Updated comments on California’s broadband subsidy program posted

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More comments are in about how broadband adoption programs should be funded by the California Public Utilities Commission. Or rather, I’ve found more comments – the filings from the CPUC’s office of ratepayer advocates (ORA) and the Central Sierra Connect regional broadband consortium landed in my spam folder last week.

It’s a chronic bug in the CPUC’s service list system. Anytime you submit something – comments, grant applications, motions, protests, whatever – regarding a formal CPUC proceeding, you have to send copies to anyone who’s signed up to be notified. That’s great in theory, but the practice of sending files to dozens, sometimes hundreds, of people all at once is sure to trip spam filters from time to time, both incoming and outgoing. I guess finding a fix is one more thing to put on the cosmic to-do list.

ORA suggests reexamining the $49,200 median household income benchmark for determining whether a community gets preference for being “low income”…

Since this income threshold applies to a family of four,26 it is not an appropriate metric for communities with significant numbers of single occupancy households or households with five or more people…

Moreover, because the cost of living in California varies so widely, an income of $49,200 could be considered low-income in some areas, but not in others…Although publicly available data are not available to determine whether California households earning between $40,000 and [$49,200] have low adoption rates, it is clear that households earning less than $40,000 have low adoption rates.

The City and County of San Francisco submitted revised comments, dropping is argument that funding levels for digital literacy and broadband access programs should be higher because Microsoft’s Windows system doesn’t include software for visually impaired users – turns out it does.

All the comments, including those newly unearthed, are below.

Regional Broadband Consortia
Central Coast Broadband Consortium
Central Sierra Connect
CSU Chico Geographical Information Center (Northeastern and Upstate California Connect Consortia)
Gold Country Broadband Consortium
North Bay North Coast Broadband Consortium

Public Agency
City and County of San Francisco (revised comments)
Office of Ratepayer Advocates

Internet Service Providers
Bright Fiber Network, Inc.
California Cable and Telecommunications Association
Frontier Communications

Non Profit Organisations
California Emerging Technology Fund
Radio Bilingue, Inc.
Satellite Affordable Housing Associates
Tech Exchange
Tenderloin Neighborhood Development Corporation
TURN

CPUC scoping memo and proposals
Scoping memo and ruling of assigned commissioner, Martha Guzman Aceves, CASF program changes, 14 February 2018
Appendix A, AB 1665 changes to CASF program
Appendix B, CPUC staff proposals for broadband adoption, public housing and loan programs
Appendix C, CPUC staff proposed changes for broadband infrastructure grant, line extension and regional broadband consortia programs