ACLP Comments to the California PUC Regarding Broadband Adoption Trends

The ACLP recently filed comments with the California PUC (CPUC) addressing broadband adoption trends in the state. The filing came in response to a request for input by the Commission on a CPUC-authored Home Broadband Adoption Report released in April 2025. The CPUC appears poised to use the findings of the Report to support a proposed LifeLine “pilot program to enable affordable home broadband for low-income Californians.”

The CPUC’s View of Broadband Adoption

In the Report, the CPUC used data from a variety of sources to make four related arguments about broadband adoption in the state:

1. Broadband service in California is too expensive.
2. Broadband adoption is lagging in California because too many people cannot afford broadband.
3. Home broadband networks that leverage terrestrial fixed wireline connections (e.g., cable, fiber) are the only connections that adequately address consumers’ data needs.
4. The best way to address lagging broadband adoption is by offering subsidies via the state’s LifeLine program.

In its comments, the ACLP argued that none of these arguments is supported by compelling data. To the contrary, for each point, the ACLP demonstrated that there is much more to the story than what is included in the Commission’s Report.

What the Data Really Say About Broadband Adoption in California and Beyond

In particular, the ACLP noted that the CPUC Report offered only a narrow interpretation of handpicked data sources to support an overarching – and seemingly predetermined – conclusion: that Commission action is needed to narrow broadband adoption gaps by making service more affordable. In reality, however, this simplistic calculus – that lower prices will, on their own, yield higher broadband take-rates – has failed to generate promised adoption gains because it overlooks the myriad non-price factors that influence whether individuals will choose to invest the time and resources needed to go online.

The ACLP’s comments draw on data from a variety of sources to tell a different story about broadband adoption, one that reflects real world trends.

First, the comments address the Commission’s flawed interpretation of the relationship between how much broadband costs, whether service is “affordable,” and how consumers decide whether to adopt a particular service offering.

Second, the ACLP responds to the Report’s implication that only a certain kind of high-speed internet connection – i.e., wireline access delivered to homes – counts for broadband adoption purposes and argues that, given clear consumer trends and marketplace developments, the Commission should embrace a broader view of broadband adoption, one that includes widespread use of and preference for competitive alternatives like fixed wireless and mobile broadband.

Third, the comments end with the ACLP urging the Commission to think more holistically about how it and other stakeholders in the public, private, and nonprofit sectors should address broadband adoption gaps.

These comments echo points made by the ACLP on several occasions in the recent past, most notably in testimony before the New York City Council. The ACLP continues to encourage policymakers at every level of government, but especially those at the local level, to focus less on trying to make broadband “affordable” – prices continue to drop; consumers can access a variety of low-cost offerings from myriad ISPs – and more on increasing the value proposition to the many digital holdouts who do not view broadband as useful or relevant to their lives.