CPUC | BEAD Workshop 8:18 am - 4:34 pm Thursday, October 26, 2023 | (UTC-07:00) Pacific Time (US & Canada) LVK Anne Stamper Gladys Palpallatoc Kari Sinoff BEAD Presentation Kelsey Baird - City of San Diego she/her Jim Miller Itzel Hayward SBUA Mitzi McMahan Espinoza, David Vinh Pham City of San Diego T Lowery Cooke, Lisa Sherri Chat Moderator 1 (AE) Tad Gondai Dan Gonzalez Cole Przybyla Brian Roberts Justin Ryan Stanford, Robert Mitch Gorsen Dirk Gates Jenna Alsayegh Patti Ringo Cinthia Diaz Call-in User_17 (415203****) Brian Hurley JHI Audio Monitor David von Moritz Jon Gjestvang Camille Stough Felipe Monroig av Chasel Lee Siguenza, Antoinette Jason Winborn Julie Harney Grantfuson Haga Joseph Call-in User_5 (415203****) jerome Candelaria Rachel Sweetnam Torry Somers Leigh Kammerich JL Room View for Onsite Participants Singh, Amanda Alexandra Green TURN Ashley L. Salas she, her, hers | TURN David Bookhol Monique Call-in User_14 (580222****) Call-in User_11 (949903****) Monique Goelz Andrew Brickweg Bawa, Niki Donna Brandon Mike McCarthy Call-in User_18 (580222****) David Griffith Mary Alvarez-Gomez Eric Schmidt R. Johnson jessica enfl Ceilidh "Kay-Lee" Gao, CWA Conf WA HQ B2 Huddle 5400 Jessica Sankus, CSAC Lindsey Skolnik Surfnet Call-in User_13 (707536****) Ben Aron CTIA Josh Butler, Human-I-T Sarah Cooper Call-in User_10 (415314****) Tim Alborg Margaret Tobias Anthony Traini tkelly Christman, Hope Michael DeRenzo Joycelyn Bennett Jasmine Elo Jarrett Thiessen Tim Sheppard, Kerriann whughe200 Matthew Rantanen Mullaney, Michael Travis Finch Eduardo Gonzalez Rachelle Chong McDermott, Jake Susan Walters DL JHI Mobile Test Steven Crosby Scott Turner CWA D9 LPAT Deb Kollars natalie gonzalez Julie Palley Stephanie Silver Natalie Gonzalez [CCF] K Ijams Kalyn Dean Katherine Fosburgh Kim Lewis Carolina Mendez Joe Karl Wardin digital equity Meegen Murray svansa001 Louie, Elizabeth Leo Fitzpatrick he/him TURN - The Utility Reform Network Call-in User_6 (617697****) jamie Uarporn Quoc Chau John Nelson Drew Garner Jim Lüttjohann, Catalina Island LaTanya Davis Alex Damato Ellis, Maria Call-in User_2 (520237****) Andrew Cardin Melissa Slawson Daniella Espinoza Lynn Follansbee Shelby Arthur Russ Elliott Brad Johnson Constance Joves Louis Peraertz Mark Chat Moderator 2 (NB) Martha Van Rooijen Navreet Hundal Tone Consulting Group Kate Fosburgh Nelsonya Causby kam Call-in User_8 (323217****) Arturo Juarez Jeff Tyrrell Sarah House| Monterey County Hannah Donahue Davis Wright Tremaine LLP Anthony Walecki Richelle Orlando Anthony Sarah Banola Mike McCarthy Natalie Gonzalez Shayna Englin | CCF Anita Maria Kelly Call-in User_7 (619370****) camille.stough Rich Levine Fred Maldonado Bruce Vogen Minkus, Michael J. Tiffanie Myers WEBVTT 1 Haga Joseph 00:38:50.180 --> 00:39:10.020 Good morning everyone. Can everyone hear me? All right, yes. Okay, hi folks, I'm, Maria Ellis. I'm the Deputy director for Broadband at the California Public Utilities Commission and I want to thank everyone for being here. Some of you travelled to be here. So I really appreciate your time that you've come. 2 Haga Joseph 00:39:10.220 --> 00:39:21.820 Here to tell us a little bit about the speed program as we're putting it together. I want to do a little bit of housekeeping before we take off. Tom, would you be able to pull up the slides for me? 3 Haga Joseph 00:39:25.380 --> 00:39:43.300 As Tom's pulling that up, I want to do a couple, like the halfkeeping so bathrooms if you exit here and go to the left, the bathrooms will be at the very end, right before the door to your right exits on each side in case of emergency, we want to remind everyone that this is a hybrid workshop. So we. 4 Haga Joseph 00:39:43.500 --> 00:39:58.660 Have some folks present here in the room, interacting we'll be interacting with them directly as well as online, and as you've heard this workshop is being recorded. So just please note that and it will also be posted for the record. 5 Haga Joseph 00:40:01.900 --> 00:40:04.820 Joe would you mind going to the next slide for me? 6 Haga Joseph 00:40:08.300 --> 00:40:27.460 Next slide, I want to go over the agenda here or just, sorry, the, for those of you participating online, just this slide just has a little bit of information for you about how you can participate. We won't have the, the conversation is really gonna be limited to Pan. 7 Haga Joseph 00:40:29.460 --> 00:40:42.220 A comment here that will have at the front, but if you have questions or anything else that you would like to share those online are welcome to use that chat button, and again, all of this is, is part of record. 8 Haga Joseph 00:40:43.580 --> 00:41:04.020 With that, I'm gonna, if you can go to the next slide, I want to share a little bit about the agenda and then turn it over to Commissioner, Darcy, how who will take over our meetings here. Moderate, we're gonna do, I'm gonna do a quick round of introductions here momentarily about who's on the diet before we get started and then we're gonna get an overview of the NT. 9 Haga Joseph 00:41:05.540 --> 00:41:12.300 About the B program. That's the broadband equity access and Deployment program, which is the topic of this. 10 Haga Joseph 00:41:13.660 --> 00:41:34.100 Workshop, we're going to also take some public comment for a short period, and then we're gonna enter into our first panel discussion on the challenge process. We will be taking a break at that time, and then coming back after lunch, we'll come back and do the selection process and then we'll talk about the externally high cost threshold and we'll do. 11 Haga Joseph 00:41:34.180 --> 00:41:43.020 Wrap up in next steps with that before we kick off, like to have our folks on the DIAS introduce themselves starting with our commissioner. 12 Haga Joseph 00:41:44.980 --> 00:42:05.460 Hi, I'm commissioner. Half the lead commissioner for this proceeding, and then I'll let the others introduce themselves and then do the opening comments. Okay, great now turn it over to director Osborne. Hi, Robert Osborne, director of the Communications division at the Public Utilities commission. Good morning everyone. I'm Tom Glogula. I am the assigned administ. 13 Haga Joseph 00:42:05.780 --> 00:42:07.060 Law judge. 14 Haga Joseph 00:42:08.660 --> 00:42:13.420 Good morning Ben Menzy's programming project supervisor on the bed team. 15 Haga Joseph 00:42:15.900 --> 00:42:36.180 With NTIA, one of two federal program officers for California wonderful and before we dive in, I want to just also remind folks those that are doing general public comment. You'll have two minutes. We, we ask that everyone try to be as respectful of that timeframe as possible, so that we can hear. 16 Haga Joseph 00:42:36.340 --> 00:42:56.660 Everyone is needed and also our panelists when we get to our panel discussion, I'll do this as a reminder as well and feature panels, but we're gonna ask panelists to limit their comments to a total of no more than five minutes just to ensure that we can hear from as many folks as possible as well with that. I'm gonna turn it over to Commissioner, Darcy Hawk to get us started. 17 Haga Joseph 00:42:57.940 --> 00:43:17.780 So good morning everyone again, I'm commissioner, Darcy Halk, one of the five commissioners at the California Public Utilities Commission, and again, I'm the lead commissioner for our Beed proceeding broadband equity access and deployment. I'm also our lead commissioner for California Advanced Services Fund and our service quality proceedings. So. 18 Haga Joseph 00:43:17.860 --> 00:43:38.260 Broadband is a top priority for me as a commissioner and I really do believe that we will be able to accomplish historic development of broadband during my term and partnership with our sister agencies, the California Department of Technology Caltrans are local regional and tribal government partners telecommunications carrier partners. 19 Haga Joseph 00:43:38.420 --> 00:43:58.740 And of course our community based partners that we rely on to ensure we understand the needs of communities that are currently unserved and underserved as many of, you know, Beed is a forty- two billion dollar program created by the infrastructure investment in Jobs act in its administered by the National Telecommunications and Information Administration. 20 Haga Joseph 00:44:00.180 --> 00:44:19.220 And we are pleased to have NTIA join us at the Dias this morning to participate in our workshop. The goal of the Beed program is to bring everyone in the nation online by building infrastructure and increasing adoption of high- speed internet service. So, a central goal of Beed is to. 21 Haga Joseph 00:44:19.860 --> 00:44:39.700 Reliable last mile service to all unserved locations defined speeds, at least twenty- five megabits per second download in three megabits per second. Upload via reliable technology, meaning a wire line connection or licensed fixed wireless federal rules, require prioritization of. 22 Haga Joseph 00:44:40.420 --> 00:45:00.180 Fiber deployments, but there is some flexibility in where this is not feasible fixed wireless can be used as an alternative NTAI through the BEED program has allocated one point. Eight six billion dollars to the state of California to go towards eliminating the digital divide. California will be able to. 23 Haga Joseph 00:45:00.420 --> 00:45:21.300 Ward subgrants through Beed to carry out broadband deployment activities such as planning for the deployment of infrastructure deploying or upgrading internet infrastructure, deploying infrastructure in multitenant buildings, implementing adoption and digital equity programs and workforce and job training. However, before that can happen, we must develop a plan. 24 Haga Joseph 00:45:21.460 --> 00:45:41.780 In a process for implementing the bed program here in California. So the commission is open to rule making our twenty- three. Oh, two, O- one, six to set out the program rules for bed and as part of this rule, making the communications division staff are developing a staff proposal, which is why we're here today to that concepts for the initial bid propos. 25 Haga Joseph 00:45:41.940 --> 00:46:02.260 That will be submitted to NTIA and we encourage and welcome all of you to actively participate and engage in today's discussion. The POC completed its initial wave of public engagements that were jointly coordinated with the California Department of Technology over the summer, this feedback that we received from these twenty. 26 Haga Joseph 00:46:02.500 --> 00:46:22.740 Community engagements, including tribal consultations, has informed the staff development of the draft initial proposal that they're working on. We look forward to continued coordination with communities and stakeholders, including community organizations, carriers and public, and the public to ensure that this funding contributes to our greater broadband. 27 Haga Joseph 00:46:22.940 --> 00:46:43.220 Structure, deployment digital equity and affordability objectives. Today's workshop is another key opportunity to suff inform the development of this initial proposal and today we will hear from staff as they present some concepts for the proposed rules for the bid program, as well as from parties and stakeholders. 28 Haga Joseph 00:46:43.300 --> 00:47:03.700 I look forward to hearing from all participants throughout the day and before I close, I want to recognize and thank the commissions communication division staff who have been going above and beyond on their work for this proceeding. I want to thank director Osborne deputy director Maria Ellis, Jonathan lacerates, Ben me. 29 Haga Joseph 00:47:06.460 --> 00:47:24.180 IAN cover also from our legal division and everyone in the communications division for all of their work. I also want to recognize the dedication and work of Judge Glagola and managing the proceeding and assisting with organizing the workshop. I also want to thank my ad. 30 Haga Joseph 00:47:25.220 --> 00:47:44.660 Shepherd, Victor Smith, Amanda sing and especially Nikkibaua who's here today as he's the lead in my office for the bed proceeding and my Bagly King partner, President Reynold, who is not able to be here today and her advisor Michael Malaeni, for all of their support on this important proceeding, so last, but cri. 31 Haga Joseph 00:47:45.060 --> 00:48:05.140 Important, I also want to thank our IT staff who support and expertise make our virtual and hybrid hearings possible. So thank you for all of your work and traveling throughout the state to make these meetings work. So again, thank you to everyone for joining us today, I look forward to a robust and engage discussion. This is an important proceeding. 32 Haga Joseph 00:48:05.460 --> 00:48:25.540 Good to see so many people here participating both in person and virtually, and so with that I will turn it back over to Misalez. Thank you commissioner. At this time we're going to hear a little bit from MTIA, the national Tele Communications and Information administration by Marina Mcclass. 33 Haga Joseph 00:48:29.460 --> 00:48:46.100 So I do have one slide if we could go next, can you guys hear me Okay? It feels quiet to me. get one more slide. There we go. This is my one slide. So to start off, thank you to commissioner huck and. 34 Haga Joseph 00:48:46.860 --> 00:49:07.860 For inviting me to speak today and thank you to all of you that are attending this workshop both in the room and online as previously mentioned, my name is Marina Mclachi and I'm one of two federal program officers for NTIA supporting the implementation of beat and California. So my goal here is to provide a quick overview of the upcoming time. 35 Haga Joseph 00:49:08.700 --> 00:49:28.340 And also provide some NTIA framing to the policy topics. The workshop will cover today. So the beat program has a very strong federal framework, so to have the most productive dialogue today, I want to share key guidance on what's important to NTIA and what's levers the state can use to express its priorities. So starting. 36 Haga Joseph 00:49:30.900 --> 00:49:48.820 In June and TIA announced California will receive one point, eight six billion in funding for bid. This is the second highest amount in the country. States are in the process of drafting what NTIA refers to is the beat initial proposal and this document must outline the detail. 37 Haga Joseph 00:49:48.980 --> 00:50:09.300 Process and approach the CPUC will take to run its challenge process solicit and score applications and select sub- guarantees for the beat program. States must release their initial proposals for thirty days of public comment and the final submission is due to NTIA December twenty- seven NTIA will then review. 38 Haga Joseph 00:50:09.340 --> 00:50:18.420 The initial proposal and communicate with the CPUC, if any areas need to be revised based on the notice of funding and opportunity or no Fo. 39 Haga Joseph 00:50:19.540 --> 00:50:40.020 Once NTIA approves California's initial proposal, the CPUC will have one year to run its challenge process solicit proposals and preliminarily select subgrantees, the CPUC will submit all of this information in its final proposal to NTIA and once NTIA approves CPUC will. 40 Haga Joseph 00:50:41.400 --> 00:51:01.800 Need funds to confirm final subgrantee awards today. We're here to c- discuss three critical elements of the initial proposal. The challenge process project area selection, and the extremely high cost per location threshold. So first, let's discuss the challenge process by statute the CPUC. 41 Haga Joseph 00:51:01.840 --> 00:51:22.280 Must use the FCC national broadband map as their starting point NTIA has published a model challenge process. We are encouraging states to use as it is already approved by NTIA CPUC can choose to adopt the model and whole or in parts, but either way the challenge process, they design. 42 Haga Joseph 00:51:22.880 --> 00:51:42.760 The rules of Ntia's challenge process policy guidance document, two of the proposed modules for the challenge process already pre- approved by NTIA include treating all DSL is underserved and then unserved where DSL speeds are below twenty- five, three and utilizing speed tests within NTIAS approved parameters. 43 Haga Joseph 00:51:44.040 --> 00:52:03.240 California can propose modifications outside of the model to reflect data not present in the FCC map. They cannot change the definitions of unserved and underserved from those set forth in the infrastructure investment and jobs act. They must also include sufficient justification and evidence that the. 44 Haga Joseph 00:52:03.240 --> 00:52:23.720 Proposed modifications better. Reflect the locations eligible for beat funding NTIA will have an evidence- based standard of review for these modifications, for example, arguments that a type of technology is inherently unreliable by its nature. Have have not been successful in other states. states can. 45 Haga Joseph 00:52:23.800 --> 00:52:44.200 Only add locations to the map by going through the FCC challenge process. The exception to this is community anchor institutions are CAIS. The B challenge process can add Cais eligible for bed funding eligible challengers in the be challenge process are units of local government tribal government. 46 Haga Joseph 00:52:44.320 --> 00:53:04.680 Nonprofit organizations and broadband service providers. This is different than the Fcc's challenge process, which also allowed individual consumer challenges NTIA is encouraging local government associations or other non- profits to work to aggregate individual challenges for their region LAS. 47 Haga Joseph 00:53:05.040 --> 00:53:25.160 Ly, indeed, the challenge process is designed to occur prior to project selection as opposed to, after this means that the beach challenge process is different from how many states including California have run their challenge or objection process for state grants the opportunity for input is designed to occur prior to Appli. 48 Haga Joseph 00:53:25.600 --> 00:53:45.640 Submission, not after moving on to project areas and scoring the CPUC must demonstrate to NTIA that they will design the Subgrantee selection process to ensure a hundred percent coverage. This means states will have to think creatively about how to design project areas and deconflict overlapping prop. 49 Haga Joseph 00:53:45.640 --> 00:54:06.120 Proposals, this will likely look different than how the CPC grant programs have defined project areas in the past the bed. No, fo defines primary criteria. States must use for seventy- five percent of the points when scoring proposals states have flexibility in determining the secondary criteria for. 50 Haga Joseph 00:54:06.800 --> 00:54:16.080 Twenty- five percent additionally, criteria cannot be designed in a way that gives an advantage to one certain type of provider over another. 51 Haga Joseph 00:54:17.640 --> 00:54:38.080 Finally, let's discuss the extremely high cost per location threshold confusingly, there are two high cost related terms in the Beed program and they do not mean the same thing. The extremely high cost per location threshold refers to a, per location cost beyond which a state can decline to select a priority technology. 52 Haga Joseph 00:54:38.120 --> 00:54:58.600 Or a priority broadband project and can instead look at using a left costly technology California will set its own extremely high cost per location, threshold the term high cost area means an unserved area in which the cost of building out broadband service is higher as compared with the average cost of building out Broadb. 53 Haga Joseph 00:54:58.880 --> 00:55:19.080 Service and other unserved areas of the United States high cost areas were defined by NTIA, not California. the twenty- five percent beed matches not required for projects that will serve a high cost area though. A state can request a match. The extremely high cost per location, threshol. 54 Haga Joseph 00:55:19.200 --> 00:55:39.560 Should be set at the point that maximizes fiber deployment while still ensuring a hundred percent coverage states can choose more cost- effective technology when projects exceed this threshold. The threshold amount does not have to be already established and identified in the initial proposal or before applications are submitted the. 55 Haga Joseph 00:55:39.760 --> 00:56:00.040 Can include a detailed process for how it will identify the extremely high cost per location threshold in the initial proposal. The threshold must be identified in the final proposal NTIA is strongly encouraging states not prematurely define the extremely high cost per location threshold and wait until they have all possible data points to make. 56 Haga Joseph 00:56:00.120 --> 00:56:01.520 Final determination. 57 Haga Joseph 00:56:03.240 --> 00:56:23.720 So in closing in California, we're lucky to have many really engaged experience broadband stakeholders, many of them in the room interested in bed at California has a robust history of running state broadband grant programs. I encourage California to use the lessons that learned from that history in order to implement feed, but also to not be a. 58 Haga Joseph 00:56:24.400 --> 00:56:37.200 Creatively about how to design bed outside of past perimeters. I look forward to hearing the conversation today and I'm always here as a resource for any stakeholders that want to discuss the bed program further. Thank you. 59 Haga Joseph 00:56:40.360 --> 00:57:00.200 Thank you, Marina. At this time we are opening an opportunity for public comments generally speaking, and if folks would like to comment, they may do, so by going through the diet, let me make sure if it's not, this button is not green. Please make sure it is gre. 60 Haga Joseph 00:57:00.440 --> 00:57:02.320 When you come up. 61 Haga Joseph 00:57:04.200 --> 00:57:18.320 So at this time we want to open this up and also I'm not trying to ambush, but I may also refer back to our folks tracking the web chat to see if there's anything that they would acknowledge from the web chat. 62 Haga Joseph 00:57:19.480 --> 00:57:28.360 If you are interested in providing some general comment, please come up and share your name and your affiliation and you've got a couple minutes on the floor. 63 Haga Joseph 00:57:32.200 --> 00:57:33.320 Okay. 64 Haga Joseph 00:57:42.480 --> 00:57:53.000 I just had a question regarding federal lands and if they will be considered as well within the state of California for the B program. 65 Haga Joseph 00:58:00.400 --> 00:58:08.040 Such as the Procedio. I, I believe if there are a national broadband maps, then there's. 66 Haga Joseph 00:58:09.960 --> 00:58:14.720 Within the state of California or some. Okay, thank you. 67 Haga Joseph 00:58:20.000 --> 00:58:22.240 Do we have anybody on the chat. 68 Haga Joseph 00:58:24.040 --> 00:58:26.040 Okay, great. 69 Haga Joseph 00:58:29.160 --> 00:58:40.760 I'm just gonna give it a few more minutes. Oh, we can sit here in a bit of awkward silence for a bit as we allow people to just think about this and also trickle in for a couple more minutes. 70 Haga Joseph 00:59:59.400 --> 01:00:19.240 So I've been alerted that I did not turn on my microphone to answer. So sorry about that. So the question was about whether federal lands are potentially eligible for bed. I think the, the thing here is that if there's, if it's a BSL on the FCC national broadband map, it's potentially eligible for bed funding. The question. 71 Haga Joseph 01:00:20.040 --> 01:00:39.720 Through the challenge process, whether it is determined through the state to be served or unserved and then of course in terms of the actual category of the type of location versus would we, you know, would you consider something like, is it a house on, on federal lands a residents or is it like? So if you're talking. 72 Haga Joseph 01:00:40.480 --> 01:00:56.640 DIOS, that community anchor institution, there's a little bit there, but potentially, if it's a broadband serviceable location on the FCC national broadband map it is, it can potentially be funded by B- to build out service there. 73 Haga Joseph 01:01:34.760 --> 01:01:55.240 Okay, seeing as we don't have any public comment at this time, we can proceed with our agenda and our panels and our overview we will because we didn't have any public comment at this time, and we don't want a short change that opportunity. We will be having that opportunity at the end of this work. 74 Haga Joseph 01:01:55.680 --> 01:02:08.920 As well for another, for the balance of our time for twenty- five minutes. So with that, if we with that, if we could invite our first panelist to come up and let me. 75 Haga Joseph 01:02:09.960 --> 01:02:30.440 You've got, we've got several folks online, so I'm gonna ask that we first get everyone situated who is here with us in person and, and let an please correct me if I'm wrong Jonathan, but I do believe that we also have Syd. 76 Haga Joseph 01:02:32.360 --> 01:02:41.320 Online as well. We also have Natalie Gonzalez online and Alex Dumato online. 77 Haga Joseph 01:02:48.360 --> 01:02:56.640 I can confirm that Alex Dmato and Natalie Gonzalez are online, and I'm sorry, the third name was at Lindsay Scalic. 78 Haga Joseph 01:03:08.840 --> 01:03:10.880 I do not see Lindsay online. 79 Haga Joseph 01:03:15.240 --> 01:03:33.160 We have been out earlier, but apparently she's not logged in right now. So at this time, what we're gonna do is we're gonna provide a quick overview of the first topics that we're gonna talk about, which is the challenge process and before we dive into that, I'd like to just have everyone. 80 Haga Joseph 01:03:33.800 --> 01:03:42.800 Their name and their affiliation folks that are both on online and in our panel to state their name and their solution. 81 Haga Joseph 01:03:44.120 --> 01:03:46.160 Patrick, do you want to start. 82 Haga Joseph 01:03:49.160 --> 01:03:56.080 Good morning everyone. My name is Patrick Messic. Here representing Oakland and divided, and the city of Oakland. 83 Haga Joseph 01:03:57.520 --> 01:04:18.600 Good morning lanceware from AVX networks and representing Catalina and Avalon, California. Good morning Charlie and single sing representing the Green Lining Institute. Good morning I'm Meredith Williams, I'm with at and T- good morning Paul Goodman with Centerfect, accessible technology. I also want to note that we've been coordinating. 84 Haga Joseph 01:04:19.440 --> 01:04:39.080 And CWA District nine and Cal advocates and those four groups have sort of assigned a lead for each each panel. So we leave it to speaking generally about the areas of agreement to the extent. There are nuances or diverse opinions between those groups who will address those in common. Thank you. 85 Haga Joseph 01:04:40.360 --> 01:04:51.800 I'm Scott Armstrong from, in your county on the regional broadband coordinators who supporting both in you and Mono counties. Can we hear from our online panelist introduction? 86 Alex Damato 01:04:55.720 --> 01:05:11.720 I don't know if there's an order, but I'm happy to go first. I'm, Alex Dmado here in behalf of Cal Broadband and I apologize for not being able to logistically make it there in person, but thanks for including us virtually as well. 87 Natalie Gonzalez [CCF] 01:05:14.440 --> 01:05:21.080 Natalie Gonzalez, the deputy director of the Digital Equity Initiative from California Community Foundation, happy to be here. 88 Haga Joseph 01:05:27.160 --> 01:05:45.640 Okay, great, so with that, I'm gonna turn it over to Ben Menzi to provide us an overview of the topic, the challenge process and then we're gonna open this up for some dialogue. Great, thank you, Maria and thank you to all of our panelists for joining us today as well as all of the other. 89 Haga Joseph 01:05:45.720 --> 01:06:06.120 Attendees in the audience and the folks online, hopefully I think my slides should come up in a second here, but I'm going to provide a brief overview of the requirements in the challenge process. The challenge process for bed is described in detail as Marina mentioned in the notice of funding opportunity or no. 90 Haga Joseph 01:06:06.240 --> 01:06:27.240 Which is starting and starts on page thirty four as well as a challenge process policy notice that's available online. The main requirement that the no fo establishes for the challenge process is that it must be fair evidence based transparent and expeditious and it defines some specific phases that have to be. 91 Haga Joseph 01:06:27.520 --> 01:06:41.520 Out in the challenge process, including publication of an initial eligibility map, a challenge phase, a rebuttal phase and finalization of the eligibility map before subgranties can be selected next slide, please. 92 Haga Joseph 01:06:44.440 --> 01:07:03.080 Indicates that the challenge process may be open to challenges from local or tribal governments, nonprofit community based organizations and broadband service providers residents may participate in gathering data to support the challenge process, but those challenges have to be sub. 93 Haga Joseph 01:07:03.480 --> 01:07:23.560 Through permissible challenges a challenges as described above challengers may challenge the classification of a location as unserved underserved served or that it has community anchor institution status in compliance with the Beed statue, but challengers may not challeng. 94 Haga Joseph 01:07:23.760 --> 01:07:44.040 The fabric, meaning that it is not, we cannot consider challenges to add a location to the map or subtract one. Finally, once the CPUC has conducted our challenge process in accordance with Beed rules, the NTIA will review our methodology for adjudication and will ultimately make all final decisions about. 95 Haga Joseph 01:07:44.760 --> 01:07:49.480 Of locations on the beat eligibility map next slide, please. 96 Haga Joseph 01:07:54.280 --> 01:08:11.560 The, the beat. No, Fo also describes some basic timing requirements that the challenge process must meet and these are also laid out and the challenge process policy notice within these guidelines states have some flexibility in determining the length of different phases of the challenge process, but there's a MAX. 97 Haga Joseph 01:08:11.920 --> 01:08:32.040 Of a hundred and twenty calendar days from opening of the challenge window to submission of our proposed final map to NTIA. In addition, there must be a minimum of fourteen calendar days for the window for challenges and rebuttals, Those are separate fourteen of each and a minimum of sixty calendar days from publishing the final map after approval by. 98 Haga Joseph 01:08:32.120 --> 01:08:51.400 NTIA to making allocation decisions, meaning concluding the grant round. There is no requirement in the no fo for a project challenge phase as Marina mentioned, that's something of a change from our other state broadband grant programs, the challenge process only applies to the eligibility map. Next slide, please. 99 Haga Joseph 01:08:57.000 --> 01:09:13.000 Oop, there we go. Oh, actually I think it was the previous one. Sorry, there we, no, I guess it was, sorry, got a little confused. All right, so the, as. 100 Haga Joseph 01:09:13.440 --> 01:09:34.120 Marina describes the NTIA has provided a model challenge process that's pre- approved by NTIA and is encouraging states to adopt a process as close to the model process as possible in order to expedite review, but deviations may be proposed subject to the NTIA approval and in compliance with Beed rules. There are several steps in the model challenge process. 101 Haga Joseph 01:09:34.160 --> 01:09:54.600 Which I'll describe briefly. Those include the publication of the initial map in a public on a public website, then there's a challenge phase that would last thirty days calendar days followed by a rebuttal phase in which providers may rebut the challenges that have been received, which would last thirty days a determination phase. 102 Haga Joseph 01:09:54.720 --> 01:10:15.080 Which all contested locations would be subject to adjudication by the CPUC on a rolling basis and finally the eligibility map would be submitted to NTIA for their review and adjudication of all of those decisions, which would ultimately be followed by publication of a final eligibility map at least sixty days before. 103 Haga Joseph 01:10:15.160 --> 01:10:20.640 Making allocation decisions for subgrantees next step slide. Please. 104 Haga Joseph 01:10:22.760 --> 01:10:43.880 As Marina mentioned, the model challenge process includes several optional modules that states may adopt in order to make the maps more accurate. These include the DSL modules that Marina mentioned in which we may mark prior to map publications. We may treat locations that achieve served speeds according to deployment data. 105 Haga Joseph 01:10:43.960 --> 01:11:04.360 That are based on DSL technology. Those may be modified to show up as underserved on the eligibility map. There's also an area or multiple dwelling unit module, which means that after there's a number of challenges in a discrete area have been filed. The provider must affirmatively demonstrate service. 106 Haga Joseph 01:11:05.600 --> 01:11:25.920 Same area, so for instance, in a sensus block group, if there are six locations that are challenged within the same sensus block group, then the provider must prove that all the Bsls within that census block group are in fact served similarly within that module, it can apply to multiple dwelling units or apartment build. 107 Haga Joseph 01:11:27.200 --> 01:11:46.400 In which the larger of either three units or ten percent of the units listed within the fabric in that building would apply, would create an area challenge. Finally, there's a speed test module which allows reclassification of served locations as underserved if data. 108 Haga Joseph 01:11:46.560 --> 01:12:06.880 Collected pursuant to rigorous speed, test methodologies that are determined by NTIA demonstrates that speeds do not achieve the service thresholds that are claimed on the map. I should note, however, that the latest version of the model challenge process as published by NTIA only allows speed test data to be used to shift locations to underser. 109 Haga Joseph 01:12:08.320 --> 01:12:11.120 Status next slide. Please. 110 Haga Joseph 01:12:13.920 --> 01:12:33.120 To get into the speed test module in a little bit more detail. There are some pretty rigorous requirements entailed in meeting the rigorous speed test methodologies that Ntia has described in the model in the, in the challenge process policy notice one important one is that data that is submitted through the challenge por. 111 Haga Joseph 01:12:33.440 --> 01:12:53.600 For a speed test must include the name and street address of a customer, a certification that the customer is subscribed to a relevant speed tier. meaning one that would achieve served speeds and there must be a data sharing agreement with the provider and operators of the challenge process to allow the providers that are challenged and those running the challenge process to review the data Al. 112 Haga Joseph 01:12:54.880 --> 01:13:13.640 Personally identifiable information would not be disclosed in any public setting. Tests must be conducted at most sixty days before the challenge period opens and only speed tests on subscriptions above one hundred twenty megabits per second are allowed to be considered as part of the speed test data. 113 Haga Joseph 01:13:14.080 --> 01:13:34.560 Another important requirement as laid out in the, in the challenge process policy notice is that the speed tests must consist of three tests conducted on different days and only the median speed result would be considered as part of the speed based challenge. So if a subscriber condes conduct speed tests. 114 Haga Joseph 01:13:34.920 --> 01:13:55.040 Speeds of one hundred one twenty and eighty on three different days, then only the one hundred download speed would be part of the speed test challenge additionally, providers may rebut the area speed challenges based on what NTIA refers to, as the eighty eighty rule and, and that means that the provider must select ten. 115 Haga Joseph 01:13:55.200 --> 01:14:11.480 Percent of locations in the challenged area on a random basis, eighty percent of those selected locations must have speeds demonstrated to equal or exceed eighty percent of the served threshold or eighty twenty megabits per second. Next slide, please. 116 Haga Joseph 01:14:14.880 --> 01:14:33.440 Finally, before we go to our panel, I wanted to highlight another important requirement in volume one, which is the duplication of enforceable commitments to deploy broadband according to the no fo, the eligibility map may not mark locations as unserved or underserved if that location is already subject to an enforceable federal state or local commitment. 117 Haga Joseph 01:14:33.480 --> 01:14:53.920 To deploy qualifying broadband service before the challenge process takes place those enforceable commitments will be identified based on federal state and local programs and the no describes some of those in detail at, on pages, thirty- six and thirty- seven, but also that as mentioned includes state and local programs that are not mentioned in the no fel, those. 118 Haga Joseph 01:14:53.920 --> 01:15:14.400 Those enforceable commitments, meaning a grant or alone or some similar commitment to deploy broadband must meet the technology and speed requirements for broadband. So if the commitment is to deploy, not qualifying speeds or not qualifying technologies, then it doesn't count and unforceable commitments on Tribalands only count according to the no, Fo, if there is a legally. 119 Haga Joseph 01:15:14.680 --> 01:15:26.600 Agreement with the Internet service provider, including a tribal government resolution, however, that requirement may be waived by the NTIA Assistant Secretary if necessary to achieve the goals of the program. 120 Haga Joseph 01:15:27.840 --> 01:15:47.360 And with that, I think I will turn it back to Maria. Thanks Ben for that overview. I couple notes. I do believe that we have our other panelists online and I don't know if they would like to introduce themselves. It is Lindsay, do you want to just take a moment to introduce yourself? 121 Lindsey Skolnik 01:15:47.680 --> 01:15:50.240 Sure thing can you hear me? Okay? 122 Lindsey Skolnik 01:15:52.880 --> 01:16:02.120 Everyone, I'm Lindsay's call neck. I am the project manager at the California Alliance for Digital Equity. Open be participating on panel one today. So thank you so much for having me. 123 Haga Joseph 01:16:02.400 --> 01:16:15.480 Thank you, so, and then also just want to share that this, this Powerpoint will be me available on this part. We could put this online as well. So nobody has to take very copious notes here. 124 Haga Joseph 01:16:16.480 --> 01:16:37.600 So with that, I'm gonna turn it over to our. These are the questions what I'm gonna do is I'm gonna just read the questions for those that are auditory leading and so, and we'll also have them here written and then I'm gonna open this up for a discussion and again, why don't we remind folks that we are asking everyone to every panelist to limit their comments to five. 125 Haga Joseph 01:16:37.680 --> 01:16:58.080 Minutes, I'm gonna lean, I'm gonna rely on Jonathan to tell me when I'm online panelist has a, has a hand raised or is, is up and I will call on everyone in terms of groups of our consumer advocates, our, our tribal partners as they are. Present are industry partners. 126 Haga Joseph 01:16:58.080 --> 01:17:18.560 And we'll go from there, but real quick I'm gonna read these questions for everyone and pardon me if I'm stumbling through them as part what aspects of the module of the model challenge process would should be adopted or modified what additional data resources such as CPEC, availability data or demographic dat. 127 Haga Joseph 01:17:18.680 --> 01:17:39.040 Should be utilized in the commissions pre- challenged eligibility map, What forms of public and stakeholder engagement before the challenge process would be, most valuable is when should engagement occur are there modifications or additions to the commission? The commission should make to the NTIA definition of commun. 128 Haga Joseph 01:17:39.680 --> 01:17:59.520 Institutions, how should the commission structure? The required d- duplication process for removing locations with enforceable commitments, deploy broadband for the beat eligibility map and lastly, how should the commission apply the definition of the enforceable commitment area to tri. 129 Haga Joseph 01:18:00.560 --> 01:18:20.000 Should the definition of an enforceable commitment be restricted for the deployment on tribal lands to those projects with a tribal government resolution between the Tribal government and the broadband service provider. What would constitute a tribal resolution. So these are the questions before us and with that, I'm gonna start. 130 Haga Joseph 01:18:20.680 --> 01:18:32.720 I'm gonna open this up to first. I'm gonna start with Caroline. I'm gonna start with Paul and I do believe we have someone online from Kate. 131 Lindsey Skolnik 01:18:35.360 --> 01:18:36.000 I'm from. 132 Haga Joseph 01:18:37.320 --> 01:18:56.480 Great, so with that, I'm gonna go ahead and open it up. Folks you have each of you have five minutes. We also have eighty seven attendees online. That sounds like we have each of you have five minutes to respond to the, to these questions and provide comments point of information. I thought we were supposed to split the five minutes amongst the first. 133 Haga Joseph 01:18:56.760 --> 01:19:16.960 Presenters... Oh, apologies apologies. Yes, please don't gone. Perfect. Thank you. Good morning Charlotte. From the Green Landing Institute again, and for this item, I'll just run through it in alignment with Ntias stated priorities such as transparent events based and expeditious process. 134 Haga Joseph 01:19:17.200 --> 01:19:37.440 We ask the commission to create a process which does not unduly shift the burden of proof onto consumers, particularly low- income consumers of color in California who would not normally have the apparatus available to submit challenges, even though they do receive subpar service at their locations. We believe that there should be a final process. 135 Haga Joseph 01:19:37.920 --> 01:19:57.920 Which places the owners back onto providers to prove that they are in fact, providing advertised service to consumers and that the baseline assumption for the challenge process should not be that consumer should have to prove and multiple avenues that they do receive for service quality. We additionally disagree with the need for consumers to submit. 136 Haga Joseph 01:19:58.640 --> 01:20:09.120 Requirement to submit a challenge in particular due to concerns over the transmission of personally identifiable information of consumers through multiple parties as part of the process. 137 Haga Joseph 01:20:10.480 --> 01:20:30.560 Last few points we do support the addition of crowd source data as was mentioned in earlier comments submitted to the commission and we are hoping to get additional clarity on Mdus. This is an issue that particularly impacts, low income urban communities in California and we are concerned that the threshold of. 138 Haga Joseph 01:20:30.720 --> 01:20:44.680 Three units or ten percent is much too high and will prevent a lot of localities from submitting challenges to locations that are currently unserved or underserved in their area. Thank you. 139 Haga Joseph 01:20:49.120 --> 01:21:06.400 Thank you, Paul Goodman with center for accessible technology. given the time I want to address two things, the first is I think there's a really real information and resource Imbalance between challenges who are providers and challengers who are not. I. 140 Haga Joseph 01:21:07.820 --> 01:21:27.660 Providers have data, although it may not necessarily be in a format, they can access easily about who they can serve and who they can't and whereas local tribal nonprofit entities, it's harder for them to collect that data. So I'm asking if the commission. 141 Haga Joseph 01:21:28.300 --> 01:21:42.500 Interpret requirement that the process be fair doesn't requirement the process be equitable. My second point relates to the question about what additional data sources, the commission should use. 142 Haga Joseph 01:21:43.660 --> 01:22:04.140 I'll note that the require beed requirements require that. Any project built with Beed funding have at most twenty- four hours of outages every three hundred sixty- five days over three hundred sixty- five day period. We have a lot of providers in California that cannot meet that standard. Now. 143 Haga Joseph 01:22:07.620 --> 01:22:10.780 A very fair metric would be. 144 Haga Joseph 01:22:11.820 --> 01:22:27.820 A provider's past performance and service quality. So areas that consistently have outages that's total more than twenty four hours. I just score lower than- than providers that do not. thank you. 145 Lindsey Skolnik 01:22:31.660 --> 01:22:52.140 Hi, everyone, I'll go next. Like I said, my name's when Lindsay School, Mick, I'm here today representing Kate. I'd like to provide a few brief remarks and response to the design of the pre- eligibility map and the types of data, the maps are rely upon paid fields. It is essential that the pre eligibility map does not rely upon the same data sets that shape the federal funding account and middle mile broadband initiative maps. 146 Lindsey Skolnik 01:22:52.780 --> 01:23:12.620 These maps were demonstrably flawed prioritizing infrastructure and areas that are the most served in the state rather than the most disconnected and historically disenfranchised many digital equity advocates have recently voiced their concerns about both of these maps over the last week. Alone advocates have provided more than fifty public comments at the recent MMAC in California broadband council meetings to. 147 Lindsey Skolnik 01:23:13.460 --> 01:23:33.100 Widespread community frustration, however, this speed sho workshop marks an inflection point at which the CPUC can respond to those concerns and make thoughtful improvements to the pre- eligibility map. These improvements could include balancing granular address level ISP data with data collected by community as well as open data sets. There are a number of commun. 148 Lindsey Skolnik 01:23:33.380 --> 01:23:53.580 Data collection projects underway such as surveying and crench and speed testing in Oakland that could, and should be used to generate map a map. The better represents the real unserved and underserved locations across the state conditionally, Ukla's network maps and speed tests should also be used to source truth about unserved. 149 Lindsey Skolnik 01:23:53.620 --> 01:24:10.260 Locations and locations that generally exist if these proactive steps are not taking to generate an improved map, we worry the being challenged process could be ineffective and it could also place increased burdens on community to prove locations. Are in fact unserved. Thank you. 150 Haga Joseph 01:24:14.060 --> 01:24:26.380 Thank you and I also just wanna do a quick check online is to see if Mr. RAM Tenan or Mr. Coreyto have been able to join us representing tribal interest. 151 Haga Joseph 01:24:39.020 --> 01:24:58.220 Okay, well we will, we have a bit more time to get to that next up. We want to hear from our community breaths and so that is Oakland undivided CCF and any account. So I'm gonna go ahead and start here. go around, so Patrick, you're up. 152 Haga Joseph 01:24:58.860 --> 01:25:19.980 Good morning, judge commissioners, panelists and partners in digital equity across the state. My name is Patrick Messic. and today I represent the city of Oakland and Oakland divided the rules developed to allocate this once in a generation broadband infrastructure will determine if this historic funding reaches the Californians, it's intended to serve or if you had another public infrastructure investment will bypass the marginalized predominantly black and brown communities. 153 Haga Joseph 01:25:20.620 --> 01:25:40.460 And I'm grateful here to be here to uplift their voices. There are two guiding principles that should serve as a framework for the development of the challenge process. The first is transparency. The commission should adopt processes that keep the stubbornly secret of process for generating the broadband service aka funding eligibility map. 154 Haga Joseph 01:25:40.580 --> 01:26:01.580 Out in the open and apply the lessons learned from the FFA last mile application, the first lesson address level data, the DEED service map should include address level data if funding prioritizes unserved locations, it's only logical that the map features address level data, the service polygons on the FSA map, make it virtually impossible. 155 Haga Joseph 01:26:01.700 --> 01:26:22.060 To challenge the map or intentionally design projects secondly, socio- economic data layers, the single greatest predictor of California's access to Reliable high speed internet is income and race, the beed map should add a minimum include layers of Calen buyer screen disadvantage communities and the quartiles of the socio- economic vulnerability index. 156 Haga Joseph 01:26:22.700 --> 01:26:31.500 The second guiding principle for this framework should be equity as the CPUC has said time and again, deed without equity is just bad, and if this. 157 Haga Joseph 01:26:39.340 --> 01:26:40.580 All right. 158 Haga Joseph 01:26:41.940 --> 01:26:48.980 Welcome to the highway. We're used to this now in the hybrid environment. Oh, should I should, I. 159 Haga Joseph 01:26:50.220 --> 01:26:58.620 I may need you to repeat that and we'll re- we'll restart it five. All right, consider that your dry run, there we go. 160 Haga Joseph 01:27:16.460 --> 01:27:35.660 Good morning again, everyone my name is Patrick Messic. and today I represent the city of Oakland rules developed to allocate this once in a generation broadband infrastructure will determine if this historic funding reaches the Californians, it's intended to serve or if you had another public infrastructure investment bypasses marginalized predominantly black. 161 Haga Joseph 01:27:36.060 --> 01:27:48.700 Communities and today I'm grateful to uplift their voices. The challenge process should be guided by a framework that centers two principles. The first is transparency, the commission should. 162 Haga Joseph 01:27:54.700 --> 01:28:10.220 All right, transparency the commission should adopt processes that keep this stubbornly secretive process for generating the state broadband service maps out into the open and imply lessons learned with the FFA last mile application address level. 163 Haga Joseph 01:28:12.140 --> 01:28:31.340 Service map must include address several data if funding prioritizes, unserved locations, it's only logical that the map features address level data, the service polygons on the FFA broadband service map, make it virtually impossible to challenge the map because you can identify which specific locations are on served. 164 Haga Joseph 01:28:32.140 --> 01:28:51.820 Economic data layers. The single greatest predictor of California's access to Reliable high speed internet is income and race, the beed map should add a minimum include Calen buyer screen disadvantage communities and core tiles of the socio- economic vulnerability index equity, the second principle as the CPUC has said time, and again, beed without equity is. 165 Haga Joseph 01:28:52.500 --> 01:29:12.300 And if this generational infrastructure investment is going to be different, the CPUC must enact a challenge process that centers the lived experiences of those most impacted by the digital divide, historically, red line black and brown communities, low income rural communities and our traveled brothers and sisters if past performance is the best predictor of future success, we have. 166 Haga Joseph 01:29:12.380 --> 01:29:32.780 A lot of room for improvement from FFA to bed, I cannot emphasize enough the importance of addressing the black box process. We're in the CPUC receives data from the federal government showing California's wealthiest most connected communities is served this data goes into the CPUC Black Box something involving confidential subscriber, DAT. 167 Haga Joseph 01:29:33.460 --> 01:29:43.660 And then on the other end, the state generates a state map that adds a preponderance of demonshably served clusters as funding priorities for these scarce funds. 168 Haga Joseph 01:29:46.380 --> 01:30:03.580 County two of our wealthiest communities, liver more and pleasant. The FCC map shows these as entirely served common sense where ninety- seven percent of folks in these communities have high speed internet would say that it's entirely served yet. The CPUC has had no less than seven dense clusters in Livermore. 169 Haga Joseph 01:30:05.420 --> 01:30:12.580 And eleven dense clusters in Pleasantin, if not conjecture that these are served. 170 Haga Joseph 01:30:14.460 --> 01:30:24.940 Our friends at the ISPS have publicly available addressed lookup tools where you can type in these addresses and not only do they offer plans, but they'll tell you, you have an active account at this address. 171 Haga Joseph 01:30:30.740 --> 01:30:46.380 Understand that Isp's operate under a different set of motivations and have a fiduciary responsibility to their shareholders. It would be imprudent of them not to propose projects in these areas that they serve and as we now see on the FFA area map at, and T- has projects. 172 Haga Joseph 01:30:46.420 --> 01:31:07.500 Proposed in Pleasantin and Livermore because they're funding eligible, This cannot be the starting place for bed. So where should be our starting place. We should be starting in the communities where we know the digital divide resides and Allomita County. that is overwhelmingly the flatlands of Oakland, West Oakland fruit Vale and deep Stoakland. 173 Haga Joseph 01:31:08.940 --> 01:31:29.420 That the current maps and CPUC processes vastly understate need in these communities, we know because we've been in the cabling closets in public housing and seeing the rats ness of DSL cable supportedly serving entire communities of oaklanders. I want to be cognizant of people and just want to make sure that all the other part. 174 Haga Joseph 01:31:29.780 --> 01:31:49.900 In this cluster can do that comment. Great, I'll wrap up in the next minute or two, but when you look at the map again, just as far as peppering of UNSURF locations, we know this is not true because we run speed tests on thousands of district devices and have identified thousands of AD. 175 Haga Joseph 01:31:50.540 --> 01:32:11.020 Unserved locations based on publicly available speed test data. So how do we get our communities back on the map? Let me go over quickly a few of the key tenants first. We have to shift the burden away from those who are unserved to prove that they are unserved and empowered municip municipalities and trusted anchor institutions to submit challenges at scale. 176 Haga Joseph 01:32:11.020 --> 01:32:31.500 A challenge should only require three data points. the address, the provider and an internet quality metric speed latency outages, et cetera. Customer bills should not be required if ISPS do not have to submit a consumer bill to prove that the location is served, Neither should the consumer at? Oh, when we. 177 Haga Joseph 01:32:31.700 --> 01:32:51.980 To get a copy of our residents bills it took some of our residents, an hour and a half on the phone with Comcast to get a copy of their bill, but not so fine print on the bill makes clear that these are advertised speeds, not actual speeds and to require this unnecessary documentation, essentially precludes any municipality or nonprofit from submitting data at scale, similar previous. 178 Haga Joseph 01:32:52.060 --> 01:33:12.460 Proceedings DSL should be outright disqualified and for individuals who want to submit a challenge, there should be a simple web- based portal with API, not requiring an app download to submit a personal challenge process finally for M- to use California is Mdus are not like other areas where. 179 Haga Joseph 01:33:13.740 --> 01:33:32.940 All publicly owned, most of California is MDUS and public housing is actually voucher based. So the CPUC needs to take a very close look at how it defines public housing to be inclusive of farm worker housing and other communities that live in low- income housing finally to ask that a challenge from one MDU receive up to ten. 180 Haga Joseph 01:33:33.300 --> 01:33:51.740 Of challenges from the units is quite frankly absurd in a, in a building with a hundred folks that would require ten that are all relying on the same internal wiring to submit a speed test, which is not feasible at scale. Thank you so much for your time. And I hope again, that we can center the communities, This funding is intended to serve. 181 Natalie Gonzalez [CCF] 01:33:53.420 --> 01:34:13.780 Thank you, Patrick and apologies for the tick issues that we might be having. okay, I want to keep going. keep us going to our next panelist one second and I'm gonna turn it over to Natalie. Thanks so much. Can everyone hear me? Okay? 182 Natalie Gonzalez [CCF] 01:34:16.460 --> 01:34:36.940 Much commission and thank you everyone for happiness here today, again, my name is Natalie Gonzalez. The Deputy director of the Digital Equity Initiative from California Committee Foundation. The digital equity initiatives across sector, all coalition of more than fifty organizations serving communities across La County in the state, I want to first address our marks and response to the stakeholder engagement for the challenge process. We want. 183 Natalie Gonzalez [CCF] 01:34:37.020 --> 01:34:57.420 The commission to be aware that it's critical that the state engaged with community more thoughtfully impactfully and engage with industry more transparently we want to highlight that while industry has been actively engaged through data submissions and closed our meetings communities have primarily been recipients of one way information via newsletter webinar or updates to publish. 184 Natalie Gonzalez [CCF] 01:34:58.900 --> 01:35:17.900 Looks more than just workshops and webinars. It means actively incorporate our input and ground truth knowledge in the process for meaningful inclusion of community generated data and the maps driving the various programs to explicitly ensuring the industry and community input are weighted at least equally, in addition to. 185 Natalie Gonzalez [CCF] 01:35:18.620 --> 01:35:38.380 The state should commit to, as much transparency as can possibly achieve without compromising legitimate trade secrets and the wake of the community challenges to the FFA priority maps. The commission updated the public maps to exclude propose subsidy calculations to move those same discriminatory calculations behind the ND. 186 Natalie Gonzalez [CCF] 01:35:39.020 --> 01:35:59.500 NDA, accessible only to FA applicants and trying their hands with respect to advocacy regarding all the issues. The maps retain the commission has utilized several cost questions in rationale for various decisions and directions this, even though the cost was data is inaccessible to the public. The details of the model remain obscured and specific. 187 Natalie Gonzalez [CCF] 01:36:00.780 --> 01:36:19.980 Problematic issues and community and consumer advocates when we raise them only raises additional red flags overall it's critical that the state moved from a modeling of telling the community what's happening after it's happened to one of more true engagement. Second, we want to address models for adoption. We want to call attention to the option. 188 Natalie Gonzalez [CCF] 01:36:21.580 --> 01:36:40.460 Three outline in Ntias be challenge process regarding Mdus and DSL in the case of option module two, we propose taking this up further by reclassifying MDU locations, currently labeled as underserved on DSL to unserved. This shouldn't require community challenge. according to the F. 189 Natalie Gonzalez [CCF] 01:36:40.780 --> 01:37:01.580 We know that DSL speeds average thirty megabits download and three megabits upload make it unreliable for any member of a household to be online going even further, this doesn't even meet the needs of being served and to use with DSL service and the suite experience by each household varies based on the distance of the copper lines from the unit to address the CSL limitation provider. 190 Natalie Gonzalez [CCF] 01:37:01.700 --> 01:37:22.060 Have tried a technique known as pair bonding, which merges the two separate copper lines into a single connection. However, this approach results and service access to only one out of every two households, leading a significant portion of households being classified is unserved reclassifying these locations as unserved will expedite the retirement about dated copper infrastructure. 191 Natalie Gonzalez [CCF] 01:37:22.180 --> 01:37:38.060 And ensure communities have reliable and future proof broadband service in order to ensure transparency and provider accountability in cases where an MDU is challenged. It's unserved the burden shifts to the provider to demonstrate unit level service is provided at advertise speeds. 192 Natalie Gonzalez [CCF] 01:37:39.340 --> 01:37:59.180 That in twenty- twenty three, a minimum of a hundred megabits per household is essential for accessing telehealth educational content, video conferencing immigration cases, online and entertainment is evident that DSL speeds all short of the demands of our modern online environment. We hope that the state and the commission aligned with the requirements of the modern digital error. 193 Natalie Gonzalez [CCF] 01:37:59.220 --> 01:38:19.660 Adopt this new one. The second adoption we want to propose is reclassifying locations for them being marked as served on the national broadband map where license fixed wireless is a sole technology being offered examples include t- mobile Verizon, we're four G and five G home internet is most available and moving that to unserved this reclassification is Justifi. 194 Natalie Gonzalez [CCF] 01:38:19.860 --> 01:38:40.140 As according to speed test dot net for March, twenty- twenty- three, the median cellular internet speeds in the United States was approximately eighty Megabits download and ten Megabits upload falling short the definition of again being served cellular networks inherently exhibit significant disruptions and reductions and service as users move farther away from the source, such as a cell tower. 195 Natalie Gonzalez [CCF] 01:38:40.220 --> 01:39:00.620 Advertise data rates are frequently not even achieved with a short distance between a one to two miles of a cellular source from a cell tower, although these providers may not impose and reasonable data caps, they do enforce throughput limits and prioritize traffic on data plans. Even a relatively light data user conceiving a little as fifty gigabytes of the data billing cycle can. 196 Natalie Gonzalez [CCF] 01:39:01.020 --> 01:39:21.100 Extensive bandwidth allocation reduction also known as Rottling during a congestion network period, what's even more concerning, is that communities have shared their experience with unreliable service under fixed wireless plans to the extent they are unable to attain the essential twenty- five three speeds required to meet the criteria being counter- categorized is unserved or. 197 Natalie Gonzalez [CCF] 01:39:22.420 --> 01:39:24.500 Thank you so much for your time. 198 Haga Joseph 01:39:26.860 --> 01:39:47.340 Thank you, now I'm going to turn over to Scott. Mr. Scott, Armstrong. Good morning, good morning Commissioner. Haulk Directorizebornela. I just have a couple of recommendations for the commission to consider when they're looking at modules to include and probably the, the modul. 199 Haga Joseph 01:39:47.460 --> 01:40:08.460 I think think is the most valuable to include in the challenge process would be a speed test module and acknowledging that there are some challenges for individuals having to respond to speed test requirements to fill out forms. We're doing that as well. Getting data from the consumers is. 200 Haga Joseph 01:40:08.500 --> 01:40:28.940 Usually quite difficult getting people to take the time to do it as quite difficult. So looking at what I saw the CPU C- do during the digital equity survey, they included a speed test in that survey and I thought that was pretty slick because it presented. 201 Haga Joseph 01:40:30.940 --> 01:40:49.420 Speed test for people to click on capture the information and moved on so that, right there does several things it gets, it makes it easier for the person to take the speed test. It's a consistent test with, without having to look at the different types of speed test. you're doing and. 202 Haga Joseph 01:40:51.020 --> 01:40:53.700 Information, right back to you guys where you need it. 203 Haga Joseph 01:40:55.180 --> 01:41:15.660 Now if it's a challenge process that a provider is asking for, we may need to be able to provide that information to them as well, but I think that presenting an easy access speed test, maybe, you know, if a provider needs to want to challenge and they want to challenge specific addresses, they can, we can. 204 Haga Joseph 01:41:17.500 --> 01:41:37.980 Email message saying please do this. Your location is being challenged and we'd like you to do this and just make it as easy as possible. So focusing on making it easy on the easy on the people who are doing the test because you really need to do it from location and also making consistent so that you're always measuring apples to apples. I think that would be very beneficial. now. 205 Haga Joseph 01:41:39.340 --> 01:41:58.460 I believe I saw in the V- no, fo that at the end of the project also requires speed tests. So it's a trust, we verify once it's done, you have to do the same thing unless I'm reading it backwards. Is that correct that I would. 206 Haga Joseph 01:41:59.100 --> 01:42:18.940 I want to refer to the no Fo, but I believe you. Yeah, I, I, I was looking through it and I'll double check, but I think that if, if in fact there is a speed test requirement for providers, once they deliver the service that same speed test can be used and also I think. 207 Haga Joseph 01:42:18.980 --> 01:42:39.420 There was a mention that challenges needed to be an information needed to be available for the challenge, so it could be who the provider, if they're asking to cover an area say I, they've identified this area to be to get a grant to send a message out saying we're going. 208 Haga Joseph 01:42:39.460 --> 01:42:59.900 Going to apply to cover your area. Would you please complete this speed test that he could speed test data in advance of that. It could also verify how they're associated with the SCC map and two other points. I'd like to make DSL while squeaking above the threshold of being. 209 Haga Joseph 01:43:01.860 --> 01:43:20.380 We're looking at how to future proof our digital world today, and while yes, it technically can meet the threshold of being served the next time our served threshold increases it won't. So if we exclude it now, a plan for that maybe put them. 210 Haga Joseph 01:43:21.780 --> 01:43:40.860 On a second wave or whatever we are looking at future proofing our, our internet connections and the last one has to do with multiple drawing units. Multiple dwelling units are kind of interesting, but if there's some way to define the number of tests required in an. 211 Haga Joseph 01:43:42.260 --> 01:44:01.340 In different locations, some end user, multiple stories, some are really spread out. Internet service is gonna come into the facility in one location and they should be able to provide, however, they do it service to all of the units, then you can't cluster them all around the network closet. 212 Haga Joseph 01:44:01.380 --> 01:44:20.540 You really should find a way to have them demonstrate that they're reaching the far ends and you've probably all experienced this in a hotel where you're just beyond that access point. So if there's a way to work that into the language, I think that would be very helpful. Those would be my recommendations. 213 Haga Joseph 01:44:22.460 --> 01:44:36.660 Thank you, Scott. Helpful, we have a couple of more, a few more palace to go, but at this time I just want to take a quick pause to see if the commissioner has any questions for our panelist so far, and if not, we can. 214 Haga Joseph 01:44:38.460 --> 01:44:53.020 I did have one question, and I don't know if at, and t would be the best person to answer this or not, or one of the providers, but the comments regarding the DSL and reclassification for thirty- megabites. 215 Haga Joseph 01:44:55.740 --> 01:45:08.220 So I guess I just wanted the carrier's perspective on that given the disinvestment and copper lines and the lack of service quality that, that we're seeing in that regard. 216 Haga Joseph 01:45:09.180 --> 01:45:25.860 Where the carriers are in, in looking at that again, given there's been a disinvestment in the, the copper system and if we're talking about lower speeds for these lines, as well as the fact that we have some carriers that are looking to. 217 Haga Joseph 01:45:27.500 --> 01:45:47.580 In the service and more and more customers are going to wireless and to, to look at fiber, where are the carriers and looking at the classification of the DSL at those levels as served or unserved and I don't know if that's a question you can answer, and that's fine if you're not the prepared to do that. 218 Haga Joseph 01:45:47.740 --> 01:46:08.060 But I, I do think that is an important question is we see so many areas that are listed as served that may not be within just a few years, depending on where we go with the copper system and I'll just say I apologize, but I was not prepared for that. I just was added to the panel this morning this particular panel, but if my other provide. 219 Haga Joseph 01:46:08.460 --> 01:46:28.540 Want like to comment on that. I'm happy to turn it over to them. Thank you commissioner. I think that's a very valid question and we're seeing that in a lot of places in, in particular, there's places where at and t- is all, but shut down and I'm not just picking on at and t- but, you know, discouraging the use of copper lines for even voice and so DSL has all been. 220 Haga Joseph 01:46:28.580 --> 01:46:49.020 Abandoned, for instance in Catalina, even though there's Yahoo DSL sticker on the window, you cannot move it. You cannot change it and it's not available which limits competition in turn to the cable MSO. In that case. So I think that there's a very strong case for raising the bar so that DSL is, is not considered to served run serve, It should be unserved. Sorry. 221 Haga Joseph 01:46:52.860 --> 01:47:09.500 And I did want to see if anyone else, if there are any of the carriers here that have a perspective on that, and I, I know that a number of them are looking at, at projects where they're looking to put in fiber, which I think is great, but that is, I, I think. 222 Haga Joseph 01:47:09.820 --> 01:47:27.260 An issue we're gonna have to deal with, with the challenge process, especially given the current model challenge process and, and looking at what Ntais definition of served is with the realities that we're actually facing on the ground and being able to coordinate and. 223 Haga Joseph 01:47:29.340 --> 01:47:49.180 Confer with the providers on that issue, I think is going to be really important to get all of us in the best place possible and we need everybody at the table on that and appreciate the participation by everyone, especially to providers on, on looking at that issue commissioner. It looks like Alex Themato. 224 Haga Joseph 01:47:49.260 --> 01:47:51.580 May have his hand- raised online. 225 Alex Damato 01:47:53.660 --> 01:48:14.140 Hi, yeah, this is Alex Dato with Charter Communications here today on behalf of Cal Broadband. I do think that we believe in the context of the BE program and Ntias Clear guidance to fund to the maximum extent feasible future. 226 Alex Damato 01:48:14.420 --> 01:48:34.620 Proof broadband service that we Cal broadband believe that adopting the DSL module is certainly a reasonable and good choice here, independently validated to the Fcc's measuring broadband America reports and we would support inclusion of that module here. 227 Haga Joseph 01:48:38.460 --> 01:48:40.220 Thank you, Alex. 228 Haga Joseph 01:48:41.660 --> 01:48:54.740 Should we keep going with our panelists for the rest of. So I do want to check real quick with Jonathan to see if there is, if you have any of our tribal partners online. 229 Haga Joseph 01:48:56.420 --> 01:49:12.860 I'm not aware of any of our travel partners online at this point. So I'm gonna go ahead and proceed to our industry partners. We've got Alex Meredith and Lynce as our panelists, and I'm gonna go ahead and start with Alex online. 230 Alex Damato 01:49:14.300 --> 01:49:24.660 Thank you for two. Thank you again. This is Alex Dato. I'm with Charter Communications here today on behalf of Cal Broadband. 231 Alex Damato 01:49:26.700 --> 01:49:46.940 Operators in California offer fast and Reliable broadband service to the vast majority of Californians having collectively invested over forty- five billion dollars in California's broadband infrastructure since nineteen ninety- six, I think today in our. 232 Alex Damato 01:49:46.940 --> 01:50:07.420 Brief comments, we'd like to highlight a couple of process considerations for the commission and a couple of substantive recommendations on the modules and the modifications to NTIAS model challenge process on the process aspects of the challenge. 233 Alex Damato 01:50:07.420 --> 01:50:27.900 Process we would know as it's been discussed that the model guidance allows for a total time frame of one hundred twenty days. I think consistent with a lot of the comments that we have heard so far, we would recommend adoption of a forty- five calendar day or thirty- business day. 234 Alex Damato 01:50:27.940 --> 01:50:48.380 Timeframe for each phase of the challenge process. I think we think it will be critical to adopt sufficiently long time frames, particularly in California that will allow all participants in all parties to be able to thoroughly review the data that the commission is presented as part of the Chal. 235 Alex Damato 01:50:49.020 --> 01:51:08.860 Process, particularly in the context that it will require all participants to comprehensively review and respond to commissions, initial service ability, designations, every eligible location in that context, we think forty- five calendar, day thirty business day timeframes for e. 236 Alex Damato 01:51:09.020 --> 01:51:25.020 Individual phase of the challenge process, that is the initial challenge phase in the rebuttal phase are appropriate for adoption here. Consistent with that as well. We believe that as part of the challenge process. 237 Alex Damato 01:51:27.460 --> 01:51:48.260 Be sufficient time in between the challenge and the rebuttal phase for the commission to ensure that the data submitted through the challenge phase is valid and beats the evidentiary requirements that have been laid out and the NGI model process and the process that the commission ultimately adopts. 238 Alex Damato 01:51:48.940 --> 01:52:08.780 The North Star for this process is, of course accurately identifying the locations that should be eligible for bed consistent with that, The best way to ensure an efficient challenge process will be to ensure that the data submitted through the challenge process is. 239 Alex Damato 01:52:08.780 --> 01:52:16.300 Is valid and accurately meets all of the evidentiary requirements that are included as part of this process. 240 Alex Damato 01:52:17.740 --> 01:52:38.220 The, the specific requirements laid out in the NTI guidance are relatively comprehensive and they will present a significant opportunity to ensure that the data submitted is valid, but taking the time to ensure before that is submitted for the rebuttal process. We'll allow us to focus. 241 Alex Damato 01:52:38.340 --> 01:52:59.340 On ultimately identifying the locations that are in need of service through the beat program as far as the modifications that we would love the commission to consider as part of this process has already briefly discussed, we think it is appropriate to adopt the DSL modification. We would note that in the updated guidance. 242 Alex Damato 01:53:00.340 --> 01:53:19.820 Has recently released that includes additional language that, that determination can't be rebutted. Should the commission choose to adopt it consistent with other comments today and with the DSL modification, we do believe. 243 Alex Damato 01:53:21.660 --> 01:53:40.300 Fixed wireless modification would be appropriate in this context, we would note that some states that have consistent have been working through this process have adopted the DSL and the Slicense fixed wireless MOD. 244 Alex Damato 01:53:41.620 --> 01:54:00.620 In some form with an acknowledgment that most of the speed test challenges, for instance, will likely come from location served by these technologies consistent with that. We would know that NTIA is guidance. does include. 245 Alex Damato 01:54:00.820 --> 01:54:21.260 Robust evidentially requirements that the state needs to adopt should it adopt the speed test module and we think that perhaps a more elegant way to address this issue is as state such as Wisconsin have decided, which is. 246 Alex Damato 01:54:21.300 --> 01:54:41.740 Say that for copper and fiber technologies, it is extremely uncommon that they would provide speeds below. One hundred twenty, which is, of course the deed eligible speed and staff they are anticipates that the vast majority of challenges would come from DSL and fix. 247 Alex Damato 01:54:41.900 --> 01:55:02.220 Wireless served locations. So adoption of those two modifications would alleviate the requirement to accept speed test challenges in the first place, which in other context that was acknowledged are perhaps not the most efficient way and effective way to actually Ultim. 248 Alex Damato 01:55:02.540 --> 01:55:06.340 Identify the locations that are in need of service. 249 Alex Damato 01:55:07.340 --> 01:55:26.260 And I think I will love to have any further discussion, but I don't want to occupy too much time so any of the other questions would love to speak to, as well, but I will hand it over to my colleagues now and, and look forward to further discussion. 250 Haga Joseph 01:55:26.580 --> 01:55:31.100 Thank you, Alex. I'm going to turn over to Meredith now. 251 Haga Joseph 01:55:32.300 --> 01:55:52.780 Thank you again, Meredith Williams for at and T- and I just want to say, Hey, we appreciate the opportunity to be a part of this, including joining this panel as of this morning, and, you know, before I get started into some of the questions at, and t alone has invested over eight point six billion in our wired and wireless networks in California over the past three years we. 252 Haga Joseph 01:55:53.100 --> 01:56:13.180 Fiber it over two point. Nine million customers right now in California, and so we believe that this is a really important initiative to be a part of, in general NTIA developed a very robust set of policy guidance around the challenge process and we encourage the commission to adopt that challenge process. 253 Haga Joseph 01:56:13.260 --> 01:56:15.540 To the extent that they can, as written. 254 Haga Joseph 01:56:17.220 --> 01:56:38.220 Particular, I want to focus in on one of the points that my colleague Alex made, which is allowing at least thirty days for the challenge of rebuttle period, especially in the state, like California, it's a very large state, We want to make sure that challengers are able to have sufficient time to submit challenges and there's sufficient time to provide the data necessary for rebuttles. 255 Haga Joseph 01:56:38.220 --> 01:56:46.900 So that is the one place where it's slightly above the minimum required in the challenge notice, but we think that's really important in the seat like California. 256 Haga Joseph 01:56:48.460 --> 01:57:08.940 I would also say to the extent that the commission wants to adopt the speed challenge module, we would encourage it to not to apply to location certified fiber as we know fiber will provide a consistent upload and download speed, and so that should be sufficient to make clear whether or not that location. 257 Haga Joseph 01:57:14.060 --> 01:57:34.540 I know that some of the other panelists today have talked about providing challenges from individuals that we encouraged as it's written in the NTI notice for those challenges to be directed through local governments or nonprofits, and we would agree with our other panelists who suggest that this data be available address level and for the. 258 Haga Joseph 01:57:35.220 --> 01:57:46.660 Providing to providers that is provided at a broadband service location data point because that's when we get most efficient for us to respond to those challenges. 259 Haga Joseph 01:57:51.820 --> 01:58:09.100 And finally, I would just touch on the question related to enforceable commitments and we think it's incredibly important that all enforceable commitments at the state local and tribal level are included up front in the duplication process and that those locations are taken off the map for the purposes of feed. So that. 260 Haga Joseph 01:58:09.300 --> 01:58:29.580 This funding will incredibly large will be able to reach as many other locations as possible in the state of California and with that, I will turn back over the time. Thank you, Lance. You are yours. Good morning Commissioner. Director. 261 Haga Joseph 01:58:30.300 --> 01:58:50.060 Judge and staff, thank you for this opportunity to, to speak before you, We've put a lot of talk here about last mile in broadband service locations and how those challenges go both in bulk or in part. I support the earlier comments on making it eas. 262 Haga Joseph 01:58:50.380 --> 01:59:10.540 For the consumer we put together from our effort trying to bring consumers to the table, but it's the, the process is arduous to get them to do. So, and so making that more seamless more easy, either at the sake city or county level would be very helpful, but I hear a lot hear about wireless fixed wireless and what not in the last mile. 263 Haga Joseph 01:59:10.580 --> 01:59:31.020 I don't hear a lot about how we address fixed wireless license fixed wireless in the middle mile and how that affects all last mile subscribers, regardless of what the marketed speed to them are, and so I feel like the modules for speed tests are important that they have to be again, accessible to consumers or developed into a way that can be used as a network. 264 Haga Joseph 01:59:32.420 --> 01:59:51.500 In essence for an Mspality to distribute so that they're transparent to the consumer and operate it on a regular basis. Again, we've tried on successfully to push consumers to cow speed. The website itself is kind of a turn off for folks that are concerned about security and fishing. So providing those to. 265 Haga Joseph 01:59:51.820 --> 02:00:11.980 So that the data can be fed back to the PUC in real tangible terms is important. We support UKLA and open source testing. However, a lot of that data is quite sparse in the regions we're looking at and so the sample size is not good enough. We believe to represent reality on the ground, so I'd ask those to consider. 266 Haga Joseph 02:00:12.100 --> 02:00:32.460 Modules and speed tests how we make that more usable both from a Challenger's perspective from a, you know, it's a probably perspective and from ISP and consumers perspective, I agree with your earlier comments on timing, However, I would like to suggest that we have at least sixty. 267 Haga Joseph 02:00:33.780 --> 02:00:52.660 Stage of this, there's a lot of data to parse in many of these cases, and so we need as much time as possible to, to get that feedback in and give valid data, not rush data, and then I would like to just speak a little bit about the, the existing mapping and, and what California and the POC intends to Bribe is tools. 268 Haga Joseph 02:00:53.100 --> 02:01:13.420 Some have commented on the FAM apps. They seem somewhat disconnected from reality in the way that data comes in where some areas are served and others are not served and particular with the same middle mile in between and how we can work together to further improve that data without having to touch every record in the BSL files. 269 Haga Joseph 02:01:13.540 --> 02:01:17.340 The NCI data. So thank you all. 270 Haga Joseph 02:01:22.380 --> 02:01:30.700 Oh, thank you for that comments. I do, I believe that we have Mr. Mattenan online and so I'd like to. 271 Haga Joseph 02:01:31.640 --> 02:01:35.960 And, and provide him an opportunity to provide some comments. 272 Matthew Rantanen 02:01:36.920 --> 02:01:38.680 Thank you, can you hear me? Okay? 273 Haga Joseph 02:01:38.720 --> 02:01:40.600 Yes, we can hear you. 274 Matthew Rantanen 02:01:40.600 --> 02:02:01.080 Excellent appreciate you inviting me, So I wanted to touch on a couple of things, the speed test issue, you know, obviously that's, it's a very valuable metric, but we think latency should be included in that because latency allows us to do things that we're doing today, which is participate from remote. 275 Matthew Rantanen 02:02:01.120 --> 02:02:21.560 And, and engage in video by directional video interactions. I think, you know, that's a highly valuable metric to add to speed test and then, you know, specifically, there's a question after the commission applied that definition of an enforceable commitment area to tribal lands Tribalands definition. 276 Matthew Rantanen 02:02:21.720 --> 02:02:22.840 Is. 277 Matthew Rantanen 02:02:24.160 --> 02:02:41.400 You know, includes a lot more than just the reservation boundary. A lot of travel members live outside of that reservation boundary, but in the local area, historical travel homelands extend far beyond the reservation boundaries. So a lot of traditional areas where population densities are for the trib. 278 Matthew Rantanen 02:02:42.080 --> 02:02:54.080 Exist around and outside reservation space. So when tribes build networks, they intend to serve their community outside of their reservation spaces. So I think we ought of look at that definition. 279 Matthew Rantanen 02:02:55.520 --> 02:03:01.720 More closely and not just limit that to the reservation that's been dictated by the federal government. 280 Matthew Rantanen 02:03:03.160 --> 02:03:23.640 The next piece of a tribal, you know, access to a tribal land for a non- tribal carrier or provider should require consent from the tribe and that is in the form of a trouble resolution. Trouble resolution is a mechanism which. 281 Matthew Rantanen 02:03:23.640 --> 02:03:44.040 The tribal council government of a tribe in acts effectively equated to an act of Congress at the, at the US government level. Not an executive order. So the actual sitting travel government votes on a process or a. 282 Matthew Rantanen 02:03:44.200 --> 02:04:04.600 Measure to accept or deny access to their travel lands for the specific purposes of, of serving their community and we feel that the commission should not, and, and the B program should not endorse any or accept any applications that say they're going to serve Tribaland without consent of that. 283 Matthew Rantanen 02:04:05.480 --> 02:04:08.880 And I'll leave my comments to that at the moment. Thank you. 284 Haga Joseph 02:04:11.080 --> 02:04:31.480 Thank you, Matt. At this time, I'm gonna over to Jonathan Wesis to see if there's anything that we need to know about it online. I could morning everyone. There are two, there's several comments online that I will just summarize one question is, there's a question from a local or from a county government that wants to. 285 Haga Joseph 02:04:31.560 --> 02:04:51.960 Know how they will be able to know, which are the unserved locations in light of the recent FFA applications and well, I think what they're really searching for is how to get access to address level specific information, so they're better equipped to be able to participate in the process, another comment. 286 Haga Joseph 02:04:53.240 --> 02:05:12.440 Believe a service provider. They're wanting to demonstrate service in an area. Does a provider have to show that it actually provides service to all locations or only that service is available for all locations in the area, and then the last comments from another service provider, the gentleman agrees with at, and t's comments about the no. 287 Haga Joseph 02:05:12.480 --> 02:05:23.640 Which regards to Reliable Broadband Service and encourages the CPUC to follow the directions, those guidance set forth in the Novo. Those are the comments that we have from online. 288 Haga Joseph 02:05:32.960 --> 02:05:50.840 Commissioner at this time. Would you like to ask any that is our complete panel on this. You have any questions that you'd like to discuss? I did, I believe that Ken Lewis from Scenic is online and I don't know if he had anything that he wanted Kim, Lewis, okay. 289 Haga Joseph 02:05:51.480 --> 02:05:58.720 And Kim, this is Jonathan, if you can send me a chat, I can make your presenter associate. You can engage. Thank you. 290 Haga Joseph 02:06:15.800 --> 02:06:35.640 While that's happening, Marina, I don't know. We, we heard a little bit about some of the information on address level information and I didn't know if you could share anything from NTI level about about that. Yeah, absolutely so really appreciate that question at that point made by Patrick. 291 Haga Joseph 02:06:37.560 --> 02:06:56.760 I do not control how the United States government has entered into contracts to share its broadband data, so I'm just gonna say that off the top of my head in terms of like, what can be changed and what cannot be, and TIA and FCC are contracting with cost quest as the basis for their, for the licensing and the data one thing that I want to. 292 Haga Joseph 02:06:56.920 --> 02:07:17.880 Is there's a couple different types of licenses and a couple different light types of licenses that cost quest is making available within the context of the Beed program for participation. So one that's already been out there for a while. Is a Tierd license that tier D license is primarily for broadband service providers that are intr are going to be potential. 293 Haga Joseph 02:07:18.520 --> 02:07:38.360 Subgrantees recently they've also made available a request for a tier e- license and that's primarily aimed at nonprofits and local governments and other organizations that might, that aren't broadband service providers that want to participate in the challenge process and need access to that fabric data. 294 Haga Joseph 02:07:38.480 --> 02:07:58.840 So I, I have sent the link to CPC, it's something I can definitely follow up with. There's still gonna be time when it comes to, right? We're still in the process of CPC can't start us challenge process until we approve their, their initial proposal and they still have to turn it in and all of these types of things, but it's one thing to think about is making sure that. 295 Haga Joseph 02:07:59.480 --> 02:08:19.320 Your organization, nonprofit local government has access or knows how to get access to this tier e- license. You need an FRN, which I is like an FCC, kind of number that I don't know the acronym for, off the top of my head, and so I know that can take, you know, a little bit to put in a request, get them to send it back to you. 296 Haga Joseph 02:08:19.960 --> 02:08:40.440 We're helpful to, we're, I'm totally open to working with people to make sure they get the resources they need to be able to challenge the map as part of this process, which includes location level data, and I'm sure the CPU C is as well, and they're probably going to put out even more extensive step by step processes and documentation. 297 Haga Joseph 02:08:41.800 --> 02:09:00.920 As we're moving forward, there's also a couple states that are going to run their challenge process first, so hopefully there's gonna be some good lessons to learn from getting access to that data and stays like, like I think Louisiana is currently open so that we can hopefully avoid some of those issues for other challenges in California when we get to our process, but. 298 Haga Joseph 02:09:01.560 --> 02:09:16.320 There is going to, hopefully be a way to get that location level data that Patrick is referencing in advance of participation in the challenge process in order to fully participate. 299 Haga Joseph 02:09:18.840 --> 02:09:38.680 Thank you, Marina. It sounds like Carl, you may be speaking on behalf of the Transportation Commission of course psych Maria, that's a gift. Yes, I just checked with Jonathan after receiving a text from the commission to speak wearing my vice chair had, but I'll wait until you tell me it's appropriate. 300 Haga Joseph 02:09:39.640 --> 02:09:49.960 Ask me to step up to the absolutely. Any questions about Raina's comments or anything before we turn over to Carl. 301 Haga Joseph 02:09:53.560 --> 02:10:11.960 One question we're on those on the files available from cost question, NJAY and it comes back to how we feed data back in terms of availability and speed as it possible that, that could be used to supplement the data on poor downtime and if so at what Threshol. 302 Haga Joseph 02:10:12.640 --> 02:10:32.440 Availability, so we've heard earlier about twenty- four hours out of three hundred sixty- five days, if it's some threshold below that would that be a fair way to report data back or just have to be something completely outside this process. Do you mean in terms of utilizing that data for the challenge process? Okay, I think that's something that would need to be proposed. 303 Haga Joseph 02:10:33.320 --> 02:10:46.440 And then the state would need to determine the data set. It's using to determine that those areas receive under tw, you know, have the sort of don't meet the out outage threshold, right? And so. 304 Haga Joseph 02:10:47.800 --> 02:11:08.280 I'm less familiar with reporting data and service reliability for the FCC and like what it shows you and what it doesn't. I know that, that, and that CPUC collects its own data. so like, maybe it's proposing to use its own data set, but I think that would be something that the state would have to clearly identify in its initial proposal, like we are using this DA. 305 Haga Joseph 02:11:09.040 --> 02:11:28.760 Overlying it in XYZ in way it's, it's collected by CFC. It's collected by us. It's collected by whatever and, and then propose using that as an overarching layer in terms of incorporating that as part of the sort of data that's already part of sort of the download portals and stuff. 306 Haga Joseph 02:11:28.880 --> 02:11:49.240 Like that, I think that's probably gonna be a more specific cost list question, but I think that the key thing is that when NTIA is evaluating any proposal for additional modifications outside of the RD approved model challenge process that it's going to want details on the data set that's being us. 307 Haga Joseph 02:11:50.820 --> 02:11:54.700 It's being overlaid to make those determinations. Thank you. 308 Haga Joseph 02:11:56.740 --> 02:12:07.340 And I believe just Vicola may have a follow- up questions. I think Natalie Gonzalez of CCF has her hand up. Do we want to wait, yes, okay. 309 Haga Joseph 02:12:08.620 --> 02:12:29.100 File means Carl Maria, thank you and Commissioner Hack. Thanks for leading this proceeding and to the administrative law judge Googola as well. Thank you for your team and for the NTIA to be here as well, and partnership is terrific and in that spirit of partnership as many of you may know, the Cal. 310 Haga Joseph 02:12:29.740 --> 02:12:49.580 Transportation commission on which I'm honored to serve as vice chair and has served for seventeen years. Is one of the named public agencies in the governor's twenty- twenty executive order to ensure universal service. One hundred percent of our unserved and underserved population throughout our state. 311 Haga Joseph 02:12:49.580 --> 02:13:04.100 Overwhelmingly, that's in our most rural areas as well as Trival nations and stranded streets in our urban areas and Patrick, your comments were spot on. I look forward to working with you. 312 Haga Joseph 02:13:05.620 --> 02:13:26.060 Wearing both my day job had as well as vice chair of the California Transportation Commission. I wanted to underscore that goal that we mutually have and that the commission certainly has according to the cost quest information, the consultant for our PUC. There are nine hundred, nine. 313 Haga Joseph 02:13:26.540 --> 02:13:46.540 Three hundred and two thousand unserved and underserved broadband serviceable locations in our state. Those are primarily families and at three point, one, four Californians per family, that's nearly three million out of thirty- nine million people in our state that are unserved. 314 Haga Joseph 02:13:47.820 --> 02:14:07.020 As Patrick's so articulately reminded us both send a bill on fifty six, which calls for at least at least ninety- eight percent of all California families. Not only statewide, but in six of the regions of California have affordable reliable. 315 Haga Joseph 02:14:07.780 --> 02:14:27.500 High speed service. And that's a goal we can achieve if we're all working together from the perspective of the commission, it's also a green strategy to meet California's ambitious, but appropriate greenhouse gas reduction strategies because when people have. 316 Haga Joseph 02:14:28.260 --> 02:14:47.980 Able affordable high speed service. We can work from home be educated from home, Have telehealth from home. Have emergency response in public safety services from our homes and those are all essential to the twenty- first century. Life and economy. So we are here to work. 317 Haga Joseph 02:14:48.140 --> 02:15:08.460 With you in that way at the commission because we have to get this right? The biparisan infrastructure law is clear. One hundred percent of unserved and underserved states can prioritize, but it's still one hundred percent of the unserved. 318 Haga Joseph 02:15:09.820 --> 02:15:28.940 The Biparisan infrastructure also refers to itself as once in a lifetime, so let's take advantage of this opportunity to work together with the goals of SB one fifty six once in a lifetime, the Bitisan infrastructure law, once in a lifetime and the governor's executive order for one hundred. 319 Haga Joseph 02:15:29.620 --> 02:15:49.420 And we're here to walk with you in that journey to make sure it's accomplished. Thank you and later today that text was from our CTC to come forward later today. I'll be wearing a different hat and I don't want to confuse which hat I'm wearing, nor do I want to lead to any. 320 Haga Joseph 02:15:49.420 --> 02:16:00.140 Confusion, so thank you Maria. Thank you Commissioner. Thank you right here. Natalie, I see your hand raised online. 321 Natalie Gonzalez [CCF] 02:16:01.580 --> 02:16:09.260 Thank you, I just had a quick clarify question for NTIA regarding the Tiere with the fabric maps. Do you mind reiterating that one... 322 Natalie Gonzalez [CCF] 02:16:10.820 --> 02:16:11.820 My notes are correct. 323 Haga Joseph 02:16:12.060 --> 02:16:32.300 Before I answer follow up, yes, so that there will be, there is a tier e- license available through cost quests for location level data access to the FCC broadband fabric that is going to be, that is available as a tool for organizations who want to participate in the. 324 Haga Joseph 02:16:32.740 --> 02:16:33.860 Process. 325 Natalie Gonzalez [CCF] 02:16:35.500 --> 02:16:36.139 Okay, I just. 326 Natalie Gonzalez [CCF] 02:16:38.139 --> 02:16:45.099 Community engagement side that a lot of them that's resources and the availability of them really do favor Isps. So just. 327 Natalie Gonzalez [CCF] 02:16:45.780 --> 02:16:51.860 Erate the commission to take into account that meeting engagement on This is a priority for us. 328 Haga Joseph 02:16:54.059 --> 02:17:15.179 Yes, and we hear the, we, we, we hear that and we do definitely want to do community engagement. We have, what is a short period of time to get these rules out as compared to some of our other proceedings, but we are going to do our very best to go out and meet with communities. I've met with folks in Oakland at least once I'm hoping to get out. 329 Haga Joseph 02:17:17.219 --> 02:17:35.660 Planning to be down in, in Los Angeles and working with my staff now to talk about how we can expand community engagement over the next couple of weeks to make sure that we have that information and again, want everybody at the table to participate in that so that we can all work together to make this the most effective program that we. 330 Haga Joseph 02:17:35.700 --> 02:17:56.139 Possibly can to get as much broadband to deploy to those that need it. the most as possible. So thank you for the comments on the community engagement. We, we hear you and we are going to follow up and Maria. I know that Mr. Razwell in the back had wanted to make a comment. 331 Haga Joseph 02:17:56.219 --> 02:18:16.620 If that's okay, and I know that judge click also mon up to the podium in the meantime, I think Marina has something else to add. Yeah, I just want to say that part of the initial proposal that's going to go out the CPUC must define how it's going to do outreach for the challenge process, including for these other types of entities. So I really encourage you particularly CCS, but. 332 Haga Joseph 02:18:16.740 --> 02:18:37.099 Everyone who's listening thinking about what you want to see what that engagement looks like, and then making sure you provide that feedback to the CPUC as part of the initial proposal, whether that's formally or informally, so they know what resources to give you because that is a requirement of the program. The last thing that my, I'm being. 333 Haga Joseph 02:18:37.420 --> 02:18:55.660 Ically texted by my team is that a. So to mention that the tier e- license is free. So I want to make sure that I emphasize that because I don't think that's been the case universally for all broadband data across time and space. Thank you Marinet. Would you kindly introduce yourself in your affiliation? Sure. 334 Haga Joseph 02:18:55.780 --> 02:19:16.139 Patrick Rossball here for the small X and for those who don't know, this is a group of thirteen rural Islex throughout the state that served some of the most hard to reach areas, high cost areas and, you know, are very interested in pursuing fiber deployment in these areas and are actively doing that using many programs. 335 Haga Joseph 02:19:16.900 --> 02:19:23.179 And the companies own money. I just had a few, I think three comments in part two address commissioner. 336 Haga Joseph 02:19:23.820 --> 02:19:43.660 Question and also the respond to some of the things we've heard here. The first thing is, I would urge the commission to focus on speed tests as the way to challenge these, these projects and not get captured by subscription data. I think dreamlining said it, well, and my fellow Patrick from Oakland, it should not. 337 Haga Joseph 02:19:44.540 --> 02:20:04.140 ARY to look at what people's bills look like. What specific services there? They're purchasing and if this were in the telephone contacts, that's just clearly CPNI- not subject to any exception. I mean, public utilities code, twenty- eight ninety one would prevent somebody from providing that even to the commission without an order. 338 Haga Joseph 02:20:04.260 --> 02:20:24.620 Specific order and, you know, the federal regime, forty- seventy, forty- seven USC two, twenty- two, similarly, you know, would, would prevent that on the federal side and even though there are some nuances about broadband, not necessarily apply or CPNI, not necessarily applying to broadband we should all view that. 339 Haga Joseph 02:20:25.540 --> 02:20:45.100 Highly personal data as far as what someone's actually subscribing to, so you should base it on tests, you know, and I think that's the, the most important thing anyway because it's what measures the, what the network is actually capable of, and I won't go into too much detail, but if you're talking about social engineering things and fishing, ty. 340 Haga Joseph 02:20:45.340 --> 02:21:05.580 Expeditions that can harm consumers knowing exactly what they're ordering can facilitate that, which is why that sort of thing should be considered TPNI second point. I guess, building on commissioner Hack's question as far as DSL. The small X are in a transition moment here and are moving. 341 Haga Joseph 02:21:05.980 --> 02:21:26.060 Fiber, but they do have significant DSL at this moment. I think it would not be appropriate to consider DSL to be categorically excluded from the perspective of determining whether something meets twenty five three and which I think is the underserved category or rather if you're below that. 342 Haga Joseph 02:21:26.180 --> 02:21:46.540 Would be considered unserved if you bond enough pairs, you can get the twenty- five three using DSL, so that, that really shouldn't be categorically excluded from that perspective. I think that if you're talking about a hundred slash twenty, that's a much more reasonable thing to say that, you know, only fiber can get you in any reasonable way to that level, unless you're right. 343 Haga Joseph 02:21:46.540 --> 02:22:07.020 Next stored of the central office or something. So I, I think there's a real distinction there, but I think if you're focused on speed tests as part of this challenge process, you don't need to wonder whether DSL is categorically excluded or not, and so I would urge the commission just to focus on that as the way to, to determine this, and I guess the last point, which is something that. 344 Haga Joseph 02:22:08.820 --> 02:22:28.660 Is just when we think about enforceable commitments at the state level and the federal level I want to make sure that the commission considers all the things that the small x are doing and are subject too. So there's obviously recently been enhanced Daycam, Thursday, cam one, there's AKM two, those are federal commitments that are very clear and if. 345 Haga Joseph 02:22:29.420 --> 02:22:49.140 Made those commitments. There shouldn't be a bid project on top of that. There are also high cost blue support commitments and there are connect America funds CAF BLS commitments on the federal level and I guess more importantly, and I'm saying this having just reviewed all of the FFA prop. 346 Haga Joseph 02:22:49.140 --> 02:23:09.620 Proposals, there are a ton of overbuilt projects in there and if small X are willing to spend their own money as part of rate cases to deploy fiber in an area, subject to, you know, a return on those investments through the rate, making process, the, the commission shouldn't be awarding beed money on top of that, and, and so. 347 Haga Joseph 02:23:10.900 --> 02:23:30.100 In rig case, I would just urge you to also consider that to be an enforceable commitment if the commission says, yes, you should go build this, the fact that it isn't directly linked to a grant program, shouldn't make a difference and I would just ask you to consider it in a rate case a small equer to say I'm gonna go build something and I'm gonna. 348 Haga Joseph 02:23:30.420 --> 02:23:50.580 I'm gonna do this in the test here, so maybe that's next year if someone didn't do it if they just blew it off and didn't do it. I am certain that the commission would consider that to be enforcement issue, so it's an enforceable commitment. It's not a grant program, but it is an enforceable commitment, so I would just urge you to look at that and. 349 Haga Joseph 02:23:50.700 --> 02:24:11.060 Also, just isn't a reasonable allocation of resources to be approving projects through the right case process and then approving competitors on top of it. So those were my comments. I don't know if that prompts any questions, but I just wanted to make sure that the small issues are considered. Thank you Marina. Do you just really fast in the context? 350 Haga Joseph 02:24:11.220 --> 02:24:31.540 Of the beach challenge process. I want to clarify that enforceable commitments and planned service are two separate challenge process categories, right? So enforceable commitment refers to, if you have like a ready to authorize notice or letter specifically, but planned services on the model challenge process is something that providers can specifically. 351 Haga Joseph 02:24:32.820 --> 02:24:52.660 Claim for, if they have planned service in an area, there are rules around that, and I mean, it has to be rebutable, right? People are, if you claim you're gonna plan service somewhere, so people can rebut that, and then you also have to provide evidence, right? Like permits or building contracts or things that show that the development is already in the process of taking place, but. 352 Haga Joseph 02:24:53.060 --> 02:25:13.140 I think that there's been some confusion between those categories, so I just want to make sure to that, you know, the evidence requirements and what those are categorized are different based on whether it's like a grant or whether it's plant service by a provider in an area just briefly on that point. I, I think what I'm expressing is that and so far as the commission. 353 Haga Joseph 02:25:13.580 --> 02:25:29.220 Projects through the right case process. It may, in fact, be both of those categories and I'm certainly aware of the other category and I take your point. It's important to keep those separate, but it may, in fact be both both grounds. 354 Haga Joseph 02:25:31.140 --> 02:25:32.380 Thank you. 355 Haga Joseph 02:25:35.740 --> 02:25:54.100 I just wanted to briefly respond to this question about not the enforcement commitments part, like the plan spilled part. I remind the commission that the legislature actually removed the right of first refusal provision from the CSS statue because a provider's. 356 Haga Joseph 02:25:54.380 --> 02:26:14.580 History of saying... Oh, yes, we're gonna build there any day now and then not doing it, and it also say that I agree with Mr. Rosswal that the commission might take action if a provider failed to meet a commitment, but that action may not result in those folks having service and it could be a fine. 357 Haga Joseph 02:26:15.380 --> 02:26:26.940 It could be calling back money and any event. There's going to be an unreasonable delay before we finally get deployment to those customers. So I just asked that we'd be mindful of that. 358 Haga Joseph 02:26:28.020 --> 02:26:48.500 Thank you, Paul Missioner. Now we have an opportunity if you have any further questions for I, I wanted to give Judge Googola an opportunity to ask his questions first. Oh, thank you commissioner. I just wanted to follow up with you MS, MS. Williams and one, thank you for joining us and, and, and. 359 Haga Joseph 02:26:48.580 --> 02:27:01.580 The last minute, maybe I wanted to ask Commissioner hug's question at least how I interpreted a little bit differently. Does at, and t- have a position on the DSL module. 360 Haga Joseph 02:27:05.140 --> 02:27:20.180 I would say more generally all of us providers who are building fiber are looking to modernize their networks and so to the extent that this wouldn't incentivize more modern networks across, you know, these locations we would be. 361 Haga Joseph 02:27:21.140 --> 02:27:23.780 We would not object to that module. 362 Haga Joseph 02:27:30.900 --> 02:27:51.220 I know we heard comments and I believe it was from Kel broadband about thirty calendar, thirty- business days or forty- five day challenge opportunity. Could we hear from some of the community based organizations and the local governments on whether they agree with that time frame or what you think. 363 Haga Joseph 02:27:51.260 --> 02:28:12.340 Appropriate time frame would be regarding the challenge process and, and then, and this may be a question for RCRC and I see Tracy here as far as counties that may won't want to challenge if they are not on the service list is our CRC helping to coordinate to make sure. 364 Haga Joseph 02:28:13.780 --> 02:28:21.420 Any counties that may want to challenge are gonna know in time to be able to meet those time frames. 365 Haga Joseph 02:28:23.580 --> 02:28:43.700 Thank you, Tracy. Ryan real kind representative of California. We represent forty rural counties in California and through a JPA go and say, connect authority. We are, we have applied for thirty- seven individual jurisdiction projects through the federal. 366 Haga Joseph 02:28:43.900 --> 02:29:04.180 Funding account as we move forward to your question commissioner and hoping in, in helping disperse the information about challenges and help coordinate with our counties. I think that we can, we can definitely fulfill that role and we can discuss exactly what that looks like with our counties. Obviously we. 367 Haga Joseph 02:29:04.900 --> 02:29:22.540 In close communication as we move forward with our proposed projects and as, you know, we have two counties here today that can speak probably more directly to those efforts, but yes, I think that's something that the statewide associations, including California State Association of Counties can also help with. 368 Haga Joseph 02:29:28.020 --> 02:29:44.500 Speaking on behalf of some small counties. I think that if we were to extend the challenge period by two thirty business days or forty- five calendar days that may not be necessary, but I think that's also dependent on the size of the counties as an. 369 Haga Joseph 02:29:45.820 --> 02:29:59.540 A couple of the projects in, in your mono counties are gonna cover four hundred fifty locations. So if somebody's challenging an area with four hundred fifty locations, they don't need forty- five days to do that, but, you know, we're not la county, either. 370 Haga Joseph 02:30:02.420 --> 02:30:12.300 Yeah, just to add in briefly having gone through the price of acquiring a license through cost quest, it is not a simple process. 371 Haga Joseph 02:30:13.300 --> 02:30:33.780 And the data that you get back, it's not like a map that you can pull up you, you need a GIS specialist to apply the, the file that you get from cost quest into a map. It's quite complicated and I think one of the challenges we faced as a community is just making sure we have clarity as soon as possible on what is the burden. 372 Haga Joseph 02:30:33.860 --> 02:30:54.260 Proof that's going to be placed on communities, municipalities are nonprofits to submit a viable challenge if we get the guidance and that initiates the clock on the challenge window, it is remarkably difficult in the city with thirty- six thousand unconnected households to collect data at scale when you have no clarity up to the start of the clock. So. 373 Haga Joseph 02:30:55.540 --> 02:31:14.740 For me, I'm less concerned about the duration of the window and more concerned about how soon can the city of Oakland and through our partnership with OSD schools and other trusted anchor institutions and the non- profits, we work with have Crystal clarity that the Herculine effort, it's going to take to demonstrate the reality of the Experi. 374 Haga Joseph 02:31:15.220 --> 02:31:35.220 Of our community members can be gathered and put together and uploaded within that window, and, you know, we're still awaiting some, some clarity. I want that process looks like, and as currently the comment window on the CPUC map, we've submitted challenges through that mechanism for. 375 Haga Joseph 02:31:35.300 --> 02:31:47.540 Five months and still haven't heard back. So just as expeditiously as possible getting us guidance on what burden of proof are going to meet and please make that a reasonable burden of proof given the concentration of need. 376 Haga Joseph 02:31:48.700 --> 02:32:09.140 I see someone at the putting if you could put your name in your association Sure Lindy grude a project manager for Broadband for twelve accounting. I just want to echo the idea that more time is better. It is a resource issue. Mr. Armstrong and I are out of these, There are not many rural counties that have people ded. 377 Haga Joseph 02:32:10.260 --> 02:32:16.020 To the extent that we are so having extra time would be beneficial. I think to those other counties. 378 Haga Joseph 02:32:17.300 --> 02:32:18.540 Thank you. 379 Haga Joseph 02:32:22.420 --> 02:32:28.820 I know if Matt ran Tannon is still on if Matt's there, I have a question just about. 380 Haga Joseph 02:32:29.460 --> 02:32:31.820 Okay, I'm at. 381 Haga Joseph 02:32:32.220 --> 02:32:53.140 For the, the tribal resolution in tribal commitment, we obviously are very committed to respecting tribal sovereignty and ensuring that the tribes are on board for projects that include tribal lands and appreciate your comments regarding ancestrial territory or members that may be served off Tribaland. I also understand that there may be either. 382 Haga Joseph 02:32:53.220 --> 02:33:13.620 Carriers or other entities that are working with tribes to provide services as well. So if a resolution may not be able to be enhand at the time, the applications are due, but a project is in process. How do we balance ensuring that. 383 Haga Joseph 02:33:13.780 --> 02:33:34.100 The tribal projects where tribes want to be considered are considered while ensuring that we do get that documentation and commitment from the tribe. Is there any flexibility that you may be able to see for purposes of submitting the application, but having the documentation in place. 384 Haga Joseph 02:33:34.380 --> 02:33:45.340 Before the award is given if, if they're sufficient information showing that, that there is a real and viable project that the tribe is participating in. 385 Matthew Rantanen 02:33:45.660 --> 02:34:06.100 Yeah, I mean, yes, and no, so a letter of intent that says that the tribe is going through the process of, of developing a resolution to support the project or support the carriers efforts and it will be turned in by the time of the award or to determine the award. I, I think is appropriate, but the. 386 Matthew Rantanen 02:34:07.140 --> 02:34:26.580 Concern we have, I think are, and what we've seen is, is the nature of, of trying to get, you know, putting pressure on tribes that don't have access to broadband from a carrier perspective when a carrier is looking at a, at a sum of money for a census block or a service area and. 387 Matthew Rantanen 02:34:27.260 --> 02:34:47.060 Needing that, that tribal sign off, We want to make sure that it's goes to the travel government that the travel government gets there, say on it, that the, the presentation from the carrier is in line with the tribal needs for the communication efforts that, that are needed there and many tribes are interested in building. 388 Matthew Rantanen 02:34:47.180 --> 02:35:07.300 Out their own communications and aren't interested in an outside of vendor coming in and serving their community, and they're going to have those conversations with carriers that are engaging tribes that, that, you know, intend to serve those service. Where are those sensus blocks and, and so it is a negotiation and. 389 Matthew Rantanen 02:35:08.220 --> 02:35:28.020 And then interaction process with that tribal government. We need to make sure that they're not getting signed off by somebody. That's just a generic travel member that is actually somebody that is engaged in the government. The government actually goes through a process and develops, you know, through their mechanisms a way to document that they have signed on to. 390 Matthew Rantanen 02:35:28.100 --> 02:35:37.900 Or consented to the build out. So, a letter of intent, but with the, with the restriction that a resolution would come. 391 Matthew Rantanen 02:35:39.260 --> 02:35:42.860 Time for that, that award. 392 Haga Joseph 02:35:45.300 --> 02:36:05.140 No, thank you for that. Maria Marina, did you have anything you wanted to add? The only thing I wanted to know on the tribal side was just some of the structure of the program not actually feedback on that specific point, but, you know, for cause when we're talking about tribal consent in terms of the challenge. 393 Haga Joseph 02:36:05.180 --> 02:36:25.620 Process what we're talking about is an enforceable commitment on the map being removed if it covers Tribalands, if the tribal, the tribal government didn't consent to it because I don't think that there's a tribal consent requirement in a lot of other federal programs. So the big one that we've seen this happen with is Art off for. 394 Haga Joseph 02:36:25.620 --> 02:36:46.100 For example, right? So under our program rules, you do have to deduplicate Artoff and the FCC can't or Ntia can't make the FCC require tribal consent for their own programs, right? But what is possible is that the tribe could submit a letter for. 395 Haga Joseph 02:36:46.100 --> 02:37:06.580 For the challenge process And I think Matt's making some really good points about, like, who, who is submitting that letter under what contacts and making sure it's the right, you know, the right contact saying we do not consent to this Ardof project being built on our lands and that can be submitted to NTIAS a waiver and, and so it could come off the map, right? So that. 396 Haga Joseph 02:37:07.300 --> 02:37:27.060 Like a specific type of other federal enforceable commitment, blocking tribes from receiving funding for a project that they don't consent to. So that's, that's it through the context of the challenge process, then is when we're moving to. I just want to note that for the context of bed projects, themselves, tribal cons, a formal tribal consent. 397 Haga Joseph 02:37:27.780 --> 02:37:47.540 Is a hundred percent required in order to receive funding for a project. The commission has some flexibility in terms of when they can require that in the process, so it could be at the time of application, but it has to be into NTIA by the final proposal, and so I think that's one thing I really want to make sure tribes know. so if we're talking about two competing propos. 398 Haga Joseph 02:37:47.820 --> 02:37:49.100 On Tribalands. 399 Haga Joseph 02:37:51.380 --> 02:37:57.140 The project that does not have tribal consent will not be moving forward and so I think that's an important. 400 Haga Joseph 02:37:57.380 --> 02:38:12.500 For tribes to know and understand in the context of the BEED program, separate from how we're trying to deconflict projects on tribal and with enforceable commitments in the challenge process. Does that make sense? 401 Haga Joseph 02:38:13.260 --> 02:38:13.780 Confuse Everyth. 402 Matthew Rantanen 02:38:15.260 --> 02:38:15.700 That's. 403 Haga Joseph 02:38:18.260 --> 02:38:33.660 Yeah, so, so the bottom line is we need the tribal resolution before an award can be provided, but we have some flexibility to work with tribes depending on where they are in the process and what they're looking at and to the extent, a tribe wants to challenge. 404 Haga Joseph 02:38:35.540 --> 02:38:56.020 The map or location. I guess the one concern I have, and I don't know, Matt if you can offer any insight, it's just information to know what, what the timing is and it based on the resolution requirement that I think it's unlikely that we're gonna get applications for projects that haven't worked with tribes because that would. 405 Haga Joseph 02:38:57.140 --> 02:39:09.140 For the project, ultimately, but just being able to ensure that we have the appropriate information getting to the right people in time to participate if they, if they want to participate. 406 Matthew Rantanen 02:39:10.780 --> 02:39:31.220 I mean, tribes, you know, there they, they can move slower than- than normal process, but when there is an opportunity for engagement, you know, they, they make exceptions. I mean, they typically meet on a regular interval and most tribes meet we meet if not more than. 407 Matthew Rantanen 02:39:31.500 --> 02:39:51.700 That, so, I mean there is an opportunity to, to get this in the process, but my concern would be that somebody would say, Oh, we're serving this trouble. These trouble census blocks and then not ever engage the tribe until the last minute and put pressure on the tribe to try to get a tribal resolution last minute rather than start. Now if you are tru. 408 Matthew Rantanen 02:39:51.900 --> 02:40:12.180 Are trying to include those census blocks have an engagement with the tribe, you know, potentially a letter of intent then, and then, you know, actually work with a tribe on the process because a lot of what we've seen in the past is, Oh, we're gonna serve you. Oh, we know what your needs are here, this is what you need and you'll be fine when that's not fine at all. 409 Matthew Rantanen 02:40:12.380 --> 02:40:32.660 What the tribe actually has a plan, you know, especially lately we've been developing broadband plans for our community so that we can address these issues ourselves, but we may have a broadband plan that, that totally dovetails into a carrier's efforts that might take the burden off of us and we'd want to partner with that carrier, but if that carrier doesn't have that conversation upfront and there's no trouble consent. 410 Matthew Rantanen 02:40:32.820 --> 02:40:50.820 We don't, you know, we're not, we're not getting a solution that works for us so I think that's the, the concern is to make sure that the engagement happens and to ensure throughout the process that it's not a last minute pressure to sign a resolution just to get service or you're never gonna get service kind of an attitude. 411 Haga Joseph 02:40:52.500 --> 02:40:57.580 No, thank you. I, I appreciate that and that's important information for us to consider. 412 Haga Joseph 02:40:59.540 --> 02:41:07.540 And then I don't know, Rob or Judge Clickala and do you have any questions? 413 Haga Joseph 02:41:09.180 --> 02:41:21.700 Any final thoughts that, before we, I think Judge Google has a question. Yeah, I just so... yeah, sorry I just wanted to make sure. 414 Haga Joseph 02:41:25.020 --> 02:41:43.700 CK that we had everything that you presented today was already in your comments so that we have it on the record. Is it already because I, I haven't read it lately. I don't so forever forgive me for not reading everything or remembering, but I just wanted to make sure as this, the stuff that you presented is that content. 415 Haga Joseph 02:41:44.020 --> 02:42:03.940 Already, like in comments that you filed with us quite a bit of it is, but in the ensuing timeframe, when we submitted the comments to, now we've learned a lot more and so there may be some additional information I can provide to amend and provide that additional context. Okay, awesome, thank you. and I'm on, I'm, I'm also an Oaklander, so. 416 Haga Joseph 02:42:05.460 --> 02:42:16.540 And certainly if there are comments that we weren't able to get to for whatever reason in this panel, everyone is more than welcome to con- submit those as part of their comments as well. 417 Haga Joseph 02:42:20.060 --> 02:42:29.780 Give a couple more minutes to see if there's any final spots or questions too, or from the commissioner and comments from our panel. 418 Haga Joseph 02:42:34.780 --> 02:42:52.060 So I'd like to propose that we take a, since we're getting closer to lunchtime that we take a slightly longer lunch. I think we had time from noon to one is that, would you be amenable? I would be, but. 419 Haga Joseph 02:42:52.060 --> 02:43:12.540 Before we do that, I know that we don't typically start with public comment at the beginning of the day, so I don't know if there is any comments or from anyone in the room or online that they may want to make just before we break just, I just want to make sure we're hearing from everyone commissioner. We do have one individual. 420 Haga Joseph 02:43:16.180 --> 02:43:24.660 Uncing his name and he has his hand raised. So if we could promote him to a presenter, then he can go ahead and provide his comments. 421 Jim Lüttjohann, Catalina Island 02:43:29.820 --> 02:43:32.020 Can you all hear me now? 422 Haga Joseph 02:43:33.020 --> 02:43:34.940 Yes, we can understand, We could just. 423 Haga Joseph 02:43:35.180 --> 02:43:37.780 Tell us your name and your affiliation. Please. 424 Jim Lüttjohann, Catalina Island 02:43:38.540 --> 02:43:55.900 Johan, CEO loved Catalina Island where Ketalina Islands Tourism Authority and Chamber of Commerce and one of three nonprofits and I handful of other community stakeholders engaged in trying to improve reliability of internet service on Catalina Island. 425 Jim Lüttjohann, Catalina Island 02:44:01.180 --> 02:44:01.820 Should I go. 426 Haga Joseph 02:44:03.100 --> 02:44:05.140 Yes, sir, sorry. 427 Jim Lüttjohann, Catalina Island 02:44:05.660 --> 02:44:26.140 On the island, we suffer from a lack of reliable service, we suffer from a lack of redundancy of service types. we often experiences outages earlier this year for multiple days due to that lack of redundancy, we find that we are repeatedly falling outside the funding. 428 Jim Lüttjohann, Catalina Island 02:44:26.780 --> 02:44:46.620 Of, of yours or other funding sources due to our location, often even being left entirely off of maps we suffer from misrepresentation on last mile speeds as advertised versus received due to the middle mile limits that we are. 429 Jim Lüttjohann, Catalina Island 02:44:46.660 --> 02:44:57.460 Subject to, and with great interest, we are wondering how we can be included in the community outreach that member help mentioned. 430 Jim Lüttjohann, Catalina Island 02:45:00.840 --> 02:45:02.520 That's all. 431 Haga Joseph 02:45:04.680 --> 02:45:14.120 And we can work with our staff and, and reach out to you and see what we can do to set up a time to hear from, from your community. 432 Jim Lüttjohann, Catalina Island 02:45:15.640 --> 02:45:16.880 Thank you. 433 Haga Joseph 02:45:21.320 --> 02:45:28.600 Any other folks here. Joining us or online that wish to provide comments for our break. 434 Haga Joseph 02:45:34.880 --> 02:45:50.760 None correct, no, what do your mind either? Oh, with that. We can adjourn and come back and we just want to thank our panelists very much for your time for your participation here, really appreciate you being. 435 Haga Joseph 02:45:50.880 --> 02:46:11.240 Here and contributing to this and we'll reconvene at one o'clock. Yeah, and just remind everyone that we will be publishing the proposal soon and we really do encourage and need your input. So please provide comments on the proposal when it's issued there'll be a thirty- day comment period, but we do have a short turnaround. 436 Haga Joseph 02:46:11.360 --> 02:46:20.280 Time, so, so please do review it and provide your feedback. We, we need that to make it the best possible proposal possible. Thank you everyone. 437 Haga Joseph 04:07:22.960 --> 04:07:35.960 Good afternoon and welcome back. My name is Aliashi Program and project supervisor forbid, and we are going to start the second panel the first panel in the afternoon project selection. 438 Haga Joseph 04:07:38.920 --> 04:07:40.040 So. 439 Haga Joseph 04:07:41.560 --> 04:07:53.720 We're going to have a staff present short of staff presentation on this, but before that, maybe I ask all the panelists to introduce themselves started Carl on this side. 440 Haga Joseph 04:07:54.920 --> 04:08:15.400 I think delighted, Ali and thank you there. I go is my sound system working great, thank you honored to be here today. I want to thank the administrative law judge for reaching out a couple of days ago for this invitation. My name's Carl Guardino. I'm vice president of Global Government Affairs and Policy. 441 Haga Joseph 04:08:16.040 --> 04:08:33.800 For Toronto wireless, which is a technology company. Not an Internet service provider that was founded and his headquartered here in Silicon Valley, Twenty- six Phds, four hundred employees and one political science major. 442 Haga Joseph 04:08:35.880 --> 04:08:37.320 Great, so obvious. 443 Haga Joseph 04:08:39.080 --> 04:08:42.200 Good morning or good afternoon. 444 Haga Joseph 04:08:44.200 --> 04:08:53.960 Good afternoon, my name is Sam Eckland. I'm of Wilki Foreign Gallagher Council to Comcast in here on behalf of Cal Broadbin. 445 Haga Joseph 04:08:57.640 --> 04:09:16.200 Good afternoon, I'm Meredith Williams here representing at, and t- thanks for having us good afternoon. My name is Scott Armstrong. I'm from Inno County, and I'm the regional broadband coordinator for anyone on counties. Hello, everyone, my name is Georgeous Savage. I'm here representing Oakland and divided as the. 446 Haga Joseph 04:09:16.520 --> 04:09:36.680 Director Hello, Caroline. Single sink and representing the Green Lining Institute Eileen O- Dell representing the public Advocate's office. Thank you to all our in person palace. Now let's turn into our virtual panels. We have three online people who. 447 Haga Joseph 04:09:37.360 --> 04:09:44.280 With us for this panel. So should I'm asking the people online to interrupt themselves. 448 Ceilidh "Kay-Lee" Gao, CWA 04:09:45.640 --> 04:09:55.480 Hi, I'm Keyle, Gal from Communications Workers of America at District Nine. We're a labor union representing workers who work building and maintaining broadband networks. 449 Matthew Rantanen 04:09:58.600 --> 04:10:03.040 You ran Tannon, Director of Technology for Southern California Travel Chairman's Association. 450 Shayna Englin | CCF 04:10:05.760 --> 04:10:10.640 England, director of the Digital Equity Initiative at the California Community Foundation. 451 Haga Joseph 04:10:11.240 --> 04:10:31.720 Thank you all before we start this discussion on this topic, let's have a short presentation on this topic from Ben. Great, thank you Ali and thank you again to all of our panelists and attendees in the room and online. This panel will focus on project selection. 452 Haga Joseph 04:10:31.760 --> 04:10:34.560 Rules next slide. Please. 453 Haga Joseph 04:10:36.840 --> 04:10:56.680 So there are multiple project selection requirements that are specified in the notice of funding opportunity or no fell that our rules that are established in the initial proposal will have to optimize and balance some of these include prioritizing complete coverage of unserved locations, then under. 454 Haga Joseph 04:10:56.880 --> 04:11:17.160 Locations and then providing gigabit service to community anchor institutions and fund in the and funding non- deployment subgrants, so that prioritization is a requirement that the state establish a plan to serve unserved locations as defined in the statute, then underserved locations and then gigabits service to. 455 Haga Joseph 04:11:17.200 --> 04:11:37.640 Community anchor institutions as funding permits another requirement that are as project selection Rules will have to optimize for is to solicit applications on a geographic basis that will achieve complete coverage of locations, and so this is potentially a little different from some of the other state broadband. 456 Haga Joseph 04:11:37.960 --> 04:11:58.760 Programs where applicants have been free to draw their own project areas, one of the specific things that NTIA is looking for in our initial proposal is to, is an understanding that project areas will encourage applications for all unserved locations and not allow cherry P. 457 Haga Joseph 04:12:00.080 --> 04:12:19.240 Another requirement that has to be prioritized as part of project selection is to prioritize fiber deployment as much as is feasible as well as prioritizing what the no fo defines is reliable broadband technologies where feasible, we'll have a panel a little bit later today on establishing the. 458 Haga Joseph 04:12:19.880 --> 04:12:39.720 High cost per location threshold, which is an integral part of both of those of both prioritizing fiber and reliable broadband technologies, but in general, beat has a preference for fiber. It's fiber first, but it's not fiber only, and then finally I want to highlight that the project selection rules. 459 Haga Joseph 04:12:39.760 --> 04:12:53.080 Must utilize subgrant T- selection scoring criteria or a rubric of points that are aligned with the bed. No folk program goals and the next slide gets into some of these in more specifics. 460 Haga Joseph 04:12:56.360 --> 04:13:15.560 So the scoring requirements for bed are in part established by the No, and in part are free for us to determine as part of the initial proposal in ESTA in selecting subgrantees, the CPU C must utilize a scoring rubric of points and award subgrantees. 461 Haga Joseph 04:13:15.560 --> 04:13:36.040 On the basis of that scoring these, the scoring rubric is, will be, is split into primary scoring criteria and secondary scoring criteria again, established by the no, the primary scoring criteria must account for at least seventy- five percent of available points according to the rubric and these are defined by the no fo as. 462 Haga Joseph 04:13:36.080 --> 04:13:56.520 Minimum B- program outlay affordability and fair labor practices for the minimum Beed program outlay primary scoring criterion that refers to the total beed funding required for the project's completion, the affordability primary scoring criteria is specifically defined as the most affordable total price to the. 463 Haga Joseph 04:13:56.520 --> 04:14:17.000 Customer for one gigabit bit symmetrical service for priority broadband projects and that means end to- end fiber projects or for one hundred twenty megabits per second service for other last mile broadband deployment projects. So non- fiber deployments and then finally the no fo requires us to prioritize fair labor practices. 464 Haga Joseph 04:14:17.640 --> 04:14:37.480 Meaning a record and commitment to be in compliance with federal labor and employment laws as well as applicable state labor and employment laws. So those three criteria need to be part of the primary scoring criteria and must be the basis for at least seventy- five percent of our scoring rubric, the secondary scoring criteria cannot count for more than. 465 Haga Joseph 04:14:37.600 --> 04:14:57.960 Twenty- five percent of all points and no secondary criteria may count more than any primary scoring criteria. So the no fo defines two specific secondary scoring criteria, but allows definition of additional secondary criteria that meet those requirements. The no, fo defines a speed to deployment secondary criteri. 466 Haga Joseph 04:14:58.600 --> 04:15:18.440 Which applies to both priority broadband projects and non- priority and other last mile broadband deployment projects and that means the DA, the binding commitment to complete deployment by a date, certain to the faster. The project can be completed. The more points it would get the other secondary scoring criteria defined in the no- fo is. 467 Haga Joseph 04:15:18.560 --> 04:15:38.920 Speed of network or other technical capabilities criterion and this only is required to apply to other last mile broadband deployment projects. So non- fiber projects and this requires prioritization based on the greater scalability or longer useful life of the technology funded. So essentially the speed of the technolo is the speed that's a technology can support. 468 Haga Joseph 04:15:40.360 --> 04:15:57.720 Sticks can result in additional points as I mentioned within the context of secondary scoring criteria and within the context of these defined scoring criteria that are required, the CPU C- may define other scoring criteria in evaluating projects. next slide. 469 Haga Joseph 04:15:59.400 --> 04:16:19.240 So finally, after soliciting applications on a, on a project area basis that will, that will encourage complete coverage. The CPUC must engage in certain post- application activities before making awards these include deconflicting overlapping applications if necessary. So to the extent that applicants. 470 Haga Joseph 04:16:19.280 --> 04:16:39.720 Are able to draw their own project areas that could potentially overlap the CPU. C- must conduct a deconfliction process to allow, like, for like, comparison of competing proposals and scoring between those projects, the CPUC must also score the applications and determine the winners for areas with applications received and then finally for areas. 471 Haga Joseph 04:16:39.840 --> 04:17:00.200 Did not receive applications this, the NTIA is encouraging states to engage perspective subgrantees for any of those areas that did not receive applications and negotiate any necessary inducements to obtain applications for those locations. This process must be as transparent as possible and remain fair. 472 Haga Joseph 04:17:00.200 --> 04:17:20.680 Particularly by potentially, by defining rules for how that post application inducement and negotiation process will function, but it is part of getting to complete coverage, even if areas do not receive applications, I believe that is my last slide. Thank you Ben. So now. 473 Haga Joseph 04:17:20.800 --> 04:17:23.480 Let's move to next slide. 474 Haga Joseph 04:17:25.200 --> 04:17:45.000 These are the questions that we are going to discuss with our panelists. The questions going to be on the screen, but I'm going to just going to read them quickly and then we are going to have the discussion the same process as our first panel this morning, asking our panels to limit their comments to five minutes. 475 Haga Joseph 04:17:46.280 --> 04:18:06.120 So I'm going to read the questions if Apple Cans are allowed to construct their own project areas, what mechanism should be used to one in short complete coverage of uncert and, or under several locations and to the conflict overlapping proposals, if project areas are predef. 476 Haga Joseph 04:18:08.040 --> 04:18:27.240 These pre- existing geographies such as counties, tribal lands, or cities that should be used or should project areas be drown based on clusters of unserved or underserved locations. How should the required scoring criteria including affordability labor standards, minimum beat. 477 Haga Joseph 04:18:28.560 --> 04:18:47.720 Deployment and technical capabilities be applied to individual projects and where did we see Arubric? Are there additional scoring criteria such as awarding points on the basis of equity or climate resilience that should be included. How should those points be awarded in the POS. 478 Haga Joseph 04:18:47.840 --> 04:19:08.200 Application process, how should the commission prioritize identifying applicants to remain remaining answered or under sublocations, not included in an application, but inducement should be used to encourage applications applications for those locations. Now we are going to start. 479 Haga Joseph 04:19:08.840 --> 04:19:24.720 With our customer advocates participants, we have three pounds on this Eileen, Kayley and Caroline. So want to start and please limit your total comments to five minutes. 480 Haga Joseph 04:19:26.120 --> 04:19:46.600 So thank you, Commission staff commissioner hack. Thank you all for letting us speak today. I am speaking on behalf of the public Advocates office and in general, on behalf of the Center for Accessible Technology and return consumer advocates here are concerned with cherry picking, leaving out red line and other historically disadvantaged communities, there's certainly nuance. 481 Haga Joseph 04:19:46.640 --> 04:20:07.080 Between our positions as consumer advocates on how to prevent this and folks may expound upon those in comments. Cal advocates believes that predefined project areas are the best way to efficiently ensure complete coverage of unserved locations and to generate apples to Apple's project comparisons within the beed timeline of the twelve states that have submitted. 482 Haga Joseph 04:20:07.080 --> 04:20:27.560 An initial proposal volume two to the NTIA as of about four o'clock yesterday, all twelve have proposed predefined project area units based either on geographic or political boundaries like census blocks, census block groups, unified School District, or based on excuse me commission generated state generated clusters of unserved and under. 483 Haga Joseph 04:20:27.880 --> 04:20:48.040 Locations all states, but one require project proponents to apply to serve all eligible locations within those predefined project areas, Vermont requires ninety- five percent. The commission should designate census, block level project area units, allowing applicants to propose projects covering one or more census blocks, but committing to serve all eligible. 484 Haga Joseph 04:20:48.760 --> 04:21:08.520 Locations in each census block applied for census block level project units allow applicants more flexibility in defining overall project areas, given their relatively smaller size and would allow for greater participation from non- traditional providers as the state of Louisiana noted in their draft initial proposal volume two, this methodolo. 485 Haga Joseph 04:21:08.800 --> 04:21:29.000 Allows perspective grant subgranties wide flexibility to define their own proposed overall deployment projects provided that such proposals are submitted in the form of sets of predefined project areas. I'm going to move into talk about the respond to the second question, however, there are too many scoring criteria to ade. 486 Haga Joseph 04:21:29.920 --> 04:21:49.480 All of them in this venue. So I'm going to focus on those that we consider a primary importance and that's affordability our opening comments on the, OR filed on April seventeenth relay our preferences for the weight, each scoring criteria should be afforded in a rubric, but in short, if the commission does not intend to adopt comprehensive affordable. 487 Haga Joseph 04:21:49.920 --> 04:22:09.960 Plan requirements for low- income and middle class Californians given the mandate to ensure that Beed funded projects deliver affordable service affordability should be the primary and most heavily weighted criteria and applied when deciding between competing projects, this primary criteria should be applied to individual projects as. 488 Haga Joseph 04:22:10.600 --> 04:22:30.440 Of the relative affordability of plans offered at the one gigabit symmetric level five hundred one hundred megabits per second level one hundred one hundred level and one hundred and twenty- megabits per second level. The commission should assess affordability at each of these levels to induce applicants to propose lower rates for wider range of plans than just the one gig. 489 Haga Joseph 04:22:30.800 --> 04:22:50.920 Plan referred to, in the no fo for priority broadband projects. The commission should consider awarding points either only to the cheaper of the plans offered by each competing application at each speed threshold or awarding points to each plan based on the proposed rates variation from a reference point as proposed by the state of Illinois. The applicant should be required to commit to. 490 Haga Joseph 04:22:51.200 --> 04:23:11.400 ING these rates at no more than proposed in the application for five years following project completion to earn those points while the no folk provides a bare bone description of this comparison point. The commission should consider aspects of the plan under comparison beyond pricing speed, including any other initial or recurring costs to the customer or data CAPS plans that have marginally. 491 Haga Joseph 04:23:11.800 --> 04:23:31.880 Service costs, but that also have data caps or larger deposits or activation fees should not be preferred. That's a lot of detail for this response here, and I am gonna yield my time. Thank you, thank you all for allowing me to speak today and I would like to note that my comments are focused on the questions pertaining two additional scoring criteria and the project selection process. 492 Haga Joseph 04:23:31.920 --> 04:23:52.360 As previously stated in our opening comments in April and the OAR, we requested the commission- prioritized direction of resources to disadvantage communities along with the provision of open access networks and lifetime affordability agreements for built infrastructure. Additional equity provisions are also needed in the final scoring criteria. 493 Haga Joseph 04:23:52.360 --> 04:24:13.480 To ensure that the lowest income and most disadvantage communities are well positioned to combat private sector disinvestment, which has allowed for the proliferation of the digital died and digital red lining and many of these communities we're also in support of a clearly defined rubric with additional points being offered for applicants who prioritize low- income communities of color using. 494 Haga Joseph 04:24:14.400 --> 04:24:33.960 Tools such as Subie or Calenvirus Green that are used for additional state programs being made publicly available to all applicants in order to encourage such equitable investments and in the case of duplicative projects, we would support the final determinations being made in a manner that is equally minded of disadvantage communities and prioritizes using. 495 Haga Joseph 04:24:34.680 --> 04:24:54.440 The study or calend screen in eligible locations and in a state as large as California it is also essential that greater consideration is given to the climate resilience of proposed speed projects to maximize the impact of this once, in a lifetime federal investment GLI is adminant in our request for greater affordability requirements for the full. 496 Haga Joseph 04:24:54.640 --> 04:25:14.240 Built life of federal broadband infrastructure projects, in addition to any other shorter term affordability commitments and we believe in the absence of meaningful affordability requirements that go beyond traditional short term timeframes. This program could possibly not be a steward of taxpayer funds effectively. 497 Haga Joseph 04:25:14.960 --> 04:25:22.160 Thank you, thank you. So let's turn to our online panels. 498 Haga Joseph 04:25:27.080 --> 04:25:28.200 Kelly. 499 Haga Joseph 04:25:32.840 --> 04:25:34.760 You can't hear, you're spea. 500 Ceilidh "Kay-Lee" Gao, CWA 04:25:36.720 --> 04:25:38.200 How about now? 501 Haga Joseph 04:25:39.080 --> 04:25:40.520 We can hear you. Thanks. 502 Ceilidh "Kay-Lee" Gao, CWA 04:25:41.780 --> 04:25:56.380 Apologies for that. The communications workers of America CWA is a labor union whose members are workers on band networks. I will speak on labor standards a statu. 503 Ceilidh "Kay-Lee" Gao, CWA 04:25:57.740 --> 04:26:00.220 CWA, we like to. 504 Haga Joseph 04:26:03.460 --> 04:26:05.180 You're cutting an out. 505 Ceilidh "Kay-Lee" Gao, CWA 04:26:12.420 --> 04:26:15.180 Not sure what else I might change. 506 Haga Joseph 04:26:17.140 --> 04:26:18.180 That seems better. Go ahe. 507 Ceilidh "Kay-Lee" Gao, CWA 04:26:18.220 --> 04:26:31.540 Hopefully, okay, I, I guess it's a physical thing apologies, so I will speak on labor standards a statutory priority. We like to highlight the jobs, part of the infrastructure. 508 Ceilidh "Kay-Lee" Gao, CWA 04:26:33.540 --> 04:26:54.020 The feed, no, full requires that labor standards receive substantial weight and CWA recommends that labor standards receive a third of the weight given to the three primary volume, two proposals of other states released so far are similar, for example, elaware allocating and Nevada twenty percent to labor standards as. 509 Ceilidh "Kay-Lee" Gao, CWA 04:26:54.020 --> 04:27:14.500 Recognized by the seat of California in its high road labor policies, labor standard support, effective programs and uninterrupted build and points allocated to labor standards are well spent supporting multiple objectives. The commission should also ensure the fair labor practices category is as effective as possible by adding additional factors to. 510 Ceilidh "Kay-Lee" Gao, CWA 04:27:14.820 --> 04:27:34.980 Consideration of plans to be in compliance, including prioritizing a directly employed workforce for broadband deployment installation maintenance, robust in- house training programs, family sustaining wages and benefits and policies that support job creation for tribal members and other disadvantaged communities, additionally, collect. 511 Ceilidh "Kay-Lee" Gao, CWA 04:27:35.100 --> 04:27:51.540 And publishing information regarding subgrantees. Workforce plans is a simple way to multiply the benefits of labor standard requirements and allows the public and worker organizations to be an ally in enforcement and accountability. Thank you for your time and work on the program. 512 Haga Joseph 04:27:52.340 --> 04:28:12.180 Thank you, so now we move on to our community reps on the panel. Scott. I met good afternoon again, Scott Armstrong, Rena Broadband Coordinator for any Amono counties. So this is an interesting. 513 Haga Joseph 04:28:14.020 --> 04:28:33.220 Problem to solve from the perspective of the rural counties because we realize that selecting projects to get the most coverage generally looks at larger populations and we are looking at towns of nineteen thousand, twenty- five thousand, you know, you, you. 514 Haga Joseph 04:28:33.340 --> 04:28:53.700 Can make a case for that when you're looking at counties of twelve thousand and nineteen thousand, it's a bit more of a challenge. So what I, what I'd like to offer is when I saw as an intent in the FFA applications to, for. 515 Haga Joseph 04:28:54.060 --> 04:29:02.260 Providers applying for grants to partner with county governments and tribal governments. I think that would be. 516 Haga Joseph 04:29:04.260 --> 04:29:12.740 Useful scoring amount to include in this as well. I think what Matt Ranchanna described earlier with. 517 Haga Joseph 04:29:15.460 --> 04:29:34.660 Full awareness of what the project application is going to be, would be critical. I think the FA, the intent of FFA was to get to that, but I think as we saw in our first round, it didn't quite give us what we needed. So I think that using the county governments and the tribal tribal nations to. 518 Haga Joseph 04:29:36.860 --> 04:29:55.140 Partner with the providers and a word points for that partnership. I think that would, that would help the county governments and the tribal nations know what's where the gaps are larger, small and it's easier for me to see the problem. 519 Haga Joseph 04:29:55.140 --> 04:30:08.860 Problem in my area because we have nineteen thousand people in our county. It's the second largest by land County in the state. So as far as deconflicting overlapping applications, I think that would solve that problem. 520 Haga Joseph 04:30:11.780 --> 04:30:30.340 And I do like the idea of using since this blocks or groups of census blocks as project definitions, primarily because the federal government and the state government already have so much information associated with that. It'll make it easier to associate data in maps and reports. 521 Haga Joseph 04:30:30.420 --> 04:30:39.660 At that level, I think the county itself as a project area might be a little bit too large to, to focus on. 522 Haga Joseph 04:30:43.140 --> 04:31:01.700 I think I'd like to stop at that point, but thanks, thank you. So Georgia. Thanks great, thank you again for inviting me here today Georgia, Savage from Oakland, Divided in response to the first question d- conflict overlapping proposals. I want to first uplift. 523 Haga Joseph 04:31:01.860 --> 04:31:22.180 Comments made by my fellow panelists, Caroline from Green lighting, open undivided agrees that in the case of overlapping proposals, the commission should develop a point system that allows the CPUC to prioritize projects with the largest weight given to disadvantage communities and disadvantage communities can be defined using existing metrics such as the fifty. 524 Haga Joseph 04:31:22.540 --> 04:31:42.660 Of communities with the highest study score or calen by or screen disadvantage community in the case of Oakland, this would certainly benefit the communities that have been historically red line and we know have the least connected residents for question two. I also want to respond to that, particularly the question should project areas be drawn based on clusters. 525 Haga Joseph 04:31:42.700 --> 04:32:03.140 Of unserved underserved locations in short, our answer is no project areas should not be drawn based on clusters of unserved under serve locations as I know many of you are aware since February and as recent as yesterday at the California Broadband Council meeting, equity advocates from, across the state have provided the CPU C- with evidence. 526 Haga Joseph 04:32:03.180 --> 04:32:23.620 Of an accurate data in the current FFA maps and I've seen from Patrick who presented on panel one. The visual is there show that the FFA maps have fabricated need in the wealthiest areas of our county and Alimina County. That's pleasant. That's Dublin and we've used the publicly available tools. The ISPS have provide. 527 Haga Joseph 04:32:25.100 --> 04:32:44.100 And at, and t- lookup tools and we can verify that these locations are actually already being served at extremely high speeds on the other end of that we see under stated needs in the lowest income historically, red line communities and once again, Patrick presented our work with Hubaiq and OSD we're using. 528 Haga Joseph 04:32:44.180 --> 04:33:04.580 Student chromebooks to run SP tests at home and in only thirty days we were able to see density of red dots and Eastern Watch Oakland, the historically red line communities that vastly out number the dots that we see on the FSA map and that was only in a time period of a month on the topic of clusters. 529 Haga Joseph 04:33:04.699 --> 04:33:25.699 We're also seeing clusters in wealthier communities and more sports dots and lower income communities, which makes these areas obviously more competitive for grants. So our primary question is how will the process for creating this map be different from the creation of the FSA map, if it's created using the same process, we obviously expect the same results, which is. 530 Haga Joseph 04:33:25.779 --> 04:33:46.180 A demonstrably inaccurate map that results in disparate impact, we understand that starting with the FCC fabric is rough given the inaccuracies there, but obviously NTIA has communicated, we can use our best global data. So I want to uplift what Lindsay from Kate said in panel one that, you know, this is a really important juncture in which. 531 Haga Joseph 04:33:47.020 --> 04:34:07.301 Can respond to these community calls for a transparent process of creating this map in partnership with the community, which we hope will reflect more on the ground truth and lastly question four additional scoring criteria such as awarding points on the basis of equity, we want to refer to advocates. 532 Haga Joseph 04:34:07.340 --> 04:34:27.779 First of all, really encourage equity considerations in the rubric, however, we do want to reference that for last mile FSA Rubrick section g, which was targeted at identifying community disadvantage communities and prioritizing those, unfortunately the last additions to the FFA scoring Rubric Dilut. 533 Haga Joseph 04:34:28.420 --> 04:34:48.900 Points and two critical ways, the first of which, that there was no scoring. So in nearly every other major categories, such as match or type of partnership, the CPU c awarded partial points, but for this equity category, it was all or nothing, so applicants were either awarded the twenty points or not, which is obviously a sizable amount of points. 534 Haga Joseph 04:34:48.900 --> 04:35:09.381 For that application, and if there's ever a category to word partial points, it's definitely the equity based metric. So, call and virus green communities are the most vulnerable marginalize in the state. So the full twenty points should be awarded to those communities and reserve for those partners from opportunity. The second point we want to raise is. 535 Haga Joseph 04:35:09.461 --> 04:35:29.859 The definition for disadvantage as it stands as it stood in the FFA definition. This could include California's wealthiest communities. So the CPUC was awarding the full twenty points to projects where fifty percent of the unserved locations are incredibly wealthy. So long as the least fifty percent of the locations are. 536 Haga Joseph 04:35:30.779 --> 04:35:50.340 Eighty percent of the median household income state or county whichever is higher. So this led to some applicants, cherry picking projects to ensure they receive the points, for example, in San Francisco, you know, a project serving Noa Valley could earn that twenty points for disadvantage communities. So long as they included a slever of the mission and we believe this is inequitable. 537 Haga Joseph 04:35:52.660 --> 04:36:12.420 So to summarize, we do believe the point should be awarded on the basis of equity by including disadvantage communities, but we need to make this agredient score and we need to redefine disadvantage communities using the previously proposed definition fifty percent of communities with the highest SEV score or calenvirus green disadvantage community. Thank you. 538 Haga Joseph 04:36:12.420 --> 04:36:19.381 Thank you, now let's turn to Shane, England from CCF with us remotely. 539 Shayna Englin | CCF 04:36:21.381 --> 04:36:41.859 Hi, thank you for having me, I'm, I'm gonna stay off video because totally appropriately I'm working in the field today from what the community partner in downtown Los Angeles where the internet is expensive and can best be described as Iffy. So, so that you can continue to hear me. I want to stay off video. I'm Shane, England, director of the digital equity. 540 Shayna Englin | CCF 04:36:41.939 --> 04:37:02.340 Initiative at the California Community Foundation and co- convener of the digital equity LA coalition we're going to address two, the two questions we're running project area definitions and the two questions regarding scoring big picture first, we do want a second, the comments of you heard this morning from my colleague Natalie, my fellow panelists just now Georgia. 541 Shayna Englin | CCF 04:37:02.779 --> 04:37:22.820 Really all community and advocates for quite some time. Now that broadly the big process rules and approach must be more inclusive of community- led broad based truths and more consistently and effectively center equity than the federal funding account or other cassive fundings programs have to date and generally speaking we encourage the commission to ADO. 542 Shayna Englin | CCF 04:37:23.221 --> 04:37:43.301 Watch words as they think about this as community equity and transparency. So getting to specifics, we believe that project applicants should broadly be allowed to define their own project areas around complete sensus blocks or census block areas. Sorry, essential block groups, but to protect against the demonstrated practice on the part of incumbent is. 543 Shayna Englin | CCF 04:37:43.580 --> 04:38:05.061 Of cherry picking, the most lucrative areas over those most in need. There should be an appealable requirement to serve every location in the chosen area and a requirement to demonstrate that the project area encompasses the entirety of what could be locally defined as a community. So some examples of this that make this practicable in the city of Los Angeles. There are neighborhood area councils with. 544 Shayna Englin | CCF 04:38:05.061 --> 04:38:25.539 Specific boundaries in other cities and actually in, in the city of LA, there are local electoral districts, city council or school board and absent these kinds of official boundaries, affidavits, or other community- based affirmations of what those boundaries are, could serve and on this, we also want to be very clear that we defer to tribal leaders regarding project areas in this way on. 545 Shayna Englin | CCF 04:38:25.539 --> 04:38:46.020 Around Tribalands regarding the question of de- duplicating locations and proposed project areas, we would advocate, in addition to what you've heard from our, our partners and can we second at green lighting and open a divided foodicate for a ride of first refusal for projects that are municipal in community driven. 546 Shayna Englin | CCF 04:38:46.260 --> 04:39:06.500 Those that are partnered with municipal or community organizations as a gentleman from Indio mentioned, and in the case where duplication is versus two private providers there with no partners or any connection to this or public preference should go to the applicant that scores the highest on equity affordability and labor metrics. We holy reject BAS. 547 Shayna Englin | CCF 04:39:07.221 --> 04:39:26.980 Excuse me basing project areas on clusters of unserved or underserved locations, given as Georgia mentioned the very well documented reality that the state's mapping of those locations is consistently insist in medically flawed with imagine clusters of need and wealthy communities and disappeared needed low income communities, Georgia mentioned examples and I don't. 548 Shayna Englin | CCF 04:39:27.260 --> 04:39:47.460 County here where I'm sitting in LA, our community of Cover City, which is wholly served by charter and by team and pockets of at, and T- has many dense plusters of showing need on the maps, whereas the community of Mcarthur Park, which has about a thirty- five dis percent. 549 Shayna Englin | CCF 04:39:47.780 --> 04:40:07.940 Connected rate and we have documented time and time, again, large building serving low income communities that have no service at all on the map show. No need, we could come up with example after example after example the existing maps and how the CPUC is looking at what is an unserved or understerved cluster. It's is perhaps Irretrieva. 550 Shayna Englin | CCF 04:40:09.940 --> 04:40:28.420 Affordability on labor standards, including local hire and equity should be waited significantly more heavily than speed to deployment and technical capabilities past and inequitable is worse than slower and actually contributing to solving the digital divine and with respect to affordability. We think. 551 Shayna Englin | CCF 04:40:29.300 --> 04:40:48.900 Model as originally a visioned is a reasonable starting point. Applicant should be required to commit to a maximum price for the life of the public infrastructure with the requirement transferred in the event of the sailor merger and with the price adjustable over time for inflation for other market driven factors in collaboration with CPUC, we also want to flag. 552 Shayna Englin | CCF 04:40:49.540 --> 04:41:09.380 The, under use of the commissions, extensive affordability rule making, we are an urgent updated report producing current areas of affordability concern that affordability ratio data for the state and the use of the public advocate's office, recent report on broadband pricing to identify additional metrics that may be useful with respect to pricing practices that affect affordability. 553 Shayna Englin | CCF 04:41:10.020 --> 04:41:29.860 And finally with respect to equity metrics, the commission to take to heart and early lesson from FFA as we were learning this week and ensure that they have, the score is not a switch, but a dial, the POC as Georgia just mentioned towards the full twenty points to projects were up to fifty percent of unserved location. 554 Shayna Englin | CCF 04:41:30.580 --> 04:41:50.340 Are wealthy, so long as at least fifty percent of the locations are at or below eighty percent of medium household income at the state or county level, whichever is higher. So that is a very easily gamed twenty points and our analysis of FFA applications by private providers showed that they have indeed gained it. So we'll see, we see. 555 Shayna Englin | CCF 04:41:50.460 --> 04:42:10.820 Many projects that have are mostly serving high income low need communities and then they maybe jut out to collect a block of apartment complexes in order to hit that kind of laughable threshold for disadvantage community. so we recommend along with open divided in others, a. 556 Haga Joseph 04:42:15.980 --> 04:42:26.900 Now we are ha almost halfway through our panelists for this session, just a quick pause to see if Commissioner or Josh, if you have any questions so far. 557 Haga Joseph 04:42:44.740 --> 04:42:49.420 Just a question and maybe direct it to the, the. 558 Haga Joseph 04:42:50.500 --> 04:43:10.980 The counties and to Mr. Ramtan on the. Can you talk a little bit more about what you anticipated regarding partnerships. So the suggestion was that if the carrier is gonna partner with the counties that it be treated similarly to what the NOFO requires for. 559 Haga Joseph 04:43:11.060 --> 04:43:32.100 Tribes or would you be looking to have a, like some sort of additional points that would be put in there if a carrier can show that they've coordinated and are working directly with, with the tribes. I know that we have that in. it's in an o- four, the tribes already, right? And if we had something similar for the count. 560 Haga Joseph 04:43:32.820 --> 04:43:37.060 And we were able to truly emphasize. 561 Haga Joseph 04:43:39.140 --> 04:43:58.980 Criteria that a provider provider would have to meet to get those points. That would be very useful and I'll, I'll explain where that's coming from. So we had during the FFA application process, we had one provider who did show me maps of. 562 Haga Joseph 04:43:58.980 --> 04:44:19.460 Whether they're going to cover, so I knew that they were hitting areas that needed to be covered. They were already on our list to knock out, we had another provider who said, Yep, around this town never got any detail on it. It got to the point where we weren't going to be able to realistically sign. 563 Haga Joseph 04:44:21.500 --> 04:44:39.940 Support for a project that we had no definition of, and I understand the sensitivity of what a- what a provider is trying to plan for, they don't want to show their hand too much, but if, if we're going to build out to everywhere, there will have to be some trust and. 564 Haga Joseph 04:44:40.140 --> 04:45:00.420 I fortunately, I, I said, I'll sign an NDA whatever, but I'd like to see where you're gonna where you're gonna build out and that worked for us, and so I think that level other than just Hey, I'm gonna cover your area sign this letter the week that it's due isn't. 565 Haga Joseph 04:45:01.740 --> 04:45:20.900 Because my, the county boards and the C and the city boards they want to know what, what the plans are, and it really, they're not really in the driver's seat when I have to tell them after the fact. Oh yeah, these applications went in. They need to know ahead of time that the applications are going to go in and. 566 Haga Joseph 04:45:21.580 --> 04:45:28.580 If that, if that makes sense, if that comes across, right, what I'm looking for is real true engagement and. 567 Haga Joseph 04:45:29.900 --> 04:45:44.580 Partnering between the county governments, the tribes and the providers who are putting in the applications and I don't know if any of the providers wanted to comment on how they're coordinating with any of the, the local governments or. 568 Matthew Rantanen 04:45:44.580 --> 04:45:45.860 I do have comment. 569 Haga Joseph 04:45:47.140 --> 04:45:48.420 Oh, go ahead. map. 570 Matthew Rantanen 04:45:48.620 --> 04:46:08.900 So I'll go ahead and tie you Scott's comments and then, and then we can hopefully move past that. So, yeah, Mr. Armstrong is illustrating something that's happening actually, in this area, which I've been engaged with tribes in that area that are having a problem with a provider who is coming in and, you know, has applied for FFA Fund. 571 Matthew Rantanen 04:46:10.260 --> 04:46:30.740 Is interested in serving their census blocks and is telling them verbally that they're gonna serve their community with, you know, x amount of service and X amount of connectivity and coverage, but there's no written agreement. There's no, there's no written proposal. There's no understanding of coverage the tribe. 572 Matthew Rantanen 04:46:30.740 --> 04:46:51.220 Is, is being pressured and designing a letter of vin ten or support for this, This carrier and tribes are very confused. So they're reaching out to people that they know to ask questions, so, you know, what is this mean? Why are they doing this and, and that is not, that is not, you know, proper engagement with the tribe, if you are going to serve. 573 Matthew Rantanen 04:46:52.260 --> 04:47:11.700 That is a travel community. You should be engaged with the government. There's a process there where you interact, you know, as you would with any other business or any other community, you should, you should be engaging the stakeholders of that community and the government of that community, that, that understand the needs and understand. 574 Matthew Rantanen 04:47:11.700 --> 04:47:32.180 Understand the value. So to go down the points, I mean, in short complete coverage of a underserved or unserved areas. So if this census block is, you know, in, in that carrier suite spot and they would like to retain those funds for that, then, you know, present a solution and, and then have a dialogue and listen. 575 Matthew Rantanen 04:47:32.340 --> 04:47:53.300 To the needs of the, of the community of the tribe and then come up with that final solution or an adjustment to solution that serves the complete sensus block at the coverage rates that are needed. Some of those tribes are also being told that they don't need more than twenty five three or they don't need more than what they have. Now that is behavior unbecoming. So. 576 Matthew Rantanen 04:47:53.300 --> 04:48:13.780 I think tribes know what they need. I think tribes understand the value of broadband, especially after the rest of the world got to see what it was like to not have broadband during COVID and be trapped at home. I, you know, tribes get it. We get it. I mean, we, we all figured it out, you know, the value of this and, and we know the needs of our education departments, we know the needs of our travel governments. 577 Matthew Rantanen 04:48:15.060 --> 04:48:34.260 In our, after school program, so, you know, they'll tell a community what they need because that's what you want to serve them with. Let's, let's have an engagement process. So if a tribe is truly involved in the process and, and signs off on the. 578 Matthew Rantanen 04:48:34.540 --> 04:48:44.140 The consent then you won't have to deconflict overlapping proposals because there won't be any, and then if project areas are predefined. 579 Matthew Rantanen 04:48:47.060 --> 04:49:06.260 I think areas like the tribal lands. I think we need to worry a little bit about definition because tribes often have, like I said, pre- in the previous panel, there's populations that are outside the federal reservation boundaries. So we might consider, you know, a definition of. 580 Matthew Rantanen 04:49:06.620 --> 04:49:26.740 Lands that was used. Prior was used during the Obama administration that was supportive of travel communities that lived outside the, the boundaries of the federal reservation and then I, you know, I post it to the CPU C to consider their state recognized tribes and how they, how they would like to work with, with those. I. 581 Matthew Rantanen 04:49:26.860 --> 04:49:42.460 You know, I, I think a representative from the state represent a state- recognized tribe should probably be weighing in on this, and I'm not an expert in that space, but, you know, that's, that's something that should be considered because California has quite a few state recognized tribes. so thank you. 582 Haga Joseph 04:49:43.380 --> 04:49:54.020 So thank you, Mr. Renthannon. Thank you, Mr. Armstrong and I didn't know if any of the carriers wanted to talk about how they're coordinating with local governments and what their perspective is on. 583 Haga Joseph 04:49:55.580 --> 04:49:58.620 The point system in, in that regard. 584 Haga Joseph 04:50:01.300 --> 04:50:20.500 I will just wait in a little bit because I was gonna address this in my comments anyway, but I agree that there should be coordination with the communities that you're gonna be working with. I think the concern from a provider perspective is when you tie that coordination to ownership of assets are being built and so there, I think as long. 585 Haga Joseph 04:50:21.540 --> 04:50:28.540 Separate those two things. I think that we are fully in agreement with the counties and tribes that we're talking to today. 586 Haga Joseph 04:50:30.100 --> 04:50:44.860 Thank you, and then one other question, and I think this goes to some comments that Miss England from CCF and Miss O. Dell from Cal Advocates on affordability. Can you talk a little bit more about? 587 Haga Joseph 04:50:46.100 --> 04:51:06.580 How we can fully address the affordability issues as the intent here is to get infrastructure out to unserved communities, but we, we do not rate regulate broadband service and so in regards to how we can address our point system and balance that fact along with the comment that. 588 Haga Joseph 04:51:07.460 --> 04:51:19.180 Had made regarding how we could potentially utilize our affordability proceeding to further address this issues. Just wanted to hear what some of her thoughts were on that as well. 589 Haga Joseph 04:51:23.260 --> 04:51:24.780 Do you want to go? 590 Shayna Englin | CCF 04:51:25.140 --> 04:51:28.340 Yep, no, elite Eileen, go ahead. I'll follow you. 591 Haga Joseph 04:51:28.980 --> 04:51:48.820 Thanks Shina, so, so first of all I do want to be clear on the differences between a gate requirement like a baseline requirement that's going to be required of all projects and then these scoring criteria, absolutely, I think the, the gate requirements are going to be the strongest way to ensure all of these projects do deliver affordable. 592 Haga Joseph 04:51:48.820 --> 04:52:09.300 Service and we think that that's best achieved through the required low cost broadband service option, but also a very strong plan requirement for middle class affordability, so that those baseline requirements are how I think that we can best tackle affordability here. I don't think rate regulation is an issue. This is not rate regulation. This is a term of a grant. 593 Haga Joseph 04:52:09.460 --> 04:52:17.340 This is a contract term and I think the courts are very clear that this is not regulation. We should not be distracted by arguments to that effect. 594 Shayna Englin | CCF 04:52:21.460 --> 04:52:22.740 I, I. 595 Shayna Englin | CCF 04:52:23.540 --> 04:52:43.860 Add plus one plus a hundred plus a thousand two eileen's point there. I think that the conversation of the concern that's raised around regulation is entirely misplaced and is a distraction. We should just dismiss out of hand. There's no requirement that any company applied for or accept public money to build. 596 Shayna Englin | CCF 04:52:44.300 --> 04:53:04.340 Their networks, so there is no rate regulation. We would concur also with public advocates on the, the gate approach and then beyond that in terms of the affordability, we're making that exists and the, the reports we just flag that, the last one that was done was in. 597 Shayna Englin | CCF 04:53:04.420 --> 04:53:24.820 Twenty- twenty and I think the more recent pao- broadband pricing report, you know, points to a real need for update there and in terms of how to use it, and I think that there should be a look at maybe thinking about where some of these affordability points. 598 Shayna Englin | CCF 04:53:24.820 --> 04:53:35.700 Or even a category of affordability points live is in areas that are of high affordability concern or where the affordability ratios are. 599 Shayna Englin | CCF 04:53:37.060 --> 04:53:57.460 Of concern, and so I think, you know, in terms of today here could have kind of specific recommendations of what that would look like. I think we're compared to make those, but broadly, there's clearly a wealth of very good databased information within that role, making, and within what should. 600 Shayna Englin | CCF 04:53:57.700 --> 04:54:01.420 Updated reports to help drive that thinking. 601 Haga Joseph 04:54:04.500 --> 04:54:24.980 Thank you, Mr. Clickal, judge, click goal. Did you have a question? Excuse me. Could I sure would it be possible away in as well? Yes, yeah, and well, yes, so anyone else that wants to weigh and let us know, and then we'll go to Judge Quickel. Thank you, just stepping back a little. 602 Haga Joseph 04:54:25.460 --> 04:54:46.100 On the topic of affordability to give context Congress in the IIGA incorporated affordability in two ways. So first was enactment of the affordable connectivity program and second is the requirement that all be funded providers. 603 Haga Joseph 04:54:46.140 --> 04:55:07.220 Provide a low cost service option to then be able to take advantage of the affordable connectivity program and this approach is supported by longitutoral data from NTIA itself over a year after year, the data shows that affordability is a barrier to broadband adoption, but. 604 Haga Joseph 04:55:09.580 --> 04:55:27.700 Demonstrably the largest barrier for the lowest income residents and that is exactly what ACP is designed to address. That's exactly what the low cost service option is designed to address. Now when it comes to affordability subgrantees selection criteria. 605 Haga Joseph 04:55:29.060 --> 04:55:48.180 We strongly propose that. The state take the approach that other states have adopted as well and use a tried intrude method for determining affordability in high cost broadband equipment, grant deploy deployment programs, which. 606 Haga Joseph 04:55:48.180 --> 04:56:08.660 Which is what they BSCC has used for years. So in this respect, you know, the commission should be looking at applicants commitment to provide service and customers at rates that are consistent or reasonably comfortable in subsidized areas that. 607 Haga Joseph 04:56:09.980 --> 04:56:29.140 To the rates that they provide and non- subsidized areas. It's the same thing, you know, alternatively, or in addition, making sure that those rates are consistent with the SECS annual urban rate survey. again, the, the design of this, which is in the communications act. 608 Haga Joseph 04:56:31.140 --> 04:56:50.780 Consumers in high cost areas to serve are not undually footing the bill for more expensive broadband service. We want to make sure that, that everybody, that's connected to be funded networks are being served with high quality affordable broadband service on par with. 609 Haga Joseph 04:56:52.740 --> 04:56:57.260 Available to existing customers in the state. 610 Haga Joseph 04:56:58.460 --> 04:57:18.940 We don't what the state should avoid doing and, and commissioner. How thank you for recognizing the strict prohibition and the IJ against rate regulation. We don't want the state to be benchmarking affordability against an arbitrary number dollar amount again. 611 Haga Joseph 04:57:18.940 --> 04:57:39.420 Going to the reasonable comparability standard. This is a standard that's been used for exactly the set of programs for a long time and, and avoids any of the pitfalls or rate regulation and I appreciate comments deferring from a legal perspective as to whether or not. 612 Haga Joseph 04:57:39.540 --> 04:57:51.020 This would constitute regulation and we'd be happy to provide citations and a further discussion in comments in support of this. So thank you. 613 Haga Joseph 04:57:52.340 --> 04:58:12.700 Commissioner be very brief on your question, three sentences and no run on sentence involved. So first I believe there's roughly a hundred and nine federal recognized tribal communities in California about another forty- on that, that have not sought federal recognition and each with their own unique needs, but. 614 Haga Joseph 04:58:13.340 --> 04:58:33.180 In our most rural parts of California and therefore the most difficult to serve, so we have to be, especially sensitive to how we best partner from the beginning all the way through implementation and ongoing. We're working for instance, one of the many tribes that trying to wireless is partnering with is the. 615 Haga Joseph 04:58:33.220 --> 04:58:53.660 Around valley tribal community and that has been our approach with them. The third comments to Samuel's point on the ACP that is currently a probably going to run out April of twenty- twenty- four fortunately, President Biden is seeking an addition. 616 Haga Joseph 04:58:53.900 --> 04:59:14.140 Six billion dollars for the ACP, which would at least get us to the end of twenty- twenty- four, but for those of us who believe in that more affordable service thirty per household, thirty dollars a month per household for people of modest means in the United States seventy- five per month for people in our tribal communities, we need to be working to. 617 Haga Joseph 04:59:15.420 --> 04:59:16.700 That extended. 618 Haga Joseph 04:59:18.620 --> 04:59:39.100 And I see lots of headshaking on that front, hopefully vertically and not horizontal. Yes, I think I see melts of head noddings, I guess I'll, I'll let people Commissioner could I add something to that as well. Thank you. Yeah, I just want to respond to some of Samuel's comments as well, notably, obviously we're encouraged to. 619 Haga Joseph 04:59:39.260 --> 04:59:59.580 I think all of us that the ACP, the White House has asked Congress to approve that six billion dollars to run through twenty- twenty- four, but it's unclear if that's enough for that or, you know, whether that's going to get approved and the second point I'd just like to add is, you know, affordability and broadband infrastructure are really inextricably linked. 620 Haga Joseph 04:59:59.780 --> 05:00:21.980 We've seen that from, you know, markup, the report of journalist who said you maybe paying more for less because there isn't as much competition or investment and these historically red line communities, which means, right, that providers can, can kind of charge what they like, or there's no competition driving those rates down and we've also with Oakland divided have worked with Oakland housing author. 621 Haga Joseph 05:00:21.980 --> 05:00:40.260 Authority and working with residents and public housing and have seen that they are not actually receiving the speeds that they're paying for, which we're happy to share with folks as well, and again, that's largely due to monopolistic markets and they're being only one provider option available for them. 622 Haga Joseph 05:00:43.100 --> 05:01:02.300 I would like to also add that green lining is cautious about a lack of meaningful affordability provisions encouraging further pricing discrimination in digitally red line communities in the absence of meaningful affordability agreements. We've seen the proliferation of pricing discrimination where lower income areas actually are unduly subsidizing. 623 Haga Joseph 05:01:02.340 --> 05:01:13.940 Their wealthier peered neighborhoods, most notably in Los Angeles County and we're concerned about the continuation of this practice with the beat program using publicly subsidized infrastructure projects. 624 Haga Joseph 05:01:17.660 --> 05:01:36.220 Okay, thank you, Judge. Click on thank you Commissioner. So I want to ask our ISP panelists kind of falling up on a statement that was made by missing the, the term lifetime affordability and. 625 Haga Joseph 05:01:36.900 --> 05:01:56.700 What would be a stretch goal for your company's in terms of I guess a stretch goal for the term of the, the project, you know, how, how far can you use a certain price or assume that a certain price is what? 626 Haga Joseph 05:01:56.740 --> 05:01:58.140 You would charge. 627 Haga Joseph 05:02:00.540 --> 05:02:19.980 I'll start first. I guess I think for us when we were talking about the low cost plan, which would be available to right at this point, it's people who are eligible for ACP and by the administration said that's about forty percent of Americans. I unfortunately don't have the exact number for California, but use that as a rough number. 628 Haga Joseph 05:02:21.660 --> 05:02:40.860 Well, we understand the need to have perhaps a price at the start. I don't think any of us think no of any product that keeps the same price for decades due to cost and labor costs to make it inflation. We've all been hearing about that for the past couple of years, so to be extent that there. 629 Haga Joseph 05:02:41.140 --> 05:02:52.420 Requirement for price at the start of the program, we would assume that it would be recognized that you could increase that in a way that's reasonable based on cost increases to provide the same service. 630 Haga Joseph 05:02:54.940 --> 05:03:14.140 And I would also note that the term useful night life of the network assets is in fact, a, it's a legal term of art, and if we look to how Treasury defined it for the RPA broadband grant programs, they defined as eight years, so it, it takes into account. 631 Haga Joseph 05:03:14.900 --> 05:03:34.620 Issues of depreciation, tax and so forth. So, but I agree with Meridith that in any event, we should be looking in, in light of just the factors that this is a vibrant marketplace that there are mechanisms in place for, you know. 632 Haga Joseph 05:03:35.500 --> 05:03:44.660 Just reasonable increases based on inflation, but for, for how long eight years ten years. 633 Haga Joseph 05:03:46.140 --> 05:03:53.180 If it's appreciate the question of whether take it back to our member companies can follow up in comments. Okay. 634 Haga Joseph 05:03:55.140 --> 05:04:08.500 Commissioner, there is one of our panels has their hand up, and I think then we'll, we're still continuing on with the rest of the panel. Yes, Okay, so Shena, if you can, you have the floor. 635 Haga Joseph 05:04:15.580 --> 05:04:18.780 China, if you're speaking, we can't hear you. 636 Haga Joseph 05:04:26.460 --> 05:04:45.660 You still can't hear you. Maybe continue with our panel and come back. OK. let's move on with the, could I just note way one thing on the affordability side, just some additional NTIA framing. So one thing I wanna know is that, you know, I think we highlighted. 637 Haga Joseph 05:04:45.900 --> 05:05:06.140 The requirements of the beat program to offer a low cost service option, right? When we are looking at receiving a proposal from states NTIA is looking for a defined number or a process to identify a defined number, right? When it comes to that low cost, we, we wanted to be able to actually substantiate the IMPA. 638 Haga Joseph 05:05:06.780 --> 05:05:26.620 To the percentage of people like, what are you paying, if you are ACP eligible. So we're expecting a number there and we see that as a grant condition, so I do want to just emphasize that there's a little bit more wiggle room when it comes to the middle class affordability approach and what that can look like NTIA might, I mean. 639 Haga Joseph 05:05:26.620 --> 05:05:47.100 States can decide what they're gonna propose, but we're allowing a little bit more flexibility there into what states are actually able to deliver to us. So I just want to be clear on those two requirements, How NTIA is going to review them when they are submitted. The other quick thing I just wanted to know on some of the tribal stuff is going back to Eileen's comment on gating versus scoring cri. 640 Haga Joseph 05:05:47.780 --> 05:06:07.580 When we're talking about federal tribal lands, tribal resolution of consent is a gaining criteria, right? That's not like you get extra points for doing that. That is a gating criteria in order to move forward, it looks a little bit differently when we're talking about how we get. 641 Haga Joseph 05:06:09.060 --> 05:06:28.060 Government and that type of support, right? As we're discussing it now, we're discussing it in that. It's for states, it's meant to be part of that twenty- five percent. It's meant to be part of the point scoring criteria, right? Not necessarily default gating criteria and the way I, I think a key thing to note here. 642 Haga Joseph 05:06:29.620 --> 05:06:48.540 That's maybe a little bit different from FSA though It's been a while since I've been in that program in those program rules, is that when you're putting together points for these types, So for like, if it's local government support, if it's letters, it's that kind of thing. if that gives you a significant points advantage when your submitting an. 643 Haga Joseph 05:06:49.820 --> 05:07:10.220 Want that community support, It needs to be an option that is available for all types of providers to get. So at certain type of ownership structure, like only fully private companies. Could you can't create criteria where only a fully private company or only a fully public company could get those points. So when you're. 644 Haga Joseph 05:07:10.260 --> 05:07:30.700 Thinking about it in terms of like local government support and writing a letter and that kind of thing if we want that to be meaningful to what Scott's talking about local governments need to know that they have the option to include or not include a letter, right? I think that this is a common ask for people in grants and that kind of thing that sometimes local governments will. 645 Haga Joseph 05:07:30.980 --> 05:07:51.180 Yeah, yeah, well here's your letter. Here's your letter here, form letter, but if we want it to be meaningful, if we want local governments and stakeholders to be able to kind of vote in a way that reflects the meaningful engagement an ISP or that locality itself has taken, then we need to make sure that local governments are sort of aware of how that scoring. 646 Haga Joseph 05:07:52.020 --> 05:08:11.660 Are able to give their support without it just being something that sort of handed out de- fact though, or also do values that on the scoring criteria, right? But, but keep in mind we are still developing the proposal, The state does have some flexibility. So these are comments, we need to hear from you and developing that, and then when the written proposal's out. 647 Haga Joseph 05:08:11.860 --> 05:08:32.140 We will want to get your comments on the specific language that, that we're looking at at proposing. So hearing from Mr. Armstrong and Mr. ran Tannon about the importance of community support is definitely something we'll, we'll consider, but we need to hear from all of you on what this should look like. 648 Haga Joseph 05:08:33.740 --> 05:08:48.780 Areas that we do have some flexibility in deciding where the priorities are for California. So I just wanted to, to put that out there as well, and then I, I do think Miss is MS. England is, were we able to. 649 Shayna Englin | CCF 05:08:49.620 --> 05:08:50.060 I am back. 650 Shayna Englin | CCF 05:08:53.260 --> 05:08:53.900 Internet drop. 651 Shayna Englin | CCF 05:08:56.460 --> 05:09:15.660 So I just wanted to say a couple things. One is, I think that the comments and the kind of attempts at directing toward the ACP on behalf of industry is another really important place for the commission to look at its existing resources and research on this. So the Pao's broadband pricing report that. 652 Shayna Englin | CCF 05:09:16.980 --> 05:09:36.140 Found very clear evidence that many of these providers actually monetized the ACP rather than pass that benefit onto its intended beneficiaries. So prices went up by thirty dollars rather than having those thirty dollars, go to making that, that. 653 Shayna Englin | CCF 05:09:36.180 --> 05:09:57.900 Service more affordable and that again, is in data that the CPU sees PAO published very recently. So that's just one more example of how the POC actually has a significant number of resources to lean on as it thinks about the supportability question, and then the second thing I, I wanted to add is just as. 654 Shayna Englin | CCF 05:09:58.140 --> 05:10:18.380 We kind of contemplate what the rules might look like for kind of exceptions or saying things like, well, we can't build out everywhere because it's not affordable there or, you know, it's not financially feasible, and this is another area where the PUC should be pretty expansive in terms of the kinds of data it consider. 655 Shayna Englin | CCF 05:10:19.140 --> 05:10:38.860 And I would offer one specific example, so at, and TS most recent filing to the SEC, they reported a billion dollars in profit over that quarter on three billion dollars of revenue and they reported in effect highlighted, eight fifty- five point nine percent. 656 Shayna Englin | CCF 05:10:38.900 --> 05:10:59.340 Service profit margin on their, their mobile service and I bring that up just as that is the kind of data that should actually be used when the company claims that they can't build to a specific area or within a specific street because it's not financially feasible. So that was all I wanted to. 657 Shayna Englin | CCF 05:10:59.580 --> 05:11:00.620 Thank you. 658 Haga Joseph 05:11:01.260 --> 05:11:21.100 Thank you in the interest of time. Let's move on with the rest of our panelists to provide their comments on the questions and hopefully we have a few minutes at the end of this panel for more Q and A. So let's turn to Matt antenna from Tridle. 659 Haga Joseph 05:11:21.180 --> 05:11:22.300 Broadband. 660 Matthew Rantanen 05:11:25.580 --> 05:11:30.820 Hi, Matt Renten. From travel to drill village, Southern California trouble Chairman's association. 661 Matthew Rantanen 05:11:32.620 --> 05:11:50.500 I mean, I made most of the points in, in response to the, the previous questions, but I feel like, you know, additional scoring criteria would be affordability. I mean, it's mentioned, it's been mentioned before, but affordability for. 662 Matthew Rantanen 05:11:51.940 --> 05:12:12.300 Four tribes is key. They're in, in situations where, you know, poverty is greater than fifty five percent in California tribes and, and a lot of people can't afford even the lowest tier of internet when, when we're talking about speeds of one hundred down twenty- up, I think that, that speed threshold should be the low tier of internet service, not the high tier of in. 663 Matthew Rantanen 05:12:12.740 --> 05:12:32.780 Service that should be the base offering when we're moving forward and, and to think it, it offers the opportunity for tribes to operate it today's standards or today's, you know, hopefully average standards of internet access so that they can compete educationally, you know, resource acquisition as well. 664 Matthew Rantanen 05:12:33.180 --> 05:12:41.060 Job training and things on the internet. So if that ACP valued tier. 665 Matthew Rantanen 05:12:42.460 --> 05:12:53.940 Could be higher than one hundred twenty or, or at the minimum of a hundred and twenty hundred down twenty up. I think that really benefits drives moving forward. 666 Matthew Rantanen 05:12:55.820 --> 05:12:57.340 And then. 667 Matthew Rantanen 05:13:00.300 --> 05:13:03.540 Just rereading the last question and post- application process. 668 Matthew Rantanen 05:13:09.900 --> 05:13:29.740 I, I don't know. I don't know how to phrase this without. I don't know, just being, you know, very trouble centric, but I am very trouble centric and that is that if the tribe has a solution and the tribe is, you know, decides to be the carrier of last resort or the carrier that serves this commun. 669 Matthew Rantanen 05:13:29.780 --> 05:13:37.660 Then I think the tribe should be given that opportunity. I don't know how else to phrase that. So thank you. 670 Haga Joseph 05:13:39.340 --> 05:13:44.940 Now turn to our panels from ISPS, Merdus. 671 Haga Joseph 05:13:47.020 --> 05:14:06.860 Thank you and thank you again for having me here today, just to start, I want to sort of frame our points and then I'll go into a little bit more detail on the question. So IJA created the program as a means of reducing the number of us households that lack access to reliable high speed broadbands and the extent to which. 672 Haga Joseph 05:14:07.180 --> 05:14:27.340 California can address this with the bed program will depend significantly on the rules of the commission adopts to implement it as Mariana pointed out earlier, NTA has allowed states some of discretion in adopting rules that will govern the allocation of Beed funding, but we encourage the commission to refrain from its limited. 673 Haga Joseph 05:14:27.380 --> 05:14:49.740 Discretion to impose additional criteria or requirements as straight from the program's objectives and priorities, which is to connect as many Californians reliable high speed broadband as possible, instead the commission's initial proposal should leverage beat funding to efficiently, bring broadband service that is as future proof as possible to the greatest number of Californians while minimizing the risk of default. 674 Haga Joseph 05:14:51.020 --> 05:15:10.220 So what we've seen in some other states and I know some of the other panelists have referenced those already is that many of them are proposing to do a pre- qualification round for being where they measure the operational managerial and technical capabilities of applicants prior to putting the areas. 675 Haga Joseph 05:15:11.500 --> 05:15:30.700 For application establishing standards that are challenging, but achievable and reviewing all applicants qualifications in full before allowing them to participate in the be competitive funding process. We'll ensure that the bound projects are proposed actually get completed in. 676 Haga Joseph 05:15:30.980 --> 05:15:51.180 Terms of defining project areas to ensure an efficient use of funds. The commission should allow applicants to combine unserved and underserved locations into logical project areas, the day, the applicants, define, and this is because providers are in the best position to design project areas that will make the most cost effective use of existing infrastructure. 677 Haga Joseph 05:15:51.260 --> 05:16:01.020 Will minimize the number of new permits and rights of way and speed deployment helping California's connect reliable high speed broadband sooner rather than later. 678 Haga Joseph 05:16:02.060 --> 05:16:22.540 However, we recognize that there is a desire to incentivize deployment to locations that might otherwise get overlooked and so we believe there are a couple of opportunities for the commission to do this without further defining project areas. This would be creating incentives for applicants to include economically or geographically challenging the. 679 Haga Joseph 05:16:23.900 --> 05:16:43.020 Project areas one is high cost areas and NTIA has already permitted states to wave the match requirement for those high cost areas in order to incentivize appointment there. The state could also identify priority locations that they want to make sure are served by these projects that may be. 680 Haga Joseph 05:16:43.100 --> 05:17:01.820 Persistent poverty counties or within a community that's determined by the Census Bureau to be an economic need and to incentivize appointment to those priority locations. They could award additional points using the discretionary scoring to encourage providers to include some percentage of those locations in their applications. 681 Haga Joseph 05:17:05.040 --> 05:17:11.840 Encourage them to identify in advance and publish points on this. An application could earn by going to those locations. 682 Haga Joseph 05:17:13.800 --> 05:17:35.560 If the commission does feel that they needed to find project areas in some way, we encourage them to do it with a smallest geographic unit possible, preferably a sensus block, which I think has been raised by others here, requiring every provider to serve every eligible occasion in a large area with necessitate the provider's deploy of a significantly beyond their existing footprints. 683 Haga Joseph 05:17:35.560 --> 05:17:56.040 And the need for a total new build could increase the total average cost and the total subsidy needed to reach some of these locations unnecessarily driving up costs and how much money can be used to deploy end- to- end fiber to, as many locations as possible, in addition, by using smaller geographic units, this can allow for all companies of all sizes to. 684 Haga Joseph 05:17:56.240 --> 05:18:16.520 Participate including those that do not have a large frint at this point on affordability. I just want to go back really briefly to the comments about the ACP program and point out the at and T- has the access from at and t- service low cost option, which is thirty dollars a month and so combined with ACP, that's actually zero dollars. 685 Haga Joseph 05:18:16.760 --> 05:18:37.000 So other than having a zero dollar plan to start with, I don't think there's a way we could have driven up that cost by thirty dollars with admin of the ACP program, but we also recognize that the be NOFO requires states to judge affordability based on the one could give it tier and so we would concur with Cal Broadband's comments along. 686 Haga Joseph 05:18:38.320 --> 05:18:57.480 To use the urban rate survey benchmark as comparison as two other quick points on the minimal beat Outley question, simply giving the highest number of points to projects to propose at least amount of funding we'll continue to dep prioritize, high cost areas and so we think. 687 Haga Joseph 05:18:57.680 --> 05:19:17.960 There's a way to balance both the need to minimize program funding, but also encourage deployments, higher cost areas by splitting the way these points are used for half being based on the amount of match offered and half being based on the number of unservocations in identified high cost locations. Therefore, getting more deployment to these high. 688 Haga Joseph 05:19:18.240 --> 05:19:38.440 Locations and then finally, I just want to reiterate that we welcome collaboration with local governments and communities and tribal communities and we'll continue to do that as we deploy broadband across the states, but if the commission decides to allocate points for these collaborations, we just would like them to be clear that the rules in the rules that the. 689 Haga Joseph 05:19:39.760 --> 05:19:54.200 Applicant, whether alone or collaboration that will ultimately provide service, the end user may retain salt ownership of the infrastructure. Thank you again for having us, thank you, Paul, just go ahead. 690 Haga Joseph 05:19:57.000 --> 05:20:02.960 Thank you and thank you again to Commissioner, how can to. 691 Haga Joseph 05:20:04.920 --> 05:20:17.320 For bringing us together today, I always rate a panel on how much I learn and I've learned so much from this panel both in the room and online. So I, I just wanted to comment really quickly to Matthew. 692 Haga Joseph 05:20:18.800 --> 05:20:39.240 On the screen on the earlier panel, you mentioned the importance of low latency for interactive video and I, I couldn't agree with that point more, so I just wanted to reinforce that as well. How critical that is, and your comments about one hundred by twenty being the floor, the foundation and not the overall goal, and in that way we future proof for. 693 Haga Joseph 05:20:39.920 --> 05:20:43.760 Needs that families and communities have. 694 Haga Joseph 05:20:45.000 --> 05:21:05.480 So, again, I try not to be presumptuous about a, a small technology company that's pre- public Toronto wireless, Carl Gordino, fourteen years old created in two thousand and nine by three Phd graduate students who were in who were earning those Phd degrees as part of the International. 695 Haga Joseph 05:21:05.520 --> 05:21:25.960 Program that you see Berkley, go bears and fast forward fourteen years. four hundred million dollars in privately funded research and development later in just the past two years serving previously, unserved and underserved families in twenty one countries. Forty- five. 696 Haga Joseph 05:21:26.120 --> 05:21:46.440 States, numerous tribal nations with nearly three hundred ISP customer partners and we can have other conversations about the technology and I brought something to pass out and for the record on the technology, but I want to go to the questions on if applicants are allowed to construct. 697 Haga Joseph 05:21:46.520 --> 05:22:06.760 Own project areas based on our experience in digital divide projects. Now several hundred across the US and around the world, we believe that Toronto that allowing providers to invent their own optimal or cherry picked coverage areas in locations will create an untenably. 698 Haga Joseph 05:22:07.560 --> 05:22:27.400 And practically irreconcileable mix of proposals for the target and underserved areas, I'm making Fair Award decisions impossible and yielding to failure to fulfill the BEED programs objective of reaching one hundred percent of unserved. 699 Haga Joseph 05:22:28.040 --> 05:22:47.880 Underserved households at the pleasure at lunch of, of being on the phone with Courtney Dozer at the NTIA and she reminded me Carl. The program is internet for all. It's not internet for some, We have to get the versus out of our language and replace it with, and. 700 Haga Joseph 05:22:47.960 --> 05:23:08.360 It's not real versus urban and as Patrick, so well summarize this morning, it's end, it's all of us in California. It's nine hundred ninety- six thousand, three hundred and two places and we can learn from others and best practices. I've now read eighteen state broadband plants. 701 Haga Joseph 05:23:08.360 --> 05:23:28.840 Page turners all of them what Kansas is doing in their initial proposal on this. They're going by school districts so they covered their whole state and it can't be cherry picked, and if you have a big district, like la, then maybe you go by the, the sub- districts that people run under and same with La Unified, so that you've covered the whole state, but no one can cher. 702 Haga Joseph 05:23:30.120 --> 05:23:49.320 The next question is on deconflicting overlapping proposals is noted, we're strong supporters of defining coverage areas in need clearly in advance so that we eliminate the problem of deconfliction altogether, takes it right off the table. The next question is on. 703 Haga Joseph 05:23:49.360 --> 05:24:09.800 Project areas are predefined et cetera as also noted above having our POC set target project areas based on existing geographic areas, school districts, sinces tracks, black groups that contain un and underserved locations insurers that providers do not cher. 704 Haga Joseph 05:24:10.480 --> 05:24:30.280 I loved that, that point that Eileen O- Dall made earlier about that, and we agree completely with that, and in that way we're serving, we're seeing, we're serving hard to reach locations therefore, much more expensive locations and that they cannot be. 705 Haga Joseph 05:24:30.320 --> 05:24:50.760 Denied of what they should have under broadband for all the next question is around required scoring criteria and I'm going to go back to Matthew's excellent point, make a hundred by twenty the floor because we're gonna continue to grow the need at Toronto. We think, okay, if one hundred by twenty s- the floor, then maybe inscor. 706 Haga Joseph 05:24:50.920 --> 05:25:11.240 Criteria, the next is two hundred by fifty or four hundred and then four hundred by a hundred and then a gigabit by two fifty, but keep those so that we're looking forward to the future of families and communities needs. The next question is. 707 Haga Joseph 05:25:11.400 --> 05:25:31.720 Around additional scoring criteria such as awarding points on the basis of equity climate resilience we agree on all of that, and again, remember the Bitisan infrastructure law is internet for all the governor's executive order is around broadband for all all being the. 708 Haga Joseph 05:25:32.440 --> 05:25:52.200 Caroline's points from the Green Lining Institute of once in a lifetime funds, we can't forget that. This truly is once in a lifetime, the state funds, the federal funds current and future through the one point eight six billion all, and we can do it if we do the math, right with Technolog. 709 Haga Joseph 05:25:52.560 --> 05:26:12.680 That are based on what they can provide in terms of reliable and affordable service. By the way I have printed out the questions and my responses so that you have it for the record and we can stay within the five minutes. So I'll pass those around here to the panel, the people in the Audi. 710 Haga Joseph 05:26:12.840 --> 05:26:27.320 If people remotely would like it, we are completely transparent at Toronto. Just let me know the email address through the staff here of the POC and we'll get it to you. The last is around. 711 Haga Joseph 05:26:29.640 --> 05:26:49.160 The post- application progress process. I'm gonna just keep that on what I have written here, but I want to go to Scott Armstrong's point from rural in Yo County and Gracy's point from our CRC earlier forty of California fifty- eight counties. 712 Haga Joseph 05:26:49.800 --> 05:27:09.560 Are completely rural. The other eighteen have rural areas, but those are completely rural. That's one of every five Californians, it's sixty percent of our land mass in our rural counties, not completely, but are overwhelmingly more expensive to serve. 713 Haga Joseph 05:27:11.340 --> 05:27:31.660 Geography distance and they are overwhelmingly completely, but overwhelmingly people of color and often of more financial modest means we cannot afford to miss those communities when we. 714 Haga Joseph 05:27:32.380 --> 05:27:52.140 With an end of approach rather than a versus approach of serving everyone. So let's not forget technology advances and it has, which is a point marina made earlier about fiber or fixed wireless or satellite standards bas. 715 Haga Joseph 05:27:52.860 --> 05:28:12.620 Fiber is preferred and we agree with that, which you may not expect to hear from a fixed wireless company, but we do fiber everywhere, you can, as long as it is cost- effective and can be deployed in the time we manner second point along with technology advances is finances or finite. 716 Haga Joseph 05:28:12.620 --> 05:28:33.740 And that's why your good work together is we have to leverage limited dollars and we think from the final five year action plan, thanks for your transparency. in that plan, we could be as much as five billion short. We actually think it's more than that with inflation and labor shortage issues and. 717 Haga Joseph 05:28:34.620 --> 05:28:54.220 Supply chain issues is probably more than that, but we have to get till nine hundred ninety- six thousand, three hundred and two in the final one is quick deployment matters. I hate to make it personal, but we have a seven year old in first grade who we foster adopted at three months old from a homeless woman in somewhere in Silicon Valley. 718 Haga Joseph 05:28:54.860 --> 05:29:14.700 If we solely dependent on a fiber to the premise approach as good as fiber is he would be in fifth to seventh grade, if we hadn't run out of money before we would have fiber to the home in all of California, we can't afford to lose another generation. 719 Haga Joseph 05:29:14.780 --> 05:29:35.180 Whether tribal rural suburban or urban. So thanks for letting me be on this panel, it's really been an honor and I'll pass around my written comments. Thanks, Carl and our last Palace, Sam, thanks so much. Again, my name is Sam Acklin. I'm from Wilki Faring Gallagher Council to Comcast on here on behalf of Cal Broadband. 720 Haga Joseph 05:29:35.220 --> 05:29:55.660 Commissioner hack director, Osborne and Judge Googola and all the staff we thank you for the opportunity to participate in this workshop and for all the work you're doing to fulfill this generational opportunity presented by the B program Congress NTIA and the commission have made clear that the number one. 721 Haga Joseph 05:30:00.300 --> 05:30:20.780 The state and this is a monumental task as a CPUC explained in the five year action plan. This is at least over four hundred fifty thousand locations and Carl just brought up the elephant in the room, you know, while one. 722 Haga Joseph 05:30:21.460 --> 05:30:29.260 Six billion dollars allocated to California is a lot of money relative to what was allocated to other states in the country. 723 Haga Joseph 05:30:30.540 --> 05:30:50.860 Still a staggering multi- billion dollar gap that the state recognized in the five year action plan that it's gonna, it's a huge gap to a huge bridge gap to bridge if particular. 724 Haga Joseph 05:30:51.260 --> 05:31:11.340 If the state is looking to fulfill the directive to connect as many locations as possible with end- to- end fiber and do so in a way that's going to ensure the, not only that these projects get built, but looking beyond the build that they will be managed and operated in a sustainable manner for many years to come. So. 725 Haga Joseph 05:31:11.500 --> 05:31:19.700 Broadband offers the, our comments today on ways to ensure that the sub grantee selection process through the, the project selection. 726 Haga Joseph 05:31:20.980 --> 05:31:28.180 Design the primary criteria and secondary criteria are designed to bridge this multi- billion dollar gap. 727 Haga Joseph 05:31:29.260 --> 05:31:49.100 We want to make sure that the state retains enough money to connect all unserved locations. Let alone underserved locations in the state. So on project selection, we strongly encourage that the commission allow applicants to define their own project areas in the, in the initial round of funding. 728 Haga Joseph 05:31:51.060 --> 05:32:10.220 Has Meredith described eloquently, this will allow shovel ready projects that are can leverage existing networks to hit the ground. Be competitive be efficient and it's going to be saving the state substantial money on the front end. Now this is not cherry picking. 729 Haga Joseph 05:32:11.700 --> 05:32:30.700 Clear that all unserved and underserved locations in the state must be served. So this will allow providers to put put forth their very best options that will save the save money on the front end. Allow fiber to get deeper and deeper into the state. 730 Haga Joseph 05:32:31.380 --> 05:32:51.820 And obviate the need to utilize extremely high cost threshold later on, in the selection process. Now from there, this, depending on how many unserved or underserved locations are left after that initial, those initial proposals, the state can either work with providers to. 731 Haga Joseph 05:32:51.860 --> 05:33:12.300 Expand those remaining locations or can then take those remaining areas and sort them into project areas for competitive bidding in a subsequent round of funding. So, again, this is not cherry picking. This will ensure every location is accounted for. It's just gonna save the state. 732 Haga Joseph 05:33:12.300 --> 05:33:32.780 Money and allow beat funds to go a lot further and allow fiber to go a lot further in the state to that end on primary criteria. How broadband strongly urges the state to prioritize minimal beat outlay in the selection criteria. So as a no post. 733 Haga Joseph 05:33:32.780 --> 05:33:43.860 The no fo direct states to regularly explore ways to incentivize higher matches and matches greater than the minimum twenty- five percent. 734 Haga Joseph 05:33:44.980 --> 05:33:59.660 Doing, so again is going to be critical and the most efficient way to be able to bridge this multi- billion dollar gap and make sure that this funding gets to every unserved and underserved location in the state. 735 Haga Joseph 05:34:00.940 --> 05:34:21.420 I think it's instructive to take a look at what Illinois has done, Illinois is another highly large state highly popular state and they've allocated fifty percent to the minimum beat outlay criterion, we urge the state to, to consider doing the same. 736 Haga Joseph 05:34:22.100 --> 05:34:41.540 We've gotten into affordability. I do also want to echo Meredith response, you know, speaking on behalf of Comcast here, Comcast is offered Internet essentials for over twelve years long before EBB or ACP. 737 Haga Joseph 05:34:42.780 --> 05:35:03.020 Was even offered Internet essentials plus provides a hundred over twenty service for thirty dollars effectively cost free for ACP subscribers. So again, there's really no credence to the idea that providers would are looking to monetize off ACP. It's intended to. 738 Haga Joseph 05:35:03.820 --> 05:35:10.820 Provide high quality broadband service at no cost to those qualifying customers. It's also. 739 Haga Joseph 05:35:11.980 --> 05:35:32.460 In terms of data notwithing, the fact that this country has seen inflation over the past few years that has not been seen for decades months after month over the past couple of years, the US Bureau of Labor Statistics data shows that broadband prices have. 740 Haga Joseph 05:35:33.140 --> 05:35:46.220 Had a deflation area effect. They, as opposed to gas electricity food at home, other household staples broadband at no point was driving inflation. 741 Haga Joseph 05:35:47.860 --> 05:36:07.900 So put a pin on that with respect to the labor primary subrantee selection criterion. We just want to briefly state that Cal broadband providers incentives are aligned with all other stakeholders that we want to attract the very best. 742 Haga Joseph 05:36:08.460 --> 05:36:13.060 Limited currently limited pool of. 743 Haga Joseph 05:36:14.060 --> 05:36:34.540 Shovel ready workforce for, for broadband deployment, the state recognized in the five year action plan that this is a significant barrier. So the no California sets a very high bar for labor standards. The no, fo also sets a very high bar just as a baseline we. 744 Haga Joseph 05:36:35.300 --> 05:36:55.020 State in considering fair labor practices selection criterion to stick with the requirements in the NOFO, looking at record of fair labor practices and plans for future compliance with respect to the number of optional encouragements. 745 Haga Joseph 05:36:55.140 --> 05:37:15.500 NTIA offers we urge the state to take a flexible approach there, understanding that it's a highly competitive labor market, We want to build the best highest quality provide high quality jobs, high quality training with which are our members do, but also understanding that these projects. 746 Haga Joseph 05:37:15.540 --> 05:37:36.620 Need to get built under pretty tight deadlines, thirty seconds, okay. Yeah, just very briefly in terms of other criteria to consider technical labor, technical operational managerial, financial capacity. 747 Haga Joseph 05:37:36.980 --> 05:37:57.100 Is a gating threshold, but the state should stop there. This is really important. We need to be making sure that the investment made in these networks is sustainable in the last long time state, like Delaware has proposed additional criteria for experience in fulfilling commitments and. 748 Haga Joseph 05:37:57.180 --> 05:38:17.580 Deploying Bradband Networks. That's something the state should consider. The state should also consider additional criteria for projects that proposed to serve a greater number of unserved and underserved locations. The, the IHA is very strict overbuilding limits. No more than twenty percent of a project area. 749 Haga Joseph 05:38:17.580 --> 05:38:38.060 Can be served that being said, the state should be incentivizing projects proposed much a much lower percentage to make sure that again this, these limited dollars are spent efficiently and in a manner that's going to preserve the opportunity for the state to fund fiber as deep into the state as possible. Thank you. 750 Haga Joseph 05:38:38.860 --> 05:38:58.540 Thank you, Sam. So that concludes our panelists just quickly checking with Jonathan, if you have anything online, you don't commissioner, George, any questions I do have a couple of questions, but I wanted to turn it over to director Osborne. I think he has a question that he wanted to ask. 751 Haga Joseph 05:38:58.580 --> 05:39:19.020 Thank you and I really wanted to see if Kayley gal wanted to comment on the workforce development requirements that are called out in the NTIA. No, fo, I believe under the CDO CWA comments on the ruling, they quoted the NTIAS encouraging states to consider scoring applicants on job quality and job training. 752 Haga Joseph 05:39:19.180 --> 05:39:39.500 I think the workforce development is a key component that hasn't really been touched on here in terms of what should the state require beat applicants with regard to workforce development because building the networks is a one time thing, and then the next step is maintaining those networks and, you know, not having the workforce in place to build them again is, is. 753 Haga Joseph 05:39:39.660 --> 05:39:49.900 Issue, but there's the other issue of developing a workforce that can operate these networks and also providing employment and training for, for disadvantage communities. Thank you. 754 Ceilidh "Kay-Lee" Gao, CWA 05:39:52.940 --> 05:39:54.940 Are you able to hear me now? 755 Haga Joseph 05:39:55.500 --> 05:39:56.620 Yes. 756 Ceilidh "Kay-Lee" Gao, CWA 05:39:57.020 --> 05:40:17.260 I adjusted the settings. I've been in contact with ITU, so thank you so much for the opportunity to respond on this point, and we definitely do encourage viewing the point structure as considering fair labor practices as itself A workforce development tool. We know that funds are limited, and of course. 757 Ceilidh "Kay-Lee" Gao, CWA 05:40:18.340 --> 05:40:38.660 Aren't likely to be, you know, extra funds for workforce development after all the other priority areas in how the CPU chooses to structure its points system, it will be incentivizing employers to take different high road labor practices. So as opposed to viewing these as nice to have additional encouragements. 758 Ceilidh "Kay-Lee" Gao, CWA 05:40:38.940 --> 05:40:59.140 NTIA, no fo CWA would say they really align with the broader goals of workforce development and a sustainable workforce too, as you're saying, maintain the network going forward in incorporating high road labor factors into the, the point system, the commission would be in. 759 Ceilidh "Kay-Lee" Gao, CWA 05:40:59.500 --> 05:41:18.380 IZING higher labor practices that will encourage employers to invest in a locally based workforce, a well trained workforce that's going to support workforce development in the long term of good jobs in California, necessary to maintain the network in the long term. 760 Haga Joseph 05:41:22.300 --> 05:41:36.420 Director Osborne, if I may, and this is Carl wearing his CTC California Transportation Commission Hat on Kayley's point, not toron it just because I've never socialized it toronta, but I hope this will also include people in our communities. 761 Haga Joseph 05:41:38.220 --> 05:41:47.820 Someone who deeply believes in second chances for formally incarcerated individuals in California as part of that workforce training. 762 Haga Joseph 05:41:49.700 --> 05:41:53.140 Hi Matt, we see you have your hand up. 763 Matthew Rantanen 05:41:53.540 --> 05:42:14.020 Yes, thank you. I wanted to also address comments or question, so workforce development is the key aspect of Indian country. We are working with populations that sometimes have not been exposed to the field of technology or, or the. 764 Matthew Rantanen 05:42:14.340 --> 05:42:34.500 Of infrastructure broadband this is very functional field for, for tribal members, especially when they're going to build out some of their own solutions, but in situations where outside partners might be building and, you know, in their regions or building in even in their communities, you know, there's, there's great opport. 765 Matthew Rantanen 05:42:35.860 --> 05:42:54.980 As well as build so build some of these solutions. So teaching increases the value of some of the solutions that are being deployed and, and we think that, that, you know, shadowing opportunities training opportunities are very valuable in this space, especially with those. 766 Matthew Rantanen 05:42:55.740 --> 05:43:15.460 Agreements where an outside vendor may be building assets on community on tribal community land on sovereign land and they may have an agreement to transfer the assets of, of the network to the tribe at a three or five year period based on, you know, like recovery of, of funds, et cetera. 767 Matthew Rantanen 05:43:16.740 --> 05:43:35.940 And having a training program in that three to five year period where tribal members learn the process and understand the process of deployment and management of that network to be able to take that over and, and not neces stride in managing that service, and then there is also the, you know, the fact that there's terror, which is the tribal employment. 768 Matthew Rantanen 05:43:36.020 --> 05:43:57.060 Requirement and many tribes are very adamant about their terror opportunity and hiring tribal workforce when in and around travel regions. So I just wanted to hammer that. I mean, I, you know, it's no secret that I run the trouble broadband boot camps. 769 Matthew Rantanen 05:43:57.100 --> 05:44:11.100 And those are very instrumental in illustrating the tribes, the base level understanding of what it takes to run a network and where to start with workforce development planning and growth. So thank you. 770 Haga Joseph 05:44:14.980 --> 05:44:35.460 Thank you commission. A question, yes. I've got a question for Miss Williams and Mr. Eckland. I think you both commented. I think MS Williams, you commented on looking at combining served and unserved areas to provide the most cost effective use of funds and Mr. Eckland, you commented on letting that. 771 Haga Joseph 05:44:36.140 --> 05:44:55.460 We should be allowing applicants to define project areas in first round of funding to leverage existing networks. Can you talk about what combining served and unserved areas could look like whether that would be in compliance with the no fo in looking at serving unserved areas and then. 772 Haga Joseph 05:44:55.940 --> 05:45:16.420 As a follow- up and I can repeat this, Mr. Eckland, you talked about states should work with providers to serve these remaining high cost isolated areas. So I think you're saying first round looking at how you can leverage existing networks and then later looking at how we can address the, the remaining higher cost more isolated areas. 773 Haga Joseph 05:45:16.580 --> 05:45:36.900 Can you talk about how that would be done and given the lack or limited funding that we have here? What that would mean for those areas that, that are higher cost and more isolated? I, I hope if you need me to repeat any of that, I appreciate it. I can, I can do that. 774 Haga Joseph 05:45:37.540 --> 05:45:57.380 Happy to address that, and so, and if I miss anything, please let me know. So first, I'll just say, and Marina can tell me if I'm wrong, but I feel believe I'm quoting your colleagues at NTIA that they've been very clear that the requirement for unserved and underserved in the NOFO is not a temporal require. 775 Haga Joseph 05:45:57.660 --> 05:46:17.620 It's not a requirement to go build to all the unserved locations and then come back and build to all the underserved it is, I think I've heard it scrub once as a budgeting exercise, which I think diminishes the amount of work that goes into that, but in to the extent to say, we know we have enough money to cover all these locations, so we can also cover all these other locations. 776 Haga Joseph 05:46:17.980 --> 05:46:38.340 And so I think what we would propose is that, you know, applicants would be able to combine unsurface and underserved because oftentimes, you know, you kind of what likely haven't donate effect, right? You're gonna have answered locations and sort of the donut hole and then underserve location surrounding them and then likely the infrastructure as we get there is outside of that donut. 777 Haga Joseph 05:46:38.420 --> 05:46:58.820 And so from an efficiency perspective, it doesn't make sense to define a project to get to the dart hole and then come back and define a different project to get to the donut, especially if you look at using two different providers. So their network infrastructure is kind of crossing over each other, so that was really the intent we were talking about there, but please let me know if I didn't address your question. 778 Haga Joseph 05:46:59.540 --> 05:47:19.300 I think you did, I guess that would mean a question to Marina and I don't know if you're prepared to answer that if, if we're looking at the prioritizing the unserved areas of a project came in as MS. Williams described that could fill a donut hole and would also be serving unserved areas before other unserved areas would that. 779 Haga Joseph 05:47:19.940 --> 05:47:39.780 Be a project that needs the be requirements. So I think there's some nuance here when it comes to states that don't think they will make it to all of their underserved because, you know, Ntia does say you have to meet, you know. 780 Haga Joseph 05:47:39.860 --> 05:47:47.180 Prioritization wise it's unserved underserved community anchor institutions, but that said, I think. 781 Haga Joseph 05:47:50.020 --> 05:48:09.220 In terms of a, again, budgeting exercise is probably not the best term specifically here, but we don't NTIA also doesn't want to segment things out in terms of like you have to wait to all of the unserved applications to get covered. 782 Haga Joseph 05:48:10.100 --> 05:48:29.700 Do the underserved in order to then do the thing? I think it's a, it's looking at the total amount of funding you have looking at these total numbers that you have and where you're gonna end up with and trying to figure out sort of where that cutoff is going to be, but a project itself doesn't necessarily have to. I think we're expecting project bids to come in for. 783 Haga Joseph 05:48:29.780 --> 05:48:50.180 Unserved and underserved at the same time, and in some cases, combined those locations because otherwise it's going to be challenging to make feasible projects, but I think that there is probably a little bit more discussion to be had in terms of what does serving the unserved actually look like. order wise if. 784 Haga Joseph 05:48:51.540 --> 05:49:00.660 You have to wait to deploy until because we don't necessarily want it to be sequential. We just want the plan to be to get to everywhere. 785 Haga Joseph 05:49:02.980 --> 05:49:22.820 Right, and I guess that's my concern if we have just enough money to get to all the unserved without addressing underserved, I'm just not sure where, where the, the balances and trying to get the projects that make sense in, if we have other restrictions about where the money has to go first, So I, I think. 786 Haga Joseph 05:49:23.460 --> 05:49:43.300 Just being able to, to have those conversations about how to balance that in, in where we need to go because we do have limited funding, but we do want to use it if in the smartest possible way to get the most people served as quickly as possible in the most logical order. So. 787 Haga Joseph 05:49:44.620 --> 05:50:03.780 To that point, you know, the no fo does contemplate that in high cost areas. Has Marina was explained that the sincture between extremely host threshold and high cost areas that those may be so difficult to serve that it may not be appropriate to, to seek matching funds there. That's all the more reason that. 788 Haga Joseph 05:50:04.580 --> 05:50:24.260 The state needs to incentivize for non- high cost areas as rigorous matching funds as possible. There will be like, as much as the state can save money on the moving from inside out to those rural and remote areas where the state. 789 Haga Joseph 05:50:25.660 --> 05:50:30.540 Spending a disproportionate amount of the beat funds. 790 Haga Joseph 05:50:31.980 --> 05:50:52.460 The most effective efficient way for the state to ensure that there is that money to, to serve the, the role in remote areas is to make sure that we're rigorously incentivizing higher matching funds and lower minimal beat outlays. 791 Haga Joseph 05:50:53.100 --> 05:51:12.940 In those intermediate areas and commissioner hub. Thank you. I am on the ISP side of the panel, even though we're a technology company, not an ISP, you know, this is a math problem and it's very doable. The, the NTIA is very clear in the ninety- five page Beed. No fo that there's. 792 Haga Joseph 05:51:12.980 --> 05:51:33.420 A preference for fiber, there's not a requirement for fiber. There is a, there's a requirement for reliable affordable high speed and I agree again with Matthew low latency, even though that's not in there home broadband and the math works if we stick to a standards one hundred by twenty. 793 Haga Joseph 05:51:34.060 --> 05:51:53.900 And hopefully much better approach, rather than a technology approach. The math works and we would be happy to enter into the record after this for both the construction and ongoing maintenance and operations that the math works when we take a hybrid approach that picks the right. 794 Haga Joseph 05:51:54.140 --> 05:52:14.380 Tool for the job for that family in that community to stretch the funds, We have, we do not have to make a choice of broadband for some, rather than what the Bypasan infrastructure law is, as well as the governor's executive order both broadband for all. 795 Haga Joseph 05:52:15.860 --> 05:52:34.860 Thank you, I do have a question about looking at where and how we should be addressing the issue of fiber and fixed wireless. I was gonna save that to the next panel where we're looking at high cost, but just really quickly before we get there. I just wanted to go back to Mr. Eckland. So when you were talking about the state should. 796 Haga Joseph 05:52:35.260 --> 05:52:55.980 Providers to serve the remaining high cost and then the more isolated areas was that what you, you were referring to, is that in the, in the later rounds to be looking at a higher percentage of match to help in or what was how the mechanisms that you were thinking the state could be looking at to help incentivize how we get to serving those higher co. 797 Haga Joseph 05:52:56.900 --> 05:53:16.460 Areas true, so I think it all depends on, you know, at the end of the, if, if round one is a provider or applicant proposed areas, you know, it's unclear, but we could be in the situation where there's only small pockets of unserved and underserved LOC. 798 Haga Joseph 05:53:17.100 --> 05:53:36.940 Left after scoring and awarding the best applications and, you know, in a kind of sequential manner, the highest scoring applicant gets preferenced for all the areas that it prefers proposes to serve and going down the list, so it, that could. 799 Haga Joseph 05:53:37.300 --> 05:53:43.460 Result in this scenario where there's only kind of smaller pockets of unserved and underserved locations. 800 Haga Joseph 05:53:45.900 --> 05:54:05.740 The commission could go back to those provisional awardees and say, Hey, would you be willing to incorporate this set of locations adjacent to your proposal into your application, if there's, if there are larger pockets, then it would. 801 Haga Joseph 05:54:05.780 --> 05:54:26.220 Could very well, make sense to parcel those out into project area units for a subsequent round, and then again, everyone would get another bite at the Apple to then take those remaining locations and put forth their best applications to serve them and, and do so as long as, you know. 802 Haga Joseph 05:54:26.380 --> 05:54:46.700 It may take another round or two, and if there are still pockets that it looks like the state that no one's proposing to serve yet, the no fold's clear that the state can take measures to in, you know, induce through waivers of matching funds or, or other. 803 Haga Joseph 05:54:46.820 --> 05:55:07.180 Incentives to make sure that every location is served. So just for an example, I think at the Middle Mile meeting and recently we've received a lot of comments about the big sur area being un- unserved and so to the extent there may be projects that are close to that location. You're saying to go back and have staff. 804 Haga Joseph 05:55:07.500 --> 05:55:27.660 Conversations with providers to see whether that area or another area similar to that, close to a similar project could be tied in exactly and again, the motivation behind this is to incentivize the most efficient use of funds, you know, what we would caution against. 805 Haga Joseph 05:55:28.340 --> 05:55:48.060 Starting with predefined areas is those May even the smallest areas as a sense of spot group could not take into account topography infrastructure, existing infrastructure like rail railroads or other rights of way waterways. 806 Haga Joseph 05:55:48.140 --> 05:56:08.620 That could just make things impractical to serve in that in that defined geographic area. So again, it wouldn't be excluding any location. It would just be peering the ways that every location eventually gets, you know, allocated funds. No, that makes sense. And the geographic areas. 807 Haga Joseph 05:56:08.780 --> 05:56:29.100 Another reason to discuss and I'll wait for the next panel on my question on the fixed wireless, but that, that also, in addition to high cost is, and wouldn't be boring if we always agreed, we re- believe it would lead to cherry picking and inefficiency because that requires many extra rounds instead of doing it all. 808 Haga Joseph 05:56:29.140 --> 05:56:50.140 At once, so we can get this money out of the street while making sure that we're all responsible for serving every unserved and underserved California. Just one last thing commissioner on your, on your point and your question sort of an additional clarification in terms of like, estimating how much money we have to get to unserved and underserved. 809 Haga Joseph 05:56:50.860 --> 05:57:11.340 I think Ntia is expecting a good face showing so that is going to mean when it comes to, we're going to ask states to solicit applications for both unserved and underserved and understand what those costs look like before we work with states in terms of figuring out, like, what. 810 Haga Joseph 05:57:11.500 --> 05:57:31.820 Does it look like if you can't reach all unserved and underserved, right? So understanding like the feasibility and the cost that comes in with that first round, for example of applications, we wouldn't recommend just full off saying we're not going to put, you know, the underserved locations on the map for possible bid. 811 Haga Joseph 05:57:33.100 --> 05:57:49.140 But to put them both out and then from there, looking at the results trying to figure out how we balance the amount of funding received in terms of doing the math to make sure that we're getting the maximum amount of coverage with unserved taking the top priority. 812 Haga Joseph 05:57:51.100 --> 05:58:11.500 Thank you, thank you. I'm sorry, because I just, I thank you for your time if I could add just one final point on the, if we're considering a predefined area whether again, hopefully in the, in the subsequent round, several states including Pennsylvania, Montana has also Incorp. 813 Haga Joseph 05:58:12.980 --> 05:58:30.180 A mechanism to allow applicants to descope certain limited areas within a proposed area on the basis of being an overbuild or being extremely high cost That would otherwise kind of. 814 Haga Joseph 05:58:31.740 --> 05:58:51.820 The overall cost per passing in a given project area. So, again, this wouldn't be, this would not be saying that we're not going to serve that area at all, but within an application, be able to descope a proposal. 815 Haga Joseph 05:58:52.500 --> 05:59:12.300 Be able to have, you know, another conversation subsequently about making sure any existing gaps get filled in. Thank you, okay, no, thank you. And, and I do appreciate that you were looking at ways to how we can get to some of these donut holes that have been particularly problematic, especially in some. 816 Haga Joseph 05:59:13.820 --> 05:59:32.780 Areas as well as the rule areas that we need to definitely reach commissioner, could I just add one thing there as well. Just representing the community from a community perspective, especially when we're talking about ISPS leveraging their existing networks, we are really concerned about ISPS being able to build. 817 Haga Joseph 05:59:33.100 --> 05:59:45.180 Project areas, given CPU, C's own network exam findings that incumbent ISPS disproportionately invest in wealthier communities, so that would be of concern to Oakland divided. 818 Haga Joseph 05:59:47.580 --> 05:59:51.860 Commissioner Shena has her hand raised as well. 819 Haga Joseph 05:59:54.580 --> 05:59:55.700 Yeah. 820 Shayna Englin | CCF 05:59:59.140 --> 06:00:19.500 Thanks on behalf of CCF with agree with Georgia that there's some concern about of reliance on existing infrastructure, so that infrastructure clearly already search folks and, and got doubled down on where there's gaps, but once it's on the speak again, on behalf of. 821 Shayna Englin | CCF 06:00:20.300 --> 06:00:39.980 Group since we have communicated about this on the matching front, our concern around the matching is that it may be used to effectively says qualify local municipal community based organization education agencies and other qualified public serving or. 822 Shayna Englin | CCF 06:00:41.140 --> 06:01:01.380 Building networks using public dollars for public benefit, and so while appreciate the Comcast and how broadband at and T- is working concern about efficient use of public dollars wanna suggest that something that might be helpful here and sure we're. 823 Shayna Englin | CCF 06:01:01.660 --> 06:01:21.100 By the NTIA is almost like a bifurcated recognition so that if there is, for example, projects and procedures that if there are project areas that are only proposed being served by the private provider, then. 824 Shayna Englin | CCF 06:01:22.140 --> 06:01:42.340 Prioritize if they want to take out of their profits to build in that area, that's a terrifically efficient piece of public money, but where you have projects that are being proposed to serve by public serving entities using other pockets of public dollars that there should be some sort of exception or kind of. 825 Shayna Englin | CCF 06:01:42.420 --> 06:01:45.540 Combination for that matching requirement. 826 Haga Joseph 06:01:48.740 --> 06:01:55.140 Thank you, any other questions, comments commissioner and George director. 827 Haga Joseph 06:01:57.060 --> 06:02:10.420 Thank you that concludes our second panel of the day. I want to, thank you. All are all our panelists. We have one more panel. Panel three extremely high cost per location threshold, but we are going to take. 828 Haga Joseph 06:21:18.000 --> 06:21:35.280 Good afternoon everyone. My name is Jonathan Lackwards. I'm a manager in the communications division and I'll be moderating panel three on extremely high cost per location threshold and we will start off with our presentation by Ben Menzy, that will sort of ground us on the issue before we start moving into the questions. 829 Haga Joseph 06:21:35.360 --> 06:21:37.160 Thank you, Ben. 830 Haga Joseph 06:21:39.120 --> 06:21:42.640 Great, thank you. Jonathan, next slide, please. 831 Haga Joseph 06:21:44.880 --> 06:22:00.080 So this panel will focus on the extremely high cost per location threshold, although we were already starting to get into some of the policy issues on the previous panel. The purpose of the extremely high cost per location threshold is to balance a couple of competing. 832 Haga Joseph 06:22:01.520 --> 06:22:22.000 Goals within the beat program bed rules contain a preference for end- to- end fiber projects. These projects are called Priority Broadband projects within the no FEL, but that has to be balanced with achieving complete coverage of unserved and potentially underserved locations within the allocation established by NTIA. So sin. 833 Haga Joseph 06:22:22.120 --> 06:22:42.480 Serving some locations with end- to- end fire, would fiber would require extremely high expenditures that would deplete the budget for other locations and imperial the goal of complete coverage of unserved and underserved locations. So for those areas where the high, where the cost per location is extremely high reliable non- fiber. 834 Haga Joseph 06:22:42.520 --> 06:23:02.960 Alternatives are preferred when they're less costly than fiber, so Reliable broadband technology, which is defined in the NOFO as including cable DSL and license fixed wireless or a combination of licensed and unlicensed fixed wireless may be funded in those areas where the fiber costs would exceed the extremely high cost per location, thresh. 835 Haga Joseph 06:23:03.640 --> 06:23:23.440 In addition, non- fiber reliable technologies may still be infeasible from a cost perspective and technologies that meet basic technical requirements, including speed maybe funded in those areas in lieu of a reliable technologies. So those other technologies could include unlicensed fixed wireless and potentially. 836 Haga Joseph 06:23:23.480 --> 06:23:43.920 Satellite as well. Next slide please. So in practice the extremely high cost per location, threshold would be applied to further the bed program goal of achieving complete gover coverage within the context of the budgetary constraint in those areas where costs per location would be, it would exceed the extremely high cost per location. 837 Haga Joseph 06:23:43.960 --> 06:24:04.400 Threshold for fiber the CPUC is allowed, but is not required to not fund applications that exceed the extremely high cost per location threshold and to consider other technologies to achieve complete coverage. So that was a couple of double negatives, so to put a finer point on it, the CP, the extremely high cost per location threshold provides the CPUC, the option. 838 Haga Joseph 06:24:05.760 --> 06:24:25.520 A high cost application, but it does not require the rejection of that project NTIA has also clarified that the extremely high cost pro- location threshold does not need to be defined as a number amount in the initial proposal, but that a methodology for determining the extremely high cost per location threshold does need to be describ. 839 Haga Joseph 06:24:26.280 --> 06:24:46.000 And the threshold itself can be set later on using additional data that can be brought in those inputs for establishing the high cost per location threshold could include cost modeling data as well as actual application data from other broadband grant programs or from the beat applications themselves, as well as. 840 Haga Joseph 06:24:46.040 --> 06:24:52.120 Other potential options for establishing the high cost threshold next slide. 841 Haga Joseph 06:24:55.600 --> 06:25:14.160 Thank you Ben. I will go over the questions for first, and then we will turn to our panelists. The first question is what input should be used to determine the extremely high cost per location threshold such as cost models, application data, or other information hostically should the commission app. 842 Haga Joseph 06:25:14.520 --> 06:25:34.640 Extremely high cost per location threshold in selecting subgrantees in the initial proposal, should the commission adopt a specific threshold amount a range of possibilities different thresholds through different parts of the state processes for identifying extremely high cost location threshold during the subgrantee process or some other proposal for. 843 Haga Joseph 06:25:34.840 --> 06:25:46.920 Extremely high cost per location and we'll start with the consumer advocates, Leo Fitzpatrick, are you available? Ready to present for five minutes? Please? 844 Leo Fitzpatrick he/him TURN - The Utility Reform Network 06:25:48.960 --> 06:26:09.200 If you can see and hear me, yes, yes, we can good afternoon, I'm Leo Fitzpatrick representing the utility reform network as colleagues noted earlier the views expressed here are turns we are coordinating with C- four eight and caladvocates on this issue and along with many others. 845 Leo Fitzpatrick he/him TURN - The Utility Reform Network 06:26:09.200 --> 06:26:29.680 For specific viewpoints, please refer to written comments that have been submitted or maybe submitted commissioner, Hawk judge Golla and of course, all the staff that made this workshop possible, thank you. Thank you for this opportunity for parties and stakeholders to learn and discuss important aspects of a program that could help. 846 Leo Fitzpatrick he/him TURN - The Utility Reform Network 06:26:29.800 --> 06:26:45.440 Deliver safe reliable resilient and affordable communications to, to many in the state for gravity. I will refer to the extremely high cost per location threshold, which is a bit of a tonguister and a horrible sounding acronym simply as threshold. 847 Leo Fitzpatrick he/him TURN - The Utility Reform Network 06:26:46.960 --> 06:27:08.080 If you take away nothing else know that the commission may not pick a threshold. Now there's so much more information we need before we pick a optimal threshold or threshold and particularly one that strikes the balance between Beeds program goals. Indeed, we're seeing proposals from other. 848 Leo Fitzpatrick he/him TURN - The Utility Reform Network 06:27:08.320 --> 06:27:28.560 Generally appearing to push the threshold determinations to later, rather than sooner, for example, Nevada does not propose to do does not propose a figure and does not propose to do so until the close of the application process further, it wouldn't benefit the state to constrain itself in the initial proposal. 849 Leo Fitzpatrick he/him TURN - The Utility Reform Network 06:27:28.600 --> 06:27:49.040 By limiting the inputs that it's considering for the final threshold determination while time cannot to be said to be a luxury in the beat program. The threshold determination does not need to be made now and we should take advantage of the time where it is available. It's very encouraging to hear directly from the source as we. 850 Leo Fitzpatrick he/him TURN - The Utility Reform Network 06:27:49.200 --> 06:28:09.520 Heard earlier from NTIA itself, which is advising the state, not to make premature determinations and as we've heard several, and, you know, I just want to reiterate probably for the eleventh time, you know, that's what we've heard several times today. The B program has a clear preference for. 851 Leo Fitzpatrick he/him TURN - The Utility Reform Network 06:28:09.600 --> 06:28:30.000 That the threshold pie set as high as possible to deploy five or where feasible, but also serving unserved and underserved now the work before us requires us to confront a complex and multifaceted gold default goldy locks question set the threshold, too low and aside from potentially running a file of Nti's requirements, the. 852 Leo Fitzpatrick he/him TURN - The Utility Reform Network 06:28:30.000 --> 06:28:50.480 State might lose out on say an opportunity to deploy more resilient networks set the threshold to high and to fix some of the funding might not stretch far enough to beat the state's connectivity needs finding that just right figure is also gonna be a challenge in the state that is diverse and people and communities as it is in. 853 Leo Fitzpatrick he/him TURN - The Utility Reform Network 06:28:50.480 --> 06:29:10.960 Geography and potential climate threats for, for example, California is experiencing more wildfires, landslides and even hurricanes in recognition of this, the Commission five year action plan looked at fire hardening for locations in high fire threat districts that could be an input here. 854 Leo Fitzpatrick he/him TURN - The Utility Reform Network 06:29:11.000 --> 06:29:31.440 The action plan also mentions topology or geography and certainly those are go to inputs, but when we talk about the threshold, the discussion tends to steer two questions of where, but we should also be asking who the commission should also look at and consider, for example, adjusting the threshold to account for the. 855 Leo Fitzpatrick he/him TURN - The Utility Reform Network 06:29:31.480 --> 06:29:51.920 Financial burden families at eligible locations might face using commissions, affordability ratio earlier panelists mentioned the ratio and other demographic information. They thought were important for the challenge in selection processes and the commission could consider those here as well in the OR comments parties offered specific. 856 Leo Fitzpatrick he/him TURN - The Utility Reform Network 06:29:51.960 --> 06:30:12.400 Threshold amounts and turn decline to suggest one. we requested further analysis be made available to parties and stakeholders as well as the public so that we could have a little bit more clarity on what choosing one threshold over. Another would mean for affected communities term submits that we still don't actually have all the information we need to. 857 Leo Fitzpatrick he/him TURN - The Utility Reform Network 06:30:12.920 --> 06:30:33.520 Proper balance, picking a single figure for a state, like California with information we have is, and near impossible task to succeed, the state should implement this requirement flexibly, the threshold determination should indicate as many relevant factors as allows for the final threshold or thresholds to reflect the variety of circumstances, FA. 858 Leo Fitzpatrick he/him TURN - The Utility Reform Network 06:30:34.160 --> 06:30:54.000 Eligible communities as we've already heard from earlier panels places like Headleen Island, Oakland, Triple areas, these communities are engaging now and are offering suggestions on ensuring the program meets their needs. Now there's no reason that the commission can incorporate their input for this particular issue as well. 859 Leo Fitzpatrick he/him TURN - The Utility Reform Network 06:30:55.260 --> 06:31:13.900 And I will add that it's a long run at that we need to. Yeah, we need more time to determine the threshold and, you know, that aligns with what Ntia is already recommending. Thank you and I will try to answer questions with the information we have available to us at this point. 860 Haga Joseph 06:31:14.460 --> 06:31:21.780 Thank you, Mr. Fitzpatrick. Our next presenter will be Scott Armstrong from Innial County. Thank you. 861 Haga Joseph 06:31:22.780 --> 06:31:43.260 Good afternoon, again, my name is Scott Armstrong. I'm the regional broadband coordinator for anyone, Mono counties, and I've actually been hondering stressing about this question for quite some time because we have a lot of the locations in our area that are going to be extremely high cost to connect when I saw the. 862 Haga Joseph 06:31:43.940 --> 06:32:02.700 NGA map that listed census, blocked groups or, or high cost areas. We actually have a big chunk, which is done in the death valley area, but regarding inputs to evaluate on how to determine what is gonna be an extremely head cost per location area. 863 Haga Joseph 06:32:03.740 --> 06:32:21.180 I think that basically, the information that you're trying to collect is, is mostly adequate one of the things that I've noticed in dealing in working with providers and trying to get these little isolated pockets of people connected is a hesitants to connect. 864 Haga Joseph 06:32:22.940 --> 06:32:43.420 Really small numbers of locations that are, that are expensive to build to, and so, and we, we've had these discussions with the latter grant FFA as well. So what I, what I think might help is if you identify a threshold and there's a- and you want to have. 865 Haga Joseph 06:32:44.740 --> 06:33:03.900 There may be some benefit in looking at the nearness to other high cost locations and I'll give a couple of examples we have a place in Mono County called Homewood Kenyon. They're probably gonna be pretty expensive to build too, but they're about twelve of them over a few square miles. 866 Haga Joseph 06:33:03.900 --> 06:33:25.020 We have a couple of other places both in Indiano counties where there may be two households in a hundred square miles and those are gonna be really difficult to get a provider to reach to. So there may be some benefit in having some sort of a, a nearness factor to go along with that thres. 867 Haga Joseph 06:33:26.540 --> 06:33:46.140 And I say that because I'm, I'm convinced, but I don't have any, I don't have the, the secret recipe, but I'm convinced that there is a threshold that the providers look at in, in covering ongoing service costs. So, while the construction costs for one thing, they're gonna evaluate what it's going to cost to maintain. 868 Haga Joseph 06:33:46.620 --> 06:34:06.580 Provide the service and the support. So I don't know what that number is, and I, I get it that they don't share that with me, but I know that our extremely high cost look for location areas are not gonna be ones that providers are going to want to clamor to connect because we'll have two. 869 Haga Joseph 06:34:06.860 --> 06:34:27.100 Off on this road and go up another value. We have another four, six, and so we'll want to use some different means of getting the connected rather than fiber, but for Homework Canyon and for a cotton Wood canyon, we got a couple of them like that. I think they would benefit, even even though they are rather high cost to connect. 870 Haga Joseph 06:34:27.780 --> 06:34:47.580 Per location, I think there are enough of in the region to make it viable for a provider to, to provide services and support for. So I, I do agree waiting till later to draw the line on where the high cost threshold is, would be useful because I think that once we get a better idea, what the costs are going to be to construct in a different. 871 Haga Joseph 06:34:47.740 --> 06:35:08.060 Areas, you know, how much of the budget is going to be available. I've looked at the report that the state got from cost quest a couple years back and it's pretty clear that the more expensive it is, we have very few people locations in the extremely to connect. 872 Haga Joseph 06:35:08.060 --> 06:35:28.540 A screen line of cost areas to connect and the money expended to connect those goes up exponentially. So the longer we can postpone that the better and then one last thought as I was listening the last few minutes, it may be useful to. 873 Haga Joseph 06:35:33.300 --> 06:35:49.020 If you set a range or if your project is gonna be within within this range of per location costs and you should submit two proposals, one for fiber and one for the alternate means, except if the goal is to get everybody connected who is unserved, that may be our. 874 Haga Joseph 06:35:49.060 --> 06:36:00.260 Opportunity to work through and find the best ways to connect, we may have a couple of places that could be connected with fiber, but it may make sense to connect more with. 875 Haga Joseph 06:36:02.060 --> 06:36:22.300 Wireless if we can reach the rest of our locations and I think those of us in the rural counties already have their boards prepped they already know that we're not going to have it from fiber right away, and I'm sure that we'll have further conversations for those that aren't connected with fiber. They're not gonna be future proof. 876 Haga Joseph 06:36:22.380 --> 06:36:26.900 So we'll be talking about that again in the future as well. Thank you. 877 Haga Joseph 06:36:28.100 --> 06:36:48.540 Thank you for your comments. Mr. Leon, Lynn Degret. Are you prepared to speak? Thank you. Hi, I'm, Linda grew. I'm the IT project manager for Broadband in Twelming County. We are also a very rural mountainus county, our estimate to build fiber to all of our homes is North. 878 Haga Joseph 06:36:48.700 --> 06:37:09.020 Two hundred million. So it's obvious that we're going to have to take a hybrid approach and we will need, you know, point to point wireless and whatever we can do to get people served that said there are some things that I would suggest the commission. Consider one is, is we. 879 Haga Joseph 06:37:10.340 --> 06:37:29.500 Many mountainers communities we have people at high altitudes that are going to be really high cost, but they will also be directly next to the middle mile. So I think it would be be wise to use that as one of the inputs because it'd be a shame to have a hundred and fifty homes, two hundred fifty feet from the. 880 Haga Joseph 06:37:30.140 --> 06:37:32.180 And not take advantage of it. 881 Haga Joseph 06:37:33.340 --> 06:37:53.820 The, the, one of the other things is that while point to- point wireless is great and it's evolving at a, at a really encouraging speeds, the technologies usually doing a lot. One of the challenges that we have, again, in mountainous communities is forest cover and terrain play a huge impact on whether or not. 882 Haga Joseph 06:37:54.460 --> 06:38:14.300 People can actually get point to point wireless, so, for example, if you, most of these communities are often low- income and if they have to pay two thousand five thousand dollars to put up a poll to get point to point wireless, it's no longer affordable internet for these people. So, so sort of if there's a way we could. 883 Haga Joseph 06:38:16.060 --> 06:38:33.420 Out, sort of force cover and terrain and those kind of things and take that into a calculation. Something like that. Could really go a long ways towards making the deployment of point wireless more effective and would help sort of develop some of those projects. 884 Haga Joseph 06:38:35.620 --> 06:38:55.260 I'd also like to sort of make a quick sort of caution. I would also like to suggest that we defer on the cost threshold. I think there's a, a sort of a challenge in having a single amount that we use as a threshold and the reason. 885 Haga Joseph 06:38:55.340 --> 06:39:15.740 Is because very often, you know, rural communities, especially Mountain Mountains extremely hard to serve communities fall out of that threshold and so in one project, it's not a big deal, but if in multiple projects over multiple decades that creates sort of a systemic deferral of. 886 Haga Joseph 06:39:15.780 --> 06:39:28.260 Infrastructure and while we're not gonna fix that with one, you know, broadband program, I think that should be part of the consideration when that threshold is being developed. 887 Haga Joseph 06:39:31.740 --> 06:39:33.340 Thank you very much. 888 Haga Joseph 06:39:34.300 --> 06:39:54.780 Before we move to our next panelist, I wanted to do a call out to Matt Rentan and to see if he would like to address the issues on this panel. He didn't previously sign up, but I wanted to make sure so Matt, if you are interested, if you can raise your hand or put your name in the chat, we will definitely find time to recognize you. 889 Haga Joseph 06:39:55.460 --> 06:40:15.260 Well, Matt's considering that we'll move on to our next panelists, which is met Deterra from CTIA. Excellent, thank you. Thank you Commissioner, Hackola, the entirety of the commission and the staff for having us here today We really appreciate it. I'm, Matt Datora. I'm the council for. 890 Haga Joseph 06:40:15.900 --> 06:40:35.740 State Affairs on behalf of CTIA where the trade association for the wireless industry, so, you know, as my previous panelists have noted the extremely high cost per location threshold or threshold is really the key mechanism to ensure the commission has flexibility to reach as many Californians as possible who limited beat funding. 891 Haga Joseph 06:40:35.780 --> 06:40:56.220 And how, and how high the commission sets the threshold is going to determine where carriers can bid to serve areas with fixed wireless and bring broadband more quickly and cost effectively to unserved and underserved areas, and I think it's Mr. Fish, Patrick, noted the threshold is an important folk from, in the B process, right? On one. 892 Haga Joseph 06:40:58.660 --> 06:41:20.940 May be able to be served by fiber cost effectively on the other. You'll have areas above the threshold where you'll want to use technologies other reliable broadband technologies such as fixed wireless, which has been embraced by consumers is fast to deploy and most importantly is cost effective for California's limited beat funding. So, with regards to the couple of the questions that the commission has proposed today. 893 Haga Joseph 06:41:21.660 --> 06:41:42.060 You know, I want to, I want to look at those with a little more specificity with regard to inputs. The commission ought to use available reliable data, in particular, I think we've seen some good data come out of the Fcc's broadband maps, which are subject to a challenge process as well as reliable tools as the commission mentioned like network cost modeling, but. 894 Haga Joseph 06:41:42.700 --> 06:42:02.540 I really want to emphasize as it considers these inputs as important for the commission not to set the threshold too high, rather California ought to set a level that facilitates broad participation by different types of providers and give the state the flexibility to choose a mix of technologies that gives California the best chance to reach all. 895 Haga Joseph 06:42:02.580 --> 06:42:23.020 Unserved and underserved locations. I was hardened to hear commissioner, how mentioned flexibility a couple of different times today. No matter where the commission sets the threshold. The commission retains the ability to prioritize and select broadband projects based on the factors it deems appropriate from the no fo things like speed capacity. 896 Haga Joseph 06:42:23.020 --> 06:42:44.780 Cost and time to deploy. So no matter where the commission sets the threshold threshold fiber is going to be able to bid on these areas, but setting the threshold to high means less areas where the commission has that flexibility to choose from different technologies. So all it does by keeping it too high is, is stop the possibility that you can pick the most effect. 897 Haga Joseph 06:42:45.020 --> 06:43:05.260 Service for the area. The commission also asked how strictly should it apply the threshold and CTI feels the commission seek to minimize waving the threshold where possible, any location where the commission waives the threshold is a location that the commission acknowledges by the threshold is extremely high cost, but won't allow alternative. 898 Haga Joseph 06:43:05.300 --> 06:43:25.740 Technologies to make their case for serving that area and we feel, that's not an effective use of b dollars that we emphasize. Of course that in these extremely high cost areas, fixed wireless is a major tool in the commissions toolbox, so Reliable broadband service that meets and exceeds consumer needs today, if you look at New Broadband subscriptions over the course of the past year consum. 899 Haga Joseph 06:43:25.980 --> 06:43:46.220 Chose fixed wireless. Nine to one over other types of technologies, fixed wireless meets all of the B- technical standards for Reliable Broadband Service and it continues to get better and faster for extremely high cost areas. In particular, we also want to emphasize that it's going to be quicker. I believe Mr. Guardino pointed that out in the previous panel to build. 900 Haga Joseph 06:43:46.300 --> 06:44:06.700 Fixed wireless because the technology is built on cell towers. It's also going to scale well, and as an added benefit, it's going to help mobile coverage and those hard to serve areas as well. Now we feel the threshold should be applied strictly because it's an important check on inefficient spending every waiver. The commission grants is less beed, money, California has. 901 Haga Joseph 06:44:06.740 --> 06:44:27.180 Meet its programmatic goals and that's not just unserved and underserved areas, but also bringing broadband to community anchor institutions, funding, non- deployment activities. Finally, the commission asked how it should determine the threshold. I'm gonna bring kind of a different take to some of my fellow panelists. We urge the commission to set a number for the threshold earlier rather than later. 902 Haga Joseph 06:44:27.220 --> 06:44:47.660 And here's why, because the threshold is a critical factor in determining where bids for Reliable broadband technologies, like Fireless will be allowed the earlier carriers and other bidders have more information about the process. We feel the likely it is, you're going to get more bidders more bidders in turn means more competition. More competition means more EFF. 903 Haga Joseph 06:44:47.940 --> 06:45:08.140 Use of California as Beed money is going to greatly increase California's ability to connect the largest number of locations at the lowest cost and really help make sure nobody gets left behind. So in conclusion, I just want to emphasize how valuable fixed wireless can be to help connect Californians with a broadband service that meets consumer needs is cost- effective and is faster deploy and that. 904 Haga Joseph 06:45:08.420 --> 06:45:28.620 The commission should set a threshold that maximizes its ability to allow fixed wireless in other reliable broadband technologies to bid on unserved and underserved areas and help California close the digital divide. Thanks for having us today. Thank you very much. Our next presenter, it'll be Lewis Peretza, that apologizes if I mispronounce your last name. 905 Haga Joseph 06:45:29.260 --> 06:45:30.500 From whisper. 906 Louis Peraertz 06:45:31.180 --> 06:45:41.580 That's okay, it's Loui Parettz and thank you so much to Judge Golla and the Cpus before I go on. Can you folks hear me? Okay? 907 Haga Joseph 06:45:42.060 --> 06:45:42.700 You can. 908 Louis Peraertz 06:45:42.740 --> 06:46:03.180 Okay, great, so thank you so much for inviting whisper to speak on this panel about setting the extremely high, cause per location threshold for California. The vast majority of whistmas members are fixed wireless providers that are small and medium companies that serve their local communities and sparsely populated rural areas that large billion dollar companies. 909 Louis Peraertz 06:46:03.220 --> 06:46:23.660 Have ignored for decades. The CPU sees approach to arriving at the proper threshold, should be guided by three key factors. First the infrastructure act mandates that California prioritize funding one hundred by twenty mega. That's per second service to last my locations, I currently lack access to twenty- five. 910 Louis Peraertz 06:46:23.740 --> 06:46:44.140 Three megabits per second speeds, The ACT also allows funding to underserve locations, then community at anchor institutions and then digital equity goals if sufficient beat funds remain second, the NTIA bead allocation to California as many prior panel. 911 Louis Peraertz 06:46:44.420 --> 06:47:04.620 Have spoken is more than is substantially short. In fact, it's more than seven billion short of the amount that the CPUC determined is necessary to connect the million, nine hundred ninety- six thousand, three hundred two last mile locations, which are currently unserved by twenty five, three megabits per second to fiber opt. 912 Louis Peraertz 06:47:04.740 --> 06:47:25.100 IC broadband the third factor is that a large percentage of locations in California are difficult to serve due to top of topographical challenges are very low population deb cities because the beat allocation is so short of the CPU C's estimate for deploying fiber the CPU. 913 Louis Peraertz 06:47:25.220 --> 06:47:45.580 Should adopt processes that enable it to stretch B dollars as far as possible and therefore it should embrace other technologies such as fixed wireless, broadband networks that can be deployed in a much faster and more cost- effective manner, for example, according to several reports, including a Carmo report, the capital cost to dep. 914 Louis Peraertz 06:47:45.940 --> 06:48:06.060 Fiber broadband could be as high as nine to ten times the cost to deploy fixed wireless broadband. So setting an appropriate threshold is a critical issue if the threshold is too high, there could be a gap between locations funded with priority broadband projects fiber and those that do not meet the. 915 Louis Peraertz 06:48:06.100 --> 06:48:26.540 Threshold, so by expanding a number of locations, we're lower costs. non- fiber technologies can be eligible. The state will serve more of the unserved at less cost and if Beed funds are used to overbuild locations already receiving one hundred by twenty megabits per second from broadband networks using. 916 Louis Peraertz 06:48:26.900 --> 06:48:46.260 Ly unliced spectrum. Those funds will be squandered and lost for the goal of bringing service they're truly unserved as a CPU C ways. Its options whisper offers three recommendations for the CPUC to consider in determining in the Stresshold first. 917 Louis Peraertz 06:48:47.980 --> 06:49:07.500 Should consider cost estimate analysis that examine the challenges of topography, low population density areas and other relevant factors to reach locations without twenty- five three megabits per second broadband as long as those analysies are submitted in the Cpuc's record for this proce. 918 Louis Peraertz 06:49:08.140 --> 06:49:28.620 Before the CPUC submits its final proposal to Nchia. This would allow the CPUC to arrive at a reasonable estimate of range of what the threshold could be second. The CPUC could invite all reliable broadband service providers, Those that rely on fiber and those that rely on fixed wireless. 919 Louis Peraertz 06:49:28.660 --> 06:49:49.100 Networks using license spectrum to apply for beat grants through a competitive process that awards higher scores to networks, delivering faster broadband speeds, this application may, however, require the CPUC to seek a waiver from NTIA and third, the CPU C could determine that any last mile locations. 920 Louis Peraertz 06:49:49.340 --> 06:50:09.580 Do not receive acceptable applications for projects from Subgrantees should be considered extremely high cost per location. Threshold locations. In other words, the market would help to set the threshold of course, the state should reserve an amount of its b- allecation for these threshold locations. 921 Louis Peraertz 06:50:09.580 --> 06:50:30.060 And when the CPUC sets its threshold locations in areas that meet the threshold in our already receiving one hundred by twenty megabits per second broadband from any networks, including networks using entirely Unlice inspection, it should be considered served and not eligible for being funded deployments. Those recommend. 922 Louis Peraertz 06:50:30.820 --> 06:50:51.180 Help to address questions one and two with regard to the third question. Should there be a single or several thresholds whisper is willing to consider several thresholds, but one of the priorities should be in this area should be to, to promote ease of subsidy allocation and planning by all relevant stake. 923 Louis Peraertz 06:50:51.860 --> 06:51:07.380 Including the CPUC and potential sub- grantees. Thank you for allowing me to present these opening remarks. I greatly appreciate the CPUC and its staff where it's hard work on making be to success and I'd be happy to answer any questions. 924 Haga Joseph 06:51:10.620 --> 06:51:17.620 Very much appreciate you and Dean on time. Our last presenter is Brian Hurley, from ACA connects. 925 Haga Joseph 06:51:18.460 --> 06:51:20.060 Pressure move. 926 Brian Hurley 06:51:22.460 --> 06:51:42.620 So thank you Commissioner. How and staff, thank you for the opportunity to participate in today's workshop ACA connects as a trade association that represents small and mid- sized broadband providers, including in California for the beginning of the BEED program. We focused on providing data and analysis to help states spend their beat allocations effectively. 927 Brian Hurley 06:51:42.700 --> 06:52:03.100 Working with our partner, the business consulting firm Cartisian and my comments today addressing the threshold build on these previous efforts now in the NOFO NTIA determined that priority broadband projects are those that use end- to- end fiber OPTIC architecture that was based in part on its observation that only end- to- end fiber will ensure that the network built by the. 928 Brian Hurley 06:52:03.580 --> 06:52:24.220 Can easily scale the speeds over time to meet the evolving connectivity, needs of households and businesses and support the deployment of five G success or wireless technologies and other advanced services. So it makes sense that NCI went on to convey its expectation that states set the extremely high cost per location threshold as high as possible to help ensure that end- to- end fiber projects are deployed wherever. 929 Brian Hurley 06:52:24.380 --> 06:52:44.700 Feasible, so the question then becomes how should the CPUC go about achieving that goal given that the funds available are limited to begin, if California calculates the threshold over a large geographic area, it will end up setting the threshold too low and that's because different eligible locations have significantly different cost characteristic. 930 Brian Hurley 06:52:44.900 --> 06:53:05.180 And a small percentage of locations will cost many more times than the rest. This is the, so called hockey stick effect on the cost curve, and if the threshold is calculated based on a large geographic area level such as a county or census tract that includes many of these very high cost, highest cost locations, it makes the average cost appear much high. 931 Brian Hurley 06:53:05.420 --> 06:53:25.660 And we'll skew the threshold lower and as an aside, we have a similar concern if applicants were forced to apply for funding based on larger geographic areas and both instances locations, where does a cost effective to deploy fiber that is below a reasonable threshold would not get fiber to address these concerns. 932 Brian Hurley 06:53:25.660 --> 06:53:46.780 We urge the CPUC to calculate over the threshold over smaller geographic areas such as by census block and in doing, so the state should remove the outliers. The very highest cost locations and, and deal with them separately and relatedly the state should allow bidding on a, on a location by location basis, allowing applicants to construct their project. 933 Brian Hurley 06:53:47.420 --> 06:54:07.260 If that's deemed administratively infeasible Adminimum bidding should be allowed to set this block level and not only will this ensure that fiber deployments are maximized, it will do, so at lower costs because it will encourage participation, especially from smaller fiber providers such as my associations members. Now once the state completes the challeng. 934 Brian Hurley 06:54:07.420 --> 06:54:28.380 Process and identifies eligible locations. We think that's the point at which it should then move on to set the threshold and as the no, PHO directs we think it would just be a single threshold at this point in the process, the state should be able to determine the cost per location in each area and then calculate the threshold. However, it is critical that the threshold be Estab. 935 Brian Hurley 06:54:28.740 --> 06:54:49.500 Before competitive bidding begins so that providers know which locations are above or below the threshold and can plan their bids accordingly and this level of certainty will also help encourage participation again, especially from smaller providers resulting in a more competitive process, like others, we, we think the state should use a cost model to estimate the cost. 936 Brian Hurley 06:54:50.300 --> 06:55:10.620 Beat eligible location, we know in the past California has used a cost quest model, our partner Cartisian has recently released a new financial model that's available for the states under their sort of initial estimate. The threshold would be said at twelve thousand dollars per location, which takes into account a three thousand dollar match. 937 Brian Hurley 06:55:10.740 --> 06:55:31.100 But we recognize, that's just a starting point, an additional work would need to be done to refine the estimate. So there are reputable models out there that can be utilized. We know different providers love different costs based on size, existing assets, financing, labor topography and so forth network deployment architecture and state. 938 Brian Hurley 06:55:31.180 --> 06:55:51.580 Should aim to specifically California, in this case should aim to model the cost based on a typical provider cost working with and engaging with local service providers to help make that assessment and once cost per location or estimated a cost curve can then be drawn to show the distribution of costs for beat ELIG. 939 Brian Hurley 06:55:51.740 --> 06:56:09.900 Locations and then by examining the total funding that's available, including both the government subsidy and the provider match, The threshold could then be calculated. So thank you very much for the opportunity to speak. I'm happy to answer any questions or to provide any supplemental information that would be helpful. 940 Haga Joseph 06:56:10.820 --> 06:56:19.980 Thank you very much. That was very helpful that was will turn to questions from Commissioner Hug and, or administrative law judge Google. 941 Haga Joseph 06:56:25.500 --> 06:56:44.700 So I guess one question would be in determining the threshold earlier from later. Can you be a little more specific and talk about some of the pros and cons because I heard some of the panelists say that they think we should wait till later and others that, that we should wait till ear. 942 Haga Joseph 06:56:45.060 --> 06:57:05.180 And then I guess a question to NTIA about how much specificity we're gonna need in our, our volume two to get approved and so it, I, I guess how early or how late would we be able to do that and I don't know if we have Marina answer that first, and then I can, if that's helpful. 943 Haga Joseph 06:57:05.820 --> 06:57:25.660 So, for the purposes of the initial proposal, volume two NTIA is allowing states to define the factors and process by which they would define extremely high cost per location threshold and that will be sufficient when there's actually a number when that needs to be released to NTIA and we have to have it sub. 944 Haga Joseph 06:57:26.420 --> 06:57:41.620 That's going to be by the final proposal and so there's a pretty large amount of flexibility for states to determine at what point in the process they want to sort of make that call before. 945 Haga Joseph 06:57:42.940 --> 06:57:51.580 Actually formally deciding on that number, and does it have to be a specific number or could it be. 946 Haga Joseph 06:57:52.620 --> 06:58:07.420 Categories with numbers. So I believe that multiple thresholds are allowed within a state. Should a state choose to do that. I think we'd want to understand the reasoning and why, and that kind of thing. 947 Haga Joseph 06:58:08.540 --> 06:58:18.100 But we don't need a number or multiple numbers for the initial proposal. Just how are you going to get to those numbers or number? 948 Haga Joseph 06:58:19.500 --> 06:58:39.900 Thank you, and then I don't know if a panelists want to respond and then I saw Mr. Razwell wanted to make a comment as well. Absolutely, commissioner, yeah, you know, I, I don't envy the commissioners in trying to figure this out because I do think the threshold is, is one of the tougher things to figure out in this whole process and again. 949 Haga Joseph 06:58:39.900 --> 06:59:01.020 In the same way that you're, you're balancing your high cost areas and, and the competing needs and the priorities of NGIA for fiber versus making sure that all the money is, well spent, I think it's a range when it comes to setting it earlier versus later and I, I just emphasized that, you know, of course the commission doesn't want to set. 950 Haga Joseph 06:59:02.740 --> 06:59:21.500 ING on data, you know, it doesn't want to be a stab in the dark and you don't want to do it blind, but on the flip side of things, you know, there is an advantage to, to more clarity and more specificity and making it earlier simply because that will bring. 951 Haga Joseph 06:59:21.740 --> 06:59:41.980 More bids and more competition because it will be easier for potential perspective subgrantees to say, Oh, okay, look. I've got X, y and Z areas that I'm going to be able to bid on with my reliable broadband technologies. Let me focus on those as opposed to the later. It gets in the process. The more, those subgranties will have to turn around and say, okay, we've. 952 Haga Joseph 06:59:42.460 --> 06:59:44.740 Time to prepare our bids. Now. 953 Haga Joseph 06:59:50.300 --> 07:00:06.300 Did anyone else? I, I certainly understand the need to, to have some time to plan to get your, your applications in. I would just suggest that there should be a period where the model's developed or that's. 954 Haga Joseph 07:00:06.980 --> 07:00:12.140 Public comment can be contributed before a threshold is set. 955 Haga Joseph 07:00:13.340 --> 07:00:16.220 And maybe multiple thresholds at that. 956 Haga Joseph 07:00:18.140 --> 07:00:37.660 That as well, and part of that is, we've been trying to get estimates on, in our ladder grant work. We're trying to get estimates on per household to connect with fiber and, you know, it's interesting, we've got between nine hundred bucks and twelve thousand bucks per. 957 Haga Joseph 07:00:37.900 --> 07:00:58.140 Per location, and I think we need to have more of that information so that we know how much the priority projects are gonna take of the budget. so we know how much we're gonna need to scale back or lower raise the threshold, but I think, you know, well, it does sound like there might be some advantage to set. 958 Haga Joseph 07:00:58.780 --> 07:01:08.980 A set of threshold now and just let people duke it out with estimates and whatnot. I think that we do need to look a little bit closer. 959 Haga Joseph 07:01:11.980 --> 07:01:19.020 So I think we have Luis, it's Patrick, once has his hand raised. Go ahead Mr. Fitzpat. 960 Leo Fitzpatrick he/him TURN - The Utility Reform Network 07:01:19.220 --> 07:01:20.300 I'm sorry. 961 Leo Fitzpatrick he/him TURN - The Utility Reform Network 07:01:20.420 --> 07:01:22.220 Mr. Louis Perettz had. 962 Haga Joseph 07:01:22.340 --> 07:01:22.860 His hand up. 963 Haga Joseph 07:01:24.140 --> 07:01:27.660 Okay, Mr. pres. I'm sorry. 964 Louis Peraertz 07:01:28.700 --> 07:01:40.140 Thank you very much for that for that Titaness Leo. So that's why our position in our opening remarks is that. 965 Louis Peraertz 07:01:42.220 --> 07:02:01.820 The CPUC allow various economic analysis that could be submitted before the CPU sees submits, it's, it's final proposal to NTIA and that's, you know, that's not due until three hundred sixty days after. 966 Louis Peraertz 07:02:01.980 --> 07:02:22.380 Proposals have been approved by NTIA. I think doing it. We, we thought we thought long and hard about this and we thought doing this before the initial proposals, which are due December Twenty- seventh would be really challenging for the CPUC, so we think there should be, so I, I agree with the, the last two. 967 Louis Peraertz 07:02:23.180 --> 07:02:42.860 Just said that there should be enough time for developing of, and a comment and reply comment period for developing more economic analysis as Brian Harley said there are the cartisian analysis out there, there are other analysis out there and I think a robust. 968 Louis Peraertz 07:02:42.940 --> 07:03:03.340 Record for the, for the CPUC to consider before it, it comes up with a range of estimates would be really important for the CPUC. It would be really important in terms of planning and ease of administration going forward for both the CPUC and the subgrated if the CPUC. 969 Louis Peraertz 07:03:03.540 --> 07:03:23.820 Say, okay, well here's what we think are a reasonable range of estimates and then we'll, we'll decide later exactly what it is, but here's what we want people to react to. Okay, and then as we get into the application process that may play a factor into the CPUC, arriving at its threshold as well, and it could. 970 Louis Peraertz 07:03:24.180 --> 07:03:32.740 It could be several thresholds again, we just want to promote ease of administration for both the CPUC and for the subgrantees. 971 Haga Joseph 07:03:36.340 --> 07:03:38.340 We can provide the mister Fitzpatrick. 972 Leo Fitzpatrick he/him TURN - The Utility Reform Network 07:03:42.420 --> 07:04:02.460 Don't want to take away anyone's moderator privilege, but I do want to acknowledge that I see Mr. Matt Raintonin is on the call and I certainly had a question for him, but I can, I can wait if we wanted to give him an opportunity to speak, I did want to respond to a couple things that I heard. 973 Leo Fitzpatrick he/him TURN - The Utility Reform Network 07:04:02.940 --> 07:04:16.940 Earlier in the presentation, Scott and Len's presentation in terms of sort of the, the depth of, you know, factors we need to consider, you know, what was particularly interesting was, you know, the question about, you know. 974 Leo Fitzpatrick he/him TURN - The Utility Reform Network 07:04:18.220 --> 07:04:38.700 Incorporate a model that considers middle, you know, existing middle mile or even the states pending middle mile build out, you know, it'd be a shame that someone is two hundred and fifty. I think that's what Lyn had said a two hundred fifty feet and from Middle Mile and it's those project proposals are not coordinating with the deploy. 975 Leo Fitzpatrick he/him TURN - The Utility Reform Network 07:04:39.020 --> 07:04:59.180 Of the middle mile broadband initiative and I also, you know, I think Scott identified two interesting points. No, it's a shame to hear about like, these non- starter locations places that are, you know, we shouldn't be writing off places without further consideration and I think that blies the need for additional time. 976 Leo Fitzpatrick he/him TURN - The Utility Reform Network 07:04:59.180 --> 07:05:19.660 And focus attention to, to make sure that we're looking at all the factors that the people, you know, I think we all agree that we need to have, you know, providers participating in the program, but we also need to make sure that the program is actually responsive to the needs of people that are receiving these, the benefits of the service, and, you know, I think the other. 977 Leo Fitzpatrick he/him TURN - The Utility Reform Network 07:05:20.300 --> 07:05:40.140 Scott identified was a continuing information asymmetry and, you know, it kind of gives me a, there's a striking parallel to the conundrum that we're facing on undertaking outreach for something like the challenge process, The roles aren't final final yet, so you can't undertake outreach, but you need to undertake outreaches early as possible. 978 Leo Fitzpatrick he/him TURN - The Utility Reform Network 07:05:40.140 --> 07:06:00.620 So I hear folks about the need for a little bit more uncertainty, but I think, you know, one approach could be sort of like what the commission did for this first panel, you know, letting folks doing robust outreach letting folks know about what's at stake with the extremely high cost with the threshold, even providing some resources and information. So. 979 Leo Fitzpatrick he/him TURN - The Utility Reform Network 07:06:00.700 --> 07:06:21.100 That someone could click on a map, you know, a state like a local or tribal government official could click on a map and be able to do comparisons and realize, okay, you know, setting the threshold here means this home here or this small business or this community will be connected in one. 980 Leo Fitzpatrick he/him TURN - The Utility Reform Network 07:06:21.460 --> 07:06:41.580 Or another, we need to get that information out there and at this point, you know, just trying to rush it before getting this initial proposal to, to Ntia just doesn't it struck me as sort of the, the best approach. Now one possibility is that the commission could potentially adopt a threshold track to run. 981 Leo Fitzpatrick he/him TURN - The Utility Reform Network 07:06:41.660 --> 07:06:53.660 Currently with other beat implementation, but, you know, that's just a- that's the possibility trying to brainstorm here and, and be helpful and responsive to some of the, the needs folks that identified. 982 Haga Joseph 07:06:55.100 --> 07:07:14.860 Great, thank you very much. I know Mr. Hurley have your hand up, but I want to turn to Mr. Randon has been able to rejoin us and first provide you an opportunity to provide any general comments. You have on the questions for about regarding the extremely high cost threshold and then I think there's a specific question that Mr Fitzpatrick has go ahe. 983 Matthew Rantanen 07:07:16.140 --> 07:07:22.780 Yeah, I thank you. I, yeah, I never left. I just turned camera off. I've been auditing so I think that. 984 Matthew Rantanen 07:07:23.940 --> 07:07:44.300 I think this is really strategic for deployment and travel communities because typically there is no infrastructure or very limited infrastructure on, on travel reservation in and around. So some of these households are, you know, fall into that category. Definitely, some of these. 985 Matthew Rantanen 07:07:44.580 --> 07:08:05.420 Communities fall into this category. So I think, I think it's very strategic for some of these to be classified as, as a high cost or extremely high cost to be able to, you know, receive the appropriate attention and solution funding that's deserved and I would like to propose. 986 Matthew Rantanen 07:08:07.700 --> 07:08:25.900 Should be able to, to self- designate with, with some, you know, provided parameters by CPUC, but self- designate some of those high cost situations on their res on their own reservations. Each travel government should be able to do that and, and to just show a similar example of, of stuff that. 987 Matthew Rantanen 07:08:25.940 --> 07:08:47.020 Designation by a tribal leader or a travel government. The FCC adopted a rule a couple of years back now that Fribes can self- designate their own libraries for the purposes of e- rate and that was something that we started from Travel Term Association in two thousand, one, two thousand, two working with a hill and, and the FCC to, to better. 988 Matthew Rantanen 07:08:47.700 --> 07:09:07.500 Frame, what needs to be done in, in legislature for tribes to be able to have access to, you know, the resources that they need to fulfill communications efforts on their rent on their lands, and twenty years later, the FCC adopted that, so twenty years of vetting tribal participation in the E- rate program show that tribes were accurate. 989 Matthew Rantanen 07:09:07.580 --> 07:09:27.980 Representing their tribal libraries along the way, and I think that, you know, we've come a long way in, in embracing technology and opportunity, and I think we see pathway to be very instrumental and designating some of these, you know, these criterias, so the high cost is obvious. 990 Matthew Rantanen 07:09:28.140 --> 07:09:48.460 To us, especially those of us that are building network. We know what, what neighborhoods are cut off or what individual homes are cut off. We know which ones are unable for connection and we, you know, it's very important that, that, those, that know the community get to weigh in on this. So thank you for, for letting me speak. 991 Haga Joseph 07:09:49.100 --> 07:09:56.140 Thank you very much. We appreciate your comments. Mr. Fitzpatrick, did you have a question for Matt? We can take care of that. Now. 992 Leo Fitzpatrick he/him TURN - The Utility Reform Network 07:09:56.140 --> 07:10:16.620 Yes, and actually I think he addressed it in part. My question for you, Matt was, you know, what are some considerations and inputs that we could be considering that would ensure that, you know, try this threshold being, however, this threshold is, is that want to impact tribes or in. 993 Leo Fitzpatrick he/him TURN - The Utility Reform Network 07:10:17.020 --> 07:10:37.100 In a negative fashion, I, I do think it's an interesting idea of the, it does appear that the B program requirement for a tribal endorsement for all tribal, you know, projects on tribal lands, you know, that is a clear recognition or advances NTIS recognition. 994 Leo Fitzpatrick he/him TURN - The Utility Reform Network 07:10:37.220 --> 07:10:46.700 Of tribal sovereignty here and the ability to set the threshold make sense here, but they. 995 Matthew Rantanen 07:10:47.980 --> 07:11:08.460 Sure, I'm gonna, it's, it's really kind of sad thirty percent of trouble households in the United States. Don't have access to plan. Hold telephone service. We know where those houses are on the reservation. Some of those households don't have power and the Navaho nation there, you know, there's an amazing amount of houses without. 996 Matthew Rantanen 07:11:08.820 --> 07:11:29.580 Some of our nations have quite a few houses without power, so it, it's very obvious to our trouble governments and our travel programs who does not have access and if they don't have access to power, they certainly don't have access to the infrastructure that gets them access to broadband and they are going to be high cost because you're gonna have to build power to support them. 997 Matthew Rantanen 07:11:31.040 --> 07:11:51.280 It's glare glaringly obvious to those of us that live and work in travel communities. It may not be so obvious to the outside the outside optics, so I think, you know, there's, there's some extreme conditions that we can identify that, that obviously are high cost and then there's some situation. 998 Matthew Rantanen 07:11:51.960 --> 07:12:11.760 Where, you know, people are living in a, in an area of a reservation that, that has less services than the bulk of the population or, you know, there's geographic limitations, et cetera. So I, I think that, you know, I think we can self- ident. 999 Matthew Rantanen 07:12:12.160 --> 07:12:29.440 That fairly easily and, and some of those things that I mentioned lack of power lack of play note, telephone service and cut off geographically or with a, you know, a mountain or something like that. I think there's some obvious situations there that can identify as well. Thank you for the question. 1000 Haga Joseph 07:12:30.320 --> 07:12:35.520 Thank you very much. Mr. early, thank you for your patience. I think we're not ready for your input. 1001 Brian Hurley 07:12:36.120 --> 07:12:56.560 Oh, thank you. and I'll be brief. So in terms of the, the point and the process when you set the actual threshold amount, the reason we, we thought that sort of after the challenge process, but before the competitive bidding begins, what might be kind of a sweet spot because after the challenge process, you'll have sort of the universe of locations that are going to be fund. 1002 Brian Hurley 07:12:56.680 --> 07:13:14.080 Through the program, but we also think I agree with my colleague from, from CTIA that it's important that we set the threshold early enough in the process that perspective bidders know which locations are gonna be above and below the threshold, so they can play an accordingly when they're making their bids. So. 1003 Haga Joseph 07:13:15.760 --> 07:13:36.240 Thank you very much commissioner. Did you have any additional questions? I just have one more question. just as mentioned in the last panel, There, there are certain, you know, there are certain situations where fixed wireless, maybe the better option, we know that the no phone and Beed Fabur favor fiber as the prefer. 1004 Haga Joseph 07:13:36.440 --> 07:13:56.720 Technology, however, whether it's rule areas that geographically, it may be difficult. It may be costly or it just may not be best to put fiber in there. There may be areas that we would want to look at licensed wireless. There's also areas in. 1005 Haga Joseph 07:13:56.840 --> 07:14:17.200 Cities whether it's old buildings and permitting issues regarding how and when you can put fiber in the ground that could significantly delay getting access to folks and as we said, we don't want to be waiting five, ten years when we're looking at particularly young people that need to depend on the internet whi. 1006 Haga Joseph 07:14:17.840 --> 07:14:23.720 To access school people that needed for healthcare. the world has changed since the pandemic. So. 1007 Haga Joseph 07:14:25.520 --> 07:14:45.360 I just want to, I, I think it's important in whether we get some comments here today or the written comments that you provide. I think it's gonna be important for us to understand the areas where we may want to be looking at fiber because we're gonna have to look at what does constitute the criteria for using alternatives to. 1008 Haga Joseph 07:14:45.480 --> 07:15:05.840 Fiber and the proposal, and so getting that feedback on when that would be appropriate when it wouldn't, I think is, is gonna be important. We are gonna have to consider different technologies, obviously we want a future proof this in as much fiber as we can get in the ground is a high priority, but we do know their circumstances in situations. 1009 Haga Joseph 07:15:06.000 --> 07:15:23.400 That may not be the most cost- effective or the best choice for getting people connected now, and so I, I just want to put that out there. get some feedback and also make sure that parties address those issues in their written comments. 1010 Haga Joseph 07:15:25.920 --> 07:15:29.160 If you want to come to the podium, please you'd be happy to hear from you. 1011 Haga Joseph 07:15:37.200 --> 07:15:55.760 Hello, again, the Megu commissioner, I'll be as brief as I can be here, finding myself wishing. I was on the panel, but here I am, we'll be sure to invite you to the next workshop. Great, great fantastic. Well, so the small x and I should say Patrick Rossball for the small X, this wall x. 1012 Haga Joseph 07:15:56.400 --> 07:16:16.240 Been serving exactly these kinds of rural areas for a hundred years and our carriers will last resort and are familiar with the decisions. You have to make in the limited circumstances where you go to like a fixed wireless solution, which the companies do do some of that where it's just infeasible to get to certain places, but our. 1013 Haga Joseph 07:16:16.280 --> 07:16:36.720 Biases in favor of, we've got to get fiber to everyone. I mean, I find myself agreeing with the, the Toronto gentleman who I think might be behind me. I mean, that's, that should be the starting point and there should be a very high threshold in light of that, and in fact, the Notebo says, I don't think anyone said this, the notepo says point blank in a couple of places. 1014 Haga Joseph 07:16:36.920 --> 07:16:57.200 You should set the threshold as high as possible, And so that's, that's our starting point. You should set it as high as possible and not only does it say that I think it's just important to honor kind of California's unique history around this, which is to say that California is different than almost every other state in the sense that there are a lot of legitimate significant communities Liv. 1015 Haga Joseph 07:16:58.080 --> 07:17:17.680 Areas whether it's because of tribal histories, the gold rush logging interests military bases, there are all kinds of reasons, but it's unlike a lot of states where you can into that and you can drive two hundred miles before you see the next town, California is not like that, and I think it's appropriate that we honor that by trying to get to all these places, not assume. 1016 Haga Joseph 07:17:18.400 --> 07:17:38.800 And the small X has gotten this feedback, sometimes maybe they should just accept that they don't have great service or any service in these places or maybe they should move to Sacramento, right? And these, I don't think we can view the problem that way. So just to be more specific, I'm skeptical of modeling just because I think you'd be very hard pressed. 1017 Haga Joseph 07:17:39.120 --> 07:17:57.560 Find a model that would capture the dynamics in Cisco County, for example, and, you know, you have canyons and forests and you have the Clamoth River and, and when you talk about getting to some of these places where there is a significant need, I'm just very skeptical that the model would allow you to capture all the variables. 1018 Haga Joseph 07:17:59.320 --> 07:18:19.760 What I can offer you, I think as a starting point is the commission's history on these subjects, and there is a lot of history from the CSF program. There's also a lot of history and smaller great cases and having looked at the various CSF grants that, you know, there are many in- going back now more than a decade, what you see is that there are including some very recent grands. There are. 1019 Haga Joseph 07:18:20.640 --> 07:18:40.240 Hundred thousand per household grants that have been granted very recently. There are several, there are many that are in the nature of twenty thousand per household, forty thousand per household things and that sort. So I heard a number earlier today. Something like thirteen thousand, if you do that, you will exclude a lot of these areas if that. 1020 Haga Joseph 07:18:40.560 --> 07:19:00.720 If that's the number, if we're talking about something in that range, it's not going to reach all the people it's supposed to. So I would, I would positive that if you look at the commission's history, things, even above a hundred thousand are being approved in the CASF context. There's only one significant decision that some of you will remember where the commission is actually pushed back and said, even though. 1021 Haga Joseph 07:19:00.840 --> 07:19:21.200 This is a good project and there's money to fund it. We're not gonna let you build it simply because of the cost for household. This was in twenty eleven. There was a, an area called Godfree Ranch, which is in Ciscus territory and they applied to, to serve the area. The money was in the grant fund. The grant fund actually went away the next year. 1022 Haga Joseph 07:19:21.200 --> 07:19:41.680 And the money was never spent. It was just absorbed into the state budget and in that instance you're, you were looking at a two hundred plus per two hundred thousand plus costs per household and in that instance, the commission did say we're not going to fund that now. I'm not sure if that would come out the same way today. I, I think maybe the commission would would reconsid. 1023 Haga Joseph 07:19:41.960 --> 07:20:02.160 That based on all the things that have happened and the importance of these, these kinds of networks, but even if it is how it would come out, I, I would su, I would suggest you that, that's in the nature of the kind of threshold we should be thinking of now the only reason you should go lower than that, my mind, two hundred thousand or something of that sort is if. 1024 Haga Joseph 07:20:02.440 --> 07:20:22.640 Just doesn't work out if you can convince yourself and I'm not convinced of it, but if you can convince yourself that the math is simply not there and you have to go to something lower, that should be the reason, but otherwise you should be consistent with the decisions you've made previously, which recognized that even a hundred thousand is potentially totally reasonable and as you think about that. 1025 Haga Joseph 07:20:22.680 --> 07:20:25.520 You know, I'll just leave you with, you know. 1026 Haga Joseph 07:20:27.120 --> 07:20:46.960 Every situation is gonna be unique, you know, there could be five households, but if it's next to a hydro facility, that's critical if it's next to a fire station, if it's in a certain area where it really need, if it's a tribal area, there's lots of reasons why you'd want to still consider the project. So, and I'll also just add that, you know, fixed wireless can't be undergrounded. 1027 Haga Joseph 07:20:47.280 --> 07:21:07.440 I know so there's some safety issues there too. I mean, in the recent fires that we've, we've encountered for the small X, the, the buried fiber, the undergrounded fiber does very well. I mean it's not perfect, but that's, that's the way we should be thinking about these networks, so I could go on, but I'm not going to appreciate. 1028 Haga Joseph 07:21:07.600 --> 07:21:11.560 Opportunity than I think there's somebody behind me. So thank you. 1029 Haga Joseph 07:21:13.200 --> 07:21:21.640 See Carl before you talk. We'll go to Louis first and then come back to you. Thank you please. Go ahead Loui. 1030 Louis Peraertz 07:21:22.160 --> 07:21:42.640 Okay, thank you Sir. So to Commissioner, how I would just suggest this and I, I don't know if I, I tried to make this point, but perhaps it didn't come out clearly enough. So again, our position is the CPU C- should consider any. 1031 Louis Peraertz 07:21:44.820 --> 07:22:04.660 Are relevant in terms of considering factors for deployment such as density population density, a load population density to pography challenges, anything that's been submitted in the record for this docket before the final proposal, but you, you said something to me that. 1032 Louis Peraertz 07:22:04.660 --> 07:22:25.140 Made me think that perhaps I should clare should also explain that it might be helpful for the CPUC to say we are very, we really think that we need to come to an understanding and have more information about how to set the extremely high cost per location threshold and before we do that, we. 1033 Louis Peraertz 07:22:25.340 --> 07:22:45.620 Think it might be helpful to open a comment and reply comment that allows for submission of other economic analysis and allows the public to react to those economic analysis and provide us with their feedback in response to that, so that perhaps could be helpful and could be done. 1034 Louis Peraertz 07:22:45.860 --> 07:22:49.780 Before the final proposal is submitted to Ntia. 1035 Haga Joseph 07:22:52.020 --> 07:23:12.500 Thank you very much. then for Carl, please, thank you again for the, for the record. Carl Guardino, with Toronto wireless a couple of observations based on a great panel, some information and an invitation, the observations, I just learned so much from this panel and Leo. 1036 Haga Joseph 07:23:12.660 --> 07:23:32.980 Turn, thank you. Your comment that we may need to make sure families are receiving the benefits of the service. I think is common ground for all of us and Matt and Loui was CTIA and Whisper unsuring that the threshold is set at a level that still achieves the beat. No fo goal of a hundred percent of unserved and under. 1037 Haga Joseph 07:23:33.100 --> 07:23:53.460 Served California families and Scott and Lynn from a real community perspective that needs to serve with affordable and Reliable Technologies and is still cost effective and doesn't break the bank and Matthew again, for a tribal communities that we provide providers that. 1038 Haga Joseph 07:23:53.540 --> 07:24:13.940 Know, and are a part of their communities can often best serve their communities and they need to be able to compete in this process as well, and Brian about early enough in the process, so that ISPS can factor that into their bids Is gonna make this more efficient and effective, and I, and I love commissioner. 1039 Haga Joseph 07:24:14.260 --> 07:24:34.420 Comments about timeliness and future proofing and future proofing is making sure that as we see technologies advance that it is future proofed so that it meets the needs of families and communities going forward on the comments on the Novo and I am always depending on. 1040 Haga Joseph 07:24:35.300 --> 07:24:54.900 To correct me on that ninety- five page document, but again, it's set the threshold as high as possible with a preference, but not a requirement for fiber while achieving the goal of the internet for all unserved and underserved that's the delicate balance and I would respectfully argue. 1041 Haga Joseph 07:24:54.900 --> 07:25:15.380 Improving grants that depend on fiber when it only needs to be a preference at a hundred twenty hundred and thirty- per household is going to ensure that we're gonna run out of money long before we run out of hundreds of thousands of California families primarily and unserved communities or stranded streets in our urban communities. 1042 Haga Joseph 07:25:15.420 --> 07:25:35.860 Or in our tribal communities that are all too often overlooked, usually more financially strapped and usually our communities of color and our cultural and ethnic diverse Californians. So those were my observations in terms of information technolo. 1043 Haga Joseph 07:25:35.940 --> 07:25:55.940 Again, does advance I was hundred to be on the earlier panel and I was scratching my head that I didn't have the opportunity to be on this panel because technologies do advance when we hear point to point Toronto fourteen million, four hundred million fourteen years, twenty- six Phds, three hundred engineers. 1044 Haga Joseph 07:25:57.300 --> 07:26:16.820 Line of sight, which meets the need of four out of five California families that don't have the luxury of direct line of sight to a vertical asset, five thousand calculations per second. It not only addresses buildings and strends of trees, et cetera, but in climate weather and that. 1045 Haga Joseph 07:26:17.460 --> 07:26:37.300 Branch blowing in the wind, et cetera. It's both licensed and unlicense needing the beed requirements for reliability both in licensed or a hybrid of the two technology has advanced and that's exciting, which is, that's what California's innovation is about. 1046 Haga Joseph 07:26:37.340 --> 07:26:57.780 So here's the invitation. We'd like to invite anyone online or in the room to live technology deployments of any of scores of communities. Thousands of families in California currently served by Internet service provider. 1047 Haga Joseph 07:26:58.420 --> 07:27:18.260 Using advanced technologies like Toronto, but it won't be limited to toronta in the future as people catch up so that you can ask the hard questions speak directly with local ISP serving their local communities as well as the larger ISPS and the customers. 1048 Haga Joseph 07:27:19.300 --> 07:27:38.740 Changed because they now have affordable reliable access to tell a health education jobs, public safety and emergency services so that on the record come see, we have dozens of deployments in our great state alone. This is not. 1049 Haga Joseph 07:27:40.020 --> 07:27:59.220 This is not a marketing floy. Thank you very much. I just want to take a quick break before we turn to Mr. Fitzpatrick commissioner and I'm happy to answer questions by the way I like hard questions. Thank you, I just wanted to turn to Commissioner Hub. Did you have any other questions or should we close as Mr. Fitzpatrick's? Our. 1050 Haga Joseph 07:28:00.060 --> 07:28:19.700 This topic is there any other questions that I do have one, but it may be a long one. I'm fine with Judge Google having is questions and then going to Mr. Patrick or vice, or the other way around, and then I did have some closing comments. I wanted to make. 1051 Haga Joseph 07:28:19.980 --> 07:28:39.860 Actually, just Google please go forward with your long question. Thank you, so it's possible that four different folks may want to answer this, including our friends at, at and T- and Comcast, and the reason that they'll start with Mr. Degurud and Mr. Armstrong. 1052 Haga Joseph 07:28:42.740 --> 07:28:58.740 Do either of you plan on having hybrid approaches to serving your communities and I think Comcast in at and t- understand where I'm going with the question to them absolutely. 1053 Haga Joseph 07:29:00.660 --> 07:29:21.100 Yes, and we're planning that for Darwin and possibly for Furnace Creek out. So just out of curiosity, if I don't know whether this is even possible or not, but could is either at and t- or Comcast in the position to submit. 1054 Haga Joseph 07:29:22.460 --> 07:29:30.340 Because I know it's different, technically different companies within the same company, but I was just curious if that's a possibility. 1055 Haga Joseph 07:29:37.180 --> 07:29:57.620 So I'll just say as some folks may know earlier this summer we launched our fixed fireless product AIA as we call it in house at and T- internet air and we have, I believe launched it in some areas across the country and we're doing a small launch to start. I failed that to. 1056 Haga Joseph 07:29:58.900 --> 07:30:18.100 Whether or not we decide to include other technologies in any of our bids, specifically for bid will impart depend on some of the requirements. I think are still under further consideration with NTIA. I have no folks talked earlier about not only having the speed requirements, but the latency requirements and the testing that will go along with that. 1057 Haga Joseph 07:30:18.180 --> 07:30:36.900 And we want to ensure that any product that we would offer through the federal program would be able to meet those requirements. So the short version is for lawyers out there it depends. So, but we certainly would be interested to have further conversations as we see more about the testing regime and other parts related to the beat program. 1058 Haga Joseph 07:30:39.860 --> 07:30:51.860 Does anybody from Comcast want to talk and if not, that's okay, it was just the reason why I'm asking the question is that is just from an ex- an expense standpoint. 1059 Haga Joseph 07:30:53.580 --> 07:31:12.700 Thanks for the question. You know, I think it, it would be totally project specific and geographic specific, but as far as a mix of technologies at Comcast could potentially include would also, you know, Comcast plans to build fiber, but to have the flexibility. 1060 Haga Joseph 07:31:13.820 --> 07:31:34.260 Where applicable to also consider line extensions of the HFC network, which already delivers one point two gigabits are down over thirty megabytes up and is rapidly advancing through our tangie initiative to. 1061 Haga Joseph 07:31:35.060 --> 07:31:54.740 Deliver multi- gigabit speeds through the existing HFC networks via Docus four point one technology. So, so yeah, I think it all depends, but, but building in flexibility to provide a hybrid build approaches. 1062 Haga Joseph 07:31:56.300 --> 07:32:00.740 Is not a bad idea. Okay, thank you. 1063 Haga Joseph 07:32:02.100 --> 07:32:04.780 Mr. Fitzpatrick, please go ahead. 1064 Leo Fitzpatrick he/him TURN - The Utility Reform Network 07:32:06.140 --> 07:32:25.740 Thank you, I just wanted to Identi. I just flag, you know, similar to the trap of focusing too much on where in terms of the threshold, especially at the expense of who, you know, I've heard a lot about economic analysis and cost models and belief believe me I've been looking at all the different propo. 1065 Leo Fitzpatrick he/him TURN - The Utility Reform Network 07:32:25.940 --> 07:32:46.220 Cost models very closely, but I would like to caution the commissions that on top of the fact that I think were the presentation did outline that, in addition to cost models, there's, you know, performance of task perf projects, you know, there's a whole CASF suite of projects that we. 1066 Leo Fitzpatrick he/him TURN - The Utility Reform Network 07:32:48.300 --> 07:33:06.700 But the commission could also potentially even look at the applications themselves, but did want to underscore that, you know, we need to also look at the, who we also need to make sure that communities are engaged and involved in the process and identifying, you know, their specific needs. I think Patrick brought up an interesting point in that regard. 1067 Leo Fitzpatrick he/him TURN - The Utility Reform Network 07:33:08.620 --> 07:33:27.180 You know, while we may debate about exactly what Resiliency should look like the, the state's efforts in the five year plan seems to hint that it's on the right track by considering resiliency and unfortunately Commissioner huck does not make your job any easier in terms of future proofs and timing. 1068 Leo Fitzpatrick he/him TURN - The Utility Reform Network 07:33:27.180 --> 07:33:47.660 I think we have to fold in something like Resiliency, you know, however, I think that's an important thing because when you combine that with say the open open access or middle mile aspects of that are projects that are permitted under the program, you know, I think that. 1069 Leo Fitzpatrick he/him TURN - The Utility Reform Network 07:33:47.660 --> 07:34:08.140 Really sets the stage potentially for the future proof networks that you were asking about, you know, you know, just, you know, you knowsa and we just want to make sure that a funded network doesn't go up in flames or gets washed away and it's available for people, you know, when they need it to survive in a disaster and the Stadian contact with emergency services. So I think. 1070 Leo Fitzpatrick he/him TURN - The Utility Reform Network 07:34:08.260 --> 07:34:28.620 It's an important factor and also some things that you, it appears to be built into the B program, but Marina can always correct me because I have probably not spent as much time looking at that document as she has, but thank you for the opportunity to provide a later comment on your question. 1071 Leo Fitzpatrick he/him TURN - The Utility Reform Network 07:34:28.700 --> 07:34:30.420 Commissioner Hug. 1072 Haga Joseph 07:34:31.820 --> 07:34:46.420 Thank you very much. Mr. Taku, did you have an additional appointment? Did you want to make? No, okay, sorry, I think that unless there's any other further comments I will turn it back to Commissioner help for closing comments. 1073 Haga Joseph 07:34:49.740 --> 07:35:08.300 So I just, again wanted to thank our staff for all of the work that they've done on this judge Googola, our, IT folks for putting this together so quickly and getting such a great excellent group of panelists together. I think we've covered a lot of different perspectives. I'm just really plea. 1074 Haga Joseph 07:35:08.300 --> 07:35:28.780 Pleased to see so many folks show up from different stakeholder groups that carriers the community based organizations rate payer advocates the counties, governmental entities. we really need all of your input and getting this, right? So thank you for, for being. 1075 Haga Joseph 07:35:28.940 --> 07:35:49.260 Here today for providing the information that you have, we look forward to seeing written comments Once the draft is out for your review and are taking into account what we've heard today and we'll be carefully reviewing all of the comments that we receive as we move forward with the process, we've got a lot of work to do and. 1076 Haga Joseph 07:35:50.780 --> 07:36:09.740 The next milestone will be getting the, the proposal out on the street for your review again, wanna thank everyone for being here for traveling to get here we have heard folks loved and clear. We need to do more community engagement. I personally committed to getting out in the community, at least one additional trip to the. 1077 Haga Joseph 07:36:09.900 --> 07:36:24.740 Area and went to Los Angeles. So thank you and then Miss Williams, you did an excellent job for being here last minute. So I just want to again, thank everyone for all of the contributions that, that you've made to today's workshop. 1078 Haga Joseph 07:36:27.020 --> 07:36:35.940 Thank you Commissioner. And just a couple other additional closing remarks related to next steps in this proceeding. 1079 Haga Joseph 07:36:37.900 --> 07:36:59.020 You know, we were working towards completing an initial proposal to be submitted to Ntia is part of that we will be doing a public comment period on these proposals and so you can expect some written comments, initial comments to be the sometime in November, once we publish at the end of November, sometimes we, after we publish and. 1080 Haga Joseph 07:36:59.020 --> 07:37:20.140 And then we'll also do some reply comments that will likely do in early December. You can feel free to include comments that you have regarding this workshop in your comments as well, want to know that there is a public participation hearing on November eighth at, there's actually going to be two- one at two P. M. and one. 1081 Haga Joseph 07:37:20.420 --> 07:37:40.620 Six PM and that's, that is all the information log on and participate participation information can be found online as a commissioner mentioned there are gonna be some additional listening sessions and opportunities to engage. So be on the lookout for those and the initial. 1082 Haga Joseph 07:37:40.620 --> 07:38:01.100 Proposal and all materials. The final that we submit to NTIS going to be due on December. Twenty- eighth to NPIA, you know, we don't, we don't know what the decision making timeline specifically is for NTIA, but we are imagining the proposed decisions on volume one and volume two will come around some time. 1083 Haga Joseph 07:38:01.780 --> 07:38:09.980 Q- one twenty- twenty- four, And then we'll be voted on after NTIA has approved that, that proposal. 1084 Haga Joseph 07:38:12.740 --> 07:38:23.140 Thank you so much. and we really appreciate your time in this long day and we're, I believe we are complete search for sure. 1085 Haga Joseph 07:38:25.460 --> 07:38:32.380 Commissioner a way drink perfect. Have a great evening. Everyone, thank you.