RESOURCE: Recommendations to Prevent Digital Discrimination

The FCC has published Recommendations and Best Practices to Prevent Digital Discrimination and Promote Digital Equity. It’s a work from people on the frontlines after doing interviews and research. They have boiled it down to a series of recommendations – with greater explanation in the report than I have recreated here. I have highlighted the recommendations that struck a chord with me. For example, number 6 on the first list focused on ISPs: encourage competition. Because so much broadband expansion is funding, at least in part, by federal grants and loans, it seems practical to reconsider at how those are funded to encourage competition rather than focus on supporting one provider in any given area.

DEI Working Group Recommendations for Model Policies and Best Practices That Can Be Adopted for States and Localities to Prevent Digital Discrimination by ISPs:

  1. Develop, implement, and make publicly available periodic broadband equity assessments in partnership with ISPs, the community, and other local stakeholders.
  2. Facilitate greater awareness and information sharing among multi-dwelling unit owners regarding tenant choice and competition considering broadband service agreements.
  3. Identify local opportunities that could be used to incentivize equitable deployment
  4. Engage, where permissible under state and federal law, in the management of public property, such as public rights-of-way, to avert discriminatory behaviors that result in or sustain digital discrimination and redlining.
  5. Convene regular meetings of broadband providers and other stakeholders, including community anchor institutions, public interest groups, community advocates, labor organizations, and faith-based institutions, to evaluate areas and households unserved or underserved with competitive and quality broadband options.
  6. Encourage fair competition and choice.

DEI Working Group Recommendations to Support Digital Equity:

  1. Make low-cost broadband available to low-income households through government benefit programs, in combination with internet service providers’ low-income programs.
  2. Build on the success of existing benefit programs that allow low-income households to apply a credit to an internet service of their choice.
  3. Raise awareness about connectivity programs for programs among eligible households.
  4. Strengthen marketing and communications about available federal and state connectivity programs and other programs that target low-income or other unconnected members of a community.
  5. Streamline the application process for government benefit programs referred to above.
  6. Increase support and funding for organizations such as schools, nonprofits, and faith-based organizations to provide digital navigation assistance in communities they serve.
  7. Fund, promote and leverage the use of digital navigators.
  8. Stakeholders should encourage Congress to create a digital public service and engagement program (e.g., digital navigators), which could conduct trainings and outreach in non-adopting communities.
  9. Increase device access and participation.
  10. Use public-private partnerships to facilitate remote learning and close the homework gap.
  11. Ensure that members of the community have safe spaces to access the internet.
  12. Strengthen digital skilling efforts in underserved communities.
  13. Encourage the creation of workforce development/training opportunities, focusing on historically underrepresented communities.

I&A Working Group Recommendations (Part Two):

  1. Adopt definitions of small minority- and women-owned (SMW) businesses.
  2. Designate a government-wide office to oversee supplier diversity initiatives, including the creation of an annual plan to increase supplier diversity.
  3. Adopt an accountable goal of no less than 30% participation of SMW businesses in state and local infrastructure grant and contract opportunities and provide incentives to first-tier contractors to partner with SMW businesses. 17
  4. Include auditing and in-progress reporting in the contracts/subgrants; implement thoughtful auditing, in-progress reporting, real-time accountability, and enforcement to ensure that SMW goals are met.
  5. The grantees, working in conjunction with the supplier diversity office, should proactively identify contracting and procurement forecasts and needs.
  6. Ensure diverse participation in task forces or committees that advise grantees on their broadband plans, including broadband supplier diversity.
  7. Promote certifications prior to disbursement of funds so that SMW businesses are prepared to participate in the funding opportunities.
  8. Grantees, subgrantees, and contractors should be required to reach out to SMW businesses.

D&E Working Group Recommendations (Part Three):

  1. The Commission needs to examine and expand the definition of “equal access” to facilitate greater adoption and use of high-speed broadband, especially among populations experiencing a range of inequalities resulting from a protected characteristic, or an intersection of various attributes or social determinants that limit their full digital engagement.
  2. The Commission should play a more active role in promoting the relevance of highspeed broadband among populations where broadband can improve quality of lives and increase consumer demand for more equitably deployed broadband services.

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