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Affordability Plan?

Stakeholders Seek More Details in Calif. BEAD 5-Year Action Plan

Consumer advocates, industry and local officials want more details in the five-year action plan California will submit to NTIA as part of the broadband, equity, access and deployment program Many in comments posted Tuesday in docket R-23-02-016 (see 2307180013) sought additional information in the final plan about affordability and digital equity efforts.

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The plan "lacks specificity about the need to improve and implement broadband access for residents of multi-family housing," said the city and county of San Francisco, saying many unserved and underserved low-income residents in suburban and urban areas throughout the state live in multifamily housing: It "must identify the challenges faced by residents of multi-family housing and propose specific strategies that target multi-family housing for broadband access." The draft "falls short in establishing a comprehensive BEAD program implementation plan that effectively addresses California's broadband goals and priorities," said Small Business Utility Advocates (SBUA). The group asked that the final plan address "nonresidential equity" and recognize the "pivotal role small businesses play in driving economic growth."

The draft plan "acknowledges that the BEAD allocation alone cannot cover all unserved locations in the state," said the Wireless ISP Association. The group sought clarification on how the state defines unserved and underserved, noting the terms "appear to shift in their definitions slightly throughout the document." WISPA also urged the state to adopt a technology neutral approach. A "common understanding" of unserved locations is "critical" to BEAD's success, said the California Broadband and Video Association. Calbroadband said the state's definition of unserved is "inconsistent with federal law" and urged CPUC to revise its estimation of locations to "align with NTIA's BEAD program methodology."

Consider the "potential for the continuation of broadband internet affordability measures at the state level" once the FCC's affordable connectivity program ends, said the Greenlining Institute. The group noted "no concrete plans are given" in the plan to address digital equity, and urged CPUC to "be increasingly mindful of covered populations with the final plan." The draft addresses affordability "almost exclusively" through ACP with "no reference to the ACP's uncertain future," said the California Alliance for Digital Equity. "Consideration of public-private, municipal, and cooperative broadband deployment should also be part of a plan to address middle class affordability," the group added.

Include elements of the state's digital equity plan, which the California Department of Technology (CDT) is working on, to "truly demonstrate the continued collaboration and partnership" between CPUC and the CDT, said the Corporation for Education Network Initiatives in California. The draft "lacks the specificity required" in NTIA's notice of funding opportunity for the state's plan for providing "reliable, affordable, high-speed internet," said Community Legal Services. It urged CPUC to include "explicit objectives to support outreach to covered populations" and ensure they "actually receive the services and any devices supplied with BEAD funding."

The draft "largely omits reference to racial disparities in broadband adoption and deployment, and digital equity," said The Utility Reform Network and Center for Accessible Technology in joint joint comments. The final plan should "expressly identify the historical and ongoing racial and economic disparities that act as barriers to broadband adoption in California," the groups said. Include "analysis, evaluation, and proposed solutions related to broadband affordability" in the final plan, said the CPUC Public Advocates Office. It also sought a "concrete timeline" for program planning and implementation, as well as estimated funding gaps. NTIA awarded the state $1.86 billion in BEAD funding (see 2306260007).