Based upon NDIA’s digital redlining maps and on behalf of 3 residents of Cleveland and 2 residents of Detroit, Attorney Daryl Parks filed FCC complaints against AT&T alleging discrimination. AT&T and Attorney Parks have agreed to mediation by the FCC. NDIA is not a party to this complaint. More info here.
Since the mediation is restricted, we cannot file comments with the FCC. Thus, NDIA has sent a letter to AT&T and Attorney Parks expressing our recommendation: AT&T should agree to take whatever steps are necessary, including additional deployment of fiber and other infrastructure, to ensure that it can offer Internet service to any Cleveland or Detroit household at speeds of at least 25 mbps downstream and 3 mbps upstream.

27 organizations signed on to the letter.

The following quote can be attributed to myself, Angela Siefer, Executive Director of NDIA.

The only acceptable result of mediation between AT&T and Attorney Parks is a commitment by AT&T to deploy broadband infrastructure with a minimum of 25 mbps upload and 3 mbps download speeds. Without competition, internet service is unaffordable for many of our neighbors. This is what has happened in Cleveland and Detroit. Ultimately, every community that has been digitally redlined needs an infrastructure commitment.

Here is a PDF of the letterNDIA Letter to AT&T and Parks 10-30-17. And here are the contents of the letter:

The National Digital Inclusion Alliance (NDIA) and partner signatories appreciate the FCC Staff’s offer of mediation of two digital redlining complaints against AT&T, brought by Attorney Daryl Parks on behalf of complainants in Cleveland and Detroit. We also appreciate AT&T’s agreement to participate. (See FCC Docket No. 17-223 and 17-270 and Joint Statement of the Parties posted 10-4-17.)

Attorney Parks and his clients, complainants Joanne Elkins, Hattie Lanfair, Rachelle Lee, Edward Garner Taylor, Esq. and Ray Taylor, have raised significant issues of law and basic equity affecting hundreds of thousands of households in Cleveland and Detroit, and millions across AT&T’s wireline service territory. We are grateful to these individuals for taking a stand on behalf of their neighbors and communities.

AT&T’s broad, decade-long pattern of discrimination against low-income neighborhoods in its deployment of fiber-enhanced broadband technologies, as documented in the complaints, can be remedied if the company is willing to undertake a serious effort to do so. We hope AT&T’s acceptance of mediation shows a willingness to discuss what such an effort would entail.

On behalf of our 281 affiliate organizations and the other signatories, the National Digital Inclusion Alliance respectfully submits the following suggested framework for a reasonable, accountable resolution of the complaints. Since the complaints were filed on behalf of complainants in Cleveland and Detroit, we limit our suggestions to those two cities.

Recommendation: AT&T should agree to take whatever steps are necessary, including additional deployment of fiber and other infrastructure, to ensure that it can offer Internet service to any Cleveland or Detroit household at speeds of at least 25 mbps downstream and 3 mbps upstream. To meet this goal, we suggest the following:

  • A detailed plan describing specific new deployments of fiber and other infrastructure, should be submitted to the FCC and Attorney Parks within 6 months of the mediated agreement.
  • New deployments covered by the plan should be 50% complete within 18 months of the mediated agreement.
  • New deployments covered by the plan should be 100% complete within 3 years of the mediated agreement.
  • Degree of completion should be measured as the percentage of residential addresses which could not receive AT&T Internet service at 25/3 mbps as of December 31, 2017, for which such service has become available.
  • Beginning three years after the mediated agreement, for each year deployment is not complete, AT&T should donate $10 million each to foundations (agreed upon by both Attorney Parks and AT&T) in each city to support broadband access and adoption.

Please do not hesitate to contact us if we can be of any assistance to your efforts.

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