband service comparison tool: the state should develop a comprehensive statewide broadband service comparison tool to streamline internet signup**

The state should develop a comprehensive statewide broadband service comparison tool, recognizing that helping residents navigate the myriad of internet options is a challenging task. This tool would serve as a one-stop resource for residents, businesses, CBOs, and others, simplifying the process of identifying and comparing available internet services at any given address, a task currently challenging for many. These features distinguish it from the FCC’s broadband map, which displays reported service availability, but requires multiple follow-up steps to verify service availability, and find the cost and speed. For the tool to be useful, it needs features to consider family’s specific needs such as the number of family members, work-from-home setup, high-bandwidth activities like gaming. It would then present suitable service options, along with detailed information on sign-up terms, inclusive pricing, and speed options. The pricing breakdown within the tool needs to be particularly comprehensive, covering base service costs, equipment and additional fees, estimated taxes. The existing tools, such as the CPUC’s Low-Cost Internet Plans dashboard, lack details and functionality that is essential for effectively navigating internet options. The new tool would empower residents to make well-informed decision that align with their unique needs and budget and would be a significant step towards improving digital accessibility and equity across the state.


**Embracing a technology-agnostic approach to broadband access is key to expanding internet service options.**

Even in urban areas, embracing a technology-agnostic approach to broadband access is key to expanding internet service options, aligning with the goal outlined in Objective 1.4. The multiplicity not only fosters competition among service providers, leading to better services and competitive pricing, but also enhances reliability and redundancy. Moreover, this approach prepares broadband infrastructure for the future, allowing new technologies to be seamlessly integrated without constraints of a single-technology framework. Broadband infrastructure grants should strongly support this technology-agnostic approach.
4715January 24, 2024 at 3:36 pmP.A.ResidentLittle River954561. Executive Summary
I understand that AT&T is considering ending their land line service here in No. Calif and that is totally unacceptable. We have fairly poor cell reception service so I rely on the land line as well.
4714January 24, 2024 at 3:29 pmEXECUTIVE DIRECTOROrganizationST FRANCIS LIVING ROOMSAN FRANCISCOCA