Communities of Concern (CoCs) experience stark disparities in access to robust, affordable broadband. While 53,000 households in the City of San Diego lack home internet (ACS 2014- 2018), in low-income areas or CoCs hardest hit by the pandemic such as the San Diego Promise Zone, over 28% of households report having no broadband internet access whatsoever. Many of these neighborhoods experience digital redlining, described by the National Digital Inclusion Alliance as “discrimination by internet service providers in the deployment, maintenance, or upgrade of infrastructure or delivery of services.” Importantly, the CEI factors in broadband access data as a key indicator.