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CWA submits comments on NTIA’s implementation of the Digital Equity Act Programs

CWA submitted comments on NTIA’s implementation of the Digital Equity Act Programs. The Digital Equity Act provides $2.75 billion to states for initiatives that promote digital equity and inclusion and aim to ensure that all people and communities have the skills, technology, and capacity needed to reap the full benefits of our digital economy.

CWA’s comments urged the NTIA to require states to fully consult with all stakeholders in their communities as part of plan development, including with labor stakeholders: state labor federations; the unions representing telecommunications workers, educators, and public sector workers; and the labor representatives on workforce boards. 

CWA emphasized that short and long-term evaluation of the Digital Equity Plans should not just look at whether individuals in the covered population have basic access to broadband and connected devices but also evaluate whether this new access is resulting in measurable improvements to the quality of life, including health, education, and employment opportunities of the covered population. 

Furthermore, CWA warned that digital equity programs may not be as effective if they do not contribute to the creation of high quality career jobs in the communities that they intend to serve. CWA suggested that worker-centered pre-apprenticeship programs in information technology, broadband network operations, and other related fields could encourage youth and underemployed aging individuals from underrepresented communities to gain the digital skills needed to be workforce-ready and even become trained to serve as digital navigators in their own communities. For digital equity investments tied to workforce training, CWA recommended digital equity plans include an evaluation of program impact on participant wages, benefits, and job security. 

For grant programs that will create new staff positions and organizational infrastructure, CWA suggested that grantees be required to comply with fair labor practices, similar to the approach taken in the BEAD NOFO and the US Department of Transportation's RAISE grants NOFO. The role of “digital navigator,” and similar positions, should be considered on par with other public service jobs and come with high quality training, good wages and benefits, the right to form a union, and other basic hallmarks of quality jobs.


Comments of Communications Workers of America, Re: Digital Equity Act of 2021, Request for Comments, Docket No. 230224–0051, RIN 0660–XC055 (CWA, May 1, 2023)