Sample Public Comments on the PA Digital Equity Plan

Written by Kate Rivera, TLC Executive Director

​The Pennsylvania Broadband Development Authority (PBDA) has drafted its Statewide Digital Equity Plan. Public Comment is open with a deadline to submit feedback by 12pm on Monday January 8, 2024.
 
The final version of the plan will serve as the state's blueprint for advancing digital equity and provide the framework for the distribution of tens of millions of dollars in federal funding. It is imperative that the state's plan reflects the needs and insights of Philadelphia's digital equity community. TLC encourages you and your organizations to review the draft plan and provide feedback via the public comment process. 
 
This is the last post in a three-part series I wrote to help you understand why the plan is important, what’s in the plan, and highlight some areas where you may want to provide feedback (that’s this post). Below are some public comment ideas that I’ve compiled based on some of my own thoughts as well as feedback that I’ve gathered from members of the Philly and PA digital equity community. I want to be clear that these are just some ideas – which you are free to use if you agree with them or ignore if you do not. I also encourage you, if you have the time, to review the plan on your own and develop your own feedback for the PBDA.
 
How to Submit Public Comment 

Submit your comments online, no later than Monday January 8th, via the PBDA’s form survey. If you require submitting comments via phone, you can reach the PBDA at 717-214-7708.
 
The survey form is a Microsoft Form that does not allow formatting, nor does it have the ability to save to continue entering comments later. Only one submission of comments per individual will be accepted, so you can’t submit some comments now and then go back later to submit more.
 
For these reasons, we recommend writing out your comments in another document that you can save and copy and paste into the form when you are ready to submit it. The form provides specific response boxes for each section of the plan – take a look at how the form is organized so that you can organize your comments accordingly.
 
Ideas for Public Comment 

While the plan is long and has substantial opportunities for public comment throughout, I am focusing here only on the Implementation Plan – Section 6 – since this is where the rubber will meet the road. If you are using any of these sample comments, enter your information in the beginning of the form, and then scroll on down past sections 1 through 5 until you get to the comment boxes for Section 6.

If you’re feeling overwhelmed, don’t be! You can comment on as much or as little of the plan as you would like. Even just one or two sentences about an issue that you feel passionately about is an important contribution.
 
Section 6.1: Goal 1 - Get People Online
 
Strategy 1.1- This strategy is over reliant on ACP and should be amended. The digital equity plan is an opportunity for PBDA to be bold, disrupt current systems, and create opportunities for equity. The PBDA should commit to forming a committee to explore options for subsidization if ACP funding is not reauthorized, such as exploring a partnership with the Pennsylvania Public Utility Commission to review state mechanisms for long-term internet subsidization.
 
This Strategy could be revised to something broader like “Advance affordable connectivity across the Commonwealth and support residents to sign-up for low-cost options.” Examples of other Actions include: 1) Fund organizations to conduct marketing and outreach campaigns (including multilingual) in their communities to raise awareness of low-cost internet options and help people sign up. 2) Fund free public wi-fi networks in areas that are considered served but have significant numbers of people who are still without internet access.
 
PBDA should consider implementing strategies focused on specific covered populations or groups with similar needs, such as working with the affordable housing community to research, launch, and fund an Affordable Housing Connectivity Program.
 
Strategy 1.2 – PBDA should include a provision for updating the minimum download/upload speed as technology and standards change.
 
Strategy 1.3- CAIs in areas with high concentrations of covered populations should be funded proportional to their covered population representation and need. 
 
Section 6.1: Goal 2 - The Right Tools
 
Strategy 2.2 – PBDA should commit to establishing standard for minimum device specs, ask grantees to articulate their strategy for providing individuals/households with the best type of device for them, and set an expectation that a certain percentage of spending should go toward assistive technology.  A more specific KPI could include a percentage increase in the supply of devices across the Commonwealth from the current baseline over a specific period of time.
 
PBDA should also commit to funding device purchasing through other funding streams beyond the CPF, like the DEA funding. Lastly, PBDA should encourage other state agencies to include a budget line item for devices in their grant programs, for example workforce, adult education, digital skills, etc.
 
Strategy 2.3- PBDA should revise this strategy to something like “Scale device recycling and refurbishing throughout the commonwealth by funding device refurbishing programs and building partnerships to increase access to devices.” PBDA can leverage existing industry partnerships in addition to establishing its own. Additionally, PBDA should explore state partnerships with device recyclers and refurbishers for its own devices that could be distributed to residents across the state. See State of Maine Digital Equity Plan and State of Michigan Digital Equity Plan (DRAFT) for exemplary recycling and refurbishing strategies in their respective implementation plans.
 
Strategy 2.4- This strategy should more broadly address the need for a comprehensive communications plan that not only includes information on the PBDA’s website but encourages (and ideally funds) communication and outreach about free and low-cost device access programs by other state agencies, local government, nonprofits, and others.
 
Strategy 2.5- While technical assistance and device repair are important components that should remain in the plan, it is not realistic to expect that all grantees that distribute devices will have the capacity for or are ideally suited to provide technical assistance and device repair. PBDA should consider funding device refurbishers and other appropriate organizations to provide technical assistance and device repair services, who can establish partnerships with grantees. PBDA should also work with industry experts to establish guidelines and standard definitions for level 1-3 technical support.
 
Section 6.1: Goal 3 - Grow Skills
 
Strategy 3.1- The strategy could be edited to “Create a statewide plan for every county to have digital navigation services commensurate with the need of the covered populations in their area.” Then, the associated Actions could be focused on convening a working group of state and national digital navigation experts to inform the development of the blueprint/standard as well as funding entities to coordinate digital navigator programs across the state or regions. This revised strategy could also incorporate the current Strategy 3.3 as an Action. A final Action for consideration is to explore creating Digital Navigator state-funded jobs that are housed within public locations like libraries, CareerLinks, CAIs, etc.
 
Strategy 3.2- The emphasis on meeting people where they are with digital skills is important, including "pre-101" digital skill building all the way up to more advanced skills. PBDA should ensure funds are disbursed based on percentage of population representing covered populations to ensure equitable access to programs.
 
PBDA should work with industry experts to create digital skills curriculum resources and recommend platforms to be used across the state (such as Northstar Digital Literacy). Guidelines should not be too restrictive but should guide grantees to best practices and widely recognized resources.
 
PBDA should work with other state departments and agencies to incorporate funding for digital skills training into other grant programs, for example adult education or workforce grants, to leverage and maximize sustainable funding for digital inclusion programming after DEA funds are expended. Working with the PA Dept of Ed on a K-12 strategy is important as well.
 
Section 6.1: Goal 4 - Stay Safe and Secure
 
This is an important and commendable goal to elevate in the digital equity plan. PBDA should consider how strategies will not only inform education and training for residents across the Commonwealth, but also compel entities that create the unsafe and predatory conditions to begin with to end their harmful practices.
 
Strategy 4.1 – PBDA should identify curriculum and resources that agencies and organizations can use to provide high quality cybersecurity and digital hygiene training. Training and outreach should be focused on a broad range of consumers including K-12, post-secondary, and adult education. PBDA should fund grantees to provide training, with an emphasis on the role of trusted messengers.
 
Strategy 4.3 – Beyond the specific DoBS financial security trainings, PBDA should commit to exploring other partnerships including both other training modules and also the production and release of PSAs in support of online safety.
 
Section 6.1: Goal 5 - Strengthen the Foundation
 
Strategy 5.1 – Working to make government funding accessible to smaller community-based groups is great! Further thought should be given to how to determine in which instances smaller entities should be awarded funds with this support, and in what instances smaller entities would best be involved in a larger partnership rather than awarded funds separately (so that this strategy complements rather than conflicts with the emphasis on partnerships in strategy 5.3.
 
Sector capacity building should be an important strategy beyond specific technical assistance for smaller orgs. PBDA should fund not only direct services and outreach to community members, but also best practice and resource sharing between organizations in the service of higher-quality outcomes.
 
Strategy 5.2- Creating a Digital Equity Readiness Checklist is a great start, however PBDA should consider supporting every county or region in planning efforts that will prepare them to effectively use this funding, such as developing its own digital equity plan and asset map (North Carolina’s Division of Broadband and Digital Equity did this).
 
Strategy 5.3 – The scoring rubric should be developed so that resources will be dedicated where there is greatest need and PBDA should allocate resources proportionately to covered populations (equitably). The emphasis on partnerships that can reach multiple covered populations with a variety of services is good, and a strategy that was proven successful with the BTOP funding. 

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This is the final post of a three-part blog series I wrote on the PA Digital Equity Plan. If you missed the prior posts, use these links to review why the plan is important and what’s in the plan.