The National Urban League's Approach to Digital Equity
Friday, April 16, 2021
The National Urban League's Approach to Digital Equity
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Round-Up for the Week of April 12-16, 2021
On March 31, the National Urban League released the Lewis Latimer Plan for Digital Equity and Inclusion, a collaborative work aimed at addressing the digital divide. If you have the time, follow the link above and give the full report a read. If not, here's the executive summary.
Ten years ago, the National Broadband Plan observed that as “more aspects of daily life move online and offline alternatives disappear, the range of choices available to people without broadband narrows. Digital exclusion compounds inequities for historically marginalized groups.” In light of these trends, that plan warned, “the cost of digital exclusion is large and growing.”
Unfortunately, only modest efforts to address those costs have been expended in the last decade. Now, as the COVID-19 pandemic accelerates a shift to “remote everything,” the costs of exclusion have grown even larger. The need for policymakers to act has become even more urgent, compelling us to ask, how can the tools of the information economy be employed to create a more equitable and inclusive society?
The answer lies in accomplishing four big, but achievable, goals:
- Deploying networks everywhere.
- Getting everyone connected.
- Creating new economic opportunities to participate in the growth of the digital economy.
- Using the networks to improve how we deliver essential services, in particular in workforce development, health care and education.
The National Urban League, working with other civil rights organizations and public policy experts, has commissioned the Lewis Latimer Plan for Digital Equity and Inclusion (the “Plan”), a detailed and comprehensive agenda to reach these goals and erase several persistent and dangerous gaps.
The Availability Gap
For millions of American homes, businesses and other enterprises, there is no available broadband network capable of allowing them to participate fully in 21st-century life. This is generally a rural problem, where higher capital costs are required to reach fewer customers. In sparsely populated areas of the country, private capital alone is unable to economically justify the investment needed to build high-speed broadband infrastructure. Currently, the federal government has not gathered the necessary data to accurately define and identify what constitutes an unserved area, nor does it have a good map of the locations where no networks are available. Further, the current system of subsidizing high-cost deployments is under significant stress, unable to fund the necessary build-out for many years, if not decades.
To Close the Availability Gap, the Plan recommends that Congress provide the FCC with sufficient appropriations to fund capital expenses necessary to deploy broadband networks to all Americans. The Plan also recommends that the FCC:
- Re-examine, based on network usage during the COVID-19 crisis, the performance standards below which an area is deemed unserved by broadband at home, and above which subsidized networks are required to perform in order to qualify for capital funding support;
- Produce an accurate map of broadband availability, pinpointing unserved by broadband services;
- Eliminate the Eligible Telecommunications Carrier (ETC) requirement, which disqualifies existing and future broadband providers who could otherwise deliver service quickly and efficiently;
- Produce a set of best practices for reducing deployment costs and times; and
- Hold a series of reverse auctions to allocate subsidies necessary to close the Availability Gap. These investments should be based on technology-neutral criteria, supporting a mix of solutions that can be rapidly deployed. Further, the FCC should adopt stronger guardrails for the short form process to examine more closely whether an entity seeking to bid has the actual technical, operational, and financial resources necessary to meet its commitments. Enterprises should not be allowed to bid on the basis of unproven technology.
In addition, the Plan recommends that the National Telecommunications and Information Administration (NTIA), which has information on its website about dozens of federal programs that support broadband deployment efforts, provide a search engine that enables stakeholders to more effectively find the programs that serve their needs, and, to the extent feasible, create a common application that enables those applying for funding from more than one program to save time and effort on the application process.
The Adoption Gap
Even among those Americans for whom a broadband network is available, there are still tens of millions who have not adopted broadband in their homes. Indeed, in terms of number of Americans affected, the Adoption Gap is approximately three times larger than the Availability Gap. There are two principal causes of the Adoption Gap. One is a lack of digital readiness. A second, and more significant cause, is the unaffordability of entry-level broadband services for a significant portion of the American population.
To Address Digital Readiness. Digital readiness refers to the skills and equipment needed to effectively use information and communications technology to find, evaluate, create, and communicate online. The lack of such skills is a significant barrier for certain demographic groups, hindering their ability to adopt and fully utilize broadband at home.
The Plan’s principal recommendation for addressing digital readiness is to create a national Office of Digital Equity to help coordinate training targeted to demographic groups with the lowest rates of adoption.
Among specific recommendations for the Office, the Plan proposes:
- Establishing a Digital Navigators Corps to help unconnected persons solve a wide range of adoption issues;
- Creating an Online Digital Readiness Portal to provide every American with access to free, age-appropriate curricula that teach digital skills and enhances digital readiness, offered in multiple languages; and
- Issuing reports on the effectiveness of different digital readiness strategies.
To Address Affordability. The principal government program addressing broadband affordability today is Lifeline, which provides a $9.25 monthly subsidy to qualifying low-income households for communications services. There is a broad consensus that Lifeline is deeply flawed, with too small a subsidy, ineffective distribution, and reliance for funding on an unsustainable model that is based on a regressive tax on traditional telephone services. Given these limits, Lifeline today is used almost exclusively for mobile, rather than in-home broadband services.
While mobile services have significant value, broadband at home creates better opportunities with enormous public benefits, benefits that today are not being captured. We all gain, for example, when the unemployed can train online for new careers, and use the same tools everyone else does to search, apply for, and interview for new jobs, getting them back in the workforce quickly. Likewise, everyone benefits when at-risk communities can receive telehealth at home, improving community health outcomes and lowering costs for government medical programs. Finally, everyone wins when all children have the tools to do their homework and engage in online learning in their homes, improving educational achievements.
To capture these benefits, the Lifeline program requires a substantial overhaul. The simplest solution, and the approach we favor, would be for Congress to appropriate funds for the FCC to create a permanent version of the Emergency Broadband Benefit that Congress passed earlier this year, which the FCC is currently implementing.
Alternatively, Congress could create a new program to address both mobile and broadband at home needs to assure access to essential government services for workforce development, healthcare, and education. While the program we propose would not have the simplicity—an important virtue in public policy design—of making the EBB permanent, it would have advantages in terms of distribution and cost savings.
The new program, which we call Lifeline+, would include a mobile benefit and a broadband a home benefit, which consists of three related programs:
- LifelineMobile, which would continue the current Lifeline subsidy for basic voice and mobile functions with some limited data, albeit with comprehensive reforms; and
- LifelineHome, composed of:
a. LifelineJobs, which would provide broadband at home to the unemployed, empowering them to utilize online programs to upgrade their skills, as well as search, apply, and interview for jobs;
b. LifelineMed, which would provide broadband at home to low-income persons, to utilize the full suite of telehealth services; and
c. LifelineEd, which would provide broadband at home to low-income families with K-12 schoolchildren and members of their households, to utilize all forms of digital learning.
All eligible families or individuals would be eligible for both the mobile and one broadband at-home benefit. Use of the broadband at home benefit would not be restricted so that regardless of the specific service, the person or family could use broadband for any purpose.
The Plan proposes that LifelineMobile and LifelineEd be funded by direct Congressional appropriations. LifelineJobs and LifelineMed should be funded through mandates added to existing government unemployment and medical insurance programs. Providing beneficiaries of these programs with broadband would, if properly designed, largely pay for itself in the form of savings to the delivery of critical services currently provided only through in-person activities.
Broadband provided through one of the LifelineHome programs will likely support several program goals. For example, approximately 70% of school children without broadband at home and who would be eligible for a benefit under LifelineEd are also covered by Medicaid, and would therefore already be eligible for LifelineMed. Providing broadband through Medicaid and other government health insurance plans would also improve the distribution of the benefit.
As with infrastructure support, the Plan recommends eliminating the ETC requirement for Lifeline service providers and recommends that support be provided directly to beneficiaries by any efficient means, such as a debit card, to enhance consumer control and choice and to reduce the possibility of waste and fraud. We note that the FCC will gain experience through the Emergency Broadband Benefit program, and such experience should inform any ultimate permanent broadband benefit.
The Access to Economic Opportunity and Participation Gap
Several decades ago, famed venture capitalist John Doerr said the personal computer industry’s growth from zero to $100 billion in 10 years was “the greatest legal accumulation of wealth in history.” Subsequently, he had to amend his comment. Noting that the Internet dwarfed the PC revolution by going from zero to $400 billion in five years, Doerr said “There are waves and then there is a tsunami.” That tsunami has continued. Today the top five American companies by market capitalization (Microsoft, Apple, Amazon, Alphabet, and Facebook) all rode the tsunami Doerr described.
Unfortunately, opportunities for wealth accumulation are not equitably distributed. Jobs, especially the higher-paying jobs in the technology industry, have not been filled by Blacks and Latinxs in any significant way. The National Urban League’s 2018 State of Black America Report found that of the 40,000 employees of four major Silicon Valley technology firms, only 1,000 were Black; the number for Latinx is paltry. Moreover, business inclusion and opportunity in the growing tech sector have lagged miserably for Blacks and Latinx.
This is not a new problem. The person for whom this Plan is named, Lewis Latimer, was a free Black patent-holder and the son of slaves, whose achievements were critical to the success of his employers, Thomas Edison and Alexander Graham Bell. Unfortunately, but typically, while Latimer was a key contributor to Edison’s and Bell’s seminal wealth-creating inventions, he had no ownership stake in the vast businesses they spawned.
We need to break that historic pattern. While much of the Latimer Plan is focused on assuring that all Americans, regardless of race, income, or location, have the tools and skills to fully participate in the economy and society of the 21st Century, we also want to close gaps that limit opportunities to participate meaningfully in the business of value creation as broadband and broadband-enabled enterprises continue to innovate, grow, and prosper. We must also ensure that job opportunities are available for the country’s growing Black and Latinx communities at every level in the technology and technology-related business sectors.
The causes of limited access to economic opportunity and inclusion are complex, but the gap can be closed with public and private intention, leaving our nation stronger, more equitable, and more prosperous. In truth, this gap was created by legal and historic barriers to capital access and legal barriers to full citizenship and opportunity. In the last decades of the 20th century, government and industry began to address some of these barriers, but these efforts lack sustainability or face legal challenges that raise the specter of “reverse racism.” The televised murder or George Perry Floyd, Jr. and the Black Lives Matter movement have prompted a renewed interest in a holistic government response and intentionality by many corporations to close the economic opportunity and participation gap. Corporate America, in a number of ways, has accepted accountability to ingrain diversity, equity, and inclusion into their corporate DNA, including creating racially and gender diverse corporate boards, staffing, C-suites, procurement, philanthropy, and community investment.
Civil rights organizations, led by the National Urban League, have pioneered the negotiation of written memorandums of understanding with several communication companies to set forth goals, timetables, and initiatives to achieve greater diversity, equity, and inclusion. As a nation, we should move forward with new vigor and intentionality in utilizing these techniques to drive towards greater economic opportunity for those who have historically been left behind.
To close the economic opportunity and participation gap, industry, government, and community organizations must work together to improve and increase commitments to racial equity in corporate board membership, staffing, the C-suite, procurement, philanthropy, and community investment. To facilitate this collaboration, the Plan recommends:
- Infrastructure. As part of any future infrastructure legislation, Congress must include mandates for companies that will directly benefit from increased federal investment in infrastructure to improve their performance in providing access to economic opportunity and participation in the categories noted above.
- Measure Diversity. The Department of Commerce and the FCC should collect information that allows the government and the public to understand and evaluate how the private sector, and the technology and related sectors in particular, are improving economic opportunity and participation in the categories noted above.
- Incentivize Diversity. The Department of Commerce, the FCC, the Small Business Administration, and the Securities and Exchange Commission should evaluate annually and report to Congress on measures that could be adopted to enhance the performance of private enterprise in improving economic opportunity and participation in the categories noted above.
- Highlight Sustainable Success. The Department of Commerce, the FCC, the Small Business Administration, and the Securities and Exchange Commission should publish an annual report on best practices for enhancing the performance of private enterprise in improving economic opportunity and participation in the categories noted above.
The Utilization Gap
Deploying networks everywhere and assuring that everyone has the skills and means to connect are necessary first steps. But they are not sufficient to achieve digital equity and inclusion. We also need to increase the utilization of digital platforms, which requires substantial improvement to essential government services offered online. The COVID-19 crisis has forced our economy and society to run a massive—if unplanned—experiment in “remote everything.” While that experiment has produced some positive trends, including greater utilization of telehealth, it has also shown that we have a long way to go in other areas, such as education. We need to be more intentional in developing new capabilities, to assure that they lift up, rather than disadvantage, low-income persons and communities of color. The Plan details recommendations on policies that can, in conjunction with universal availability and adoption, improve the delivery of essential services.
To Address Workforce Development. Governments should improve digital tools that enable people interested in every job type to upgrade their skills and to search, apply, and interview for jobs, and ensure that small businesses can use broadband-based tools to improve their prospects. The Plan makes several recommendations, including:
- The White House and Congress should expand access to digital resources and technical assistance for enterprises located in rural areas and among communities of color;
- The Department of Labor should develop more broadband, technology, and communications sector-related registered apprenticeship training programs;
- The federal government should provide incentives for companies, states, municipalities, nonprofit organizations, and the private sector to create and scale new workforce development and digital skills training programs;
- Federal agencies should increase and improve data collection related to workforce development; and
- States should modernize their unemployment benefits systems to more effectively offer unemployed citizens access to opportunities for future employment.
To Address Health Care. With healthcare services are increasingly provided online, government must assure that everyone has access to user-friendly, health-enabling tools that connect them to high-quality, affordable health services and medical information they can understand. To do so, the Plan recommends that federal and state governments act to reduce disparities in access to health care services by:
- Adopting consistent policies across state Medicaid programs;
- Removing geographic and originating site restrictions;
- Removing limitations on eligible services, providers, and facilities, and removing unnecessary restrictions on practitioners eligible to provide telehealth services; and
- Funding programs supporting digital health care infrastructure and technical assistance, digital health literacy, and workforce diversity.
In addition, the Plan recommends:
- The Department of Health and Human Services should allocate funding to develop, recruit, and retain health care professionals from underrepresented groups; and
- The FCC should modify the Connected Care Pilot Program and the Telehealth Program to focus more on improving health outcomes for low-income communities and communities of color.
To Address K-12 Education. Technology is creating a new educational infrastructure with a vast expanse of new, diverse, and relevant opportunities. Unfortunately, uneven implementation of these technologies is widening rather than narrowing existing gaps in educational outcomes. We must assure that new educational infrastructure provides all students with equal access to the tools and content of fast-evolving digital learning. Further, we need to provide teachers the support they need to enable students to maximize the value of digital content. To do so, the Plan proposes to:
- Ensure students have support for digital learning from teachers and other appropriately trained adults, such as online tutors;
- Invest in a federal research and development agenda focused on advancing new models of technology-empowered teaching and learning that promote equity and improve outcomes for all students;
- Invest in culturally responsive and relevant online learning tools;
- Reform funding systems to ensure adequate and equitable distribution of resources, particularly to advance digital learning;
- Improve access for students of color and others to educational experiences that improve their ability to utilize technology; and
- Develop a National Strategic Agenda for Education Technology Research & Development, focused on improving outcomes for students of color.
To Address Higher Education and R&D. Colleges and universities, with some of the best broadband networks in the world, remain an underutilized resource for digital equity and inclusion. We also underfund research and development in improving teaching and training. To address those shortfalls, the Plan recommends:
- Using university resources to help institutions servicing those who have been disadvantaged by failings of digital equity and inclusion;
- Focusing future research on understanding how digital education can improve outcomes and overcome persistent performance gaps;
- Understanding and promoting best practices for using digital education to build a more equitable and inclusive society; and
- Increasing efforts to identify, develop, test, and deploy applications of digital educational technologies that foster economic and social mobility.
To Address Government Services. Low-income and minority communities would benefit significantly from greater online access to government services. Many government information systems, however, are outdated. Further, budget gaps lead to failures in upgrading and maintaining digital infrastructure. Overall, governments must systematically improve their ability to use technology to deliver services. To address these issues, the Plan recommends that federal, state, and local governments:
- Optimize government websites for mobile use;
- Establish a one-stop-shop for citizens to access and control personally identifiable information held by government agencies; Improve automated online government customer support;
- Take steps to eliminate data poverty, the social and economic inequalities that result from a lack of collection or use of data about an individual or community:
- Require all government forms be provided digitally for data entry, signing, and submission; and
- Modernize and secure existing government systems, and facilitate low-contact and remote access to government websites and services.
To Address Civic Engagement. Failings of digital equity and inclusion limit many Americans from full engagement in the political and civic lives of their communities. Misinformation is overwhelming accurate information and poisoning the digital conversation, particularly for communities of color. Online platforms have created new problems related to microtargeting in advertising, algorithmic bias, digital redlining, and other uses that make the Internet problematic for communities of color. To address these problems, the Plan recommends that:
- Hold a series of civil rights-focused hearings with high-level executives from companies that have been major repositories of disinformation;
- Increase investment in reliable, relevant, and trusted information for underserved communities by grants through the Corporation for Public Broadcasting to local noncommercial stations, for journalism by and for underserved communities; and
- Restore funding to the Office of Technology Assessment.
The White House
- Impanel a commission to study how information on COVID-19 was made publicly available, how this information affected societal response, and what should be done to limit the impact of false and dangerously misleading information moving forward, while preserving First Amendment rights and values;
- Promote the establishment of a private industry-led information accuracy certification body.
The Federal Trade Commission
- Establish social media best practices;
- Propose recommendations with respect to limiting the potential damage of political microtargeting; and
- Mandate real-time ad transparency and access to archives.
Achieving digital equity and inclusion requires a sustained, systemic, and appropriately resourced effort that is highly reliant on intergovernmental coordination and collaboration. Currently, policymakers do not have the tools or data to monitor and evaluate efforts to close the gaps identified in the Plan. To address these needs, the Plan recommends that the federal government:
- Examine biases that could affect its existing collection, analysis, and interpretation of data;
- Collect the data necessary to review the use of government information and digital services by each population it serves, and track how constituents interact with each agency;
- Partner with state and local governments to collect relevant data, including as part of efforts to expand broadband availability, adoption, and utilization carried out at the local level; and
- Convene an annual National Digital Inclusion Summit to review progress, determine key barriers to progress, and adjust policies, as necessary.
While the COVID crisis appears to be ending, the need for digital equity and inclusion is not. Indeed, the economic and societal trends the health crisis accelerated make the task more urgent. We need a surge of government action that produces sustainable results.
A Note on the Authors
The Latimer Plan was a collaborative effort headed by Edward “Smitty” Smith, a partner at the firm DLA Piper, who served as the Senior Director of the Plan. The list of contributors reads like the introduction of the 2020-21 broadband all-star team:
- Blair Levin, Senior Non-Resident Fellow, Brookings Institution, Metropolitan Policy Project, who oversaw the development of the Federal Communications Commission's 2010 National Broadband Plan
- Larry Downes is the author of five books on the impact of technology on business, society, and the law. Downes has held faculty appointments at The University of Chicago, Northwestern University, and the University of California—Berkeley, where he was Associate Dean of the School of Information.
- From 2015-2019, he was Project Director at the Georgetown Center for Business and Public Policy at the McDonough School of Business.
- Paul de Sa is a co-founder of Quadra Partners, an advisory firm. He was part of the leadership team at the FCC from 2009-12 and 2016-17, serving as Chief of its Office of Strategic Planning, with a focus on merger reviews, broadband, and spectrum policy. De Sa also participated in writing the FCC's National Broadband Plan.
- Carol Mattey of Mattey Consulting has over 30 years of experience as a senior executive in the U.S. government, consultant and lawyer focusing on communications public policy. From 2010 to 2017, Carol was Deputy Chief of the Wireline Competition Bureau at the Federal Communications Commission, focusing on the FCC’s ongoing initiatives to reform over $9 billion in annual federal spending known as the Universal Service Fund, which supports broadband connectivity for rural areas, schools, libraries, healthcare providers and low-income consumers.
- John B. Horrigan, PhD, is a frequent contributor to Benton's Digital Beat and a Senior Fellow at the Technology Policy Institute, with a focus on technology adoption, digital inclusion, and evaluating the outcomes and impacts of programs designed to promote communications technology adoption and use. He served at the FCC as a member of the leadership team for the development of the National Broadband Plan.
- Angela Siefer is Executive Director of the National Digital Inclusion Alliance, a unified voice for home broadband access, public broadband access, personal devices, and local technology training and support programs.
- Melissa Turcois is an associate at DLA Piper, a global law firm
- Marcella Gadson is Manager of Communications and Policy at CTIA, which represents the U.S. wireless communications industry
- Kerry McDermott, MPH is a strategy and communications professional who helps public and private entities navigate the complex healthcare landscape
- Steve Midgley, Elise Kohn, and Whitney Whealdon of Learning Tapestry, which provides innovation and infrastructure solutions to support learners and educators
- Derek Mitchell of Partners in School Innovation, which helps urban schools and districts address their most pressing challenges
- Lev Gonick, Chief Information Officer, Arizona State University
- Rob Atkinson and Daniel Castro of the Information Technology and Innovation Foundation, which focuses on the intersection of technological innovation and public policy
- Professor Matt Perault and his Duke University class on technology policy, including Mihir Bellamkonda, James Eide, Lee Foster, Charlie Graham, Zachary Silverman Guffey, Abdur Rehman, and Niharika Vattikonda
- FCC Encourages Public to Use Its Speed Test App (FCC)
- JP Morgan digs into broadband competition via service overlap (Seeking Alpha)
- New York Mandates $15-a-Month Broadband for Low-Income Users (Syracuse.com)
- You May Have Internet Access, But Millions Do Not (Essence)
- The Future of Tech Commission (Politico)
Weekend Reads (resist tl;dr)
- State-by-State Fact Sheets Highlight Nationwide Need for the American Jobs Plan (White House)
- Municipal Broadband Is Restricted In 18 States Across The US In 2021 (BroadbandNow)
- California Broadband for All (California Broadband Council)
- 2020 Pandemic Network Performance (Broadband Internet Technical Advisory Group)
ICYMI from Benton
- Recommendations for a National Broadband Agenda
- Contributions to a National Broadband Agenda
- Broadband for America Now
- Broadband for America’s Future: A Vision for the 2020s
- Does America Want to Invest in Broadband?
Apr 19—Connecting the Heartland (Heartland Forward)
Apr 20—Strengthening the Federal Trade Commission’s Authority to Protect Consumers (Senate Commerce Committee)
Apr 20—Listening Session to Help Expand Broadband Access in Tribal Communities (Department of Agriculture)
Apr 21—Leading the Wireless Future: Securing American Network Technology (House Commerce Committee)
Apr 21—Emergency Broadband Benefit Webinar for Consumer Groups (USAC)
Apr 21—NTIA Grant Program: Tribal Broadband Connectivity Webinar, Session 1a (National Telecommunications and Information Administration)
Apr 22—April 2020 Open Commission Meeting (FCC)
Apr 26—National Supply Chain Integrity Joint Workshop (FCC)
Apr 26 & 27—USAC Board Meeting (Universal Service Administrative Company)
Apr 29—Bringing Dark Patterns to Light: An FTC Workshop (FTC)
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