Yurok Tribe Counters AT&T in Calif. BEAD Replies

R.23-02-016). The Yurok Tribe disagreed with AT&T that project area units should be as geographically small as possible. "AT&T says that requiring minimum geographic units to be equivalent to a contiguous tribal land area could ‘eliminate synergies and increase costs,’ but that’s precisely the logic that has led to a patchwork of service on tribal lands, and the chronic underinvestment of incumbent providers in remote, rural tribal locations,” the tribe said. In addition, Yurok disagreed with AT&T that applicants should have prior experience with technology they plan to deploy. "This suggestion would, quite obviously, completely disqualify a number of new providers seeking to bring quality service to areas long ignored by incumbent providers from eligibility." And the tribe disagreed with the carrier to score more points to larger projects. "Doing so would reward incumbent providers at the cost of new providers, as incumbent providers are better positioned to develop larger projects that serve more locations.” AT&T made the suggestions in its opening comments (see 2311280053). The San Diego Association of Governments urged the CPUC to better prioritize equity. "The current scoring rubric allocates only 10 points out of 100 for projects targeting low-income and disadvantaged communities,” the San Diego group said. While CPUC must comply with NTIA rules, “we contend that this limited point allocation may not serve as a sufficient incentive for ISPs to invest in areas of utmost need.” USTelecom replied, "California should rely on ACP participation and a comparability test to meet BEAD’s affordability requirements and affordability should not be scored on a sliding scale.” If the state adopts low-cost and middle-income affordability plans, “providers should be able to adjust prices to capture inflation, cost of living increases and other costs outside of the providers control such as taxes,” said USTelecom: And don’t prioritize open access. The CPUC’s independent Public Advocates Office urged the CPUC to reject recommendations to modify "affordability requirements in ways that would prioritize private interests over the public interest.”