Meters within the City’s water system allow the City to compare current water demands with demand reduction goals and adjust its shortage response actions accordingly. The City water system is fully equipped with meters which can be read remotely. The City’s Advanced Metering Infrastructure (AMI) system is complete and can provide real time water use data that allow the City to track the effectiveness of its response actions. A customer portal is planned in the future to provide users with information to actively manage their water use.
Water production and water use can be compared to previous periods. This continuous monitoring allows the City to assess water system demands and compare it with its water demand reduction goals. The City may then adjust its shortage response actions as needed to balance demands with available water supplies, based on observed system conditions and customer response, without seeking additional authorization or revision to this WSCP. For example, the City may intensify its public outreach or more vigorously enforce compliance with water use prohibitions if needed water demand reduction goals are not met for any specific shortage level. Conversely, the City may reduce public outreach frequency or adjust compliance actions if demand reduction goals are exceeded.
The shortage response actions discussed in the following sections may be considered as tools that allow the City to respond to water shortage conditions. Shortage response actions are initiated at the shortage levels shown and continue to be implemented at higher shortage levels. Because the City may continuously monitor and adjust its response actions to reasonably equate demands with available supply, the extent to which the gap between water supplies and water demand will be reduced by implementation of each action is difficult to quantify and is provided as an estimate. Certain response actions, such as public outreach and enforcement, support the effectiveness of other response actions and do not have a quantifiable effect on their own.
5.1 Demand Reduction Actions
During water shortage conditions, the City plans to reduce demand by implementing the actions shown in Table 3. Demand reduction actions are organized by the triggering water shortage level, and each action includes an estimate of how much its implementation will reduce the shortage gap. For each demand reduction action, Table 3 also indicates if the City uses compliance actions such as penalties, charges, or other enforcement. The corresponding DWR submittal table is provided in Appendix B.
Demand reduction actions are initiated at the shortage levels shown and will continue to be implemented at higher shortage levels.
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Table 3. Demand Reduction Actions (DWR Table 8-3 Retail) Shortage
Level Demand Reduction Actions
How much is this going to reduce
the shortage gap?
Additional Explanation or
Reference
LMC Reference
(if applicable)
Penalty, Charge, or
Other Enforcement?
(Yes or No)
0 Other - Customers must repair
leaks, breaks, and malfunctions in a
timely manner
Not readily quantifiable
Required at all times; maintenance
of water pipes and prohibition
on leaks.
LMC §13.04.410 Yes
0 Landscape - Restrict or prohibit
runoff from landscape irrigation Not readily quantifiable Unreasonable or wasteful runoff prohibited. LMC §13.04.440 Yes 0 Other - Require automatic shut
of hoses
Not readily quantifiable. City has
permanent ordinance which
prohibits watering of lawns and
gardens with an open hose
Open-hose watering prohibited. LMC §13.04.420 Yes
0 Water Features - Restrict water use
for decorative water features, such
as fountains
Boosts the effectiveness of other
methods - not readily quantifiable
Decorative fountains without
recirculating systems prohibited. LMC §13.04.430 Yes
1 Pools and Spas - Require covers for
pools and spas
Evapotranspiration of approximate
surface area of pools - - Yes
1 Other - Customers must repair
leaks, breaks, and malfunctions in a
timely manner
Boosts the effectiveness of other
methods - not readily quantifiable
Water leaks shall be repaired
within five days or sooner if
required by the City.
LMC §13.04.430 Yes
1 Water Features - Restrict water use
for decorative water features, such
as fountains
Boosts other methods as a public
display of drought conservation.
Not readily quantifiable
Operation of ornamental fountains
without a recirculating system is
prohibited.
- Yes
1 Landscape - Restrict or prohibit
runoff from landscape irrigation
Not readily quantifiable. City has
permanent ordinance which
prohibits runoff of water in
unreasonable amounts
- - Yes
1 Landscape - Other landscape
restriction or prohibition
Not readily quantifiable.
Dependent on number of
precipitation events
Outdoor irrigation shall not occur
during precipitation events or
within 24 hours following a rain
event of 0.20 inches or more.
LMC §13.04.430 Yes
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Table 3. Demand Reduction Actions (DWR Table 8-3 Retail) Shortage
Level Demand Reduction Actions
How much is this going to reduce
the shortage gap?
Additional Explanation or
Reference
LMC Reference
(if applicable)
Penalty, Charge, or
Other Enforcement?
(Yes or No)
1 CII - Other CII restriction or
prohibition
Boosts other methods as a public
display of drought conservation.
Not readily quantifiable
Hotels, motels, and other lodging
establishments shall post a Notice
of Drought Condition approved by
the Director of Public Services.
- Yes
1 CII - Restaurants may only serve
water upon request
50 gal/day/commercial connection - - Yes
2 Landscape - Limit landscape
irrigation to specific times
Depends on times that irrigation
will be allowed, but can reduce
water use by 20-25 gallons per
day per household
Outdoor irrigation is prohibited
between 8:00 AM and 9:00 PM. - Yes
2 Landscape - Limit landscape
irrigation to specific days
22 percent reduction in irrigation
demands
Outdoor irrigation of ornamental
turf limited to no more than two
days per week; allowable days set
by the City.
- Yes
2 Other - Prohibit use of potable
water for washing hard surfaces
Boosts other methods - not readily
quantifiable - - Yes
3 Water Features - Restrict water use
for decorative water features, such
as fountains
Boosts other methods as a public
display of drought conservation.
Not readily quantifiable.
Operation of all ornamental
fountains is prohibited. - Yes
3 Landscape - Other landscape
restriction or prohibition
Boosts the effectiveness of other
methods - not readily quantifiable
Planting or seeding of new
ornamental turf is prohibited. - Yes
3 Landscape - Limit landscape
irrigation to specific days
33 percent reduction in
irrigation demands
Outdoor irrigation of ornamental
turf limited to no more than three
days per week; allowable days set
by the City.
- Yes
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Table 3. Demand Reduction Actions (DWR Table 8-3 Retail) Shortage
Level Demand Reduction Actions
How much is this going to reduce
the shortage gap?
Additional Explanation or
Reference
LMC Reference
(if applicable)
Penalty, Charge, or
Other Enforcement?
(Yes or No)
4 Other water feature or swimming
pool restriction
Boosts the effectiveness of other
methods - not readily quantifiable
Introduction of water into
swimming pools and spas is
prohibited except to maintain
structural integrity of such facilities.
- Yes
4 Other - Prohibit vehicle washing
except at facilities using recycled or
recirculating water
100-200 gal/year/residential
connection - - Yes
5 Landscape - Prohibit certain types
of landscape irrigation
90 percent reduction in irrigation
demands
Irrigation of yards or other
landscaped areas containing lawn
or turf grass is prohibited. Irrigation
of trees is allowed.
- Yes
6 Other Up to shortage gap Potable water to be used for health and safety purposes only. - Yes
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5.2 Additional Mandatory Restrictions
In addition to demand reduction actions, the City has the mandatory water restrictions set forth in the LMC Chapter 13.04 Article VI found in Appendix A. Under water shortage Levels 1 through 6, certain uses of water may be restricted in accordance with the LMC.
The specific mandatory restrictions applicable during each water shortage level are maintained in the LMC and may be updated periodically. The WSCP relies on the LMC to define enforceable water use restrictions and does not duplicate ordinance language, ensuring that the most current requirements are always in effect. The City plans to update LMC Chapter 13.04 concurrently with adoption of this WSCP.
In addition to shortage-level restrictions, baseline water conservation requirements are continuously in effect under LMC Chapter 13.04 Article VI, regardless of water shortage conditions. These requirements generally address water waste, inefficient water use practices, maintenance of plumbing fixtures, irrigation practices, and other activities intended to prevent unnecessary water loss. These local restrictions are in addition to State mandated prohibitions. The City will enforce both State-mandated prohibitions and local water use restrictions as authorized by the LMC.
5.3 Supply Augmentation and Other Actions
The City’s water supply portfolio consists of surface water supplies from PCWA and NID supplemented by local groundwater and recycled water, as described in Chapter 6 of the City’s UWMP. The City manages the use of surface water supply conjunctively with the local groundwater. The City uses recycled water to reduce potable water demands from irrigation and industrial processing. During normal conditions and at any water shortage stage, depending on the water shortage event, the City’s water supplies will be used to complement each other. For example, should its surface water supply from wholesalers be reduced, the City may increase its groundwater pumping.
Should the City’s water supply portfolio be insufficient to meet the reduced demands of its customers, the City may augment its water supply and take other actions as summarized in Table 4. The City may also evaluate potential future supply augmentation options, such as additional regional interties or participation in regional water supply projects, to help mitigate potential shortage gaps. The shortage stage level for which each action will commence implementation is provided, along with the estimated extent that the action will reduce the shortage gap.
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13 Table 4. Supply Augmentation and Other Actions (DWR Table 8-2 Retail)
5.4 Locally Appropriate Operational Changes
The City may modify its operations on a short term or long term basis in response to any water shortage condition. The City may take any one or a combination of the following actions. • To facilitate supply augmentation, the City may operate any combination of groundwater wells to address shortages in surface water supplies.
• The City may expedite repairs of leaks in its water distribution system. Leak repairs will be prioritized based on severity and operational considerations to minimize water loss and maintain system reliability.
• During the duration of the water shortage condition, the City may limit maintenance water system flushing operations such that flushing is conducted only in areas with known water quality issues.
The City may also elect to implement operational measures to support implementation of the WSCP. This may include hiring temporary workers, reassigning staff, and/or increasing overtime to provide staffing for a range of efforts, such as conducting Water Waste Patrols, implementing the communication protocols, responding to customer service requests, scheduling, and conducting site assessments and consultations, processing incentive and rebate applications, and conducting compliance and enforcement efforts. The City may also elect to lower water system pressure and limit water main flushing. Operational changes will be considered at each level of water shortage to determine whether and when to implement such measures.
5.5 Emergency Response Plan
The City’s water shortage levels outlined in Section 4.0 apply to both foreseeable and unforeseeable water supply shortage conditions, including catastrophic water shortage conditions. Yes Volume or
Percentage
Drop down
Shortage Gap
Reduction Value(a)
(May be a range)
(AF)
1 Expand Public Information
Campaign
Percentage Up to 10%
City will expand volume and breadth of
public outreach.
2 Other Actions (describe) Percentage Up to 10%
City will expand leak detection program
to reduce water system losses.
2 Other Actions (describe) Percentage Up to 5%
City will reduce flushing, use of
construction water, and street sweeping
to reduce potable water demand.
3 - 6 New Recycled Water Percentage Up to 15%
City will expedite connecting new users
to recycled water system to reduce
potable water demand.
NOTES:
(a) Value shown is the shortage gap reduction value for the associated action. However, in practice, actual total shortage gap reduction would be cumulative and include shortage gap reductions from lower shortage levels.
Is the Supplier completing this table using the standard six levels? (yes/no) How much is this going to reduce the
shortage gap?
Shortage
Level
Supply Augmentation Methods and
Other Actions by Water Supplier
Drop down list
These are the only categories that will
be accepted by the WUEdata online
submittal tool
Additional Explanation or Reference
(OPTIONAL)
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14 The City’s Water System Emergency Response Plan (ERP) addresses catastrophic water shortage conditions. The ERP outlines response procedures associated with unforeseeable incidents such as a regional power outage, earthquake, infrastructure failure, and other events. The ERP discusses the City’s emergency management organization structure and communication protocols, resources and equipment which can be deployed in the event of an emergency, and external agencies and other resources the City can call upon if needed.
Alternate water sources identified in the ERP include bottled water or imported water trucked from other agencies to meet the health and safety needs of the City until normal water service can be restored. The City has established relationships with several external agencies which can provide aid to the City in the event of a water system emergency, including the Placer County Emergency Operations Unit and the Hazardous Materials (HAZMAT) Division at the City of Roseville.
To maintain the security of the City water system, the ERP is maintained as a confidential document and may not be incorporated in this UWMP.
6.0 COMMUNICATION PROTOCOLS
In the event of a water shortage, the City must inform its customers, the general public and interested parties, and local, regional, and state entities. Communication protocols for foreseeable and unforeseeable events are provided in this section. In any event, timely and effective communication must occur for appropriate response to the event. City staff are provided with City email accounts and cell phones to communicate internally and externally.
When a water shortage is determined, the City will coordinate interdepartmentally, with the region’s water service providers, and with the County for the possible proclamation of a local emergency in accordance with under California Government Code, California Emergency Services Act (Article 2, Section 8558).
6.1 Communication for Foreseeable Events
Water shortage may be foreseeable when the City conducts its AWSDA as described in Section 3.0. When the City determines the potential of a water shortage event, the City Council may determine and declare a water shortage emergency in accordance with LMC Article IX § 13.04.605 also found in Appendix A. The City will hold a duly noticed public meeting to present the current or predicted shortage. At the public meeting, the City Council will determine if a water shortage emergency condition exists and the degree of the emergency. The City Council will consider the shortage response actions triggered or anticipated to be triggered by the shortage level. As necessary, the City Council will act on the water shortage emergency declaration, associated water shortage level, and shortage response actions.
In general, the City will follow the communication protocols and procedures below and may trigger any of them at any water shortage level.
1. If a water shortage emergency is anticipated, the City will coordinate interdepartmentally, with the City’s wholesale surface water suppliers, Regional Water Authority (RWA), and Placer County for the possible proclamation of a local emergency.
2. The City will issue a public notice for a City Council meeting during which the AWSDA findings and recommendations for a water shortage emergency and shortage response actions are presented.
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15 3. The City will communicate actions to customers, the general public, and interested parties through a combination of bill stuffers and newsletters, website, press releases, and social media posts.
4. The City will communicate actions to relevant local, regional, and state officials and entities primarily through email correspondence.
The communication methods used to inform the public will vary depending on the severity and extent of the water shortage emergency. Communication techniques used will be modified as necessary to ensure the public stays informed of shortage response actions and other City actions until the water shortage emergency is lifted.
6.2 Communication for Unforeseeable Events
A water shortage may also occur during unforeseeable events such as earthquakes, fires, infrastructure failures, civil unrest, and other catastrophic events. For imminent events, the City Manager becomes the Director of Emergency Services and may proclaim a water shortage emergency in accordance with LMC Chapter 2.36 § 2.36.060 and activate the City’s ERP. The City’s ERP provides specific communication protocols and procedures to convey actions during these events. The City may trigger these communication protocols, depending on the event.
In general, communications and notifications should proceed along the chain of command. All City staff are provided their communication responsibilities. The City’s Public Works Director or Environmental Services Manager serves as the Water Utility Emergency Response Manager (WUERM) and determines if and when communications to external parties should be made. The Public Information Officer (PIO) or Liaison Officer serve as the point of contact for communications with the public and regulatory agencies.
The ERP provides a list of relevant contacts to notify at the local, regional, and state level.
The PIO is the official spokesperson for the City and is the only City staff authorized to speak directly to public media representatives. The ERP contains a list of contacts through which the PIO can disseminate information to the public. Additionally, the City maintains profiles on social media platforms, including Facebook and Twitter. These profiles may be used to convey information to staff and the public, in addition to their website and email.
To maintain the security of the City water system, the ERP is maintained as a confidential document and may not be incorporated in this UWMP.
7.0 COMPLIANCE AND ENFORCEMENT
This section describes how the City will ensure compliance with and enforcement of provisions of this WSCP. The City’s procedures include protocols for treatment of violations and actions associated with more egregious levels of violation. The procedures include appeal and exemption processes.
7.1 Compliance and Enforcement Procedures
When a water shortage is anticipated, the City Council will adopt a resolution declaring a water shortage emergency condition and the regulations and restrictions that should be enforced in response to the declared water shortage level.
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16 The City is metered system-wide, at production facilities and at each customer connection. Thus, water use can be quantified and compared to determine users’ extent of compliance to water reduction requirements. The City may also become aware of non-compliance through water waste reporting by the general public, the City’s online reporting tool, City staff inspections, and/or manual review of customer use data.
LMC Chapter 13.04 appliesfor violation of regulations and restrictions associated with the water shortage emergency declaration. The City Manager and duly designated representatives are authorized to enforce provisions of LMC Chapter 13.04 Article VI and Article IX. For these purposes, they have the power and discretion of a law enforcement office.
When the City becomes aware of violations, a written notice of the violation will be delivered to the customer at the premises or by first class mail and posted in a conspicuous location at the premises. A copy of the notice will also be mailed to the regularly billed customer for water use at the premises. The notice will describe the violation and request that it be corrected, cured, or abated within a reasonable period of time as determined by the City under the circumstances. The notice will include a list of potential consequences for failure to comply with the notice, including fines. Should the violation persist, the City may assess civil penalties as authorized under LMC Chapter 13.04. Civil penalties may be assessed at a daily rate as determined by the City. In addition to fines, the City may collect administrative costs incurred in the investigation, inspection, and reinspection of the property.
7.2 Appeal Process
LMC Chapter 13.04 outlines the appeal process for City customers. If a customer wishes to appeal the City’s decision, they must submit a written appeal to the Director of Public Works, or designee, within ten calendar days of service of the notice. The Director of Public Works will request the City Attorney to appoint a hearing officer and to schedule a day, time, and place for an appeal hearing. Written notice regarding the hearing will be served at least ten calendar days prior to the hearing to the appealing customer. The decision of the hearing officer or hearing body on the appeal is final.
8.0 LEGAL AUTHORITIES
The LMC Chapter 13.04 supports the City’s ongoing water use restrictions, including provisions for enforcement. LMC Chapter 13.04 provides the City authority to implement and enforce water use regulations during water shortage conditions.
LMC Chapter 2.36 designates the City Manager as the Director of Emergency Services for imminent emergencies. The City Manager may proclaim an emergency. As soon as practical, the City Manager will notify City Council. Within seven days of proclamation, the City Council shall take action to ratify the proclamation to continue the emergency proclamation.
In a duly noticed meeting, City Council will determine whether a water shortage emergency condition exists and, if so, the degree of the emergency and what regulations and restrictions should be enforced in response to the shortage. The water shortage emergency declaration will remain in effect until the City Council finds and declares by resolution that the water shortage emergency condition has abated, has changed in degree, or no longer exists.
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17 The City shall declare a water shortage emergency in accordance with CWC Chapter 3 of Division 1.
California Water Code Division 1, Section 350
The governing body of a distributor of a public water supply…shall declare a water shortage emergency condition to prevail within the area served by such distributor whenever it finds and determines that the ordinary demands and requirements of water consumers cannot be satisfied without depleting the water supply of the distributor to the extent that there would be insufficient water for human consumption, sanitation, and fire protection.
The water shortage emergency declaration triggers communication protocols described in Section 6.0 and compliance and enforcement actions described in Section 7.0.
9.0 FINANCIAL CONSEQUENCES OF WSCP
Because the City water charges are partially based on volumetric rates, the City may experience a reduction in revenue upon declaration of water supply shortage. The City anticipates that reduced water sales will lead to a reduction in revenue. The City also anticipates increased costs from implementing the WSCP as follows:
• Increased staff costs: salaries, benefits, materials and supplies for various staff and new hires required to administer and implement water shortage contingency program measures and actions
• Increased Operation and Maintenance (O&M) cost: Operations and maintenance costs associated with alternative sources of water supply, reduced system flows, or water quality challenges
• Increased cost of supply and treatment: purchase and treatment costs of new water supply or additional treatment due to existing source shortfalls The City policy is to maintain adequate water fund reserves in the event water shortage and subsequent demand reduction measures impact the City’s revenue. Rate increases may be necessary to offset decreased sales revenue and increased costs, if deemed necessary by the City Council.
The City periodically conducts water rate studies to evaluate the financial impacts of changes in water demand. As part of the future rate studies, the City may consider a drought surcharge. A drought surcharge would allow the City to mitigate revenue shortfalls and increased costs as a result of implementing this WSCP.
10.0 MONITORING AND REPORTING
The City water system is fully metered, from its water supply sources to individual customer meters. These meters may be used as monitoring tools for compliance and reporting purposes. The City’s water system is fully equipped with AMI, which provide real-time meter readings. AMI allows the City to monitor customer water usage and system demands to support compliance evaluation, demand reduction assessment, and customer outreach, as needed. The City monitors and reports water conservation activities to the State monthly as part of the required Monthly Urban Water Conservation Reporting per the State Water Resources Control Board adopted Resolution No. 2020-0009. 1126
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18 If reduction goals are not met through implementation of the WSCP (during any water shortage level), the staff will notify the City Council, and more stringent action may be taken. Additionally, if it is determined that this WSCP requires refinements to achieve reduction targets, the City will revise the WSCP according to the procedures discussed in Section 11.0 and then adopt it and make it available as discussed in Section 12.0.
11.0 WSCP REFINEMENT PROCEDURES
This WSCP is an adaptive management plan. It is subject to refinements as needed to ensure that the City’s shortage response actions and mitigation strategies are effective and produce the desired results.
Based on monitoring described in Section 10.0 and the need for compliance and enforcement actions described in Section 7.0, the City may adjust its response actions and may modify its WSCP. When a revised WSCP is proposed, the revised WSCP will undergo the process described in Section 12.0 for adoption by the City Council and distribution to the County, its customers, and the public.
Feedback from City staff and the public is important in refining or incorporating new actions. The City seeks input from staff who interface with customers to gauge the effectiveness of its response actions and for response action ideas. The City seeks input from its customers and the general public through its website and through regularly scheduled City Council meetings.
Customer water meter data may be evaluated for each customer sector or each individual customer. The City tracks water use violations and may evaluate their frequency to determine restrictions that customers may not be able to meet. This evaluation may also show water demand reduction actions that customers may effectively implement.
12.0 PLAN ADOPTION, SUBMITTAL, AND AVAILABILITY
The WSCP may be adopted concurrently with the City’s UWMP, by separate resolution, and may be revised and adopted at any time by the City. Prior to adoption, a duly noticed public hearing is conducted.
An electronic copy of the WSCP will be submitted to DWR within 30 days of adoption.
No later than 30 days after submittal to DWR, an electronic copy of this WSCP will also be available for public review and download on the City’s website.
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Appendix A
1128
1129
1130
1131
DWR 2025 Urban Water Management Plan Tables
Appendix B
1132
Standard
Shortage
Levels
Percent
Shortage Range
Suppliers
Shortage
Levels
Percent
Shortage
Range
1 Up to 10%
2 Up to 20%
3 Up to 30%
4 Up to 40%
5 Up to 50%
6 >50%
Submittal Table 8-1: Cross-reference for Standard vs
Supplier Shortage Levels
Water Code Section 10632(a)(3)(B)
Check the box if the Supplier uses the
Standard six levels of water shortage.
Proceed to the next table.
NOTES:
1133
Yes
Volume or
Percentage
Drop down
Shortage Gap
Reduction Value(a)
(May be a range)
(AF)
1 Expand Public Information
Campaign
Percentage Up to 10%
City will expand volume and breadth of
public outreach.
2 Other Actions (describe) Percentage Up to 10%
City will expand leak detection program
to reduce water system losses.
2 Other Actions (describe) Percentage Up to 5%
City will reduce flushing, use of
construction water, and street sweeping
to reduce potable water demand.
3 - 6 New Recycled Water Percentage Up to 15%
City will expedite connecting new users
to recycled water system to reduce
potable water demand.
Submittal Table 8-2 Retail: Supply Augmentation and Other Actions Water Code Section 10632(a)(4)(A),(C) and (E)
Add additional rows as needed
NOTES:
(a) Value shown is the shortage gap reduction value for the associated action. However, in practice, actual total shortage gap reduction would be cumulative and include shortage gap reductions from lower shortage levels.
Is the Supplier completing this table using the standard six levels? (yes/no) How much is this going to reduce the
shortage gap?
DWR NOTES: Units of measure (AF, CCF, MG) must remain consistent throughout the UWMP as reported in Submittal Table 2-3.
Shortage
Level
Supply Augmentation Methods and
Other Actions by Water Supplier
Drop down list
These are the only categories that will
be accepted by the WUEdata online
submittal tool
Additional Explanation or Reference
(OPTIONAL)
1134
Yes
Volume or
Percentage
Drop down
Shortage Gap
Reduction Value
(May be a range)
(AF)
0 Other - Customers must repair
leaks, breaks, and malfunctions in a
timely manner
Required at all times pursuant to LMC §13.04.410
(maintenance of water pipes; prohibition on
leaks).
Yes
0 Landscape - Restrict or prohibit
runoff from landscape irrigation
Unreasonable or wasteful runoff prohibited
pursuant to LMC §13.04.440.
Yes
0 Other - Require automatic shut of
hoses
Open-hose watering prohibited pursuant to LMC
§13.04.420.
Yes
0 Water Features - Restrict water use
for decorative water features, such
as fountains
Decorative fountains without recirculating
systems prohibited pursuant to LMC §13.04.430. Yes
1 Pools and Spas - Require covers for
pools and spas Yes
1 Other - Customers must repair
leaks, breaks, and malfunctions in a
timely manner
Water leaks shall be repaired within five days or
sooner if required by City. Yes
1 Water Features - Restrict water use
for decorative water features, such
as fountains
Operation of ornamental fountains that do not
have a recirculating system is prohibited. Yes
1 Landscape - Restrict or prohibit
runoff from landscape irrigation Yes
1 Landscape - Other landscape
restriction or prohibition
Outdoor irrigation shall not occur during
precipitation events or within 24 hours of a rain
event that produced 0.20 inches of precipitation
or more.
Yes
1 CII - Other CII restriction or
prohibition
Operators of hotels, motels, and other
commercial establishments offering lodging
shall post in each room and at each site, a Notice
of Drought Condition, approved by the Director
of Public Services.
Yes
1 CII - Restaurants may only serve
water upon request
Yes
2 Landscape - Limit landscape
irrigation to specific times
Outdoor irrigation is prohibited between the
hours of 8:00 AM and 9:00 PM. Implemented
pursuant to City authority under LMC §13.04.430
and adopted water shortage response actions.
Yes
2 Landscape - Limit landscape
irrigation to specific days
Outdoor irrigation of ornamental turf shall be
limited to no more than three days per week.
The allowable days for irrigation will be
established by the City.
Yes
2 Other - Prohibit use of potable
water for washing hard surfaces Yes
3 Water Features - Restrict water use
for decorative water features, such
as fountains
Operation of all ornamental fountains is
prohibited. Yes
3 Landscape - Other landscape
restriction or prohibition
Planting or seeding of new ornamental turf is
prohibited, including new turf planted or
seeded to replace existing turf.
Yes
3 Landscape - Limit landscape
irrigation to specific days
Outdoor irrigation of ornamental turf shall be
limited to no more than two days per week. The
allowable days for irrigation will be established
by the City.
Yes
4 Other water feature or swimming
pool restriction
Introduction of water into swimming pools and
spas is prohibited except to maintain structural
integrity of such facilities.
Yes
4 Other - Prohibit vehicle washing
except at facilities using recycled or
recirculating water
Yes
5 Landscape - Prohibit certain types
of landscape irrigation
Irrigation of yards or other landscaped areas
containing lawn or turf grass is prohibited.
Irrigation of trees is allowed.
Yes
6 Other Potable water to be used for health and safety
purposes only. Yes
Is the Supplier completing this table using the standard six levels? (yes/no) Submittal Table 8-3 Retail: Demand Reduction Actions
Water Code Section 10632(a)(4)(B),(D), and (E)
Add additional rows as needed
How much is this going to reduce the
shortage gap?
90 percent reduction in irrigation demands
Not readily quantifiable
Not readily quantifiable
Not readily quantifiable. City has
permanent ordinance which prohibits
Boosts the effectiveness of other methods -
not readily quantifiable
Evapotranspiration of approximate surface
area of pools
Boosts the effectiveness of other methods -
not readily quantifiable
Boosts other methods as a public display of
drought conservation. Not readility
quantifiable.
Not readility quantifiable. City has
permanent ordinance which prohibits
Shortage
Level
Demand Reduction Actions
Drop down list
These are the only categories that will
be accepted by the WUEdata online
submittal tool. Select those that apply.
Additional Explanation or Reference
(OPTIONAL)
NOTES:
Penalty, Charge,
or Other
Enforcement?
For Retail Suppliers
Only
Drop Down List
DWR NOTES: Units of measure (AF, CCF, MG) must remain consistent throughout the UWMP as reported in Submittal Table 2-3.
Depends on times that irrigation will be
allowed, but can reduce water use by 20-25
gallons per day per household
22 percent reduction in irrigation demands
Boosts other methods - not readily
quantifiable
Boosts other methods as a public display of
drought conservation. Not readility
quantifiable.
Boosts the effectiveness of other methods -
not readily quantifiable
33 percent reduction in irrigation demands
Boosts other methods as a public display of
drought conservation. Not readility
quantifiable.
Up to shortage gap
Boosts the effectiveness of other methods -
not readily quantifiable
Not readility quantifiable. Dependent on
number of precipitation events.
100-200 gal/year/residential connection
50 gal/day/commercial connection
1135
Water Rate Structure
Appendix G
1136
1137
1138
1139
UWMP and WSCP Adoption Resolutions
Not included with this submittal.
Appendix H
1140
Concord Phoenix
1001 Galaxy Way, Suite 310
Concord CA 95420
925-949-5800
4505 E Chandler Boulevard, Suite 265
Phoenix AZ 85048
602-337-6110
Davis Pleasanton
2020 Research Park Drive, Suite 100
Davis CA 95618
530-756-5905
6800 Koll Center Parkway, Suite 150
Pleasanton CA 94566
925-426-2580
Irvine Sacramento
25 Edelman, Suite 120
Irvine, CA 92618
949-420-3030
100 Howe Avenue, Suite 110S
Sacramento CA 95825
916-306-2250
Lake Oswego San Diego
5 Centerpointe Drive, Suite 130
Lake Oswego OR 97035
503-451-4500
11545 West Bernardo Court, Suite 209
San Diego CA 92127
858-505-0075
Medford Santa Rosa
3235 Hillcrest Park Drive, Suite 106
Medford OR 97504
458-299-0843
2235 Mercury Way, Suite 105
Santa Rosa CA 95407
707-543-8506
Oceanside
804 Pier View Way, Suite 100
Oceanside CA 92054
760-795-0365
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SUBJECT: Adopt a Resolution Adopting the Broadband Master Plan. (Jennifer Brown)
SUBMITTED BY: Jennifer Brown
DEPARTMENT: Information Technology
DATE: May 26, 2026
Item Number 15.A
STAFF RECOMMENDATION:
Staff recommends the City Council adopt a resolution adopting the Broadband Master Plan.
BACKGROUND/INTRODUCTION:
On May 28th, 2024 the City of Council voted to use the restricted ARPA funds to fund the City of Lincoln Broadband Master Plan. Staff interviewed several consultants and in August of 2024 selected EN Engineering, LLC for their 16 years of experience and impeccable reputation with cities throughout California. Over the last year and a half, staff have worked with the consultant pulling together all the information necessary for a comprehensive plan that is designed for Lincoln.
The development of the Broadband Master Plan focused on the following objectives:
1. Addressing the 'digital divide' by increasing high-speed internet access for low-income and disadvantaged residents.
2. Improve fiber access in key commercial areas to maintain Lincoln's economic competitiveness, retain, and attract job-creating businesses, entrepreneurs, and other technology-reliant innovators.
3. Expand fiber access for public facilities and infrastructure to ensure continuous connectivity and service resilience for public safety, emergency response, and other essential City functions.
4. Gain a clear picture of the current broadband environment, leverage existing assets, define governance and business models and find innovative ways in improving competition, reliability, and resiliency for the City.
To achieve the stated objectives above EN Engineering were tasked to:
Perform an asset assessment of both public and private infrastructure (Ch 2) Complete a market analysis (Ch 3)
Conduct a needs assessment (Ch 4)
o Conducted internal department staff workshops
o Community outreach through workshops and surveys
o Local Business workshops and surveys
Gap Analysis indication the need for additional resources and policies to meet the City's
STAFF REPORT
1142
broadband goals. (Ch 4)
Review of City Policy
Create a conceptual design
Create cost models and financial analysis (Ch 6)
Complete a comprehensive strategic broadband plan
FINDINGS/ANALYSIS:
The Broadband Master Plan and its supporting analysis provide a comprehensive framework for City staff to guide policy implementation, evaluate proposed development infrastructure, plan replacement and improvement projects, and identify opportunities to expand the City’s fiber footprint. The Plan is intended to function as a living planning document and may be updated over time to reflect changing conditions, available data, technological developments, infrastructure needs, and City priorities. The assumptions, evaluations, and recommendations set forth in the Plan are based on the information available at the time of preparation.
ENVIRONMENTAL REVIEW:
The Broadband Master Plan is exempt from the California Environmental Quality Act (CEQA) pursuant to CEQA Guidelines Section 15061(b)(3) because it has no potential to impact the environment and pursuant to section 15262 because it is a planning study for future action which the City is not approving at this time.
FISCAL IMPACT:
Budgeted
Broadband Master Plan $300,000
Actual project
Fund 1020 – Standard Allowance
EN Engineering, LLC $264,820
Budget Remaining
Broadband Fund $35,180
ATTACHMENTS:
BroadbandMasterPlan.DOC2.Reso.2026May26.jbrown.docx
Broadband Master Plan Final Report - v2026-03-12.pdf
1143
Resolution No. 2026-XXX
RESOLUTION 2026-XXX
A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF LINCOLN ADOPTING
THE BROADBAND MASTER PLAN
WHEREAS, on May 28, 2024, the City Council authorized the use of restricted ARPA funds to prepare the City of Lincoln Broadband Master Plan; and WHEREAS, the City selected EN Engineering, LLC to assist in the preparation of the Broadband Master Plan; and
WHEREAS, City staff and EN Engineering, LLC have completed the Broadband Master Plan as a comprehensive planning document intended to support policy implementation, evaluation of proposed development infrastructure, planning for replacement and improvement projects, and expansion of the City’s fiber footprint; and WHEREAS, the Broadband Master Plan is intended to serve as a living document, and its assumptions, evaluations, and recommendations are based on the information available at the time of preparation; and
WHEREAS, the Broadband Master Plan is exempt from the California Environmental Quality Act (CEQA) pursuant to CEQA Guidelines Section 15061(b)(3) because it has no potential to impact the environment and pursuant to Section 15262 because it is a planning study for future action which the City is not approving at this time.
NOW THEREFORE BE IT RESOLVED:
The City Council of the City of Lincoln does hereby resolve to adopt the Broadband Master Plan
PASSED AND ADOPTED this 26
th day of May, 2026 by the following vote:
AYES: Councilmembers:
NOES: Councilmembers:
ABSENT: Councilmembers:
ABSTAIN: Councilmembers:
___________________________
Richard Pearl, Mayor
ATTEST:
Hope Ithurburn, City Clerk
1144
ENTRUST Solutions Group ***DRAFT*** City of Lincoln, CA Broadband Master Plan
City of Lincoln, California
March 12, 2026
1145
City of Lincoln Broadband Master Plan Page 1
ENTRUST Solutions Group March 12, 2026 City of Lincoln, CA Contents
1. Executive Summary ............................................................................................4
2. Asset Assessment ..............................................................................................7
2.1 Public Infrastructure ..................................................................................7
2.2 Private Infrastructure .............................................................................. 19
2.3 Summary of Findings .............................................................................. 20
3. Market Analysis ................................................................................................ 22
3.1 Wired Service Providers .......................................................................... 24
3.2 Fixed Wireless Access (FWA) Providers................................................... 30
3.3 Cellular Data Services............................................................................. 32
3.4 GSO and NGSO Satellite Services ........................................................... 35
3.5 Metropolitan, Middle Mile, and Long-Haul Networks .................................. 35
3.6 Summary of Findings .............................................................................. 39
4. Needs Assessment & Gap Analysis .................................................................. 41
4.1 Indicators of Need................................................................................... 41
4.2 Community Survey .................................................................................. 45
4.3 Stakeholder Outreach ............................................................................. 58
4.3 Digital Divide .......................................................................................... 61
4.4 Digital, Equity, Inclusion, and Literacy...................................................... 62
4.5 Summary of Findings .............................................................................. 63
5. Conceptual Network Design.............................................................................. 65
5.1 Concept Design ...................................................................................... 65
5.2 Phased Implementation Plan ................................................................... 67
5.3 Construction Costs Estimates .................................................................. 73
5.4 Lease of Private Fiber Assets .................................................................. 74
5.5 Summary of Findings .............................................................................. 75
6. Technical & Financial Analysis ......................................................................... 77
6.1 Operational Model Options ...................................................................... 77
6.2 Technology Overview .............................................................................. 81
6.3 Financial Analysis ................................................................................... 86
6.4 Financing Options ................................................................................... 90
6.5 Summary of Findings .............................................................................. 98
7. Broadband Policy............................................................................................ 100
7.1 General Plan ........................................................................................ 100
7.2 Major Projects & Public ROW ................................................................ 102
7.3 Wireless Access ................................................................................... 106
7.4 Summary of Findings ............................................................................ 109
7.5 Policy Roadmap.................................................................................... 110
8. Key Recommendations ................................................................................... 116 Appendix A: Preliminary Network Equipment List .............................................. 118 Appendix B: Broadband Policy Context ............................................................. 120 Figures
Figure 1. The City of Lincoln geographic area ............................................................8 Figure 2. City of Lincoln traffic signal locations ..........................................................9 Figure 3. City of Lincoln streetlight poles ................................................................. 10 Figure 4. Streetlight pull box locations in Lincoln ...................................................... 10 1146
City of Lincoln Broadband Master Plan Page 2
ENTRUST Solutions Group March 12, 2026 City of Lincoln, CA Figure 5. Locations of poles in and around the City of Lincoln ................................... 11 Figure 6. City of Lincoln facilities ............................................................................. 12 Figure 7. City Lincoln wide-area network connections between sites ......................... 13 Figure 8. The City of Lincoln's planning process and regulatory structure .................. 15 Figure 9. City of Lincoln Specific Plan areas ............................................................ 16 Figure 10. Villages outside the City of Lincoln .......................................................... 17 Figure 11. Towers and antenna by type of placement in Lincoln ................................ 19 Figure 12. Randomly selected address locations ...................................................... 23 Figure 13. Hybrid fiber-coax network architecture..................................................... 25 Figure 14. Locations in Lincoln with internet service available from Astound .............. 26 Figure 15. Digital subscriber line (DSL) service ........................................................ 27 Figure 16. Locations in Lincoln with internet service available from AT&T.................. 28 Figure 17. Locations in Lincoln with internet service available from Fidium Fiber ....... 29 Figure 18. Cellular wireless network architecture ..................................................... 31 Figure 19. AT&T LTE/5G coverage in Lincoln ........................................................... 33 Figure 20. T-Mobile LTE/5G verified coverage in Lincoln .......................................... 34 Figure 21. Verizon LTE/ 5G verified coverage in Lincoln ........................................... 34 Figure 22. Metro fiber routes in Lincoln.................................................................... 36 Figure 23. Long haul fiber routes through the Lincoln area........................................ 37 Figure 24. California MMBI route near Lincoln.......................................................... 38 Figure 25. Availability of fiber-based broadband in Lincoln........................................ 39 Figure 26. FCC Identified Un- and Under-served Locations....................................... 42 Figure 27. CASF-eligible locations in and around Lincoln ......................................... 43 Figure 28. Percentage of households with internet by Census block group ................ 44 Figure 29. Low to moderate income census blocks ................................................... 45 Figure 30. Amount of 309 responses by type of location and level of completeness ... 46 Figure 31. Educational attainment among 184 responses ......................................... 46 Figure 32. Occupation of 182 respondents compared to the population of Lincoln ...... 47 Figure 33. Types of internet connections by survey completeness ............................. 47 Figure 34. Percentage of 215 responses of internet connection aggregate throughput 48 Figure 35. The geographic distribution of 215 speed test results in terms of Mbps ..... 49 Figure 36. Percentage of 305 responses per type of internet connection ................... 50 Figure 37. Geographic locations of 305 responses by type of internet service ............ 50 Figure 38. Importance of reasons for not having broadband by 17 respondents ......... 52 Figure 39. Frequency of broadband uses for broadband for 184 responses ............... 52 Figure 40. Sources of video content by percentage for 188 responses ...................... 53 Figure 41. Importance of internet access as a percentage by 194 responses ............. 53 Figure 42. Satisfaction with internet services from 210 responses ............................. 54 Figure 43. Willingness to pay for internet services among 151 responses .................. 55 Figure 44. Percentage of 193 responses per type of internet connection ................... 56 Figure 45. Locations of 216 responses by provider ................................................... 57 Figure 46. Conceptual Network Design .................................................................... 67 Figure 47. Phase 1: City sites ................................................................................. 68 Figure 48. Phase 2: Core public facilities ................................................................. 70 1147
City of Lincoln Broadband Master Plan Page 3
ENTRUST Solutions Group March 12, 2026 City of Lincoln, CA Figure 49. Phase 3: Community anchors .................................................................. 72 Figure 50. Factors to Consider when Choosing a Broadband Business Model ............ 77 Figure 51. Broadband Business Models ................................................................... 80 Figure 52. The Hierarchical Structure of Networks .................................................... 81 Figure 53. Transport Networks Architecture ............................................................. 82 Figure 54. Access Network Architecture................................................................... 84 Figure 55. Conceptual Network Design .................................................................... 87 Figure 56. Average Annual Operating Revenues & Expenses Estimate...................... 89 Figure 57. Network Launch CAPEX Estimate - $11.9 M ............................................ 90 Figure 58. Policy Implementation........................................................................... 111 Tables
Table 1. Costs and speeds of connections to City of Lincoln facilities ........................ 13 Table 2. Sites tested for providers and service tiers ................................................. 23 Table 3. Astound residential internet service offerings in Lincoln............................... 26 Table 4. AT&T residential internet service offerings in Lincoln .................................. 29 Table 5. Fidium Fiber business and residential internet service offerings in Lincoln ... 30 Table 6. Lincoln Crossing HOA/Succeed.net service offerings .................................. 30 Table 7. FWA services compared ............................................................................ 32 Table 8. DigitalPath service offerings in Lincoln ....................................................... 32 Table 9. Fiber-to-the-premises (FTTP) coverage in Placer Valley cities ..................... 40 Table 10. Average Costs and performance of 305 responses .................................... 51 Table 11. Cost and performance of Lincoln area ISPs compared ............................... 57 Table 12. Sites Connected to City Backbone Network in Conceptual Design .............. 66 Table 13. Routes miles by phase (Includes lease of private fiber) ............................. 68 Table 14. Phase 1: Connected priority sites ............................................................. 69 Table 15. Phase 2: Connected core public facilities .................................................. 70 Table 16. Phase 3: Connected community anchors .................................................. 73 1148
City of Lincoln Broadband Master Plan Page 4
ENTRUST Solutions Group March 12, 2026 City of Lincoln, CA
1. Executive Summary
Communities are faced with a digital world where broadband is often considered a public utility – similar to water and power. The shift to online learning, remote work, telehealth/medicine, ecommerce, automation of services, autonomous vehicles, and advances in technology require a long-term vision for how a community can utilize broadband to thrive and grow. The foundation for the digital world is fiber optic networks that can provide the high-speed, low latency connectivity required for advanced applications and uses.
ENTRUST Solutions Group (ENTRUST) was contracted by the City of Lincoln, California (the City) to undertake a Broadband Master Plan to help improve access and affordability to highspeed internet service for community members, businesses, and efficient delivery of City services. ENTRUST’s scope of work included:
• Asset inventory assessment
• Market assessment
• Needs assessment
• Gap analysis
• Conceptual network design
• Technical and financial analysis
• Policy roadmap
The City has limited public assets that would facilitate providing broadband services. The City has very limited fiber assets, but does host significant vertical infrastructure that includes 185 traffic signal poles at 42 intersections and 7,594 streetlight poles (of which 64% are Cityowned). There are, however, significant private fiber assets that could be leverged by the City to extend broadband services. The City is also in a growth pattern which provides prime oppurtunity for low cost expansion of fiber assets.
The City is considered by the Federal Communications Commission (FCC) and the California Public Utilities Commission (CPUC) as relatively “well served” with broadband, but has limited fiber options or alternative competing services. There are three broadband service providers (Astound, AT&T, and Fidium) who each have significant market share, but approximately 49% of the City has no fiber optic option and is subject to a cable monopoly. There is also a small fiber-to-the-home network available to the Lincoln Crossing Home Owners Association (HOA) residents.
Entrust conducted a survey and focus groups to evaluate the needs of the community. Survey results revealed 25% of respondents had digital subscriber line (DSL) services provided over legacy copper telephone wires – services incapable of meeting California minimum speed standards of 100 Mbps download and 25 Mbps upload. Fiber availability was mostly concentrated in the (relatively newer) northern and western areas of the City. Focus group participants were asked about existing connectivity issues they have with their broadband service. Outages were a recurring issue, with small businesses citing impacts 1149
City of Lincoln Broadband Master Plan Page 5
ENTRUST Solutions Group March 12, 2026 City of Lincoln, CA on sales and communication during storms and construction accidents. This revealed a need for stable and consistent connectivity in addition to not having ubiquitous fiber internet.
Significant gaps in the availability of broadband also suggests one or more challenges related to the Digital Divide: affordability, technology access, digital literacy, geographic limitations, and/or language barriers. There are significant portions of the City that have a higher percentage of households without an internet subscription than the national average, and when coupled with survey results that showed respondents valued lower price over higher speed, this could indicate that monthly subscription costs are a barrier for residents.
ENTRUST developed a Conceptual Network Design that would interconnect the most critical City facilities and buildings to provide City communications through a redundant network architecture. The Concept Design proposes to construct 15.4 miles of new underground routes to be interconnected with ~30 miles of existing private fiber routes (and avoid costly overbuild), creating a backbone network of 46.7 miles. The Conceptual Design is broken into three phases so that the City can prioritize the most critical connections in the first phase to City Hall and police, fire, water, public safety and emergency response departments. The total construction costs of all three phases of the design are estimated at $10.3 million.
The implementation of the Conceptual Design will depend on the selected ISP partner. The City will use a competitive process to identify a qualified partner who will collaborate to achieve the Broadband Master Plan’s objectives. If the selected partner has existing fiber infrastructure in the surrounding areas, this would eliminate the need to construct significant portions of the network. Leasing access to existing private fiber and minimizing new fiber build significantly reduces the capital required and provides opportunities for public-private partnerships.
The Financial Analysis section details that the City providing direct connectivity services is not a sustainable option. Public-private partnerships can accelerate broadband deployment and bridge funding gaps. Given Lincoln’s limited existing infrastructure, and in an effort to address broadband gaps through leveraging existing private fiber assets, collaboration with a private service provider is essential. Developing a partnership with an established ISP will facilitate the Broadband Master Plan’s success and long-term viability.
Some City policies and ordinances related to broadband are outdated, do not align with new state or federal guidelines and laws, or do not address City needs (or assert City discretion and authority where permitted). While the City does coordinate some work in the public rights of way, the City could update its policies to streamline processes and encourage more private telecom investment. The City can begin establishing a broadband-friendly environment by first streamlining internal City processes, standards, and specifications: developing and adopting micro trenching standards, creating a Master License Agreement (MLA) process for wireless applications, developing an updated wireless/small cell ordinance to maximize City discretion and aesthetics, and creating a wireless siting portal to solicit new pole and antenna leases on City facilities, assets, and land.
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City of Lincoln Broadband Master Plan Page 6
ENTRUST Solutions Group March 12, 2026 City of Lincoln, CA Once a broadband-friendly policy environment has taken hold in the City, it can encourage external participation in these processes by incentivizing participation – and disincentivizing isolation. These “carrots and sticks” can be established through formalizing four key processes:
broadband expansion integrated into Capital Improvement Projects (CIP), public and private utility coordination, developing and adopting a “dig once”/joint trench ordinance and street moratoriums, and utilizing development agreements to expand public broadband assets on major projects.
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City of Lincoln Broadband Master Plan Page 7
ENTRUST Solutions Group March 12, 2026 City of Lincoln, CA
2. Asset Assessment
2.1 Public Infrastructure
Cities typically already own and manage significant public infrastructure in order to provide services to the community. Many municipal assets can benefit from being connected to network infrastructure. At the same time, those assets can be leveraged to provide enhanced community connectivity. Existing conduit and fiber networks typically used for exclusive City communications or traffic control can also act as foundational infrastructure for residential and business internet access. Land, buildings, poles, and towers can support antenna to improve wireless connectivity. The public easements or rights-of-way (ROW) along public roads may be the most valuable assets, along with other public property, allowing for quick and cost-effective deployment of new public communications infrastructure. All of this can make widespread access to high-speed connectivity more feasible by reducing costs and accelerating the deployment of the requisite digital infrastructure.
ENTRUST assessed physical assets in the City of Lincoln for their connectivity requirements and potential usefulness in broadband development. We identified the City’s existing and planned network assets and potential locations for such infrastructure on public property and in the public right of ways. We also assessed similar assets of community anchor institutions, county and state agencies, utility companies, and others for their usefulness and connectivity requirements. This information will be combined with information about network service providers’ assets which was gathered during the market analysis supply assessment.
We acquired GIS files, capital projects, planning and development data, and other information to create a broadband asset map. Layers for conduit, poles, traffic signal cabinets and other like assets are to be used for expanding broadband. We analyzed Capital Improvement, general, and specific plans to identify strategic and cost-effective methods of deploying and expanding broadband. Planned projects that may create opportunities to install additional conduit and fiber through long-term capital projects schedules, public rights-of-way encroachments, and development agreements.
ENTRUST found seven sets or types of publicly owned assets that might be useful for broadband. Lincoln, located in Placer County, has substantial road, water, and other infrastructure that coexist with broadband in the public rights-of-way but are not directly related to broadband. Positioned in Northern California, Lincoln benefits from significant regional connectivity. State Route 65 runs through the city, linking it to major hubs in the Sacramento metropolitan area. Additionally, Union Pacific Railroad provides freight rail service, further enhancing Lincoln's transportation infrastructure and access to regional and national markets.
The City of Lincoln is expanding rapidly with a municipal sphere of influence that extends to the north and west, outside the city boundary, as shown Figure 1, and an out-parcel to the 1152
City of Lincoln Broadband Master Plan Page 8
ENTRUST Solutions Group March 12, 2026 City of Lincoln, CA northwest. The sphere of influence represents the “probable ultimate physical boundaries and service area” for the City.1
Figure 1. The City of Lincoln geographic area
Vertical Infrastructure
The City does not have any fiber cable or similar assets that might be directly used for providing broadband services. It has 185 traffic signal poles at 42 intersections, as shown in Figure 2, primarily along Lincoln Boulevard/Industrial Avenue, Joiner Parkway, Ferrari Ranch Road, and Twelve Bridges Drive.
1 General Plan, City of Lincoln, March 2008, https://www.lincolnca.gov/en/business-anddevelopment/resources/Documents/general-plan-2050.pdf, page 2-6.
City boundary
Sphere of
Influence
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City of Lincoln Broadband Master Plan Page 9
ENTRUST Solutions Group March 12, 2026 City of Lincoln, CA Figure 2. City of Lincoln traffic signal locations
Lincoln has 7,594 streetlight poles, shown in Figure 3, 64% of which are city-owned. There are also 2,876 pull boxes concentrated in clusters as shown in Figure 4 associated with the streetlights. According to data we received, the City has a small amount of conduit for streetlight electric power in the northern area on Lincoln Blvd and in a new development south of Moore Rd, in the western portion of the city.
City boundary
Traffic signal
pole
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City of Lincoln Broadband Master Plan Page 10
ENTRUST Solutions Group March 12, 2026 City of Lincoln, CA Figure 3. City of Lincoln streetlight poles
Figure 4. Streetlight pull box locations in Lincoln
City
boundary
Streetlight
City boundary
Electric pull
box
Electric
conduit
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City of Lincoln Broadband Master Plan Page 11
ENTRUST Solutions Group March 12, 2026 City of Lincoln, CA In June of 2023, the City acquired data on the location of 11,160 vertical assets in its municipal service area, generated by artificial intelligence analysis of satellite images. Shown in Figure 5, the raw AI compiled data includes utility poles as well as the City’s streetlight and traffic signal poles.
Figure 5. Locations of poles in and around the City of Lincoln City Facilities
Data provided by the City indicated it has 15 sites, including the airport, City Hall, two community centers (one co-located with the City’s Recreation Department, another is the City’s senior center), three Fire Stations, a multi-facility park (with a stadium, swimming pool, and other recreational facilities), Police Department, Public Works corporation yard, and a wastewater treatment plant (within the City boundary but owned and operated by a JPA), shown in Figure 6. The City data also includes 13 public elementary, middle, and high schools, two charter schools, three medical facilities.
City boundary
Sphere of
Influence
Pole
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City of Lincoln Broadband Master Plan Page 12
ENTRUST Solutions Group March 12, 2026 City of Lincoln, CA Figure 6. City of Lincoln facilities
The City of Lincoln's enterprise wide-area network2, depicted in Figure 7, connects eight sites— City Hall, Fire Stations 33, 34, and 35, Main Library, Police Department, Public Works Corporation Yard, and Recreation Department—via Ethernet Local Area Network (ELAN) dedicated circuits. All sites connect to City Hall, which has primary and secondary dedicated internet access (DIA) connections. The Police Department has DIA and a service that connects it to the Rocklin Police Department and Sacramento County Sheriff’s Department. The library also has DIA via CENIC3for public internet access. There is also a public infrastructure site at 3600 Vista De Madera that also has DIA.
2 The Enterprise Wide-Area Network (WAN) connectivity is currently leased by the City through the provider, Astound.
3 CENIC is a non-profit corporation that provides network services for education and research institutions in California.
City Boundary
Public Building
Community Center/Park
Fire Station
Medical Facility
Police Department
School
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City of Lincoln Broadband Master Plan Page 13
ENTRUST Solutions Group March 12, 2026 City of Lincoln, CA Figure 7. City Lincoln wide-area network connections between sites The connections range from 100 Mbps to 2 Gbps, as shown in Table 1, and average 293 Mbps.
The speeds listed refer to download speeds as information was not provided regarding upload speeds. The DIA connections provided by Astound Broadband can vary depending on the type of connection (coaxial cable vs. fiber optics); cable typically provides upload speeds in the range of 5 to 50 Mbps but fiber connections can achieve upload speeds symmetrical with the download speed. The City of Lincoln pays an average of about $713 per month for these connections, which equates to an average of $4.39 per Mbps per month. In total, the City pays over $9,000 per month for all of these connections or $119,700 per year.
Table 1. Costs and speeds of connections to City of Lincoln facilities Site Service Speed
(Mbps)
Monthly
Cost
Per Mbps
City Hall DIA (primary) 2000 $2,100.00 $1.05
City Hall DIA (secondary) 100 $600.00 $6.00
City Hall ELAN 200 $580.00 $2.90
Fire Station 33 ELAN 200 $580.00 $2.90
Fire Station 34 ELAN 100 $540.00 $5.40
Fire Station 35 ELAN 100 $540.00 $5.40
Library ELAN 100 $540.00 $5.40
Police Department DIA 500 $840.00 $1.68
Police Department ELAN 200 $580.00 $2.90
Police Department EPL 100 $755.00 $7.55
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ENTRUST Solutions Group March 12, 2026 City of Lincoln, CA Site Service Speed
(Mbps)
Monthly
Cost
Per Mbps
Public Works Corporation
Yard
ELAN 200 $580.00 $2.90
Recreation Department ELAN 100 $540.00 $5.40
Tank 1 DIA 100 $600 $6.00
Wastewater Treatment Plant
(terminates at City Hall)
DIA 100 $600.00 $6.00
There is City-owned fiber between Fire Station 33 and the McBean Pool. Point-to-point wireless is used to connect City Hall to the airport, Civic Auditorium, and Wastewater Treatment Plant. It is also used to connect the Carnegie Library to the Civic Center, the McBean Pavilion to the pool, and McBean Stadium to pavilion. The City plans to add wireless link to one of its water tanks, and from that to two other tanks and pump stations. The City uses cellular to connect traffic cameras at the intersection of Ferrari and Joiner as a pilot. Additional locations are being considered for such cameras.
Long Term Planning
The City of Lincoln’s General Plan 2050 was produced in 2008. The plan describes how and where the city is to develop to achieve citizen’s vision for the area. While we did not find it explicitly stated, the plan indicates the vision is for a self‐sustaining, integrated, and connected community.4 As illustrated in Figure 8, The General Plan provides the basis for specific planning, which determines acceptable land use and zoning for types of structures and density of development. It includes multiple elements, each of which has multiple goals, which have multiple policies and actions intended to achieve those goals, all of which apply across all the specific plans. Several of the elements are directly relevant to broadband and related assets. 4 General Plan 2050, City of Lincoln, March 2008, https://www.lincolnca.gov/en/businessand-development/resources/Documents/general-plan-2050.pdf, page 2-6, paragraph 2. 1159
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ENTRUST Solutions Group March 12, 2026 City of Lincoln, CA Figure 8. The City of Lincoln's planning process and regulatory structure The Economic Development Element “establishes the goals, policies, and implementation programs for directing economic growth towards targeted City objectives, including increasing the jobs to housing balance, attracting targeted business, and providing for a financially self‐ sustaining community. A key factor in shaping the future for Lincoln will be the niche within the regional economy Lincoln chooses to fill regarding its future development.”5Its goals include promoting strong economic and fiscal base and coordinating long‐term land use and infrastructure decisions to achieve a diverse and balanced mix of employment and residential opportunities and retain existing businesses and attract new businesses to provide jobs for current and future residents. Goals focus on the Lincoln Airport and Downtown area.
The Health and Safety Element focuses on fire and police services to provide “a high quality of life for the City of Lincoln’s residents … minimize natural hazard risks … as well as manmade hazards and nuisances.”6“The development and quality of life for the City of Lincoln is dependent on the availability of adequate public facilities and services,” the Public Facilities & Services Element notes. “Each type of service has a unique set of constraints and must adapt to growth and change differently.”7 The Transportation Element notes that “[a] city is both defined and constrained by the network of highways, streets, railroads, sidewalks, trails, and transit services that move its residents and goods throughout the city.”8“The purpose of the Open Space and Conservation Element is to protect and enhance the natural and cultural resources that make the City of Lincoln unique.”9
5 Ibid, page 3-1, paragraph 1.
6 Ibid, page 8-1, paragraph 1.
7 Ibid, page 6-1, paragraph 1.
8 Ibid, page 5-1, paragraph 1.
9 Ibid, page 7-1, paragraph 1.
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ENTRUST Solutions Group March 12, 2026 City of Lincoln, CA Figure 9. City of Lincoln Specific Plan areas10
Lincoln’s specific plans are for structured, mixed-use development that balances residential growth, commercial expansion, transportation infrastructure, and community amenities in particular areas, shown Figure 9. Each plan integrates unique characteristics while aligning with the city’s broader objectives of fostering a vibrant, sustainable community with public facilities and accessible, interconnected neighborhoods. Village centers and corridors serve as focal points, providing walkable access to amenities and services for residents. The plans prioritize transportation connectivity, with proposed realignments, arterial roads, and regional linkages for efficient traffic flow and integration with the greater Sacramento metropolitan area.
Environmental stewardship is also a recurring theme, with Lincoln exceeding its 40% openspace requirement in several plans. Parks, trails, and preserved natural areas are integrated into the designs, enhancing quality of life, and promoting sustainability. The specific plans include housing options for a wide range of demographics and income levels while supporting higher-density housing near transit and village centers. As economic development is central to the city’s vision, the specific plans also have zones for commercial, industrial, and healthcare uses aimed at diversifying Lincoln’s economy.
Lincoln’s specific plans all exhibit a coordinated, phased approach that aligns with the city’s General Plan, balancing development across various regions while ensuring long-term 10 “SUD-B NEQ” stands for Special Use District B Northeast Quadrant.
City Boundary
Sphere of Influence
Lincoln 270
Lincoln Crossing
SUD-B NEQ
Sterling Pointe
Three D
Twelve Bridges
Village 1
Village 5
Village 5A
Village 7
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ENTRUST Solutions Group March 12, 2026 City of Lincoln, CA sustainability. Connectivity is a core element. Village-specific plans (e.g., Villages 1, 5, and 7) linked to larger developments like Twelve Bridges and Lincoln 270 to create a cohesive urban framework. The plans are designed with community-centric principles, prioritizing accessibility to amenities, services, and recreational spaces. Infrastructure improvements, such as enhanced roadways and transit-oriented development, are integrated to support regional and local connectivity. Open spaces are preserved not only for environmental benefit but also to reinforce Lincoln’s identity as a balanced and livable community.
Figure 10. Villages outside the City of Lincoln
There is no explicit mention of broadband infrastructure or digital connectivity in the General or Specific Plans. Given the vintage of the plan and level of development, there are limited opportunities to integrate broadband infrastructure into these plans. Village 5 and Village 5A are the exceptions because they are relatively undeveloped. As shown in Figure 10, there are multiple villages envisioned in the City’s sphere of influence and in a portion of unincorporated Placer County—Bickford Ranch—outside of it. Broadband assets could be deployed in these areas in conjunction with other infrastructure.
Capital Improvement Program
The City of Lincoln’s Capital Improvement Program (CIP) is a set of projects to enhance and maintain public facilities, infrastructure, and services that encompasses a wide range of projects: sidewalk repairs, intersection improvements, water distribution upgrades, and utility rehabilitation. The CIP is updated annually as part of the city’s budget process to align with City Boundary
Sphere of Influence
Lakeview Farms
Special Use District A
Special Use District B
Special Use District C
Village 2
Village 3
Village 4
Village 5
Bickford Ranch
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ENTRUST Solutions Group March 12, 2026 City of Lincoln, CA fiscal planning and resource allocation.11 The CIP offers significant opportunities to integrate broadband infrastructure into ongoing and planned developments. While none of the projects are directly focused on broadband, their scope and nature make them compatible with strategies like conduit installation and joint trenching to support future broadband expansion.
Projects focused on roadway and intersection improvements, such as the Ferrari Ranch Road Intersection Improvements (644) and the E. Joiner Parkway and Del Webb Boulevard Intersection Improvements (682), are ideal candidates for incorporating broadband infrastructure. These projects involve significant excavation work, including widening roads and constructing roundabouts, making them well-suited for the installation of fiber conduit during construction, which if done concurrent with project excavation can be added for a fraction of the typical cost.
Other projects, with total budget of $3,406,826, may be opportunities for facilitating broadband development. Annual Sidewalk Repair (646) may incorporate broadband conduit alongside sidewalk and curb repairs to minimize future disruptions. UPRR Sewer Rehabilitation (477) involves work in utility rights-of-way that might accommodate conduit installation. Water Distribution Rehabilitation (485 & 487) could incorporate conduit during the replacement of water pipelines and fire hydrants. Recreational Lighting Replacement (380) involves the repair and replacement of lighting systems in recreational areas, which could accommodate 5G infrastructure.
In addition to the CIP, Lincoln has developed a series of Public Infrastructure Master Plans that serve as long-term blueprints for transportation, urban design, and public utilities. The master plans prioritize current deficiencies while also preparing for anticipated growth, ensuring that Lincoln’s infrastructure can accommodate evolving demands. Notable components include plans for downtown revitalization, road widening, and environmental sustainability.12 Together, the CIP and Public Infrastructure Master Plans guide Lincoln’s approach to infrastructure development, balancing immediate needs with strategic, future-focused planning. These initiatives collectively ensure that Lincoln continues to enhance its quality of life, support economic growth, and position itself as a well-planned, sustainable community. However, there is no separate broadband, fiber, technology plan or technology fund for broadband expansion. 11 Capital Improvement Projects | City of Lincoln
12 City of Lincoln. (n.d.). Public Infrastructure Master Plans. Retrieved November 25, 2024, from https://www.lincolnca.gov/en/business-and-development/public-infrastructure-masterplans.aspx 1163
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ENTRUST Solutions Group March 12, 2026 City of Lincoln, CA
2.2 Private Infrastructure
Towers
There are at least nineteen privately owned “macro” wireless communications facilities within the City, with one in the process for approval. These are lattice or monopole towers or poles that are located for optimal signal coverage. The typical tower structure in Lincoln is 99 feet tall. As shown in Figure 11, the towers are reasonably widely distributed across the northern portion of the city. Only two located South of Moore Road, one located in the Village 5 Specific Plan area, and none located in the 12 Bridges Specific Plan Area.
Figure 11. Towers and antenna by type of placement in Lincoln Wireless facilities typically have fiber connections for backhaul to providers’ core networks.
Various providers may place their antennas at different heights on the same structure. Existing vertical structures like building rooftops or water tanks are also used for antenna placement.
There are 22 locations hosting wireless antenna, including nine buildings and two water tanks.
Antenna Placement
Building
Building w/Antenna
Building w/Mast
Building w/Pole
None/Not Applicable
Pipe
Pole
Tower
Utility Pole
Water/Gas Tank
City Limit
Tower
Pole
Other
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ENTRUST Solutions Group March 12, 2026 City of Lincoln, CA Fourteen of these antennas are for City use. Areas in the southeast part of the city have few tower or antenna structures. Some sites within the City’s GIS dataset did not have identifying information (“None/Not Applicable”).
These sites are valuable to the City as they enhance and improve wireless connectivity for both City services and communications as well there is an opportunity to lease to private carriers. This often results in enhanced residential mobile coverage. These vertical assets can also serve to potentially generate revenue with colocation opportunities where one pole can house multiple antennas from different providers (AT&T, Verizon, T-Mobile, etc).
2.3 Summary of Findings
Lincoln has limited infrastructure for broadband
expansion.
Lincoln’s horizontal and vertical infrastructure collectively offers significant opportunities for broadband deployment, but both require targeted upgrades and strategic integration to realize their full potential. Over 100 miles of sewer, stormwater, and water systems provide pathways for underground conduits, forming the groundwork for a robust broadband network. Similarly, the city’s streetlight poles, utility poles, and traffic signals represent highly adaptable assets that can support cost-effective wireless technologies such as 5G and fixed wireless access. Traffic signals along major economic corridors could serve as fiber backbones, enabling public safety applications, smart traffic management, and municipal operations, while streetlights and utility poles provide mounting points for wireless broadband to underserved areas. With focused investment to modernize and connect these assets, their potential to bridge the digital divide and support city initiatives will accelerate economic growth and technological advancement within the city.
Incorporating broadband with capital improvement
projects can optimize costs and outcomes.
The City’s Capital Improvement Program presents an unmatched opportunity to integrate broadband into city infrastructure at minimal incremental cost. Projects like road widening and water system rehabilitation inherently involve excavation, making them ideal for joint trenching or conduit installation. Without proactive broadband planning, these opportunities could be missed, leading to higher costs for future broadband deployment. By embedding broadband considerations into its CIP, Lincoln can align infrastructure upgrades with long-term digital connectivity goals, ensuring the city is prepared to meet the demands of residents, businesses, and smart city technologies.
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ENTRUST Solutions Group March 12, 2026 City of Lincoln, CA Integrating broadband planning into Lincoln’s Specific
Plans, particularly those outside the City boundaries, in its sphere of influence, could facilitate development.
Incorporating dedicated broadband provisions into Lincoln’s specific plans presents an opportunity to accelerate the city’s growth and achieve its development goals. High-speed connectivity is essential for attracting businesses, enhancing educational opportunities, and enabling efficient municipal operations. By proactively planning for broadband infrastructure in areas like Village 5, the city can bridge the digital divide, unlock the potential of key growth zones, and foster equitable development. Prioritizing broadband in planning documents will position Lincoln as a forward-thinking, digitally connected city, ready to support economic diversification and improve quality of life for all residents.
A long-term strategy for opportunistically developing Cityowned network assets is the most economical approach and would provide the City with more control over its critical infrastructure.
Lincoln should consider investing in its own network infrastructure to ensure long-term control over critical broadband resources and reduce reliance on external providers. A city-owned network, such as a municipal fiber backbone, could support public-private partnerships while ensuring the infrastructure aligns with the city’s strategic goals. This approach would enable Lincoln to prioritize underserved areas, support public safety and smart city initiatives, and retain revenue generated from leasing or usage agreements. Moreover, city-owned infrastructure can provide the flexibility to adapt to evolving technologies and future demands, ensuring that Lincoln remains a forward-looking, digitally connected community. Developing such a network would require a phased approach, starting with feasibility studies, pilot programs, and a clear funding strategy that leverages grants, public-private partnerships, and city resources.
Public-private partnerships can accelerate broadband
deployment and bridge funding gaps.
To fully leverage Lincoln’s existing infrastructure and address broadband gaps, collaboration with private entities is essential. Public-private partnerships (P3s) offer opportunities to share costs, reduce financial barriers, and expedite deployment. By leasing city-owned assets, such as streetlights and utility poles, to broadband providers or partnering with wireless carriers, Lincoln can attract investment while retaining control over critical infrastructure. These partnerships could enable the city to implement advanced technologies like 5G and fixed wireless access, extend broadband coverage to underserved areas, and generate revenue to reinvest in infrastructure improvements. Embracing innovative funding strategies will position Lincoln to achieve its connectivity goals efficiently and equitably. 1166
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ENTRUST Solutions Group March 12, 2026 City of Lincoln, CA
3. Market Analysis
ENTRUST analyzed the broadband infrastructure and services in the City of Lincoln to determine the options available to residents, businesses, and organizations. First, we evaluated service offerings by incumbent internet service providers (ISPs) in the city with a particular focus on facilities-based carriers, or those that own their own physical infrastructure including fiber, copper, coaxial cable, or fixed wireless equipment.
The evaluation included pricing, service tiers, access, and market division utilizing public data such as the updated 2023 FCC Broadband Map, carriers’ websites, third party studies and reports, and ENTRUST’s knowledge of the broadband environment. ENTRUST also contacted wireline ISPs and had direct conversations with their representatives to better understand their strategies in the City. Descriptions of each of these providers along with summaries of satellite and mobile provider options are below. The Results section concludes with descriptions of metropolitan, middle mile, and long-haul networks.
ENTRUST checked the internet services available to 10 randomly selected residential addresses and 5 randomly selected business addresses in different parts of the city via providers’ websites. We compared provider data with the FCC Broadband Map and conducted random sampling from various areas across the city to validate the actual services available as shown in Figure 12.
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ENTRUST Solutions Group March 12, 2026 City of Lincoln, CA Figure 12. Randomly selected address locations
In total, there were three major wireline service providers (AT&T, Astound and Fidium Fiber) representing 3 access technologies (fiber, cable, and DSL) and three fixed wireless providers (AT&T, T-Mobile and Verizon serving these locations). Broadband service for each location is summarized on Table 2, in which all data is based on the FCC National Broadband Map13.
Table 2. Sites tested for providers and service tiers14 Address AT&T Astound Fidium
Fiber
Fixed Wireless
AT&T T-Mobile Verizon
Newbridge
Lane
DSL Cable FWA
Secret Lake
Loop
DSL Cable
Romano
Avenue
Fiber Cable FWA
J Street Fiber Cable Fiber FWA
13 See https://broadbandmap.fcc.gov/home
14 Per broadbandmap.fcc.com as of June 30, 2023, and last updated on April 16, 2024 Randomly Selected
Address
City Limits
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ENTRUST Solutions Group March 12, 2026 City of Lincoln, CA Address AT&T Astound Fidium
Fiber
Fixed Wireless
AT&T T-Mobile Verizon
Karchner
Road
H Street Fiber Cable Fiber FWA
Winding
Way
Cable FWA FWA
Bedell
Street
Fiber Cable FWA
Redcliffe
Lane
Fiber Cable FWA
Sun City
Lane
Fiber Cable
East
Avenue
Fiber Cable
Sterling
Pointe
Center
Fiber Cable Fiber
Flocchini
Circle
Fiber Cable
Lincoln
Boulevard
DSL Cable FWA
3.1 Wired Service Providers
Astound Broadband
Astound is the sixth largest cable provider in the U.S with over 1 million residential and business customers spread across eight of the ten top metro markets in the country. In Lincoln, Wave Broadband operated as the incumbent cable provider until they were acquired in 2017 by Astound Broadband. In 2021 Astound was acquired by Stonepeak for $8.1 billion and continues to grow by acquiring established providers in key markets.15 Astound’s network is based on a Hybrid Fiber-Coax (HFC) architecture, which includes a fiber backbone, typically laid out in a ring, with coax cable for last mile distribution, as illustrated in Figure 13. HFC broadband networks are designed to send large amounts of data from the network to the end point such as the home. While HFC networks can provide download speeds more than 1 Gbps, the networks are currently limited to a maximum upload speed of only 35 Mbps.
15 "Stonepeak Closes Acquisition of Astound Broadband," Business Wire, August 19, 2021, https://www.businesswire.com/news/home/20210819005580/en/. 1169
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ENTRUST Solutions Group March 12, 2026 City of Lincoln, CA Figure 13. Hybrid fiber-coax network architecture
As the legacy cable company, Astound covers practically all of the city’s residential areas through their HFC network, as shown in Figure 14. Astound’ s cable services in the City are based on the DOCSIS 3.1 standard, which has download data rates up to 1 Gbps.16 However, the upload data rate is limited to 35 Mbps. HFC networks are a shared network, so the actual performance will vary based on the number of users at a particular time. Consumer speeds are “best effort,” which is why ISPs add the phrase “up to” when specifying data rates. Astound’s advertised residential speeds (
Table 3) are asymmetrical (different download and upload speeds). Astound’s packages are offered with a limited-term promotional price that resets after 12 months. Prices are shown in Table 3.
The current generation of cable modem technology from CableLabs (DOCSIS 4.0) supports downstream data rates of 10 Gbps and upstream data of close to 6 Gbps. The systems incorporating the new technology were expected to first launch in 2025 with national deployments taking upward of 5 years, but cable companies have yet to provide details on locations for upgrades, and launch schedules have been consistently delayed. As part of the 4.0 migration, upgrades in the outside plant electronics are required. Astound has completed much of this upgrade and offers a 2 Gbps service with upstream data rates targeted at 100s of Mbps.
This is an interim solution that will reduce the speed gap between their HFC network and new full fiber networks. While the company has been upgrading its network to offer higher-speed services, the specific technologies employed, have not been disclosed. 16 The Data Over Cable Service Interface Specification (DOCSIS) is the standard protocol for transmitting over an HFC network.
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ENTRUST Solutions Group March 12, 2026 City of Lincoln, CA Figure 14. Locations in Lincoln with internet service available from Astound17 Table 3. Astound residential internet service offerings in Lincoln Package
Type of
Connection
Download
Speed
Upload
Speed
Promo
MRC MRC
MRC per
Mbps18
Internet 300 Cable 300 Mbps 22 Mbps $20 $30 $0.10
Internet 600 Cable 600 Mbps 22 Mbps $35 $45 $0.08
Internet 1000 Cable 1000 Mbps 54 Mbps $45 $55 $0.06
Internet 1500 Cable 1500 Mbps 55 Mbps $55 $65 $0.04
Astound also offers fiber-based services in select areas where demand and feasibility align with their market strategy, typically targeting business customers or residential developments that require higher symmetrical upload and download speeds. In these cases, Astound deploys direct fiber connections, bypassing the limitations of their Hybrid Fiber-Coax (HFC) network. 17 Source: FCC Fabric Data
18 MRC/Mbps is calculated using download speeds.
Cable Served
Address
Fiber Served Address
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ENTRUST Solutions Group March 12, 2026 City of Lincoln, CA However, their fiber deployment strategy appears to vary by location, as some areas are entirely new builds without utilizing the existing cable physical plant, while others seem to be overbuilt on top of their existing infrastructure. This inconsistency makes it challenging to determine the precise factors influencing where Astound extends its fiber footprint versus relying on its HFC network services.
AT&T
AT&T is the Incumbent Local Exchange Carrier (ILEC), or legacy telephone company, in Lincoln. Serving 19,749 of the 23,262 broadband available locations in the area (84.9%), Currently, AT&T services approximately 44% of the existing fiber market in Lincoln, but only 26% of its broadband accessible addresses have fiber connectivity. The remainder are served by DSL, illustrated Figure 15, which is essentially obsolete, with no new DSL infrastructure being deployed. The data rates supported by DSL depend on the length of the copper wire and the line equipment used. Consequently, DSL may not meet the FCC definition of 25 Mbps download and 3 Mbps upload, let alone the California minimum standards of 100 Mbps/20 Mbps, and cannot meet the speeds or service levels required by most businesses.
Figure 15. Digital subscriber line (DSL) service
AT&T has been actively phasing out its copper-based DSL services in California, transitioning customers to more advanced technologies. AT&T offers Lincoln customers a maximum DSL data rate of 50 Mbps but FCC data indicates the maximum download speed in 17 Mbps with maximum upload of 0.5 Mbps. AT&T’s maximum fiber data rate of 5 Gbps. AT&T’s footprint and area pricing are shown in Figure 16 and Table 4. Of the 23,262 Lincoln addresses in the FCC’s 1172
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ENTRUST Solutions Group March 12, 2026 City of Lincoln, CA Fabric data, 50.5% (11,737) have fiber availability, with AT&T covering 44.4% (5,216) of those fiber locations and over 99% (14,533) of the 14,655 DSL locations. .19
Figure 16. Locations in Lincoln with internet service available from AT&T20 During our discussion with AT&T they indicated that they are discouraging new DSL subscriptions and guiding customers toward the alternative services. While fiber-optic service is a primary focus of AT&T's upgrades, the replacement strategy is not exclusively fiber. In areas where fiber deployment is not feasible, AT&T is offering alternatives such as AT&T Internet Air, a wireless home internet service leveraging AT&T's network. 19 Source: FCC Fabric Data
20 Source: FCC Fabric Data
DSL-served Address
Fiber-served
Address
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ENTRUST Solutions Group March 12, 2026 City of Lincoln, CA Table 4. AT&T residential internet service offerings in Lincoln Speed (Mbps) Monthly Recurring Cost (MRC)
Service Type Download Upload Promo Regular per Mbps
Internet DSL DSL 17 0.5 $60 $70 $3.89
Internet 300 Fiber 300 300 $55 $65 $0.21
Internet 500 Fiber 500 500 $65 $75 $0.15
Internet 1000 Fiber 1,000 1,000 $80 $90 $0.09
Internet 2000 Fiber 2,000 2,000 $145 $155 $0.07
Internet 5000 Fiber 5,000 5,000 $245 $255 $0.50
Fidium Fiber
Figure 17. Locations in Lincoln with internet service available from Fidium Fiber Fidium Fiber (Fidium), is the residential fiber-to-the-home (FTTH) subsidiary of Consolidated Communications, which operates across 23 western states. In 2012, Consolidated 1174
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ENTRUST Solutions Group March 12, 2026 City of Lincoln, CA Communications acquired the assets of SureWest Communications, which had already developed a fiber presence in parts of California, including Lincoln. Fidium serves 5,823 of the 23,262 broadband serviceable locations in the area (25%), mostly located in the northwest part of the city as shown in Figure 17.
21 Fidium uses XGS-PON (10 Gigabit Symmetrical Passive
Optical Network) technology, which supports speeds up to 10 Gbps.22 Its current price offerings are show in Table 5
Table 5. Fidium Fiber business and residential internet service offerings in Lincoln Service Type Speed (Mbps)23 Monthly Recurring Cost (MRC) Download Upload Promo Regular per Mbps
100 Residential 100 100 $25 $45 $0.45
300 Residential 300 300 $40 $60 $0.20
1G Supreme Residential 1,000 1,000 $60 $80 $0.08
@ Work 300 Business 300 300 $65 $65 $0.21
@ Work 600 Business 600 600 $80 $80 $0.13
@ Work 1000 Business 1,000 1,000 $90 $90 $0.09
Succeed.Net and Lincoln Crossing HOA
The Lincoln Crossing HOA acquired the fiber infrastructure and network equipment following the bankruptcy of the previous provider, Gigamonster. The HOA selected Succeed.Net, an independent ISP based in the Sacramento Valley, to provide internet to the 3,067 homes in the HOA. Succeed.Net’s role is to operate and maintain the infrastructure. Currently, the HOA members get symmetrical 250 Mbps internet as part of their membership, at no additional cost, as shown in Table 6. They can upgrade to symmetrical 1 Gbps. The HOA and Succeed.Net plan to offer symmetrical 10 Gbps service in 2025 at a price to be determined. Succeed.Net also offers managed Wi-Fi 6, static IP addresses, and VOIP services.
Table 6. Lincoln Crossing HOA/Succeed.net service offerings Service Type Download Upload MRC MRC per Mbps
250 Mb Fiber 250 Mbps 250 Mbps NA NA
1GIG Fiber 1 Gbps 1 Gbps $20.00 $0.02
3.2 Fixed Wireless Access (FWA) Providers
Wireless internet access has been widely used in rural environments for years. Wireless internet service providers (WISPs) use microwave, wireless optical, Wi-Fi, and other proprietary 21 Source: FCC Fabric Data.
22 Consolidated Launches New Fidium Fiber Brand, Telecompetitor, December 2, 2021, https://www.telecompetitor.com/consolidated-launches-new-fidium-fiber-brand. 23 Indicates Maximum Upload Speed.
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ENTRUST Solutions Group March 12, 2026 City of Lincoln, CA technologies. 5G, 4G LTE,24 and Citizen Band Radio Service (CBRS), and other wireless technology are now being used to provide fixed wireless access (FWA) to residences and businesses in suburban and rural areas. Mobile network operators (MNO) T-Mobile, Verizon, and AT&T all provide this service via their 5G and cellular networks along with voice and lowpower wide-area network narrowband (LPWAN) services, as shown in Figure 18.
The primary difference between cellular and FWA access is mobility. Cellular subscribers can move between and within cells, but speeds are limited due to varying connection quality as they move. FWA subscribers get better performance because they do not move. The nominal download speeds of FWA are between 33 and 182 Mbps, which is generally faster than satellite and DSL, speeds vary based on the protocol (5G is much faster than 4G LTE), distance the provider’s antenna/towers, the total amount of network traffic/users, and foliage, heavy weather, and other things that might interfere with the signal.
Figure 18. Cellular wireless network architecture
AT&T’s FWA service uses 4G technology and is expanding to 5G in areas with 5G network coverage to improve speed and reliability. AT&T’s is positioning FWA as a replacement for areas where their fiber infrastructure is limited or not economical. T-Mobile provides 5G and 4G LTE FWA services to households across all 50 states in the U.S. Its residential plans' main features include contract-free services and unlimited data access. Verizon offers unlimited data and contract-free plans nationwide.
24 LTE stands for “long-term evolution” because it was originally created to facilitate the transition from 4G networks to 5G but is now commonly used in conjunction with 5G. 1176
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ENTRUST Solutions Group March 12, 2026 City of Lincoln, CA Table 7. FWA services compared
Service Maximum Speed (Mbps) MRC Notes
Download Upload
AT&T Internet Air 225 30 $ 60 Unlimited data; No annual contract
T-Mobile 5G Home
Internet 182 30 $ 50
Unlimited data; No annual
contract; No Equipment
Fees
Verizon 5G Home
Internet 100 10 $ 50 Unlimited data; No annual contract Verizon 5G Home
Plus Internet 300 20 $ 70 Unlimited data; 10-year price guarantee DigitalPath, Inc. provides fixed wireless internet services to households and businesses across Northern and Central California, including Lincoln. With coverage reaching approximately 76% of Lincoln, DigitalPath offers download speeds of up to 50 Mbps in rural areas and 100 Mbps in Metro areas.25 The company focuses on contract-free services as an alternative to traditional wired connections. Its service quality depends on factors like distance from the provider's tower, terrain, and weather conditions. DigitalPath reports annual revenue of $20.2 million, reflecting a substantial customer base in the region.
DigitalPath's pricing for broadband coverage is among the highest in the market, largely due to its focus on serving remote and underserved locations. The costs associated with operating in these areas do not benefit from the economies of scale seen in more densely populated regions. Despite the premium pricing, DigitalPath provides an essential service, delivering reliable internet access to users in remote locations who may have few, if any, alternative options for connectivity. Their pricing plans are found in Table 8.
Table 8. DigitalPath service offerings in Lincoln
Service Type Download Speed MRC MRC per
Mbps
Gen8 Metro FWA 100 Mbps $70 $0.70
Gen8 Rural FWA 50 Mbps $70 $0.70
Gen7 Metro FWA 25 Mbps $66 $2.64
Gen7 Rural FWA 25 Mbps $76 $3.04
3.3 Cellular Data Services
According to the Federal Communications Commission (FCC), the City of Lincoln is fully covered by 4G/5G data service from the three major U.S. mobile operators, AT&T, Verizon, and T-Mobile. This includes connections to outdoor stationery devices that nominally provides 35/5 25 Broadbandmap.fcc.com
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ENTRUST Solutions Group March 12, 2026 City of Lincoln, CA Mbps access, which is an indicator of where FWA service is practical. Data on actual coverage is collected from individuals by CoverageMap.com, which purports to show accurate, real-world performance of cellular networks in each area,26 indicates limited coverage outside of major corridors. Most 5G rollout to date has occurred in cities with dense populations, with deployment into suburban areas slowly rolling out when demand exceeds 4G/LTE capabilities.
Figure 19, Figure 20, and Figure 21
27 show areas with verified 5G coverage for the three major mobile network operators (MNO). It should be noted that these maps were generated using a third-party service before the City’s annexations and as a result displays the older city boundary.
These maps show signal strength. A “strong” signal can support real-time 4k video streaming and video calls. “Average” signal strength is adequate for 480-pixel video streaming, web browsing, and streaming music. Only phone calls and texting are practical for “poor” signal strength.
Figure 19. AT&T LTE/5G coverage in Lincoln
26 See https://coveragemap.com/news/community-contributed-cellular-coverage-map for additional information on CoverageMap.com and how they gather data. 27 Source: https://map.coveragemap.com/
Strong
Average
Poor
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ENTRUST Solutions Group March 12, 2026 City of Lincoln, CA Figure 20. T-Mobile LTE/5G verified coverage in Lincoln Figure 21. Verizon LTE/ 5G verified coverage in Lincoln Strong
Average
Poor
Strong
Average
Poor
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3.4 GSO and NGSO Satellite Services
Historically, two satellite internet companies serviced the entire North America; HughesNet and ViaSat. These are based on geosynchronous satellites (GEO) that orbit ~23,000 miles above the Earth. Even though the signals travel at the speed of light, the 23,000 miles up and 23,000 miles down add substantial latencies (600-700 milliseconds) and signal degradations that minimize the effective bitrates. There are at least two Low Earth Orbit Satellite (LEOS) constellations being deployed today to provide internet access, particularly in geographically challenging locations or where cost exceeds demand: Starlink, from Elon Musk’s SpaceX Corporation, and OneWeb, a UK-based consortia. These satellites orbit the earth at altitudes of about 350-500 miles. Data rates range from 20-200 Mbps download and 5-20 Mbps upload, comparable with cable HFC technology. Data rates of 50-100 Mbps download are expected once the full constellation of satellites is launched over the next few years.
Although satellites provide connectivity to remote locations and those where fiber is not currently available, they cannot provide gigabit speeds or symmetrical connections. With pricing that starts at $110 per month with a one-time $599 equipment and service initiation fee, Starlink packages are generally not cost-competitive with fiber-based services. Due to a greater likelihood of periodic service interruptions and speed constraints, ENTRUST does not consider satellite broadband to be a viable primary connection for urban and suburban locations.
However, it may be valuable as secondary back-up connection for government and business sites.
3.5 Metropolitan, Middle Mile, and LongHaul Networks
Metro networks, as the name implies, are designed to connect major sites in relatively dense metropolitan areas to each other and to other service providers, typically via colocation data centers or exchange facilities. Metro fiber services are priced on an individual case basis, based on the service level, number of sites, distance, and bandwidth required. Some carriers will lease dark fiber strands, but metro fiber services are generally lit, or active services. Figure 22 illustrates the metro fiber routes in Lincoln.
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ENTRUST Solutions Group March 12, 2026 City of Lincoln, CA Figure 22. Metro fiber routes in Lincoln28
The companies that build, own, and operate metro and long-haul fiber are the result of multiple mergers and acquisitions, which may impact how these assets are developed and used.
Astound Broadband is a holding company that developed via acquisitions of regional network operators enTouch Systems, Grande Communications, RCN, and Wave Broadband, which was originally named Astound. The company use the Wave brand for residential and offers fiber internet, connectivity, and voice services for business under the Astound Business Solutions brand. Consolidated Communications provides a variety of services, including high-speed internet, TV, and phone solutions for residential and business customers. Fidium Fiber is the company’s primary brand for residential fiber services. The Zayo metro fiber in Lincoln was originally developed under the Integra brand, before being spun off as Electric Lightwave, which was acquired by Zayo in 2016.
28 Source: https://www.fiberlocator.com
Astound
(Wave)
Zayo
Consolidated
Wave
Business
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ENTRUST Solutions Group March 12, 2026 City of Lincoln, CA Figure 23. Long haul fiber routes through the Lincoln area29 Long haul networks are generally only accessible at interconnection points in major cities and are of limited use for local applications. The long haul easement may be used to deploy local and middle-mile fiber particularly to reach distant interconnection points. As depicted in Figure 23, Lincoln has multiple long haul routes running through it, owned by Arelion, T-Mobile, and Zayo.
Formerly known as Telia Carrier, Arelion is owned by a Swedish investment company, Polhem Infra. It operates a global network with an extensive presence in North America. After its merger with T-Mobile in 2020, Sprint's long-haul fiber assets were integrated into T-Mobile’s operations, which are primarily used to interconnect T-Mobile’s switching centers, but then later sold to Cogent Communications.30 Founded in 2007, Zayo grew by a series of acquisitions, including Allstream and Electric Lightwave (spun off from Integra). It was acquired by Digital Colony and 29 Source: https://www.fiberlocator.com
30 Fierce Networks. "T-Mobile strikes $1 billion deal to sell Sprint fiber assets to Cogent." Fierce Networks, August 2022. Accessed via Fierce Networks.
Arelion
Cogent
Zayo
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ENTRUST Solutions Group March 12, 2026 City of Lincoln, CA EQT Infrastructure in 2019. Like Arelion, Zayo operates a global network but the bulk of its infrastructure is in North America.
California Middle Mile Broadband Initiative
The State of California budgeted $3.25B from the state’s American Rescue Plan funds for a Middle Mile Broadband Initiative (MMBI) to build a statewide, open access, middle-mile network to bring affordable, redundant connectivity to all parts of the state. The network is being built by the California Department of Technology (CDT), mostly in the Caltrans rights-of-way. It will be operated by a new organization, GoldenStateNet (GSN), that was spun out from CENIC, which operates the state’s education and research network, CalREN. Service offerings and pricing for cities and anchor institutions have not been published at the time of this memo but we anticipate that the offerings will be more economical than commercial services. The closest MMBI route to Lincoln is along Interstate 80 in Loomis as depicted in Figure 24. r
Figure 24. California MMBI route near Lincoln
MMBI
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ENTRUST Solutions Group March 12, 2026 City of Lincoln, CA
3.6 Summary of Findings
The City is well served with broadband but has limited fiber options and much of the City is subject to a cable monopoly.
According to FCC Broadband Serviceable Location Fabric,31 Lincoln has one of the highest fiber optic internet coverage rates in the Placer Valley Region, with 50.46% of its 23,262 service locations (residential and business) having fiber access, as shown Figure 25 and Table 9. This is more than 12.5% higher than the coverage average found in Placer County (37.83%), but less than Roseville. It is 13.5% less than the City of Sacramento (64.18%).
Figure 25. Availability of fiber-based broadband in Lincoln 31 The Federal Communications Commission’s (FCC) Broadband Serviceable Location (BSL) Fabric is a set of data for all locations in the United States, supplied to the FCC by internet service providers, indicating the services, including nominal speed, available at each location.
In this memo it is referred to as “FCC Fabric.”
Fiber-served Location
Location without fiber
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ENTRUST Solutions Group March 12, 2026 City of Lincoln, CA Table 9. Fiber-to-the-premises (FTTP) coverage in Placer Valley cities32 City FTTP
Coverage
Lincoln 50.5%
Auburn 29.1%
Loomis 29.4%
Rocklin 33.5%
Roseville 56.6%
The Lincoln broadband is not the typical duopoly.
Lincoln stands out from the typical broadband duopoly, as Astound, AT&T, and Fidium each hold significant market share across different segments of the broadband landscape. Fidium is currently the largest fiber provider in the area, while AT&T, leveraging its ILEC status and extensive DSL footprint, has the greatest potential to convert legacy infrastructure into future fiber customers. Astound dominates 99% of the cable market and has also captured nearly 6% of fiber customers.
Adding to this unique landscape, the in the Lincoln Crossing area has its own fiber-to-the-home network, operated by Succeed.net, This approach provides the most affordable fiber broadband in the market and. Basic broadband (250 Mbps) service is included in the homeowner’s association (HOA) dues. On one hand, this ensures all of the over 3,000 homes are connected, minimizes costs for the provider, promotes price stability, and provides substantial leverage to keep service levels high. On the other hand, residents do not have other options. The HOA has a monopoly for the area.
There are substantial gaps in 5G wireless service.
Despite robust wireline broadband coverage throughout Lincoln, large portions of the city— particularly beyond major traffic corridors like Highway 65, Lincoln Boulevard, and Joiner Parkway—have limited 5G coverage based on crowdsourced mapping. Signal quality diminishes as one moves further from the city center toward its outskirts. Coverage gaps are especially pronounced in the eastern residential neighborhoods, including those surrounding golf course communities, where all carriers appear to have no coverage. 32 Source: FCC Fabric
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ENTRUST Solutions Group March 12, 2026 City of Lincoln, CA
4. Needs Assessment & Gap Analysis
ENTRUST evaluated the needs of the community through several lenses and data sources, looking at existing indicators of need, a community survey, and direct outreach to stakeholders and community organizations to understand how technology and broadband either assists – or challenges – Lincoln’s economic opportunities and quality of place.
4.1 Indicators of Need
The Federal Communications Commission (FCC) identifies a location as “unserved” if it cannot secure fixed (wired) broadband services from any carrier at minimum speeds of 25 Mbps download and 3 Mbps upload; the commission defines “under-served” as locations that cannot access minimum broadband speeds of at least 100 Mbps download and 25 Mbps upload.
The Federal Communications Commission (FCC) gathers information on internet services from providers, which it refers to as the Broadband Serviceable Location Fabric (Fabric). Fabric data is available—via the National Broadband Map33—to public entities including the CPUC. Figure 26 shows the FCC identified un- and underserved locations, which are those that do not have (at least) 100/20 Mbps internet service available to them; few of these locations fall within City limits, and others have since been identified as mapping errors or new developments that actually are served by incumbent providers.
33 Visit https://broadbandmap.fcc.gov/home to view the data and https://help.bdc.fcc.gov/hc/enus/articles/5375384069659-What-is-the-Location-Fabric to learn more about the Fabric data. 1186
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ENTRUST Solutions Group March 12, 2026 City of Lincoln, CA Figure 26. FCC Identified Un- and Under-served Locations34 It is important to note that the FCC fabric only identifies what is available to consumers – not necessarily what they have secured (nor does it take into account other barriers to connectivity, such as price). The FCC fabric map (Figure 26) displays unserved areas outside of the City limits and these areas are simi-rural neighborhoods with low population density. While the FCC may consider Lincoln relatively “well-served,” there are gaps that were identified within the broadband survey and other data sources that indicate more areas of Lincoln are in need of broadband options and competition.
Figure 27 shows locations that were deemed eligible for the California Advanced Services Fund (CASF) that the CPUC administers to encourage deployment of high-quality advanced communications services to all Californians. There are some overlaps with the Fabric data, including some of the same mapping errors, but generally no significant grant eligibility for the City to pursue. As with the FCC Fabric, the CASF maps also only consider what is available and 34 Source: FCC California Fabric Data V.4
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ENTRUST Solutions Group March 12, 2026 City of Lincoln, CA do not take into account other digital barriers. Entrust explored many of these areas and determined that they were mapping errors as they are currently served by Astound.
Figure 27. CASF-eligible locations in and around Lincoln35 Notably, there were numerous speed test results from Sun City Lincoln Hills and adjacent neighborhoods that did not meet the 100/20 Mbps threshold for broadband despite the Fabric data indicating the area is fully served. There is a similar situation along Sun City Blvd. Low speeds were recorded at locations throughout Lincoln’s core and its residential developments.
Other data sources including ACS census data, showed areas of the City where number of households with an internet subscription lag behind the national average – a good indicator of a widening Digital Divide. Areas within the city with a higher percentage of households with no internet access (areas that exceed the national average) appear to be concentrated in the areas north and east of the Lincoln Hills Golf Club. The area north of the golf club roughly aligns with HUD designated low to moderate income census blocks, which is shown in Figure 29. 35 Source: https://broadbandmap.ca.gov/
City Limit
Sphere of Influence
CASF Eligible Locations
Eligible
Priority Eligible
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ENTRUST Solutions Group March 12, 2026 City of Lincoln, CA Figure 28. Percentage of households with internet by Census block group36 Finally, examining the areas of the City that fall within HUD’s low- to moderate income census blocks, as shown in Figure 29 appears to mirror the areas with lower internet subscriptions – lower than the national average in the southeast areas of the City. These two maps combined appear to suggest that there is a Digital Divide in Lincoln, and that the primary driver may be monthly subscription price in these neighborhoods.
36 Source: American Community Survey 5-year estimates, 2023, see https://data.census.gov/table/ACSDT5Y2023.B28011?q=internet+subscriptions > 95%
90% – 95%
National Average = 90%
75% - 90%
65% - 75%
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ENTRUST Solutions Group March 12, 2026 City of Lincoln, CA Figure 29. Low to moderate income census blocks37
4.2 Community Survey
There were 309 unique, usable responses to the survey, 190 (61%) of which were complete, meaning respondents made it to the end of the survey and clicked “Submit.” The results reported below, except connection speeds, come directly from respondents answering to the best of their knowledge. Consequently, data may not accurately represent some items, especially those with only a few responses. As shown in Figure 30, only seven responses (2.3%) were from organizations. Given this, it does not make sense to analyze organization responses separately. The category organization includes businesses, non-governmental organizations, community based organizations and other governmental agencies.
Respondents’ household size was quite a bit smaller than the population (2.2 versus 3.1) and median age of responding households was higher than the population (62.2 versus
43.7). Lincoln has 22% of population 65 years and old, compared to 16.2% for California and
17.7% for United States. Approximately half of the 410 persons in the 183 households that provided demographic information for the survey were 65 or over. As shown in Figure 31 and Figure 32, respondents tended to more years of formal education than the overall population and were more likely to be retired and less likely to be in arts, business, management, and science occupations than the City’s residences overall. 37 Source: American Community Survey 5-year estimates, 2023, https://data.census.gov/table/ACSST5Y2023.S1901?q=median+household+income+californi a
Percentage of State
Median Annual
Household Income
($96,334)
> 100% MHI
80% - 100% MHI
50% - 80% MHI
< 50% MHI
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ENTRUST Solutions Group March 12, 2026 City of Lincoln, CA Figure 30. Amount of 309 responses by type of location and level of completeness Figure 31. Educational attainment among 184 responses38 38 Unless otherwise stated, the source for population statistic estimates are from US Census Bureau 2023 American Community Survey 5-Year Estimates.
Household -
Complete
60%
Household -
Partial
38%
Organization -
Complete
1%
Organization -
Partial 1%
0% 10% 20% 30% 40% 50%
Elementary, middle school, or some high
school but did not graduate
High school graduate or GED
Some college but no degree
Associate degree
Bachelor degree
Graduate or professional degree
Responses Population
1191
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ENTRUST Solutions Group March 12, 2026 City of Lincoln, CA Figure 32. Occupation of 182 respondents compared to the population of Lincoln All respondents had some form of internet access. See Figure 33. The majority of respondents (67.5%) had broadband, including fixed wireless access (FWA). Over a quarter (25.9%) had non-broadband internet, including DSL.39
Figure 33. Types of internet connections by survey completeness Internet Service Performance
As shown in Figure 34, a third of respondents had internet services that fall short of the broadband baseline of 120 Mbps aggregate throughput (100 Mbps down + 20 Mbps up).
Figure 35 shows speeds varied across the city. As noted above, we did not get survey 39 DSL is not technically capable of achieving California state and de facto national standard for broadband of 100 Mbps download and 20 Mbps upload so ENTRUST does not count it as broadband. FWA is generally capable of hitting this mark so we include it as broadband.
0% 20% 40% 60%
Arts, business, management, or science
Construction, maintenance, or natural
resources
Office or sales
Production or transportation
Service
Retired or otherwise out of the workforce
Responses Population
-
20 40
60 80
100
120
140
Broadband internet No internet Low-speed internet Unsure Complete Partial
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ENTRUST Solutions Group March 12, 2026 City of Lincoln, CA responses from some areas designated as underserved by state and federal agencies but we can assume locations in those areas would have lower speed connections.
Figure 34. Percentage of 215 responses of internet connection aggregate throughput The largest percentage of respondents had service that surpassed the old 25/3 Mbps standard without meeting the new standard. Six percent of respondents had internet that fell below the old standard. Nearly two-thirds of locations had internet connections that exceeded the new standard. About a third had “fast” broadband, above 330 Mbps throughput up to 1,000 Mbps aggregate. Just about one twentieth of respondents had gigabit connections. No respondents had full symmetrical gigabit or faster service. The fastest speeds among 215 speed tests were 923.3 Mbps down, 754.6 Mbps up, and 1676.9 Mbps aggregate throughput.
31.2%
3.3%
0% 10% 20% 30%
Less than 3
3 to less than 11
11 to less than 28
28 to less than 120
120 to less than 330
330 to less than 550
550 to less than 1,100
1,100 to 1800
1,800 or more
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ENTRUST Solutions Group March 12, 2026 City of Lincoln, CA Figure 35. The geographic distribution of 215 speed test results in terms of Mbps Types of Internet Service
Effectively half of respondents had cable internet, just over a quarter had fiber-based internet, and about a tenth had DSL, as shown in Figure 36. As detailed in Table 10, satellite internet was the costliest by far. Cable and DSL were both more per month than fiber, which was just a bit more expensive than FWA.40 Fiber performed better than FWA, especially on upload, but cable did not. Respondents’ internet service upload, download, and latency were measured automatically using Measurement Lab’s Network Diagnostic Tool.41 40 FWA uses 4G and 5G cellular and related technologies to provide non-mobile connections.
41 For more information, visit https://www.measurementlab.net/tests/ndt/.
Speed Test Results
0 to 10
11 to 28
28 to 120
120 to 330
330 to 550
550 to 1,100
1,100 or more
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ENTRUST Solutions Group March 12, 2026 City of Lincoln, CA Figure 36. Percentage of 305 responses per type of internet connection Figure 37. Geographic locations of 305 responses by type of internet service Survey results show cable-served locations throughout the city. See Figure 37. Fiber connections appear to be concentrated in the northern and western portions of the city. See Figure 37. Respondents with cable internet are concentrated in the southeastern area and Cable
46%
Fiber
28%
FWA
4%
DSL
10%
Unsure
5%
Cellular
4%
Satellite
3%
Broadband Type
Cable
Cellular
DIA
DSL
FWA
Fiber
Other
Satellite
Unsure
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ENTRUST Solutions Group March 12, 2026 City of Lincoln, CA less prevalent in the older portions of the city. There also seem to be relatively fewer DSL served locations in Lincoln’s core areas but relatively more locations with cellular internet.
FWA was clustered in Sun City but also near the edges of the city.
Fiber was generally fastest but not by much, as shown in Table 10, and it was not substantially faster than cable or FWA. Indeed, cable had the second fastest speed test result, 921.2, which was right behind the fastest fiber result of 923.3 Mbps.42 FWA’s fastest test result was 473.3 and DSL’s was 141.5 Mbps, which are both suspiciously fast for those technologies. Fiber had the fastest upload speed, 754.6 Mbps, well ahead of cable (521.1 Mbps) and FWA (276.6 Mbps). FWA generally performed better than cable, including on latency, which was relatively low for FWA (typically over 40ms). DSL performance was relatively good in comparison to what we see in other communities. The reported cost was quite a bit higher than what we’ve seen elsewhere, too (typically $40 to $60 per month).
Table 10. Average Costs and performance of 305 responses Type MRC43 Down Up Latency MRC/Mbps
Cable $79.14 196.03 36.64 17.3 $0.75
Fiber $67.01 347.80 232.90 10.6 $0.23
FWA $63.57 234.78 62.26 17.8 $0.34
DSL $75.91 42.27 12.75 28.4 $2.68
Unsure $59.89 178.67 51.08 19.8 $2.19
Cellular $7.00 38.38 16.96 23.0 $0.13
Satellite $120.00 159.39 7.65 23.0 $0.72
At $0.23 per Mbps per month, fiber was the most economical service for survey respondents, as shown in Table 10,
44 followed by FWA. Both are in the range of nationally competitive rates. Cable appears to be less economical than Starlink satellite at $0.75 per Mbps per month versus $0.72. DSL was the least economical, costing $2.68 for each megabit per second of capacity per month.
42 Generally, metrics for access technologies should be take with a bit of skepticism because respondents may not know what they have. The fastest cable result, for example, could because the location is served by Astound’s fiber-based service, not cable. The fastest “Unsure” results, at 651.4/176.4 Mbps, were likely for fiber but the respondent clearly did not know.
43 “MRC” stands for monthly recurring costs. “Down” and “Up” refer, respectively, to the rate at which data comes from the internet to the device running the test and from the device to the internet.
44 We did not count results for cellular but that data point seems invalid on its face given what we know about cellular costs.
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ENTRUST Solutions Group March 12, 2026 City of Lincoln, CA Figure 38. Importance of reasons for not having broadband by 17 respondents A quarter of respondents had internet service types that are generally not considered broadband—cellular, DSL, and satellite. Nearly a quarter of ratings had non-availability as the top reason, as shown in Figure 36. While there were clearly other factors, cost and speed were also important reasons. Respondents without broadband indicated it was not due to having internet access at school, work, or other locations.
Uses of and Sentiments About Broadband
Figure 39. Frequency of broadband uses for broadband for 184 responses It is important to remember that no one “needs” broadband. They value it for its usefulness.
They need to do things with it. As shown in Figure 39, the most common use by far was communication, followed by entertainment. Online shopping was a common use, as was Broadband is not
available, 24.0%
0% 10% 20% 30%
Have high-speed access elsewhere
Broadband is too expensive
Available services are too slow
Broadband is not available
Do not need broadbad
Smartphone meets internet needs
Other reason
1 = Most important 2 3 4 5 6 7 = Least important
0% 20% 40% 60% 80% 100%
Buying
Selling
Learning
Gaming
General interest
Home business
Special interest
Remote work
Entertainment
Communication
All the time
(daily or more)
Regularly (once
per week or
more)
Occasionally
(2-3 times per
month)
Rarely (once a
month or less)
None or Never
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ENTRUST Solutions Group March 12, 2026 City of Lincoln, CA special interest research. Selling was the least common and least frequent use. Gaming and learning were common but not frequent uses among respondents.
Over a third of respondents had fully “cut the cord,” and were not getting any video content from traditional broadcast/cable television, while only using streaming media. A larger proportion—43%—indicated that they got most of their video from traditional media.
Figure 40. Sources of video content by percentage for 188 responses Internet access in general and reliability in particular were rated as critical or very important by nearly all respondents. Speed was the second most important characteristic. Price was most frequently noted as very important by respondents. Customer and technical support were most commonly rated as somewhat important and the only factor that was significantly rated at not important.
Figure 41. Importance of internet access as a percentage by 194 responses 100% Traditional /
0% Internet
10%
80% Traditional
/ 20% Internet
15%
60% Traditional
/ 40% Internet
17%
40% Traditional
/ 60% Internet
10%
20% Traditional
/ 80% Internet
12%
0% Traditional /
100% Internet
36%
Overall, 10.5% Price, 12.3% Reliability, 10.0%
0%
5%
10%
Overall Speed Price Reliability Support
Critical Very important Somewhat important Not important No opinion/Don't care 1198
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ENTRUST Solutions Group March 12, 2026 City of Lincoln, CA Respondents were generally somewhat or very satisfied with their internet services. They were most satisfied with reliability with 74% of respondents either somewhat or very satisfied, followed by speed. Price was the largest source of dissatisfaction, receiving the largest percentage of negative ratings. Less than half of respondents were satisfied with price. Respondents were the most ambivalent about customer service and technical support, with which a quarter of them were neither satisfied or dissatisfied. It got the largest percentage of neither/unsure ratings. Most respondents (70%) were satisfied with their internet service overall and less than a quarter were dissatisfied.
Figure 42. Satisfaction with internet services from 210 responses Respondents’ willingness to pay for internet service was not greatly impacted by speed. On average they indicated being willing to pay between $12 and $65 per month depending on speed and service quality. As shown in Figure 43, the average went from about $23 per month for minimal internet access speeds (comparable to 4G cellular data) to just over $50 for symmetrical gigabit broadband.
0%
5%
Overall Speed Price Reliability Support
Very satisfied Somewhat satisfied Neither/Not sure
Somewhat dissatisfied Very dissatisfied
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ENTRUST Solutions Group March 12, 2026 City of Lincoln, CA Figure 43. Willingness to pay for internet services among 151 responses At low-end speeds, respondents were willing to pay top end dollars—$2.07 per Mbps per month. Respondents’ average willingness to pay for symmetrical gigabit service was only $0.03 per Mbps per month on average. The difference between what respondents were willing to pay for high- and low-quality service varied from nearly $21 up to almost $32, accounting for between 37% and 52% of the value of the service. The marginal value of speed to respondents decreased rapidly beyond basic broadband—the more they get, the less their responses value its worth—while the marginal value of quality service increased.
Internet Service Providers
Astound serves over half of respondents, as shown in Figure 44, about two-fifths of respondents used AT&T, and about a third of AT&T locations were served by fiber. One tenth of Astound subscribers reported being served via fiber. Fidium and Succeed appear to have significant portions of the market. Most respondents using these companies report being served by fiber. T-Mobile has gotten a toehold with its FWA service. $22.74 $25.53
$33.23
$38.46
$50.38
$20.73 $19.52
$25.36 $26.20
$31.72
$0
$10
$20
$30
$40
$50
$60
$70
10/1 Mbps 25/3 Mbps 100/20 Mbps 300/30 Mbps 1/1 Gbps
Average Support Quality Premium
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ENTRUST Solutions Group March 12, 2026 City of Lincoln, CA Figure 44. Percentage of 193 responses per type of internet connection Two small ISPs, Always On and SkyHi Broadband serve locations in and around Lincoln (we included results from anywhere in Lincoln’s “sphere of influence”). Both are wireless ISPs.
Always On essentially resells AT&T, Cellular One, and T-Mobile FWA. SkyHi, which is based in Lincoln, provides connections via point-to-point wireless, which covers greater distances, so is particularly well-suited to rural locations, but requires a carefully placed antenna at the customer location.
AT&T serves locations across the city (see Figure 45), although survey responses clustered in the older areas of Lincoln and in the Sun City area. Astound also serves locations across the city, particularly in the center and along major thoroughfares. Succeed is clearly focused in the Lincoln Crossing area, in the southwestern corner of the city. Locations with service from Fidium were concentrated in the city’s core and along its northern boundary.
AT&T
35%
Astound
46%
Fidium
9%
T-Mobile
2%
Succeed
6%
SkyHi
1%
Always On
1% Other
0%
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ENTRUST Solutions Group March 12, 2026 City of Lincoln, CA Figure 45. Locations of 216 responses by provider
Almost two-thirds of respondents get internet access only from their service providers. On average, respondents paid $73 per month for internet access (see Table 11). They paid as much as $450 per month for all services and $119 on average. Respondents with AT&T spent the most on average although AT&T’s internet service costs are slightly above average. T-Mobile’s internet service is the least expensive, but they also have the highest relative costs for value-added service. This is likely because T-Mobile provides cellular phone first, as the basic service, then provides FWA internet at a discount to existing customers. Most ISPs do it the other way: sell the connection first then provide telephone/voice, television channels, etc., as an add-on.
Table 11. Cost and performance of Lincoln area ISPs compared Provider
MRC Contracted Tested Average
Total Internet Down Up Down Up $/Mon
AT&T $145.88 $75.69 327.6 310.1 182.2 109.0 $1.52
Astound $121.31 $77.34 393.5 184.2 223.7 33.4 $0.58
Fidium $67.30 $61.99 474.2 441.7 259.4 203.9 $0.20
T-Mobile $86.25 $46.25 274.4 16.9 245.2 22.1 $0.19
Succeed $69.86 $56.12 413.2 444.5 357.4 271.6 $0.14
SkyHi $80.00 $80.00 41.0 41.0 5.0 0.5 $12.64
Always On $107.50 $107.50 750.0 505.5 433.6 118.9 $0.29 Other $120.00 $120.00 NA NA 159.4 7.7 $0.72
Total $118.52 $73.19 394.6 2,507.8 223.9 94.8 $0.89
Provider
AT&T
Always On
Astound
Fidium
Other
SkyHi
Succeed
T Mobile
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ENTRUST Solutions Group March 12, 2026 City of Lincoln, CA A benchmark for national competitive rates is $0.30 per Mbps per month. Three of the ISPs actively serving locations in Lincoln come in under that threshold. Lincoln area homes and businesses are paying AT&T five times more than their peers in truly competitive markets.
Astound customers pay double the competitive rate. Succeed has the highest per Mbps per month cost according to responses because its connections are very slow and because their subscribers are located in remote locations, connected via links that are inherently slower than fiber or short-distance wireless connections.
4.3 Stakeholder Outreach
ENTRUST conducted focus groups and interviews with city stakeholder representatives, including ISPs. The following results are taken directly from participants’ comments during those sessions. These results are not from members of the ENTRUST team or City of Lincoln staff.
Internet Service Providers45
Lincoln is in the unusual position of having four facilities-based, wireline ISPs—Astound, AT&T, Fidium (Consolidated Communications), and Succeed.Net—as well as a local wireless internet service provider (WISP), SkyHi Broadband. Each has a different approach to expanding high-speed internet access. Their strategies vary in infrastructure ownership, service models, and expansion priorities.
Astound has no plans for expansion in Lincoln. Its network in Lincoln is primarily fiber. The company considers the city to be pretty well built out. The City has been a customer for 8-10 years. They currently provide Ethernet-based dedicated lines to the City, including a 100 Mbps connection between City Hall and the Police Department and dedicated internet access to the wastewater treatment facility, City Hall, and water tanks off of Vista de Madera.
Astound is open to public-private partnerships, specifically joint operations and maintenance and swapping use of the City’s assets for services. The company is very open and flexible. It currently partners with the cities of Paso Robles, San Luis Obispo, and Santa Clarita, and Ventura County.
AT&T is planning targeted fiber deployment to replace its outdated copper network and serve new developments. The company would like to bring fiber to 35 neighborhoods and 9,000 plus locations in Lincoln. It has funding to build to at least 500 customers. AT&T is actively working with developers. It sees microtrenching as a good way to bring fiber into older neighborhoods. AT&T considers Lincoln a “full-service city” that includes wireless.
They will build three wireless sites in 2025 and expect to build more in 2026. McBean Park, the Lincoln Airport, and Twelve Bridges area have been priorities. They do not have any small cells in Lincoln at this point.
AT&T leverages grants where possible to serve unserved and underserved areas, including the CASF and the CPUC’s Federal Funding Account. The company is competitive but willing 45 ENTRUST conducted interviews with all four wireline providers. This section summarizes the information they provided during those interviews.
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ENTRUST Solutions Group March 12, 2026 City of Lincoln, CA to work collaboratively to reach the unserved and underserved. Areas that require public safety connectivity46 are priorities along with the company’s other planned improvements.
The company feels there are many best practices out there and there is no need to reinvent the wheel. AT&T wants to be a true partner for the City.
Fidium was spun off from Consolidating Communications, a regional independent local telephone company based in Roseville. They began with a public-private partnership with Sacramento. They cover about a quarter of the city with fiber-to-the-home. Fidium was overbuilding incumbents but stopped expanding in California because the cost per passing became prohibitive, particularly due to labor costs from fair wage requirements. Owning assets creates more value for the company and much of its network is already constructed.
Fidium does not in plan to overbuild in Lincoln in 2026 or 2027.
Fidium’s goal is to help bridge the digital divide for underserved areas leveraging publicprivate partnerships. Fidium provided free Wi-Fi in public spaces throughout the city of Roseville. It is connecting edge AI data centers to push connectivity closer. The company would consider a grant partnership opportunity and is willing to look at any public-private partnership opportunities. A lot of areas are underserved or unserved because serving them must make sense financially for providers. Fidium sees the City’s role as addressing things like permitting, pole loads, building entrance agreements, and access to homes. The company is interested in how to maximize public assets for carrier, commercial, and residential use. A geological study would be helpful.
Succeed.net is a 25-year-old local area alternative ISP building fixed wireless and fiber optic networks in the greater Sacramento Valley, particularly for homeowners’ associations (HOA) and rural communities, emphasizing affordability and efficiency. The company claims it has the highest Google ratings of any ISP in California and stays current with the latest technologies.Succeed.net is building competitive gigabit networks in suburban and urban areas. They are the first ISP launching gigabit speed fixed wireless networks in the Sacramento Valley. Succeed.net offers optional managed Wi-Fi 6, static IP, telephone/Voice-over-Internet Protocol (VoIP).
Succeed.Net currently operates the Lincoln Crossing HOA-owned network, providing broadband service, including management, engineering, and support, as part of HOA dues.
All users are being upgraded from 150 Mbps to 250 Mbps at no extra cost and they can upgrade to 1 Gbps service for an additional $20/month. The company upgraded Lincoln Crossing’s network performance and security. They addressed major security risks and increased speeds by reconfiguring customer premise equipment (CPE). Both CPE and core network equipment were updated. Optical signal strength was boosted. The main fiber internet connections were rerouted to nearby exchanges. 46 AT&T operates FirstNet, a nationwide wireless broadband network for first responders and others in the public safety community, via a public-private partnership with the federal government. For more information, visit https://www.firstnet.com/ and https://firstnet.gov/about.
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ENTRUST Solutions Group March 12, 2026 City of Lincoln, CA Community Stakeholders
In the five focus groups hosted by ENTRUST, participants were asked about existing connectivity, issues they have with their broadband service, what they foresee as their future connectivity requirements, and their view of the role of the City in expanding broadband coverage. Outages were a recurring issue, with small businesses citing impacts on sales and communication during storms and construction accidents. Businesses stressed the importance of fiber as “table stakes” for modern operations. Wireless coverage inconsistencies, particularly during emergencies, were also highlighted as a significant concern. A major trend noted was the increasing integration of remote work and cloud-based services, requiring enhanced upload speeds and redundancy measures.
Participants expressed a need for improved redundancy and disaster recovery measures, particularly for businesses reliant on real-time communication. Increased wireless reliability and support for IoT integrations were mentioned as priorities. Participants reported a mix of fiber and wireless connectivity. Many businesses rely heavily on broadband for point-of-sale systems, online operations, and remote monitoring. Notably, one small business owner highlighted switching to satellite-based services due to outages with traditional providers, citing higher reliability and consistent performance. Enterprise businesses generally reported access to fiber as the standard for connectivity. However, gaps exist in parts of the city.
Some enterprises require dual services for redundancy, with one enterprise discussing the limited availability of competitive pricing due to a lack of provider options.
Municipal representatives reported varying experiences. Public safety agencies such as the Police and Fire Departments cited stable wired connectivity at stations but identified wireless dead zones in field operations. Education representatives highlighted a lack of competition among providers, impacting cost-effectiveness and flexibility for schools. Education officials called for more widespread broadband access to rural areas and enhanced competition among providers to reduce costs. Public safety representatives suggested initiatives to ensure 24/7 uptime during emergencies, including backup solutions for mobile and wired networks. Enterprise participants advocated for city-led initiatives to expand fiber coverage citywide and improve cellular infrastructure. Futureproofing through 5G adoption and robust support for data-heavy operations, such as automated systems, were highlighted as critical trends.
Cellular connectivity was deemed subpar by some participants. Wireless gaps were identified as a significant issue affecting public safety and education. Officials emphasized the importance of seamless mobile connectivity for emergency responders and field staff.
Educational institutions reported frequent Wi-Fi drops, which disrupted online learning and administrative tasks.
Developers confirmed access to fiber in most development zones. However, issues arise within the deeper sections of large facilities, requiring Wi-Fi extenders to maintain connectivity. One developer emphasized the importance of integrating conduit and fiber infrastructure during construction to future-proof developments. Developers noted that the permitting process for broadband installation is generally smooth but raised concerns about the limited number of service providers willing to work with large developments. This lack of 1205
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ENTRUST Solutions Group March 12, 2026 City of Lincoln, CA competition potentially delays or increases the cost of connectivity. Developers emphasized the importance of forward-looking infrastructure planning. Suggestions included mandating fiber-ready conduits in new developments and incentivizing providers to expand coverage to underserved areas. Collaboration with the city on "smart infrastructure" was also recommended.
Participants encouraged the city to facilitate partnerships with providers to improve redundancy and support small businesses during outages. Creating incentives for providers to expand fiber and wireless networks was also suggested. Large businesses emphasized the need for the city to act as a mediator, fostering competition among providers and ensuring equitable broadband access. Public officials underscored the city’s role in ensuring universal broadband access, particularly in underserved regions. Suggestions included investing in shared infrastructure, such as municipal Wi-Fi in public areas such as parks and public-private partnerships, to reduce costs and enhance connectivity. Developers proposed streamlining permitting processes for broadband infrastructure and working collaboratively with providers to identify and address connectivity gaps. Encouraging innovative solutions, such as underground fiber networks, was highlighted as a key area for city involvement.
4.3 Digital Divide
Digital Divide is the division between households, individuals, and businesses where there are disparities in the access to the internet. The causes of the Digital Divide vary, and solutions should be tailored to not only a specific City, but even to individual communities.
There are five common causes of the Digital Divide:
1) Affordable Internet Access
The cost of internet access varies by location and by the provider. Most cities have areas that are economically distressed and are comprised of households that do not earn enough income to support adequate broadband services. Not being able to afford internet access is an issue by itself; however, this can lead to several secondary impacts and a downward spiral for these households, as the internet is critical for finding gainful employment, participation in key educational activities, and accessing healthcare. The pandemic highlighted and pushed forward the online nature of the world economy, and forced many activities that were normally done in person to be done online, including banking, health care, distance learning, and shopping. When households are unable to partake in these activities because they don’t have internet access, the digital divide actually widens. 2) No access to Technology Devices
In order to access the internet, an individual must use a device, smart phone, tablet, computer, etc. These devices can be expensive, and unlike the monthly subscription cost of internet access, devices require a significant up-front investment of hundreds of dollars.
Many households simply cannot afford these devices, especially when technology advancements make devices obsolete after a couple of years. 1206
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ENTRUST Solutions Group March 12, 2026 City of Lincoln, CA 3) Digital Literacy
Many households and individuals have internet access and devices to use but lack Digital Literacy (the knowledge and technical skills to access and use the internet). This issue is particularly pronounced among older and low-income households. 4) Geographic Limitations to Broadband
Incumbent providers prefer to build in areas of high density; areas where the houses, multidwelling units, or businesses are too far apart make it difficult for private companies to achieve a return on investment in the short periods of time they seek to repay capital. This results in areas with low density – particularly semi-rural communities like the French Camp area – having a lack of private infrastructure and, thus, insufficient internet services. 5) Language barriers
Many households speak English as a second language, but many resources – particularly those centered around technology – are not accessible without strong English skills.
4.4 Digital, Equity, Inclusion, and Literacy
The City of Lincoln has virtual recreation options47 and the Lincoln Public Library provides basic help with technology. There are no digital inclusion or literacy programs in the city other than this broadband plan. Placer County has a Broadband Equity Program whose Foothill Broadband Expansion Project has contracted with Astound to provide broadband access to over 17,000 underserved homes and businesses in rural areas of the county. The first two phases for over 2,000 households in Auburn, North Auburn, and Penryn are complete. Current phases will connect nearly 15,000 homes in 12 communities along Interstate 85 from Loomis to Alta. Lincoln is not included in this project. Placer County has a number of e-government initiatives and online resources but no digital inclusion or literacy programs.
Placer County is part of Valley Vision, a regional consortium of local governments, institutions, and non-governmental organizations for understanding and addressing complex, systemic issues.48 Broadband and digital equity is one of Valley Vision’s focus areas, consisting of three projects:
• The Capital Region Coalition for Digital Inclusion engages local government, higher education, libraries, workforce boards, and other stakeholders to address digital equity for prosperity in the region including Placer County. It assessed community needs for connectivity and worked across industries on digital access via affordable internet and devices, along with digital literacy/skills, and developed a plan for 47 See https://www.lincolnca.gov/en/parks-recreation-and-activities/virtual-recreationactivities.aspx. 48 See https://www.valleyvision.org/about/.
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ENTRUST Solutions Group March 12, 2026 City of Lincoln, CA broadband access, hardware devices, and digital skills.49 ENTRUST found no evidence that these plans involved the City of Lincoln. • The Connected Capital Area Broadband Consortium (CCABC) leads strategic efforts to improve broadband access in Sacramento, Sutter, Yolo, and Yuba Counties, funded by the CPUC in partnership with the California Emerging Technology Fund and other state and local agencies and non-government organizations. Placer County and the City of Lincoln are not part of this consortium. • “The Broadband for Business: A Path Forward for the Capital Region” identified priorities and creates a roadmap for accelerating broadband adoption and use of internet-based tools for business and economic development in Sacramento, Sutter, Yuba, and Yolo Counties. While it does not include Lincoln or Placer County, it finds gaps that are relevant to the City of Lincoln:50
o Connectivity varies widely. Some businesses have excellent service “others struggle with lack of providers, slow speeds, outages, high costs, and a lack of digital education and training.”
o Accurate information about services can be difficult to acquire. o Businesses need more choices and want competition for broadband providers.
o Service is often unreliable, and speeds are often too slow for many businesses’ needs.
o It is difficult for businesses to find better services and solutions and to learn and adopt new technologies.
o Businesses need more digital training and education.
SACOG51 is a regional council for 28 member cities and counties, including Lincoln and Placer County, working together for an equitable, sustainable, and prosperous future, addressing transportation, funding, airports, and housing. Although network connectivity is essential to all of its plans, broadband and digital equity are not addressed by SACOG.
4.5 Summary of Findings
Despite having four facilities-based wireline internet
service providers, there are still geographic gaps and
areas monopolized by a single carrier.
The City of Lincoln is in the unique position of having four facilities-based, wireline service providers, not to mention a wireless ISP, in the City. It has two national cellular companies, including one that is aggressively marketing fixed wireless, as well as one of the wireline companies providing cellular data. Regardless, the city has some substantial geographic 49 Action Plan 2021, Sacramento Coalition for Digital Inclusion, https://www.valleyvision.org/projects/capital-region-coalition-for-digital-inclusion/. 50 Broadband for Business: A Path Forward for the Capital Region, Valley Vision, Spring 2024, https://www.valleyvision.org/wp-content/uploads/Broadband-for-Business-Report2024.pdf, page 11. 51 Visit https://www.sacog.org/about/about-sacog for more information. 1208
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ENTRUST Solutions Group March 12, 2026 City of Lincoln, CA gaps that appear to coincide with income levels. Substantial portions of the City, particularly in the southeast (which are also lower income areas), do not have a fiber provider, and are subject to a cable monopoly.
Consumers value lower monthly cost – even if it means
lower speeds.
The survey results for “willingness to pay” along with related ratings of importance and satisfaction indicate that Lincoln consumers are selecting providers primarily based on low monthly cost, even to the detriment of higher speeds. This gap could undermine private investment to overbuild or even upgrade current infrastructure, as incumbent providers may view lower monthly subscription rates as an indicator of potential return on investment (and thus, electing not to upgrade cable and hybrid networks to full fiber). The survey responses were generally from older persons and Lincoln has a relatively older population when compared to the rest of the state, so the demand gap may also be a generational issue.
State and Federal databases do not indicate broad
grant eligibility, but economic indicators demonstrate a digital divide growing in cable-only areas of the City.
While the FCC Fabric and State CASF maps do not indicate significant grant eligibility related to un- or under-served status, the income and internet subscription data does demonstrate a growing digital divide, particularly in the southeastern portions of the City.
State and federal data only looks at availability, and does not consider ability or willingness to pay. A new competitor in these areas should create competitive pressures to lower costs and improve service quality.
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ENTRUST Solutions Group March 12, 2026 City of Lincoln, CA
5. Conceptual Network Design
ENTRUST developed the Conceptual Network Design based on priorities identified by the City. The design serves to both connect city facilities and support city services, while also leveraging existing fiber infrastructure available through a private provider. Ultimately, this could also be used to improve community access to broadband. ENTRUST understands the resource and funding constraints faced by many cities and architected the conceptual network to minimize capital required by leveraging existing private assets.
The conceptual network design is truly that – conceptual. It is not a full engineering study and does not account for specifics such as aerial vs. underground deployment, building entry locations, which side of the street a particular fiber cable is located, etc. The conceptual design is intended to provide a roadmap for the city, and specific projects undertaken should first complete a full engineering process that will conduct field surveys to verify existing data and assumptions to move the Conceptual Design to a High-Level Design (30% HLD), to a Low-Level Design (60% LLD), and ultimately to a Final Design (90%).
ENTRUST assessed the Lincoln area for existing public and private broadband assets and infrastructure that could be used, leased, shared or otherwise leveraged to develop and construct a functional, yet cost-effective broadband network. This included surveying and mapping several data sources available for use in the region, including public infrastructure, buildings, and/or facilities, conduit and fiber networks, communications towers, streetlights, traffic signals, state-wide middle-mile networks, and private telecom assets, including middle-mile networks and data centers. Not all of these assets are publicly available and/or protected under NDAs; these assets have been incorporated into the design but may not include specific details or locations.
The City identified and prioritized 80 public and community sites; ENTRUST then designed a backbone fiber optic network consisting of four interconnected loops in a 3-phase incremental approach. The loop design ensures uninterrupted, redundant services across the City so that no single point is vulnerable to a wide network outage. The Concept Design does not account for how backbone is deployed (e.g., aerial vs. underground), so construction cost estimates assume the entire network is underground conduit and cable.
Service drops/laterals to designated sites are conceptual only; a full design engineering study would identify the specific points of entry for buildings and facilities.
5.1 Concept Design
The conceptual network design would connect the 80 identified City facilities and community institutions (Table 12) into a city-wide ring network that leverages existing private fiber infrastructure. The City can interconnect these facilities to strategically build out a broadband infrastructure, ensuring equitable access, fostering community engagement, improving administrative efficiency, and enhancing critical services. 1210
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ENTRUST Solutions Group March 12, 2026 City of Lincoln, CA Table 12. Sites Connected to City Backbone Network in Conceptual Design Site Type Priority
1 Priority
2 Priority 3
Airport 1
Ancillary City Owned Building 1
Charter School 2
Community Center 1
Elementary School 8
Fire Station 3 1
High School 3
Library 1
Local Government Building 3 1
Medical 3
Middle School 2
Police 1
Recreation Area 7 17
Utility 25
TOTAL 9 35 36
The Conceptual Network Design, as shown in Figure 46. Conceptual Network Design, proposes a future backbone network of approximately 46.7 miles that would leverage 31.3 miles of existing private fiber,52 while adding 0.5 miles of new fiber in existing city conduit, and installing 14.9 miles of new underground conduit and fiber. Most critically, the concept network ensures uninterrupted service through a redundant loop architecture and flexibility for future growth.
52 Private fiber assets, protected under an NDA, have been intentionally omitted from Figure 46; however, those private assets would complete the disparate segments into a redundant network loop.
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ENTRUST Solutions Group March 12, 2026 City of Lincoln, CA Figure 46. Conceptual Network Design
Although the private fiber assets are not shown on the map, ENTRUST has confirmed the location and availability that can be leveraged to support the connectivity of Lincoln’s facilities. By incorporating those assets into the Concept Design, instead of overbuilding at City expense, this approach could save the City between $15-25 million on construction costs. Negotiating a public-private partnership with an ISP who has fiber assets in the area may also facilitate favorable lease rates and terms, or to identify in-kind contributions that could provide further public benefits.
5.2 Phased Implementation Plan
The Conceptual Network Design can be implemented in a phased approach in order to recognize resource constraints, prioritize critical City facilities, provide flexibility relative to grant availability, and to reflect the City’s priorities for growth and connectivity. The phases outlined below can be further broken down into sub-phases or built incrementally and opportunistically through effective Capital Improvement Program (CIP), utility 1212
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ENTRUST Solutions Group March 12, 2026 City of Lincoln, CA coordination/joint build, and through developer agreements on planned, private development projects.
Table 13. Routes miles by phase (Includes lease of private fiber) Phase Route Miles
Phase 1 – City Sites 13.1
Phase 2 – Core Public Facilities 26.8
Phase 3 – Community Anchors 6.8
TOTAL 46.7
Phase 1: City Sites
Phase 1 totals 13.1 miles of fiber backbone network and would directly connect the nine priority City facilities shown in Figure 47 with redundant services ensuring uninterrupted service delivery.
Figure 47. Phase 1: City sites
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ENTRUST Solutions Group March 12, 2026 City of Lincoln, CA Phase 1 (Figure 47) utilizes 0.5 miles of City-owned existing conduit, new construction build for 0.5 miles, new construction of 0.08 miles of the City’s planned traffic signal network, and leverages 12.1 route miles of leased private fiber (not depicted in Figure 47). This phase would construct a City-wide fiber network with two interconnected redundant backbone loops and connect nine Tier 1 City priority sites (shown in Table 14). Additional redundancy would be added during future phases.
Table 14. Phase 1: Connected priority sites
Site Name Site Address
City Hall 600 Sixth Street
Community Center 2010 First Street
Corporation Yard 2100 Flightline Drive
Fire Station 33 391 H Street
Fire Station 34 126 Joiner Parkway
Fire Station 35 2525 E Joiner Parkway
Lincoln Police Dept 770 7th Street
Lincoln Public Library 485 Twelve Bridges Drive
Lincoln Regional Airport 1480 Flightline Drive
Phase 2: Core Public Facilities
Phase 2 would expand the network by 26.8 miles in order to connect 35 additional facilities that form the core of the public institutions and services – including water sites, pump/lift stations and community parks as shown in Figure 48 and Table 15. 1214
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ENTRUST Solutions Group March 12, 2026 City of Lincoln, CA Figure 48. Phase 2: Core public facilities
Phase 2 is comprised of 18.4 miles of existing private fiber (not shown in Figure 48) and 8.4 miles of new construction (7.3 miles of new routes and 1.1 miles of the planned traffic signal network). Phase 2 would directly connect the public facilities and assets identified in Table 15:
Table 15. Phase 2: Connected core public facilities
Site Name Site Address/Parcel ID
Aldo Pineschi Park 1550 Brentford Circle
Bella Breeze Park 1200 Bella Breeze Drive
Booster Pump Station 4200 Monteverdera Drive
Fiddyment Road Well 1735 Fiddyment Road
Foskett Regional Park 1911 Finney Way
Lift Station 124 Nisenan Valley Court
Lift Station 104 Corte Ocaso
Lift Station 3312 Vista De Madera
Lift Station 337-300-063-000
Lift Station 329-020-022-000
Lift Station 337-012-045-000
Lift Station 332-010-011-000
Lift Station 2472 3rd Street
Lift Station 021-750-009-000
Lift Station 021-470-043-000
Lift Station 2873 Delegate Drive
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ENTRUST Solutions Group March 12, 2026 City of Lincoln, CA Site Name Site Address/Parcel ID
Lift Station 1685 1st Street
Lift Station 021-740-040-000
Lift Station 1320 Silver Spur Circle
Lift Station 021-590-020-000
Lincoln Museum 640 5th St
Lincoln Senior Center 391 H Street
McBean Stadium 65 McBean Park Drive
Moore Road Well 2635 Moore Road
Nathan Dubin Park 1971 Hamersley Lane
Nelson Road Well 2885 Moore Road
New Fire Station FS 36 Location provided in GIS no address Robert Jimenez Park 820 Groveland Lane
Tank 1 - Vista De Madera 3600 Vista De Madera
Tank 2 145 Boulder Court
Tank 3 - Verdera North 337-012-045-000
Well 2 021-570-033-000
Well 4 466 Airport Road
Westwood Well 327-010-057-000
Wilson Park 2325 East Joiner Parkway
Phase 3: Community Anchors
Phase 3 (Figure 49) would further expand the City network by 6.8 miles and connect 36 remaining sites and facilities that provide services to the public which would benefit from enhanced broadband connectivity, including parks, schools, and healthcare facilities. 1216
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ENTRUST Solutions Group March 12, 2026 City of Lincoln, CA Figure 49. Phase 3: Community anchors
Phase 3 would extend the fiber network to these Tier 3 sites through 0.8 miles of existing private fiber (not shown in Figure 49), and 5.9 miles of new construction. Phase 3 would connect 36 locations to the fiber network as shown in Table 16. 1217
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ENTRUST Solutions Group March 12, 2026 City of Lincoln, CA Table 16. Phase 3: Connected community anchors
Site Name Site Address
Aitken Ranch Park 877 Sorrento Parkway
Atkinson Park 1987 Beale Circle
Auburn Ravine Park 1300 Green Ravine Drive
Brown Park 1899 McClain Drive
Carlin C. Coppin Elementary School 150 E. 12th Street
Catta Verdera Country Club 1111 Catta Verdera
Coyote Pond Park 2543 Old Kenmare Drive
Creekside Oaks Elementary 2030 First Street
First Street Elementary School 1400 First Street
Foskett Ranch Elementary 1561 Joiner Parkway
Glen Edwards Middle School 204 L Street
Horizon Charter Schools 873 1st Street
John Adams Academy 1797 Bella Breeze Drive
Joiner Park 1701 Nicolaus Road
Kaiser Medical Offices 1900 Dresden Drive
Leaman Elementary School 1200 Brentford Circle
Lincoln Christian Academy 1200 Highway 193
Lincoln Crossing Elementary School 635 Groveland Lane
Lincoln High School 790 J Street
Lincoln Urgent Care 77 Lincoln Boulevard
Machado Park 646 Downing Circle
Markham Park 1175 Toyon Circle
Meadowlands Park 432 Ashwood Way
Palo Verde Park 680 Costa Lane
Pasillas Park 2772 Mackinac Drive
Pete Demas Park 1164 Stansbury Lane
Peter Singer Park 371 Danbury Lane
Phoenix High School 870 J Street
Scheiber Park 2472 Third Street
Sheffield Park 681 Sheffield Lane
Sutter Medical Plaza 685 Twelve Bridges Drive
Twelve Bridges Elementary School 2450 Eastridge Drive
Twelve Bridges High School 2360 Fieldstone Drive
Twelve Bridges Middle School 770 Westview Drive
Twelve Bridges Park 2250 Eastridge Drive
Waste Water Treatment Facility 1245 Fiddyment Road
5.3 Construction Costs Estimates
The estimated capital construction cost of the Conceptual Network Design for new Cityowned routes is $10,321,615, which includes estimated design and engineering and permitting costs, 0.5 mile of new fiber cable installation (in existing city-owned conduit), and
14.9 miles of new underground construction (which includes 1.2 miles of the planned traffic 1218
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ENTRUST Solutions Group March 12, 2026 City of Lincoln, CA signal network).53 Cost estimates do not include anticipated annual fiber lease costs that may be incurred in order to secure existing private fiber assets.
A thorough design engineering process would be able to identify areas that could utilize aerial construction on existing utility poles, which could substantially reduce the total capital cost (aerial construction averages $75/LF compared to underground at $130). However, conceptual designs do not take into account specific means and methods of construction, and thus works from the assumption that all construction will need to be underground. Cost estimates for the Conceptual Design are only estimates based on existing market conditions and would be further refined upon completing design engineering and putting the project out for a public bid.
The design engineering and field surveying process for each phase would verify and record all existing assets and could uncover additional assets that would reduce the need for some of the new construction, identify areas for aerial deployment on existing utility poles, or identify cost-effective strategies, thereby lowering the total overall construction costs.
Construction costs can be even further reduced through effective utility coordination, implementing a dig once/joint trench program, and aligning broadband expansion projects with other major CIP projects, particularly those with excavation in the City right-of-way (ROW). The labor required for excavation can account for 40-60% of total construction costs.
When work is coordinated between utilities and public agencies, all parties can expand their fiber footprint at a fraction of the cost by taking advantage of synergies with other projects.
5.4 Lease of Private Fiber Assets
The Concept Design proposes that the City secure access (through a dark fiber lease, IRU, or other contract) to 31.3 miles of existing, privately-owned fiber assets in order to avoid a costly overbuild. Although not shown on the maps above due to proprietary status under NDAs, ENTRUST has confirmed the availability of private assets at specific locations that would enable a redundant interconnected web of private and future public routes.
Typically, dark fiber leases are a monthly rate based on a “per strand mile” (single glass strand of fiber traversing one route mile) basis. In the greater Sacramento region, monthly “route mile” rates are between $55-75; at a minimum (and assuming the City has adequate equipment to enable efficient use of fibers as detailed in Appendix A), the City would need two (2) strands across the 31.3 miles identified. That equates to an estimated annual lease cost between $41,000 to $56,000.
Using the current comparable construction rates used above in the Construction Costs Estimate, building 31.3 miles of new underground conduit and fiber would cost an estimated 53 Construction costs account for prevailing wage and are based on ENTRUST’s analysis of comparable cities, recent construction bids, equipment and material costs, and a regional assessment of the labor and construction market. An inflation factor has been included to address future, short-term cost increases.
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ENTRUST Solutions Group March 12, 2026 City of Lincoln, CA $21,484,000. At that cost, it would take 383 years for the City to justify building new fiber as opposed to leasing existing fiber.
Additionally, leasing private fiber assets opens up opportunities for the City to explore innovative public-private partnerships, and potentially negotiate more favorable terms and/or additional public benefits through joint use of other assets within the public right-of-way.
5.5 Summary of Findings
Conceptual design connects 80 locations while
leveraging existing, private fiber to avoid overbuild and high costs.
The City of Lincoln prioritized 80 locations for connectivity, which include public facilities, community parks, schools and community anchor sites. Providing connectivity to these locations results in a design covering approximately 46.7 route miles. This includes 15.4 route miles of proposed new fiber optic network (new conceptual routes as well as portions of the City’s planned traffic signal network). In order to keep costs down and avoid overbuilding networks, the design assumes access to a minimum of two (2) strands of existing private fiber infrastructure54 covering a total of 31.3 route miles, as well as the use of
0.5 miles of existing city conduit. Leasing or contracting access to existing private fiber assets avoids overbuilding multiple networks, significantly reduces the capital required, and opens up opportunities for beneficial public-private partnerships between the City and private provider(s).
The Concept Design prioritizes the most critical sites
first.
The Conceptual Design is broken into three phases, in order to prioritize the most critical City sites first and focus on providing redundancy to these locations. The phases can be built incrementally or broken down into sub-phases, which would incorporate the leased fiber and the new build construction accordingly.
54 ENTRUST identified significant private fiber assets within city limits that could be leveraged through a dark fiber lease, IRU, or other contract to establish a broader City network. However, details of these assets are proprietary and protected under NDAs, so specific locations of private networks have been intentionally omitted from this memo. 1220
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ENTRUST Solutions Group March 12, 2026 City of Lincoln, CA Total construction (3 phases) is $10M, but can be done
incrementally and opportunistically.
The total construction cost of all three phases of the Conceptual Design is estimated at $10.3 million, assuming that all routes are underground conduit and fiber cable.55 There are further opportunities to reduce construction costs, as each phase and route offers unique opportunities for value engineering, developer joint build, utility coordination, and grant eligibility.
The $10.3 million estimate does not include recurring annual fiber lease costs; these would need to be negotiated directly with the provider and may even be further mitigated through a public private partnership. However, based on competitive market rates, typical monthly dark fiber lease rates in the Sacramento region range between $55-75 per strand, per route mile. 55 Opportunities to utilize aerial fiber deployment on existing utility poles, which can be constructed at about 40-60% of underground costs, would be identified during a design engineering process, and thereby could reduce the total capital estimate of $10. 3 million. 1221
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ENTRUST Solutions Group March 12, 2026 City of Lincoln, CA
6. Technical & Financial Analysis
Cities are realizing the importance of next-generation broadband services to support the future of their communities, beginning with delivering 21st century services to community members, businesses, and stakeholders. Evidence demonstrates that broadband services have a net positive economic and social impact to communities by enhancing competitiveness, workforce development, educational capabilities, municipal operations, and smart city deployment.
Figure 50. Factors to Consider when Choosing a Broadband Business Model To determine which business model for municipal broadband is best, local governments should understand various factors, such as: organizational requirements for security and control over its internal communications (including emergency response), community needs, competitive market factors that define infrastructure options, and organizational and operational capabilities of the local government itself. The various business models involve different levels of investment and control that come with varying risks and rewards.
6.1 Operational Model Options
Public Policy Only
The municipality utilizes its public policy tools to influence how broadband services are likely to develop in its community. Public policies are shaped to streamline the processes of designing, constructing, and managing broadband infrastructure in a local government’s jurisdiction. Focus areas include right-of-way access, permitting processes and costs, construction practices and placement methods, franchise agreements, and utility fee assessments. Examples of broadband policies and standards include joint trenching and “dig once” policies, utility relocations, road moratoriums, and funding mechanisms for design, labor, and materials. This option is not considered a true business model but does impact the local broadband environment and is therefore included as one option.
The key to successful policy development and implementation is inter-departmental coordination and communicating the shortcomings in current practices and policies. With a better understanding of interdependent responsibilities, policies can be improved. In addition, changes often come with an associated cost, so the municipality will often need to establish a fund to assist in the early adoption of certain policies. 1222
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ENTRUST Solutions Group March 12, 2026 City of Lincoln, CA Public Services Provider
Public services providers utilize publicly owned fiber and broadband resources to interconnect multiple public organizations with fiber or wireless connectivity. These organizations are generally limited to the community anchors within their jurisdiction, including local governments, school districts, higher educational organizations, public safety organizations, utilities, and healthcare providers. The majority of these anchors require substantial connectivity and often, the local government’s network can provide higher capacity at lower costs than these organizations are able to obtain in the commercial market.
Infrastructure Provider
Cities that provide conduit and dark fiber services to local organizations are generally considered infrastructure providers. They lease these assets to community organizations, businesses, and broadband providers. These organizations use municipal fiber to connect to one another and to data centers to reach the Internet, cloud services, and other content networks. Many municipal providers who have deployed these services began by building their own fiber networks to serve purely municipal functions. As their networks grew, they realized that these networks could provide access to local organizations needing fiber connectivity.
Dark fiber is the core product of most infrastructure providers and is generally utilized by businesses and community anchor organizations in order to reduce their telecommunication expenses and achieve higher bandwidth speeds. Typically, dark fiber strands are leased using a simple mileage-based price calculation to the end user. However, customers may require new construction to reach their facilities, resulting in construction costs to be incurred by the municipality and which will be charged back to customers to allow the municipality to recoup its investment.
Open-Access Provider
Local governments that adopt the open-access model generally own substantial fiber-optic networks in their communities. Open-access allows these local governments to “light” the fiber and equip the network with the electronics necessary to establish a transport circuit to interconnect service providers with the local network.
The concept of open access enables competition among service providers across a network that is owned by the local government. The municipality remains neutral and nondiscriminatory and is open equally to any providers that seek to deliver services over the network. Service providers lease access to the network based on the amount of bandwidth required by the end customer and an established standard rate structure and terms of service. Open-access networks generally charge wholesale rates to retail broadband providers. They publish rates for competitive service providers, charging a monthly recurring fee based on bandwidth of the service utilized or a flat fixed fee per month. Services offered may include Internet, telephone, data connectivity (transport), and dark fiber. 1223
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ENTRUST Solutions Group March 12, 2026 City of Lincoln, CA Municipal Retail Provider- Business Only
A common goal for municipalities that deploy broadband networks is to support local economic development needs. Local governments equip their business and industrial districts with fiber infrastructure through which they can provide cost effective, high-speed Internet and other data services to local customers.
Municipal business providers offer competitively priced Internet and communication services that are generally very competitive in the small and medium business market against other provider offerings. They compete on both price and quality, generally focused on the following value proposition, all at a lower monthly cost:
• Higher bandwidth, scalable to Gigabit speeds
• Symmetrical service, the same upload and download
• Higher quality fiber connections with less downtime and a stronger service level agreement
• Responsive local customer service
Municipal Retail Provider- Full Residential & Business
Services
Municipalities that provide end user services to residential and business customers are considered retail service providers. Most commonly, local governments offer triple-play services consisting of phone, television, and Internet services, essentially becoming an equal competitor to incumbent cable and broadband providers. As a retail provider, the organization is responsible for a significant number of operational functions, including management of retail services, network operations, billing, provisioning, network construction, and general management.
Public-Private Partnerships
Public-private partnerships (P3s) are an emerging business model that provides an innovative solution to an ongoing municipal broadband issue: how does a local government invest in municipal broadband without operating a broadband network? Generally, P3s create a cooperative platform for a local government and one or more private organizations to plan, fund, build, and maintain a broadband network within the municipality’s jurisdiction.
To make a P3 successful, each organization should align on negotiable agreements, which can include:
• Who has rights to access the network – is it exclusive or non-exclusive? • What are the public and private partners’ goals and how are they incentivized? • What roles and responsibilities does each partner have? • What assets are financed through the public?
• What revenue model is used to recoup investment? What requirements must the private partner meet, in terms of service availability, speed, price, build locations, and performance schedules?
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ENTRUST Solutions Group March 12, 2026 City of Lincoln, CA • How will the partners determine future buildouts and who pays for them? • What happens if the private assets are sold or acquired? The key factors that define a public-private partnership, as opposed to simply a customervendor relationship, is that: (a) all parties contribute, (b) each parties’ benefits are based on their contributions, and (c) one partner does not pay another; there are few or limited transactions between partners.
Figure 51. Broadband Business Models
The business models in the middle of the continuum (Figure 51) accommodate, but don’t necessitate, a P3. The essence of such a partnership is that for-profit and for-people entities collaborate to achieve complementary, if not common, objectives. The bottom line for private entities is profit, while it is quality of place for public agencies. In concept, private entities can flexibly mobilize resources where there is money to be made and public agencies can redistribute resources to ensure no one is left out. A P3 can help realize both these outcomes: public involvement reduces risk to private investment, and private involvement enables faster and more extensive execution. Generally, partnerships decrease risks while enabling larger or new forms of rewards.
Implications for Lincoln
The City is already in the process of utilizing the Public Policy Only approach and should continue to emphasize these broadband-friendly policies that encourage private investment while expanding City communications through opportunistic builds and utility coordination.
The City has relatively little existing conduit, and a small amount of existing fiber cable, so business models that hinge on direct service provision (infrastructure provider, services provider, etc.) are not viable as there is not an existing fiber network on which to rely.
However, the City could approach a P3 model with the right partner –an incumbent provider that can offer favorable dark fiber lease terms to the City to fill the gaps and connect the new build of the Conceptual Design. The City could still offer tremendous 1225
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ENTRUST Solutions Group March 12, 2026 City of Lincoln, CA benefits to the partner in exchange for those lease terms – including expanded market reach (through construction of the 15.4 miles of new network build and the 1,323 homes, businesses, and community anchor institutions (CAIs) those routes pass), master encroachment and permitting processes that streamline deployment for the private provider, and coordination on new development projects that enable the partner to install new infrastructure at minimal cost through joint trenching practices.
6.2 Technology Overview
Fiber network technology is deployed in a hierarchy with a core network (the red oval in Figure 52) that interconnects to other local fiber rings. Distribution infrastructure and fiber laterals extend from the feeder networks to enterprise and institutional networks for retail broadband service. Various entities own different parts of this, represented by colored “private partner” elements in the figure. Cellular antennae and other wireless infrastructure connect to providers’ core networks via fiber. Backbone fiber can also be used to fully separate traffic from utility management networks. The proposed Conceptual Design, which utilizes existing private fiber for a city-wide backbone, utilizes this hybrid network technology approach of interconnecting public and private assets.
Figure 52. The Hierarchical Structure of Networks
Generally, due to the hierarchical nature of modern networks, technology options can be divided into (a) high-capacity “core” networks that interconnect providers’ major facilities, including co-location and exchange facilities, (b) regional backbone, “feeder,” or “metro” networks that connect major customers and distribution hubs, (c) distribution infrastructure that extends into neighborhoods, and (d) access infrastructure to networks users’ physical devices, homes, offices, shops, etc.
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ENTRUST Solutions Group March 12, 2026 City of Lincoln, CA There are two general classes or types of services that can be provided over modern network infrastructure: transport or access. These services are complementary but involve different components and costs.
Transport services are dedicated services that typically come with guaranteed bandwidth and uptime commitments, which are referred to as service level agreements (SLAs).
Transport services are variously referred to as “backhaul,” “bulk IP,” “carrier-class,” “enterprise,” “long-haul,” “managed,” “metro,” or “middle-mile” services, depending on the context. Generally, they are used by large organizations and institutions that have missioncritical needs for uninterrupted, high-speed broadband connections (government, education, medical, or large anchor enterprises, including ISPs).
Access services are relatively inexpensive, “best effort” services (e.g., “speeds up to 1 Gbps”). Access services are often referred to as “retail networks,’ and do not include any solid performance guarantees. This is the type of service offered to residents and businesses by incumbent internet providers such as AT&T or Comcast.
Transport Services
Transport services involve relatively few stable, but high-performance connections. Users are major businesses and institutions, including network service providers. The service is moving information from one point to another, rather than leasing an asset, so the value comes from ensuring the information keeps moving. This requires equipment that lights the fiber, maintains connections, and transmits data as diagrammed in Figure 53. Some form of interconnection with other networks or services, which requires additional equipment, is commonly a part of transport service.
Figure 53. Transport Networks Architecture
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ENTRUST Solutions Group March 12, 2026 City of Lincoln, CA Networks typically have a core network composed of a few centralized sites—called central offices, data centers, or headend depending on type of ISP—interconnected by fiber in a ring architecture. Core sites contain critical equipment to connect the local network to the global network. They must be secure, with reliable power and backups, and preferably centrally located. At least one site, but ideally two, must connect to high-capacity dedicated internet services, ideally via different providers with fiber following separate routes, for backhaul.
Transport customers typically have substantial network operations of their own that incorporate services where needed, which requires next generation technologies— specifically software-defined wide-area networks (SD-WAN) and sophisticated management systems. Customers may require dual-homed connections, which connect to the core site via two diverse routes, and redundant connections to cloud services, tier 1 ISPs, and other service providers.
Transport service providers often co-locate in other companies’ data centers to reduce costs.
Access service providers generally prefer to own their core network sites, where they can access infrastructure called “pedestals” or “points of presence” (POP). This is changing somewhat with the emergence of wholesale open access infrastructure. Interconnection sites between different providers ranges from massive data centers to relatively small structures.
The network equipment required to deliver broadband services to customers is comprised of several functional groups and multiple components. All business models require core equipment, which must be supplemented with various types of access equipment and infrastructure.
Core Equipment
The core equipment aggregates traffic from all access equipment, connecting customers and routing their data to and from the IP edge equipment or other end-point destinations.
Standard network protocols provide link redundancy and dynamic traffic re-routing in the event of an equipment failure or fiber cut. Core equipment can easily support thousands of customers and hundreds of gigabits of traffic throughput at deployment and will accommodate future system growth through the addition of service modules, optical interfaces, and/or software licenses.
Internet Protocol Edge (IP Edge) Equipment
Separate from the core switches, the network must maintain an “internet perimeter.” The internet perimeter will include internet routers and internet firewalls to be used to manage routing throughout the network. Firewalls will be utilized to protect critical back-office systems, including provisioning, network management, data storage, and other information.
The two core switches will be interconnected to two internet routers providing redundancy for internet services in the event of a single interface or equipment failure. As mentioned above, backhaul circuits should be acquired from at least two providers using diverse paths. 1228
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ENTRUST Solutions Group March 12, 2026 City of Lincoln, CA The central office would house core and edge equipment for ISPs serving customers within the area. Other carriers could be co-located in these sites so circuits and traffic could be connected and routed to the rest of the world. Equipment and facilities requirements are reasonably modest—primarily separate, secure cages for providers and major network users to place equipment, along with environmental controls and clean, reliable power. We assume the central office would be the City’s data center. Otherwise, costs to build out a data center, not including property acquisition or construction costs, could be an additional $500,000.
Access Services
The major difference between a local transport network and a fiber access network is the addition of access and distribution infrastructure, including hubs and multi-site terminals, illustrated in Figure 54. The core network delivers much the same functionality to broadband distribution hubs—also called points-of-presence (POP)—as to transport service customer sites. The dedicated connections function as feeder lines, which are also typically deployed in rings, between the core sites and distribution hubs. The core and feeder networks and hubs comprise the “transport” network. Access requires additional equipment that supports connections to many customers.
Figure 54. Access Network Architecture
Feeder fiber connects optical line terminators (OLT) in the core sites to passive splitters called fiber distribution hubs (FDHs), typically in outdoor cabinet enclosures placed strategically throughout the service area. Splitters may also be located within the access POP itself. In areas where aerial fiber deployment may be used, FDHs may be placed aerially or transitioned from the aerial pole to a ground mounted FDH. As this plan is limited to assessing major corridors as fiber routes, we assume coverage is limited to customer premises within 175 feet of the backbone. This requires only a single FDH. 1229
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ENTRUST Solutions Group March 12, 2026 City of Lincoln, CA The distribution network branches out from the FDHs. Multiple access lines drop off the distribution lines—hence the term “fiber drops”—via drop terminals into customer premises.
Major sites can be directly and diversely connected to the core sites via “laterals,” basically putting them on the feeder network. The backbone fiber may be used for a distribution, feeder network, and/or laterals, as well as core network. The particular use of specific fiber strands is a matter of how they are spliced together and where they terminate. Indeed, a single fiber cable can accommodate multiple physically separate networks for purposes such as SCADA or traffic signal interconnection.
Hubs may be powered cabinets, prefabricated shelters, or existing structures with sufficient space for equipment racks and other components. Fiber in the routes analyzed above could connect retail service providers’ POPs anywhere in the City with backhaul via diverse routes to multiple upstream service providers for maximum fault protection. In practice, a distribution infrastructure can and should be built in a phased manner in response to consumer demand and/or in conjunction with other capital projects.
Feeder and Distribution Fiber
Feeder infrastructure that extends from the POPs to neighborhoods and business districts typically requires only a few fibers, at most a single 24-strand buffer tube. The backbone typically consists of 288-strand fiber therefore at least a hundred strands would be available for use as distribution. The estimated costs are based on feeder fibers are sized based on the demand forecast and sizing of each enclosure to ensure that each service area is well equipped for broadband services. These details are addressed in engineering design to get optimal coverage for the least practical costs.
Each OLT serves 512 subscribers at a 1:32 split. The number of POPs and OLTs per POP depends on the number subscribers. The cost includes OLT and backhaul hardware necessary to connect each POP to the core routers. In an actual design/implementation, each OLT would not need backhaul hardware, two line cards, 16 optical interfaces, etc.
Distribution fiber extends from the splitters in the FDHs to network access points (NAPs), or drop terminals, which connect individual fibers entering customers’ premises. NAPs may be attached to aerial strand, located in ground level pedestals or placed in underground vaults or hand holes located near the sidewalk or curb in residential neighborhoods or business districts. NAPs are costed as an integral component of the distribution infrastructure estimates. Fiber distribution to NAPs will be sized based on the service area density to provide service to between 8-12 premises per NAP.
Fiber Service Drops
Fiber drops connect from each NAP to the customer premise equipment that delivers broadband service. At the customer premise, the drop cable terminates in a protective “clamshell” enclosure attached to a home or building for storage of slack and connection to the home equipment. Drop fiber may be installed aerially or underground, typically for a flat fee. Providers may charge additional drop costs for special circumstances such as burying fiber through difficult landscapes or under driveways.
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ENTRUST Solutions Group March 12, 2026 City of Lincoln, CA Optical Network Terminal
An Optical Network Unit (ONU), sometimes called an Optical Network Terminal (ONT), serves as the demarcation point between the retail ISP’s fiber network and the router or firewall connecting to the customer’s local area network (LAN). There are two general methods for installing ONTs. The first method involves mounting an outdoor rated ONT on an exterior wall of the structure and extending service wiring inside the premise. The second method involves extending the fiber into the premise and installing an indoor-rated ONU inside. In either case, the ONT is typically installed somewhere near the fiber entrance and an AC power source. The ONT terminates the fiber-based PON signals and provides customer access to their services through traditional copper interfaces. XGS-PON ONT’s supporting greater than 1 Gbps data service may also support optical small form-factor pluggable (SFP) interfaces for connection to enterprise-class LAN equipment.
Implications for Lincoln
With little to no existing public fiber assets, the City is not in a position to offer either Transport or Access Services. However, a public-private partnership could provide the City and its departments with the Transport Services it needs to ensure City communications and public services; in exchange, if the City were to offer access to the 15.4 miles of new build identified in the Conceptual Design. The new build will generate 1,323 new passings which is not enough to sustain a new enterprise but the private partner would be able to expand their existing customer base to more potential subscribers – a win-win for the City and its partner.
It should be noted that its possible (though not necessarily recommended) for the City to offer both Transport and/or Access Services to subscribers by essentially leasing out the portions of the network it needs to provide those data services (i.e., the backbone ring and routes to data centers in San Francisco, San Jose, and/or Los Angeles). However, as will be shown below in the Financial Analysis, the number of unique potential customers that the Conceptual Design might create access to is likely not enough to cover costs of a standalone enterprise.
6.3 Financial Analysis
ENTRUST used the Asset Assessment, the Market Analysis, and the Conceptual Design developed as part of the Broadband Master Plan to inform the Financial Analysis. Many factors should continue to be evaluated and considered for the initial construction/capital funding, such as value engineering, opportunities for joint build, partnership options, regional collaborations, the competitive environment, and grant funding options.
This analysis is intended to assist the City in understanding the costs of monetizing a public asset, the value proposition of a private partner, where there is existing need to attract private capital, and how revenues can be leveraged in negotiations to secure the best position for the City. This memo is not a business plan or feasibility study and is not intended as a definitive financial statement or pro forma. Rather, it is intended as a tool to ensure the 1231
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ENTRUST Solutions Group March 12, 2026 City of Lincoln, CA City has an overview of the potential revenues and expenses and the impacts of different business model approaches.
In a City like Lincoln, where there is already near-ubiquitous cable access and significant private fiber backbone routes throughout the City, particularly along major corridors and arterials, overbuilding existing private networks with a new public network may not only be costly, but also may not be the best use of public funds. As noted in the Conceptual Design (see Figure 55),
Figure 55. Conceptual Network Design56
ENTRUST recommends building public fiber laterals to critical City facilities (identified as Priority 1, 2 and 3 Locations) that would extend off of existing private routes, and securing access to existing fiber through dark fiber leases. This minimizes the capital cost to establish a redundant, looped-architecture network for City services by building only in areas where no existing private fiber exists – while simultaneously creating a leverage point for the City by creating new fiber routes that could complement incumbent providers by providing access to 56 Private fiber assets, protected under an NDA, have been intentionally omitted from Figure 55; however, those private assets, secured through a dark fiber lease, would complete the disparate segments into a redundant network loop.
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ENTRUST Solutions Group March 12, 2026 City of Lincoln, CA new markets not currently served.
With an estimated construction cost of $10.3 million, the three phases of the Concept Design would add 15.4 miles of new conduit and fiber cable that extends from 31.3 miles of existing private fiber (secured through a long-term dark fiber lease, estimated between $41,000 and $56,000 annually). This conceptual network would provide 21st century connectivity to critical City facilities and sites, ensuring City control and security to sustain City operations, public services, and emergency response communications. However, when examined through the lens of a public-private partnership, a financial analysis should consider the revenuegenerating potential of these networks to calculate their value during any possible negotiations with a private ISP.
Passings Analysis
Placing a 175-foot buffer57 around the proposed new 15.4 miles of City build within the Conceptual Design, and cross-referencing an address database, provides the ability to quantify the potential reach of the conceptual network to potential residential and business subscribers that can be economically connected into the City/Private network (typically addresses falling within 175 feet is a feasible distance that can be bridged by a private ISP through last mile service drops).
All three phases of the new build would pass more than 1,323 residences and businesses within 175’ of the backbone. However, individual service drops to connect each address to the City’s fiber will still be required, which will generate significant need for start-up capital, as discussed in the next section.
Operational Revenue & Expense Impacts
Offering retail data services to paying customers can generate revenue, but also creates substantially more obligations that come with the expectation of a fee-for-service. Broadband enterprises require significant direct costs to deliver services, as well as a minimum level of staffing and industry expertise. Some municipalities – particularly ones that already operate an electric utility – may already have some of the support staff and infrastructure in place that can be leveraged for a broadband enterprise, such as billing support and software, fleet vehicles and maintenance, and even field staff. However, broadband typically has specific requirements with respect to equipment and technical expertise and is prohibited from being subsidized by any electric utility, which means new staff and assets specifically for broadband must be acquired.
Examining the anticipated revenues and expenses of such an endeavor can give the City a realistic understanding of the risks and investment needed to transform a public fiber network into a functioning, competitive retail broadband enterprise. The cost drivers, staffing needs, and equipment listed in these estimates will be required whether the network is operated directly by the City or by another business model described above. However, an 57 Typically addresses falling within 175 feet is a feasible distance that can be bridged by a private ISP through last mile service drops.
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ENTRUST Solutions Group March 12, 2026 City of Lincoln, CA existing ISP may already have many of these resources already in-house and thus could minimize expenses through a P3 approach.
The financial analysis uses several industry-standard assumptions that take a conservative – yet realistic – approach. The model begins with the assumption that the network would be operated as a new stand-alone enterprise – requiring all the necessary staffing, support, technical expertise, and maintenance to sustain day-to-day functions. The model estimates average annual operating expenses once retail subscriber levels stabilize after 5 years, with 30% of all passings purchasing retail internet service at the standard rate of $60 per month for a 1 Gbps download/1 Gbps upload connection. That translates to 397 customers and results in approximately $261,954 in annual gross revenues.
However, the requisite staffing and annual direct expenses – many of these fixed costs that cannot adapt to such a small market size - are estimated at $1,383,764, broken down into various cost drivers as shown in Figure 56.
Figure 56. Average Annual Operating Revenues & Expenses Estimate The estimated earnings before interest, taxes, depreciation, and amortization (EBITDA) are estimated to exceed revenues by $1,118,000. This is primarily due to the cost of maintaining a 15-mile network and the fixed costs of staffing necessary, coupled with a market (~400 subscribers) that is too small to cover those fixed/sunk costs.
However, this figure does not account for the debt service needed to cover start-up capital costs; there is more than $11,985,544 million in network launch capital expenditures Average Annual Revenue Estimate
Service Revenues (MRC) $ 261,954
TOTAL $ 261,954
Average Annual Expenses Estimate
Direct Cost of Services
Data Transport $ 60,000
Data Center $ 12,000
Vehicle Maintenance $ 29,250
Network Maintenance $ 206,000
Utilities $ 10,000
Field Tools $ 27,667
Network Software $ 10,729
SUBTOTAL $ 355,646
Administrative Expenses
Staffing $ 980,828
Legal Fees $ 2,000
Marketing $ 5,239
Reporting $ 12,000
Travel & Training $ 7,000
Office Supplies $ 5,263
General Overhead $ 13,157
Bad Debt $ 2,631
SUBTOTAL $ 1,028,118
TOTAL EXPENSES $ 1,383,764
EBITDA $ (1,117,999)
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ENTRUST Solutions Group March 12, 2026 City of Lincoln, CA (CAPEX) that would be required in order to construct the 15.4 mile extensions and connect 397 customers (30% of passings), as shown in Figure 57.
Figure 57. Network Launch CAPEX Estimate - $11.9 M
None of these estimates are viable due to the same single factor: 1,323 passings (translating to approximately 400 customers) is not a sustainable market size for a standalone enterprise.
Thus, the value of the City’s proposed Conceptual Design is not in creating a new stand-alone enterprise, but rather in expanding an existing market that can leverage existing operations, staffing, and fixed costs.
An ISP already in the Lincoln market already has many of the support staff in place (billing, network operations and engineering, etc.), thus eliminating the need for new hires. The marginal costs of serving 400 new customers in an existing market is negligible; but it would have a net positive impact on revenues.
If the City were to enter into P3 negotiations with an ISP, both sides would need to be creative and innovative to identify a balanced and fair approach that creates advantages and benefits for both sides. Greater leverage in negotiations will also help the City in resolving the digital connectivity issues it wishes to prioritize – whether that be sharing some of the capital costs of network expansion, community Wi-Fi, closing the Digital Divide, improving affordability and choice, or expanding into underserved neighborhoods. These negotiations could involve working with the ISP to evaluate all the expenses in greater detail, identifying potential synergies between the ISPs current operations and new markets, and evaluating different growth models and timelines to spread costs out over longer periods.
6.4 Financing Options
A wide range of funding mechanisms are available to support construction and long-term operations, but the City’s goals for the network (e.g., municipal services vs. community subscriber networks) will influence which mechanisms are best fitted to address funding 1235
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ENTRUST Solutions Group March 12, 2026 City of Lincoln, CA gaps. Some options are traditional municipal finance tools, such as bonds and special districts; others are newer models enabled by recent state legislation, joint powers authorities, and dedicated federal and state broadband grants. Lincoln may also benefit from opportunistic development strategies, revenue reinvestment, and creation of dedicated enterprise funds. The following subsections outline the major financing mechanisms, their governing authority, and their potential applicability for Lincoln.58 Bond and Other Debt Financing
Municipalities frequently turn to debt financing to fund major infrastructure projects, and broadband is no exception. Traditional bond instruments remain attractive because they offer longer repayment periods and lower interest rates than corporate bonds, with interest generally tax-exempt for investors. These features reduce the cost of capital and spread repayment over time, making bonds a reliable source of upfront funding for backbone construction.
General Obligation Bonds
GO Bonds are backed by the full faith and credit of the issuing city or county. They are repaid through general taxation and do not rely on project revenues. GO Bonds are often used for essential infrastructure where there is broad public benefit. In Lincoln, the 15-mile new build identified in the Conceptual Design is primarily intended to ensure uninterrupted City communications and public services, and thus could utilize GO Bonds, subject to voter approval of the bond measure.
Revenue Bonds
Unlike GO Bonds, revenue bonds are repaid from the income generated by the project they fund. They are typically secured by user fees or other dedicated revenue streams. In a broadband context, this might include lease payments from service providers using City fiber or conduit. Revenue bonds reduce reliance on tax revenue but require a demonstrable revenue source to secure favorable rates. Recent California legislation — Senate Bill 156 (2021) — specifically authorizes local agencies, including joint powers authorities, to issue revenue bonds for broadband infrastructure and establishes the Broadband Loan Loss Reserve Fund to support such financing.59 However, as noted above, the preliminary financial analysis of a broadband enterprise network does not indicate sufficient revenues to support repayment of Revenue Bonds.
58 Information provided in the section does not constitute a legal opinion and should not be construed as such. Questions about interpretation or applicability of these or other provisions of federal or California law should be referred to legal counsel. 59 Senate Bill 156, An act to add and amend various sections of the Government Code and Public Utilities Code, relating to communications, Chapter 112, Statutes of 2021 (effective July 20, 2021).
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ENTRUST Solutions Group March 12, 2026 City of Lincoln, CA Private Activity Bonds
Local governments may also issue tax-exempt bonds on behalf of private companies if the project serves a clear public purpose. The Infrastructure Investment and Jobs Act expanded the categories of eligible projects under the federal PAB program to include broadband in unserved and underserved areas.60 While PABs are most commonly used in rural settings, they could be considered in Lincoln for targeted urban build-outs. PAB issuance is subject to the State’s annual volume cap, so projects must compete with other qualified infrastructure for allocation. However, Lincoln’s dearth of unserved areas, per the California Public Utilities Commission (CPUC) and Federal Communications Commission (FCC) broadband maps, do not indicate that PAB are a viable option.
Alternative Financing Instruments
In addition to traditional bonds, Lincoln may consider alternative debt mechanisms. One such tool is the 63-20 bond, in which a nonprofit issues tax-exempt debt on behalf of a city or county to finance public facilities, with the facility reverting to the government once the debt is repaid. Another option is subordinated debt structured as equity, which can attract private investors by offering higher returns while allowing the City to retain ownership of the infrastructure.
These instruments are often facilitated through statewide entities such as the California Statewide Communities Development Authority (CSCDA), the California Infrastructure and Economic Development Bank (IBank), and the California Enterprise Development Authority (CEDA).61 While none currently administer broadband-specific programs, they provide flexible vehicles that cities can leverage to issue debt for eligible infrastructure, including telecommunications facilities. Still, the issue of negative annual operating revenue challenges the City’s ability to utilize these alternative financial tools.
Special Districts
Special districts are local government entities created to provide public infrastructure or services not otherwise delivered by general-purpose governments. In California, they are common for water, fire protection, parks, sanitation, and other services. They can also be structured to finance and deliver broadband infrastructure. The two defining attributes of special districts are: (1) they require majority citizen support, often through a vote on formation, and (2) residents or property owners within the district may be subject to assessments, taxes, or fees to support operations and debt service.62 60 Infrastructure Investment and Jobs Act (IIJA), Pub. L. No. 117–58 (2021), expansion of qualified projects under the Private Activity Bond program to include broadband in underserved areas.
61 California Statewide Communities Development Authority (CSCDA), http://cscda.org , California Infrastructure and Economic Development Bank (IBank), https://ibank.ca.gov and California Enterprise Development Authority (CEDA), https://ceda.caled.org 62 Special District Formation Guide (2016). California Special Districts Association 1237
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ENTRUST Solutions Group March 12, 2026 City of Lincoln, CA The Local Agency Formation Commission (LAFCO) oversees the formation and regulation of most special districts. Applicants must follow statutory procedures, including submission of petitions or resolutions, compliance with state formation requirements, and LAFCO approval.
While the process can be rigorous and time-consuming, special districts can provide a sustainable funding source for long-term infrastructure.
Community Facilities Districts (CFDs)
Authorized under the Mello-Roos Community Facilities Act of 1982, CFDs allow cities, counties, or joint powers authorities to finance public improvements and services through special taxes.63 Formation requires two-thirds voter approval within the proposed district boundaries, after which a special tax lien is placed on each property. CFD revenues can support debt issuance, including municipal bonds, to fund broadband-related capital improvements.64 Community Facilities Districts (CFDs), may be viable in Lincoln if residents are willing to support a special tax to finance broadband infrastructure in targeted neighborhoods.
Community Service Districts (CSDs)
Community services districts provide a wide range of local services and may be governed by an elected board of directors or a county board of supervisors. California law was amended in 2018 (AB 2748) to authorize CSDs to construct, own, and operate broadband facilities, provided retail services are delivered through a qualified broadband provider. This makes CSDs a flexible tool for broadband deployment, though LAFCO approval is required for new or expanded powers.65 CSDs may issue bonds, levy assessments, or create improvement districts to finance infrastructure, subject to voter or landowner approval.66 CSDs could become relevant for Lincoln through coordination with LAFCO, particularly if broader service areas or regional partnerships are pursued.
Joint Powers Authorities
Joint Powers Authorities are authorized under Section 6500 of the California Government Code, which allows two or more public agencies to jointly exercise their common powers.
Agencies may either act through an agreement or establish a separate legal entity. In the latter case, the JPA assumes a distinct legal identity, insulating its members from direct liability while allowing the JPA to contract, hold assets, and issue debt. This structure makes 63 The Mello-Roos Community Facilities Act of 1982, Cal. Gov. Code §§ 53311–53368.3. 64 CSCDA – Local Goals and Policies for Use of Mello-Roos CFDs (2019), http://cscda.org/getattachment/Infrastructure-Finance-Programs/Community-FacilityDistrict-(CFD)-Financing/Further-Amended-and-Restated-CSCDA-Local-Goals-and-Policiesfor-use-of-Mello-Roos-CFDs-2019-(1).pdf. 65 Cal. Gov. Code §§ 56000–56133 (LAFCO jurisdiction over local agency formation and expansion).
66 Cal. Gov. Code §§ 61121, 61123, 61130–61133 (bonding, taxation, and improvement district powers of CSDs).
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ENTRUST Solutions Group March 12, 2026 City of Lincoln, CA JPAs particularly useful for delivering public services and infrastructure at a scale that individual jurisdictions could not achieve on their own.67 JPAs can own and operate broadband infrastructure, contract with service providers, and issue debt to finance construction. Senate Bill 156 (2021) expanded the utility of JPAs for broadband by authorizing them to issue revenue bonds specifically for broadband deployment and establishing the Broadband Loan Loss Reserve Fund to cover costs of debt issuance and credit enhancement.68 This combination lowers financial barriers for local and regional agencies pursuing broadband initiatives.
Case Study: Golden State Connect Authority (GSCA)
The Rural County Representatives of California (RCRC) formed the Golden State Connect Authority (GSCA) to expand broadband access across its 39 member counties. GSCA illustrates how a JPA can aggregate local governments to secure funding, coordinate strategy, and build infrastructure at scale. Early efforts included serving as the applicant for U.S. Economic Development Administration grants for county broadband planning, followed by the creation of a broadband-specific JPA to own and operate infrastructure. 69 The Golden State Connect Joint Powers Agreement, filed in compliance with Senate Bill 1266 (2016), provides the legal framework for this collaboration.70 It establishes GSCA’s authority to construct, own, and maintain broadband infrastructure; issue debt (including revenue bonds under SB 156); and apply for state and federal grants. The agreement also outlines governance, with each county appointing a delegate to the Governing Board and an Executive Committee empowered to approve projects. Importantly, it shields member counties from liability for GSCA debts, while preserving their right to pursue independent broadband projects.
Together, RCRC’s leadership and the GSCA agreement demonstrate how a broadbandfocused JPA can be structured to balance local control, shared risk, and long-term financing authority.
JPAs offer Lincoln the ability to pool authority and resources with neighboring jurisdictions.
The Golden State Connect Authority (GSCA) illustrates how counties have used this model to plan and deploy broadband infrastructure with shared governance. For Lincoln, joining or forming a broadband-focused JPA could expand its financial and technical capacity, though participation would depend on alignment with regional partners and willingness to share decision-making. The model provides insulation from debt liability and could strengthen Lincoln’s competitiveness for state or federal grants but may be less attractive if the City prefers to retain sole control of its broadband initiative. 67 Cal. Gov. Code § 6500 et seq. (Joint Exercise of Powers Act). 68 Senate Bill 156, Chapter 112, Statutes of 2021 (effective July 20, 2021). 69 Rural County Representatives of California (RCRC), https://www.rcrcnet.org/affiliatedentities 70 Senate Bill 1266, Chapter 173, Statutes of 2016 (effective Jan. 1, 2017), requires JPAs that provide municipal services to file agreements with LAFCO; see also Golden State Connect Authority, https://goldenstateconnect.org/about-us/ 1239
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ENTRUST Solutions Group March 12, 2026 City of Lincoln, CA Grants
State and federal grants have traditionally been a critical funding source for broadband expansion in California. These programs target unserved and underserved areas, digital equity, and infrastructure resiliency. While competitive, grants can reduce reliance on debt and provide Lincoln with opportunities to align local investment with broader state and federal initiatives.
California Advanced Services Fund (CASF)
The California Advanced Services Fund (CASF) was created in 2007 to bridge the digital divide and is administered by the CPUC. Over time, CASF has been expanded and refined through legislation, most recently Senate Bill 156 (2021), which increased funding, created new subaccounts, and extended program deadlines. CPUC has currently extended the deadline for applications through October 31, 2025. CASF grants typically carry a match funding requirement of 20-25%. However, initial review of the CASF eligibility map does not indicate significant areas of Lincoln that are eligible for infrastructure funding.71 • Infrastructure Account: The Infrastructure Account subsidizes the cost of middlemile and last-mile broadband infrastructure to expand the state’s network. Preference is given to projects in communities with limited broadband access and in areas facing socioeconomic barriers. Under SB 156, “unserved areas” are defined as lacking 25/3 Mbps service, and CASF-funded projects must provide at least 100/20 Mbps speeds.
The CPUC aligns this account with federal BEAD guidelines, using updated eligibility maps to identify unserved and underserved areas.72
• Public Housing Account: The Public Housing Account provides grants and loans for projects in publicly supported housing developments, mobile-home parks, or lowincome housing communities. Eligible projects include installation of inside wiring and broadband equipment, with funding available for up to 100% of costs if residents lack access to a provider offering free broadband service at or above state standards.73 • Adoption Account: The Adoption Account supports digital inclusion by funding programs that increase broadband access, public education, and digital literacy.
Eligible initiatives include after-school access, community training programs, public Wi-Fi, and device distribution, with priority given to low-income households, seniors, and communities with historically low adoption rates.74 71 https://broadbandmap.ca.gov/
72 California Public Utilities Commission, CASF Infrastructure Account. https://www.cpuc.ca.gov/industries-and-topics/internet-and-phone/california-advancedservices-fund/casf-infrastructure-account 73 California Public Utilities Commission, CASF Public Housing Account. https://www.cpuc.ca.gov/industries-and-topics/internet-and-phone/california-advancedservices-fund/casf-public-housing-account 74 California Public Utilities Commission, CASF Adoption Account. https://www.cpuc.ca.gov/industries-and-topics/internet-and-phone/california-advancedservices-fund/casf-adoption-account 1240
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ENTRUST Solutions Group March 12, 2026 City of Lincoln, CA Economic Development Administration (EDA) Grants
The U.S. Economic Development Administration (EDA), under the Department of Commerce, periodically offers competitive grants to support redevelopment of commercial areas and infrastructure improvements. Broadband infrastructure, including publicly owned fiber networks, is an eligible expense when tied to economic development outcomes.
EDA programs historically include Planning and Local Technical Assistance, Research and National Technical Assistance, and Public Works and Economic Adjustment Assistance. 75 These programs prioritize projects that demonstrate clear connections to job creation, retention, or business attraction. Broadband projects are eligible if they improve the competitiveness of key development sites or help anchor employers remain in place.
Proposed projects must align with the region’s Comprehensive Economic Development Strategy (CEDS). Applications are relatively complex and require a local match, typically ranging from 20–40%.76 While EDA broadband-related funding opportunities are currently paused during program review by the Department of Commerce, they remain a potential source for Lincoln in the future. Preparing broadband projects that also serve economic development zones or job-creating initiatives will position the City to apply quickly when funds reopen. Regional partnerships would likely strengthen Lincoln’s competitiveness in any future EDA round.
Community Development Block Grants (CDBG)
The U.S. Department of Housing and Urban Development (HUD) administers the Community Development Block Grant (CDBG) program, which provides annual funding to cities and counties for projects addressing housing, public infrastructure, and economic opportunity. CDBG is targeted toward low- and moderate-income households and census blocks.
Broadband infrastructure is an eligible use of CDBG funds when it advances program goals, such as improving quality of life in low-income communities.77 However, funds must align with the City’s Consolidated Plan and housing element. Lincoln’s current housing element does not explicitly include broadband or digital equity, which limits the immediate applicability of CDBG for broadband deployment. The plan does reference renovation and inside wiring, which could serve as an entry point if broadband infrastructure is integrated into property improvement activities.
If Lincoln wishes to pursue CDBG for broadband, the City may need to revise its housing plan to incorporate digital equity and connectivity as infrastructure priorities. Doing so would 75 U.S. Economic Development Administration, Programs and Initiatives. https://www.eda.gov/programs
76 U.S. Economic Development Administration, Funding Opportunities. https://www.eda.gov/funding
77 U.S. Department of Housing and Urban Development, Community Development Block Grant Program (CDBG).
https://www.hud.gov/program_offices/comm_planning/communitydevelopment/programs 1241
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ENTRUST Solutions Group March 12, 2026 City of Lincoln, CA open the door for CDBG-supported broadband projects, particularly in neighborhoods where affordability and adoption remain barriers.
Federal programs such as EDA or HUD’s CDBG could supplement broadband investment when tied to economic development or housing priorities, but only if Lincoln integrates broadband into its planning documents. Taken together, grants will require the City to prepare shovel-ready projects and position broadband as a cross-cutting priority across housing, economic development, and equity planning.
Other Funding
Schools and Libraries Universal Service Support Program (E-Rate Program) The Federal Communications Commission’s (FCC) Schools and Libraries Universal Service Support Program (commonly known as the E-Rate Program) is designed to make telecommunications and internet services more affordable for schools and libraries across the United States. Funded through the Universal Service Fund and administered by the Universal Service Administrative Company (USAC), broadband discounts range from 20% to 90%, depending on factors like poverty level and whether the institution is in a rural area.
E-Rate Program funding covers both Category One Services (broadband connectivity to the building (e.g., internet access, data transmission)) and Category Two Services (internal connections like Wi-Fi equipment, managed internal broadband services). Voice services are no longer covered as of 2020.
Eligible entities include public and private schools, school districts, libraries, and consortiums. Before applying, applicants must have already issued a Request for Proposals (RFP) for a construction contractor. E-Rate Program funding usually opens once per year.
Private Investment
Private capital remains an important complement to public funding. Lincoln can attract investment through partnership models such as long-term leases, concession agreements, or public–private partnerships. These structures, discussed in greater detail in prior technical memoranda, allow the City to leverage private operational capacity while retaining public control over assets or policy objectives. Private investment may be particularly valuable in areas where grant funding is insufficient or where market conditions support rapid buildout with shared risk.
Technology Enterprise Fund
Lincoln currently maintains enterprise funds in areas such as Public Works and Water but does not have one dedicated to broadband. Establishing a technology enterprise fund would allow the City to dedicate revenues from leasing or licensing its assets—such as antenna sites, towers, conduit occupancy, or dark fiber—to reinvest directly in broadband infrastructure. By recycling these revenues into future projects, the City can create a recurring, sustainable source of broadband funding outside of annual General Fund appropriations. This type of fund could also serve as a local match for state or federal grant programs, strengthening Lincoln’s competitiveness for external funding. 1242
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6.5 Summary of Findings
A Public-Private Partnership model offers the City a viable alternative to provide City communications & services
without incurring ongoing costs.
The City has relatively little existing conduit, and no existing fiber cable, so business models that hinge on direct service provision are not viable. However, the City could approach a public-private partnership (P3) model with the right partner –an incumbent provider that can offer favorable dark fiber lease terms to the City to fill the gaps and connect the new build of the Conceptual Design. Dark fiber is unused fiber infrastructure and providers routinely lease the fiber asset to other organizations for their dedicated use.
The City could find synergy with an existing ISP by
combining their backbone routes with the Conceptual
Design.
A public-private partnership could provide the City and its departments with the Broadband Transport Services it needs to ensure City communications and public services; in exchange, if the City were to offer access to the 15.4 miles of new build as identified in the Conceptual Design that was delivered to the City, the private partner would be able to expand Access Services to more potential subscribers – a win-win for the City and its partner.
The Conceptual Design, as a stand-alone enterprise, does not create a sufficient market size to support operational expenses or repayment of capital costs – but could be a viable market expansion for an existing ISP.
Due to its reliance on leasing existing (private) dark fiber for the backbone, the Conceptual Design would generate 1,323 passings. A take rate of 30% equates to 397 customers which does not generate enough unique customer passings to sustain ongoing operations (or to repay any debt incurred in the construction of the $10.3 million network). However, an existing ISP would view those network expansions in the Conceptual Design as a market expansion opportunity, and would be able to absorb the expenses into existing operations.
The City could pursue grant funding through the Economic Development Administration (EDA).
EDA represents the most practical near-term grant opportunities, particularly if the City develops a high-level design and cost model to support applications. EDA focuses its funding on programs and projects that attract, retain, or expand employment; the City’s 1243
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ENTRUST Solutions Group March 12, 2026 City of Lincoln, CA Conceptual Design could be leveraged as routes connecting key commercial corridors and development areas, while simultaneously providing a City communications network for public services. The City should contact their regional EDA for additional program information. 1244
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7. Broadband Policy
ENTRUST evaluated the City of Lincoln’s policies that relate to broadband infrastructure for wired and wireless broadband services, considering ordinances in other California cities, recent state of California (CPUC) and FCC decisions, and regulations and actions on broadband policy taken by Congress and the California Assembly. After a desktop review of City policies and ordinances considering the field of regulatory items, ENTRUST met with department heads for further elaboration on these policies from the City’s perspective.
ENTRUST also reviewed the City’s plans and acquired additional information from various other public documents. Background and context for the policy analysis and discussion can be found in Appendix B.
7.1 General Plan
As required of all California cities, Lincoln has a General Plan, which includes a Community Vision, seven elements mandated by the state, and an Economic Development Strategy.
The General Plan was adopted in 2008 and has been amended at least 15 times to include 14 projects and a 2021 Update to the Housing Element.
Guiding Principles supporting Lincoln’s Community Vision most relevant to policy analysis include Community Design (addressed in the Land Use element), which seeks to build an urban fabric that strengthens Lincoln’s assets and strives to bring coherence and identity to the rapidly developing area;78 Economic Development, which envisions Lincoln becoming a self-sustaining community (estimated to require a population in the range of 120,000);79 and Fiscal sustainability, which requires development and sustainment of a level of service that is of high quality and provides for health and safety of residents.80 Economic Development is very important to the City of Lincoln given its rapid growth, with the goal of becoming a self-sustaining community. Economic development is a strategic priority which includes “strategic investments that ensure long term fiscal sustainability via growth of jobs and local revenues.”81 Infrastructure is also a strategic priority because it is the “underlying foundation on which the continuance and growth of our community depends.”82 Thus the City Council seeks to prepare an Economic Development Vision, “for future economic growth and retention.”83
The General Plan was adopted when “broadband” was Digital Subscriber Line (DSL) from the telephone companies and coaxial cable modems (DOCSIS 2.0) from cable companies 78 General Plan, Section 2-4.
79 General Plan, Section 2-4.
80 General Plan, Section 2-5.
81 2021 City of Lincoln Strategic Plan, https://www.lincolnca.gov/en/ourgovernment/resources/Documents/CityClerk/City-of-Lincoln-Strategic-Plan-2021.pdf, page
6. 82 Ibid.
83 Council Strategic Planning Report 2023-25, City of Lincoln, https://www.lincolnca.gov/en/our-government/resources/Documents/CityClerk/10CFinal.pdf, page 5. 1245
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ENTRUST Solutions Group March 12, 2026 City of Lincoln, CA typically providing 5 Mbps to 20 Mbps. Contrast this with fiber optic cable being the present mode of provisioning broadband, capable of symmetrical 1 Gbps and faster or more. The City Council’s 2023-2025 Strategic Plan adopted in 2023 includes Goal 8, to conduct a review of the City’s General Plan to “specifically identify areas/policies for a major General Plan amendment.”84
The General Plan uses the term “wide band,” which is not common use and has a different technical meaning than the term “broadband,” in reference to telecommunications services.
The General Plan does not mention the internet. It currently addresses Communications Services in Goal PFS-7 as follows:
• Policy PFS-7.1: Telecommunications Services
The City shall work with telecommunication providers to ensure that all residents and businesses will have access to telecommunications services, including wide band service.
To maximize access to inexpensive telecommunications services, the City shall encourage marketplace competition from multiple service providers. • Policy PFS‐7.2 Communication Technologies to Improve Citizen Participation The City shall expand opportunities for citizen participation for all residents through use of communication technologies such as the City website, cable channel bulletin boards, and public service / educational programming.
• Policy PFS‐7.3 Siting of Telecommunications Infrastructure To minimize the visual impact of wireless communications facilities, the City shall encourage the siting of telecommunications infrastructure using the following guidance:
o Locate in areas that minimize visibility from public rights of way and residential areas;
o Whenever possible, locate on existing buildings, poles, or other support structures; and,
o Facilities should be painted, camouflaged, textured, or otherwise designed to better integrate into existing conditions adjacent to the installation site and to minimize visual impacts.
Also, PFS-6.2 requires undergrounding of utility lines in new development except where it is not feasible due to operational issues.
84 Ibid, page 9.
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7.2 Major Projects & Public ROW
Capital Improvement Plans
A Capital Improvement Program (CIP) outlines the planned and ongoing capital projects for a city that maintains or replaces existing infrastructure assets such as streets, sidewalks, lighting, parks, and waste/wastewater lines, facilities, or constructs new assets. Long-range projects may involve significant excavation and improvements that provide the opportunity to jointly deploy broadband assets at incremental cost, typically through adding communications conduit to open trenches/excavation, or by planning for wireless/Wi-Fi capabilities and monitoring applications on poles, public buildings, or other public areas.
Capital improvement projects should be reviewed in the planning stages from a broadband perspective: is there an opportunity to jointly install communications conduit while a trench or other excavation takes place or to include other broadband support assets? Opportunistic deployment of broadband assets with other construction provides significant cost savings and can, over time, result in extensive public fiber infrastructure. A broadband strategic plan should define network design goals and match them with opportunities to build.
Many types of projects include opportunities for inclusion of broadband and internet connectivity. Parks and Recreation projects can provide opportunities for installation of Wi-Fi connectivity, data and montioring applications, and connection of City assets. Traffic projects provide the opportunity for connecting City assets, conduit and fiber placement, and Smart City applications. Streets, bridges, and crossing projects also provide these opportunities as do water, sewer and storm drain projects, and electric utility undergrounding, SCADA, and AMI projects, some of which may be eligible for infrastructure funding.
The City’s CIP Tracker was reviewed for examples of potential key large-scale opportunities for the City to include broadband considerations in the early planning stages. Projects that have the potential to align with broadband development efforts include parks projects (Wi-Fi and fiber for connectivity), construction of Class 1 Trail under SR65 bypass bridge within Caltrans right of way, Auburn Ravine bridge replacement, roundabout construction for intersections of Ferrari Ranch Road, Ingram Slough, Sun City Boulevard, E. Joiner Parkway and Del Webb Boulevard, and water projects to replace old and deteriorated water lines.
By coordinating broadband infrastructure deployments with ongoing street, sidewalk, and other capital projects, the City can take advantage of planned excavations to place communications conduits, integrate wireless capabilities, and expand connectivity across public spaces, while also attracting additional investment from the private sector to further enhance broadband infrastructure. To the extent the City does not do so already, it should consider a practice of methodically asking in regard to each capital improvements project:
“Does this project provide opportunity to expand broadband infrastructure?” Larger capital improvement projects may involve significant excavation in an area that could benefit from concurrently installing fiber optic facilities.
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ENTRUST Solutions Group March 12, 2026 City of Lincoln, CA Special Conditions on Development Projects
Conditioning approval of development projects to include installation of broadband infrastructure (fiber, conduit, pullboxes, vaults, telecommunications closets, etc.) is an approach taken by many cities to expand broadband infrastructure. The City currently conditions approval of major developments for different requirements but is interested in considering a requirement to place conduit as broadband support infrastructure. It is reasonable for the City to place special conditions on development projects consistent with the City’s Fiber Optic Broadband Plan.
For example, Rancho Cucamonga has special conditions for fiber that can be considered and modified by the City as needed. For residential developments, approval of a multi-family development included special conditions for placement of fiber optic broadband infrastructure:
The City will require the developer to install a 1-4” UG Fiber Optic dark conduit on the frontage of the development along the project boundary along with a 3’x4’x3’ pullbox on each end of the route and into the project boundary. The size, placement, and location of the conduit and vaults shall be shown on the Street Improvement and/or Public Improvement Plans and subject to the Engineering Services Department’s review and approval prior to the issuance of building permits or final map approval, whichever comes first.
On site, the City will require 1-2” UG high-density polyethylene (HDPE) or equal fiber optic conduit to be placed underground within a duct and structure system to be installed joint trench by the developer per Standard Drawing 135-137 and interconnected into the City’s 4” fiber optic conduit. The size, placement and location of the conduit and/or vaults shall run into each of the development’s individual telecommunication rooms and be shown on the final dry utility on-site substructure plans and subject to the Engineering Services Department’s review and approval prior to the issuance of building permits or final map approval, whichever comes first.85
This may be appropriate for older areas of Lincoln that are being redeveloped as well. For approval of a mixed-use building:
The City will require 1-2” UG Fiber Optic dark conduit to be interconnected to the City’s existing fiber optic backbone conduit located in the west side of Archibald Avenue along the frontage of the property. The applicant will locate, pothole, and intercept the existing conduit.
Placement and location of a fiber pullbox shall be connected to the 1-2” conduit structure (Service) with HDPE directly from the mainline pullbox to an 8” round plastic “flowerpot” type telecom access box (flush mounted to finish grade) to serve as a drop access point to the City network directly at each individual unit or a dedicated telecommunication closet. This drop conduit shall be dedicated for City fiber drop installation only.
An optical network demarcation enclosure/panel shall be mounted on the side of the unit or utility closet for the placement of a Fiber Optic Network Interface Device. Place a #6 solid 85 Rancho Cucamonga Planning Commission Agenda Packet, August 14, 2024, page 182. 1248
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ENTRUST Solutions Group March 12, 2026 City of Lincoln, CA ground wire from the network demarcation enclosure to power ground. If no power ground exists a 5/8” x 8” copper clad ground rod is to be installed for ground wire to be connected.86 Finally, approval for projects can be (and often is) conditioned on certain improvements being constructed including streetlights and traffic signals. To help deployment of an ATMS, project approvals can be conditioned on placement of “traffic signal conduit, and interconnect conduit,” specifically with a clause stating: “signal conduit with pull boxes shall be installed for any new construction or reconstruction project along major or secondary streets and at intersections for future traffic signals and interconnect wiring.”87 This will facilitate the fiber optic connectivity needed for ATMS.
Utility Coordination and “Dig Once”
“Dig Once” and utility coordination offer the opportunity to extend broadband infrastructure methodically and opportunistically in the City for the public benefit while minimizing public inconvenience from repeated excavation of roads, streets, and public rights of way. The City doesn’t have a formal coordination policy. It coordinates with utilities on an informal basis such as coordinating road projects with PG&E and informing other utilities of larger projects going to construction.
A moratorium concept is being considered for streets paved or reconstructed within the previous five calendar years or sealed or coated within the previous three calendar years.
However, there is not much full reconstruction being done due to funding issues, with much of the roadwork limited to slurry seals or overlays. There is some interest however in implementing an annual notification of projects and offers to meet with occupants of the public rights of way. This would facilitate further coordination. A pavement cut impact fee would also help here. As an overall policy matter, the City is pro-development and believes it has struck a good balance with its informal coordination practices.
Microtrenching
California requires cities to allow the use of “microtrenching” which is a process where a narrow slice is cut in the roadway at a relatively shallow depth, conduit containing fiber optic cables is laid in the small trench created, and then material is backfilled over the conduit and the trench is sealed. Since microtrenching is initially much cheaper and faster than other more traditional excavation methods like trenching or boring, there has been increasing interest among some service providers to deploy additional fiber facilities using microtrenching. Service providers supported legislation in the California Assembly (Senate Bill 378) which required cities and local authorities to allow use of microtrenching, which passed and went into effect January 1, 2022.
Local agencies are now required to “allow microtrenching for the installation of underground fiber if the installation in the micro trench is limited to fiber, unless the local agency makes a written finding that allowing microtrenching for a fiber installation would have a specific, 86 Rancho Cucamonga Planning Commission Agenda Packet, February 28, 2024, page 275. 87 Rancho Cucamonga Planning Commission Agenda Packet, February 28, 2024, page 277. 1249
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ENTRUST Solutions Group March 12, 2026 City of Lincoln, CA adverse impact on the public health or safety.”88 Senate Bill 378 provides relevant definitions:
• “microtrench” is defined as a narrow open excavation trench that is: (1) no wider than 4 inches; (2) at a depth of 12 to 26 inches; and (3) created for the purpose of installing a subsurface pipe or conduit.89
• “fiber” includes fiber optic cables, and related ancillary equipment such as conduit, ancillary cables, hand holes, vaults, and terminals.90
Microtrenching’s shallower depth often is considered undesirable for long term health of City streets as it inevitably requires additional maintenance and reduces lifespan. Also, the practical experience in some cities has not been good including such issues as having to “chase” contractors around to get them to properly restore the pavement after the project.
Lincoln’s City management indicated significant concerns like these regarding microtrenching since it impacts pavement condition integrity. It is important to ensure that facilities are placed below the structural profile in the aggregate compacted base zone. The Engineering Department plans to establish a pavement cut impact fee per foot, scaled depending on the age of the pavement. Further conditions that may be worth considering include:
• Microtrenching is allowed unless and until there is a written finding demonstrating that it would have a specific adverse impact on the public health or safety. • Microtrenching shall only be used for installation of fiber conduit. • Microtrenching shall not be allowed on collector or major streets, concrete paved or asphalt overlayed concrete streets, sidewalks, parkways, curbs, and gutters.
Private Premises Right of Entry
Physical building access has been noted as an issue by the City and its partners. Some property owners want to be paid for access. It can be very beneficial for multi-premise buildings such as apartment complexes, condominiums, and malls to have inside wiring to all premises. There are regulatory approaches to requiring such access and options for tenants, it is helpful to have a “carrot” as well as a “stick.” The City may wish to consider a “consumer choice of broadband provider” ordinance, similar to the City of Oakland’s ordinance for Multi-Tenant Environments.91 Also, the City may wish to consider a condition for new multi-tenant construction such that the property developer is required to install sufficiently sized conduit (e.g., 4 inch) and quantity of four (4) one (1) inch innerducts, along with additional backboard space for terminating equipment for multiple broadband providers. Access to that conduit would be granted on a non-discriminatory and competitively neutral basis. This requirement as applied to new development and 88 Government Code § 65964.5(b)(1).
89 Government Code § 65964.5(a)(3).
90 Government Code § 65964.5(a)(1).
91 See Appendix B
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ENTRUST Solutions Group March 12, 2026 City of Lincoln, CA construction would have minimal additional cost as it could be accomplished within construction plans before construction starts.
7.3 Wireless Access
The City adopted Chapter 18.41, Wireless Telecommunications Facilities, in 2000. This ordinance focuses on “macro” cell towers and antennas with differing reviews based on class (Class I, II, and III). This ordinance is straightforward and consistent with similar ordinances in other California cities.
In 2020 the City adopted Chapter 18.43, Small Cellular Communications Facilities.
Ordinances like these were adopted around the country because of the issues raised in the FCC’s Small Cell Order. The City’s small cell ordinance is also straightforward and consistent with other California cities. The ordinance properly seeks to protect and promote public safety, and community welfare, and preserve the City’s character and aesthetic quality, require minimal impacts on the City’s streets and sidewalks, minimize adverse visual impacts, while providing wireless services to the City’s residents and businesses.
The ordinance provides for aesthetic and design standards for small cell wireless facilities, which is a common provision with other California cities (but has not yet been adopted by the City). It allows for development of an MLA for use of City poles and structures for small cell antennas, which is also a common provision among California cities (but has not yet been adopted by the City). The ordinance also provides for submission and review of a radio frequency exposure report which is a best practice among California cities given community concerns that arise from time to time. Finally, the ordinance defines but does not otherwise address Section 6409(a) of the Spectrum Act, which creates a gap in addressing “eligible facilities requests” that caused issues with the AT&T Colocation Application.
The AT&T Colocation Application
In 2023 and 2024 AT&T proposed replacement of an existing stadium light pole at McBean Memorial Park with a larger diameter pole to accommodate the additional weight of placing antennas, remote radio units and associated equipment at the top of the pole and construction of a new equipment building to house a backup emergency generator. AT&T stated the proposed facility would fill a significant gap in coverage using the least intrusive means possible and in so doing support extension of FirstNet public safety service. AT&T’s application was under Chapter 18.41, Wireless Telecommunications Facilities as a Class II facility requiring design review.
This Application was AT&T’s third colocation application before the Planning Commission with a pending appeal before the City Council of the Planning Commission’s denial of the second application. Further discussions occurred during the appeal which laid the path for approval of the third application consistent with FCC rules for “eligible facilities requests,” which is not addressed in either of the City’s wireless ordinance chapters. This is crucial information required to comply with state and federal law.” 1251
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ENTRUST Solutions Group March 12, 2026 City of Lincoln, CA The events related to this colocation application emphasize the need for the City to have ordinances and rules in place that comply with Federal Communications Commission (FCC) guidelines. It appeared that not having this in place resulted in a planning commission denial. The City should amend ordinances and policies to align with FCC regulations.
Master License Agreement
The FCC’s 2019 Small Cell Order prompted many cities to adopt MLA templates for use in deployment of 5G antennas by Verizon, AT&T Wireless, and T-Mobile or their infrastructure contractors (such as Crown Castle). Use of MLAs has emerged as a key practice for cities and counties to deal with the large number of pole attachments that are associated with 5G deployment. An MLA establishes the procedures, terms, and conditions under which licensees (wireless providers or their agents) may request individual pole licenses for attaching antennas to City poles and structures. MLA requirements are included in the City small cell ordinance at Chapter 18.43.040.C. but an MLA template has not yet been created by the City.
The MLA is a comprehensive document that contains uniform terms and conditions applicable to all wireless facilities installed on City-owned poles. Individual pole licenses identify the licensed pole and contain detailed exhibits for the site plans, permits, fee schedules, insurance documentation, and other materials that are unique to each site. When the City grants a pole license, that pole license (together with all the plans, equipment specifications, and fee schedules) become integrated with the MLA.
Use of an MLA framework provides for a level playing field since the MLA format remains essentially the same regardless of licensees. Each wireless service provider executes a separate MLA with the City that entitles them to obtain pole licenses on a first come, firstserved basis for a specific time. Thus, one set of rules is used for all wireless service providers which in turn reduces the administrative burden on the City and promotes a level playing field among competitive licensees.
The wireless service providers benefit from the use of an MLA to license existing City-owned infrastructure to install small cell facilities rather than bearing the time and cost of negotiating individual pole licenses. This more streamlined process accelerates the deployment of advanced wireless facilities. The City benefits from use of an MLA by establishing more robust wireless broadband networks available to the City’s residents and businesses, maintaining greater control over aesthetics and potential liability from wireless facilities on City-owned poles, earning license revenues which help defray the costs of managing and administering access to the public rights of way, and through general recognition of the value of attaching to City assets.
Consideration of an MLA may be especially important for the City since it owns many streetlights. The lack of a defined approach to placement of 5G antennas using template contractual documents (the MLA) may inhibit wireless providers from approaching the City for 5G deployment and likely impedes wireless provider engineers and contractors from 1252
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ENTRUST Solutions Group March 12, 2026 City of Lincoln, CA conducting detailed engineering studies prior to approaching the City. We recommend the City consider establishment of a Master License template and an application submittal checklist for wireless providers to use as well as making available to them the GIS-located City-owned streetlights which could be used for 5G antennas under an MLA. This should be supported by an “FAQ” section on the City’s website pertaining to 5G deployment.
ENTRUST can assist the City with all these tasks.
Small Cell Design and Deployment Standards
Small cell design and deployment standards are intended to, and should be applied to, protect and promote public health, safety, and welfare, and balance the benefits that flow from robust, advanced wireless services with the City’s local values, including the aesthetic character of the City, its neighborhoods, and community. Design and deployment standards are intended to reflect and promote the community interest by (1) ensuring that the balance between public and private interests is maintained; (2) protecting the City’s visual character from potential adverse impacts and/or visual blight created or exacerbated by small wireless facilities and related communications infrastructure; (3) protecting and preserving the City’s environmental resources; (4) protecting and preserving the City’s public rights of way and municipal infrastructure located within the City’s public rights of way; and (5) promoting access to high-quality, advanced wireless services for the City’s residents, businesses and visitors.
Design and deployment standards for small cell installations include a number of requirements, visual criteria, and provisions related to poles and location, equipment, wiring and cabling, radio frequency matters, submittals, and standard conditions and maintenance obligations. ENTRUST can assist the City in drafting and finalizing design and deployment standards for small cell installations.
Abandonment of Copper Plant by AT&T
“Turning off” the copper network in favor of broadband and wireless networks is an emerging national issue. AT&T serves a substantial portion of California, including Lincoln, with copper network facilities, while it continues fiber investment programs where profitability requirements can be met. AT&T petitioned the California Public Utilities Commission92 to allow it to cease maintaining its copper-based network throughout the state of California, except where consumers have no alternative to AT&T service it would continue to maintain the copper network. On June 25, 2024, the CPUC dismissed this application with prejudice using strong language.93
92 Amended Application of Pacific Bell Telephone Company d/b/a AT&T California for Targeted Relief from its Carrier of Last Resort Obligation and Certain Associated Tariff Obligations, Application A.23-03-003.
93 Decision Dismissing with Prejudice the Application of AT&T California to Withdraw as a Carrier of Last Resort; before the Public Utilities Commission of the State of California, Application of Pacific Bell Telephone Company d/b/a AT&T California for Target ed Relief from its Carrier of Last Resort Obligations and Certain Associated Tariff Obligations, Application A.23-03-003; Decision 24-06-024 issued June 25, 2024. 1253
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ENTRUST Solutions Group March 12, 2026 City of Lincoln, CA The CPUC then opened a rulemaking to consider changes to the Commission’s Carrier of Last Resort (“COLR”) rules94 that among other things would respond to AT&T’s efforts to terminate service over copper network facilities. Since that time AT&T has stated it will petition to eliminate copper network services in one-quarter of its wire centers across the country. To plan for the eventuality that telecommunications providers are allowed to terminate provision of services over copper facilities, the City should identify each location in the City where it utilizes AT&T services over copper networks (if any) and consider alternative modes of provisioning communications to those locations and functions. This could implicate a number of services or functions including basic telephone connections, alarm services, monitoring services, in-home detention surveillance, elevator emergency phones, dedicated circuits, etc.
7.4 Summary of Findings
Key language in City policies and ordinances needs to
be amended, revised, or updated to address changes in
federal and state policies, markets, and technologies:
• Formally include broadband, digital connectivity, and network assets as a consideration for all capital improvements and formalize utility coordination activities. • Adopt Small Cell Design and Deployment Standards to ensure small cell antenna placements for public safety and welfare, balancing the benefits of from robust, advanced wireless services with the character of the City. • Amend City ordinances to address the Federal Communications Commission’s (FCC) “Eligible Facilities Requests” requirements under Section 6409(a) of the Spectrum Act.
• Create and adopt a template Master License Agreement (MLA) for use with wireless providers to establish prices, terms and conditions for antenna placement on Cityowned structures including streetlights. • Establish a public-facing GIS portal for use by wireless providers (for planning purposes) to identify City-owned structures available for placement of antennas and ancillary equipment.
• Update General Plan PFS 7- to modern broadband terminology and objectives, consistent with this memorandum.
• Consider formalizing conditions on microtrenching consistent with requirements of SB 378, including:
o Continue work on establishment of pavement cut impact fee with scaled fee per foot depending on age and condition of pavement.
o Allowed unless and until there is a written finding demonstrating that it would have a specific adverse impact on the public health or safety. o Only for installation of fiber conduit.
o Not be allowed on collector or major streets or other places with heavy traffic. 94 Order Instituting Rulemaking Proceeding to Consider Changes to the Commission’s Carrier of Last Resort Rules; Rulemaking 24-06-012, issued June 28, 2024. (“COLR Rulemaking”)
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ENTRUST Solutions Group March 12, 2026 City of Lincoln, CA Coordination and guidance for work in the public rights of way on various types of infrastructure is adequate
but could be formalized to streamline processes and
encourage more private telecom investment.
The City should establish more formal guidelines and standards for wired and wireless network assets—appearance, location, etc. Microtrenching and small cells are two specific examples. Lincoln needs MLAs to use public assets for wireless and place assets in public easements. Proactive coordination will ensure the City realizes the maximum benefits from broadband and related services while minimizing operational and other costs. For example, an online tool for identifying vertical assets and getting detailed information about them (like an economic development site list), would improve connectivity, increase investment, and reduce overall costs for the City. Coordination and clear guidance is needed to ensure alarm circuits and similar connections are not lost as AT&T abandons its copper wires.
The City lacks special conditions on development such
as requiring conduit for fiber optic cables or other
network infrastructure assets, that could further
expand telecom investment and opportunities in the
City.
Fiber adds great value for the community at nominal cost to the developer, who passes those costs directly on to buyers. Special conditions should also apply to any new construction or reconstruction project along major or secondary streets and at intersections for future traffic signals and interconnect wiring to require placement of traffic signal conduit, and interconnect conduit with pull boxes, to aid the deployment of Advanced Traffic Management System (ATMS). Conditions should include producing geo-data indicating the precise location and capacity of these assets. Consider ordinance for multi-tenant environments to provide consumer choice of broadband provider, and condition requiring inside conduit and backboard for multiple broadband providers.
7.5 Policy Roadmap
While not as heavy or costly a lift as some of the more active municipal broadband operating structures (municipal utility, etc.), establishing a broadband-friendly policy environment within a municipality still requires an active approach to ensure that measurable impacts in the community are realized. Many of the appropriate policies can be grouped into two sequential categories, as shown in Figure 58: First creating internal City standards and specifications that streamline the process for external stakeholders and entice private investment, and secondly, utilizing “carrots and sticks” to encourage active participation in a coordinated process.
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ENTRUST Solutions Group March 12, 2026 City of Lincoln, CA Figure 58. Policy Implementation
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ENTRUST Solutions Group March 12, 2026 City of Lincoln, CA Streamlining City Standards & Specifications
While joint trenching or development of MLAs are some of the most useful tools to expand broadband, they cannot be implemented in a vacuum; they require a conducive environment in which to thrive. That requires the City streamline (and modernize) its processes, signaling to the telecom industry that they are “open for business.” In Lincoln, ENTRUST has identified four key components that will update the City’s processes to reflect new technology, methods, and approaches to foster private broadband investment.
Microtrenching Standards & Specifications
California state law requires all municipalities allow for microtrenching, but has only provided a frame of reference for trench depth, restoration methods, and other material and aesthetic aspects of the process that leave room for City discretion. Microtrenching does not have a single defining standard, but is rather an approach that can significantly reduce the costs of deploying underground conduit and fiber cable – all which can have very different impacts on the wear and tear of public streets, curbs, gutters, and sidewalks.
Deeper trenches may be better for cities to protect future street repaving, but every inch a microtrench deepens adds substantial dollars to the overall cost, which can deter private telecom from deploying fiber in a community if the cost rises too high. On the other hand, trenches that are too shallow can leave streets vulnerable to abnormal deterioration, conflict with other and work in the public ROW, or hinder other street improvement projects. The same pros and cons apply to street restoration methods (grind & pave T-cuts, cement slurry seal, rubberized gromets, etc.).
Effective microtrench standards require careful consideration by a City that include multiple internal departments – the needs and concerns of public works, water, IT, planning & development, and even economic development, should be taken into account when crafting City-wide microtrenching standards for depth, restoration, and permitting. This is a process that requires some up front investment of time and effort by City staff, but, if done thoughtfully, will bear fruit over many years as more broadband providers look to expand services in Lincoln.
Small Cell Ordinance
While the FCC and California state law have imposed mandatory requirements and shot clocks on municipalities to review and approve fixed wireless/small cell applications to locate antennas and related equipment within the public ROW (including on publicly-owned street light poles), state and federal law does still allow for some City discretion over aesthetics and placement (like avoiding historic districts, etc.). Typical “emergency” ordinances that many cities passed to comply with FCC rulings do not take advantage of City discretionary rights, nor do they ensure a smooth, standard process. Thus, as many communities look to the coming switch from 4G/LTE to faster 5G mobile technology, the mobile providers (AT&T, TMobile, Verizon) tend to deploy new 5G equipment where there is both minimal risk and a defined process. Revamping the City’s small cell ordinance will serve both purposes:
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ENTRUST Solutions Group March 12, 2026 City of Lincoln, CA streamlining a process for the mobile providers, while also ensuring City discretion over aesthetics and placement.
Master License Agreements (MLAs)
As an integrated part of an updated Small Cell Ordinance, many cities utilize MLAs to facilitate and expedite small cell applications and permitting. The use of MLAs also establishes a defined relationship with each of the major mobile carriers, providing them with a clear process – as well as minimizing the internal City review of applications. Fees, timelines, application requirements, maintenance responsibilities, and review processes can all be negotiated and agreed to with each carrier, allowing future applications to be easily added to an existing agreement as each new application is submitted to the City.
Wireless Site Portal
Wireless and cellular providers are regularly looking for ideal (and cost-effective) locations to deploy new or updated antennas and equipment. Cities are particularly well-suited to provide these sites given the various facilities, buildings, and land (both parcels and within the public ROW) that they control across a geographic area. Cities can take a proactive approach to soliciting leases on public sites to wireless and mobile carriers by creating a GIS portal, which identifies City-owned structures, land, and locations available for placement of antennas and ancillary equipment. This portal, if publicly accessible, can help facilitate and expedite private infrastructure upgrades and new technology deployment that can expand broadband access and connectivity within the community, while simultaneously generating recurring revenues through lease and potentially Indefeasible Right of Use (IRU) payments.
External Participation – “Carrots and Sticks”
Once the City has established a streamlined environment through internal processes and policies, it can then move effectively into implementation and infrastructure expansion – both through internal publicly-owned assets, as well as by encouraging private investment and technology deployment. Incentives, such as streamlined processes and cost-saving approaches, can entice private implementation; however, creating “disincentives” will help emphasize the benefits of external participation – the proverbial “carrot and stick” approach.
Capital Improvement Projects (CIP) Integration
Although not technically “external,” getting buy-in from various City departments outside of IT can be challenging. The first and most beneficial area is the Capital Improvement Program, where major City projects can concurrently deployment broadband assets at a fraction of the cost while excavation work in the public ROW or on publicly-owned sites is already occurring. Fully integrating broadband into a CIP requires careful planning, including identifying how to fund the marginal cost of broadband (such as utilizing a Technology Enterprise Fund), especially so that complex projects are still compliant with multiple funding sources (state and federal grants, tax funding, etc.). Full integration also requires periodic review of CIP projects by IT staff, as not every CIP project has a broadband nexus. 1258
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ENTRUST Solutions Group March 12, 2026 City of Lincoln, CA Utility Coordination
Utility coordination is one of the most useful tools to reduce public and private costs, encourage infrastructure deployment, and entice private investment, but it requires active curation of project lists and regular solicitation of participation, especially among the private utility sector. A comprehensive utility coordination effort considers not only private telecom opportunities, but also water, power (electric and gas), sanitation/flood, and public works – any work within the public ROW (especially excavation).
Initially, not all parties – especially private telecom – will be willing to share planned project lists or details, but, regardless of willingness to share, every party should be invited and encouraged to participate in the regular coordination meetings (bi-monthly or quarterly).
Once the City demonstrates its willingness to work with utilities to share trenches/costs, jointly deploy conduit, fast-track (or slow-walk) street projects to complete utility work before repaving so that no single provider is stuck with high restoration costs, private utilities will be more willing to share their own plans. In the end, lowering infrastructure deployment costs for all utilities – public and private – will only increase the investment in the community, avoid costly emergency repairs, and reduce future lags in technology adoption.
Dig Once Ordinance & Moratoriums
Joint trench ordinances (commonly known as “dig once”) create the requirement for utilities operating within the public ROW to share trenches (and costs), allowing for cost-effective broadband asset deployment (e.g., a water trench can be widened slightly to allow for concurrent broadband conduit to be placed at the same time for marginal cost, thereby also reducing trenching costs for water). However, dig once ordinances are not a passive tool; they require effective utility coordination efforts – as well as strong street moratoriums that disincentivize latecomers from operating independently. Moratoriums with reasonable restoration requirements on recently-paved or repaired roads and sidewalks signal to utilities that coordination and cooperation is necessary, and highlight the cost-savings advantage between the two options.
Dig once ordinances require careful thought and planning to ensure that public assets are protected, that requirements are feasible and reasonable, and that standards and specifications (depth, separation, etc.) have been identified to minimize conflicts and expedite field repairs without causing incidental damage to adjacent assets.
Development Agreements
Large private development projects in cities often require a land entitlement process and associated development agreements, which typically require privately-financed public improvements (sidewalk, roads, traffic signals, water upgrades, etc.) in exchange for development rights. Many cities are including broadband assets (underground conduit networks, including drops/laterals to proposed new buildings) that are deeded over to the City once construction is complete, allowing the City to expand its broadband footprint at the cost of the developer – while ensuring that the improvements are done during overall project excavation so that the conduit can be installed at a fraction of the normal cost. This requires 1259
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ENTRUST Solutions Group March 12, 2026 City of Lincoln, CA clear City policies and ordinances set forth prior to any entitlement processes, so that these are known costs for any new private development.
In addition, cities often include a “Consumer Choice” ordinance for entitlement processes, particularly for business/commercial developments or multi-family housing developments, ensuring that the developer provides open access infrastructure all the way to the tenant/owner so that no single telecom entity can monopolize services.
Effective developer agreements are a long-term strategy, particularly for cities that are still in the growth stage, to establish a city-owned communications network while also creating a broadband environment that allows for true competition and access among multiple providers, including potentially even City-provided internet services. 1260
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ENTRUST Solutions Group March 12, 2026 City of Lincoln, CA
8. Key Recommendations
1) Solicit & negotiate a Public Private Partnership (P3s) that facilitates extending fiber infrastructure in Lincoln.
The proposed conceptual network was designed to leverage existing public and private assets in Lincoln in order to reduce capital construction costs and avoid overbuilding existing networks. Utilizing existing private fiber would necessitate negotiating a public-private partnership that would allow the City to secure access (though a long-term lease) to dark fiber required to interconnect its facilities. In exchange for favorable lease terms, the City could work with the ISP to provide retail internet services utilizing existing and future City assets.
P3s offer opportunities to share costs, reduce financial barriers, and expedite deployment.
By leasing City-owned assets, such as streetlights and utility poles, to broadband providers or partnering with wireless carriers, Lincoln can attract investment while retaining control over critical infrastructure. These partnerships could enable the City to implement advanced technologies like 5G and fixed wireless access, extend broadband coverage to underserved areas, and possibly generate revenue to reinvest in infrastructure improvements. Embracing innovative funding strategies will position Lincoln to achieve its connectivity goals efficiently and equitably.
2) Implement the first phase of the Policy Roadmap to
streamline City standards, specifications & processes
The City can begin establishing a broadband-friendly environment by streamlining internal City processes, standards and specifications, developing and adopting microtrenching standards, creating a MLA process for wireless applications, developing an updated wireless/small cell ordinance to maximize City discretion and aesthetics, and creating a wireless siting portal to solicit new pole and antenna leases on City facilities, assets, and land.
Formalizing and modernizing these processes signals to the telecom industry that the City is “open for business” and will attract private investment in new infrastructure and technologies that will benefit the City’s businesses, residents, and stakeholders. 3) Leverage the City’s inventory of street light poles to expand wireless coverage, speeds, & services.
The City has an inventory of approximately 7,594 street lights (of which 64% is owned by the City) that can be leased to private cellular companies to locate small cell antennas and equipment. Improving cellular and wireless coverage and speeds can also provide more high-speed competition in areas underserved by the incumbent ISPs. Lease revenues for 1261
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ENTRUST Solutions Group March 12, 2026 City of Lincoln, CA these poles could be dedicated to fund future City network expansion, joint trenching opportunities, installation of smart city devices, or other technology upgrades. Creating the Wireless Site Portal, as part of the first phase of the Policy Roadmap, will assist in advertising and soliciting interest in these sites, while improving private cellular and wireless services for City stakeholders and residents.
4) Establish a Technology Enterprise Fund as an ongoing funding source.
Many cities create dedicated funds for revenues generated from shared revenue and/or leases of City assets by private telecommunications companies. A dedicated fund with ongoing revenues—separate from the General Fund—prioritizes new City/public technology deployment for future build opportunities (locating new smart city devices concurrent with expansion of private wireless connectivity, or funding for fiber network expansions through incremental builds/joint trench coordination). Creating a fund in the early stages helps plan strategically for the years to come when use of public assets/ROW will increase, creating new City revenues.
Additionally, the unscheduled nature of joint trench/dig once opportunities means cities need a dedicated funding source outside of the normal budgeting process to take advantage of open trenches to further the broadband plan. Cities often will ensure ongoing resources by dedicating any revenues received through shared revenue, the license of City assets, or lease of City land to private telecom for the placement of cell towers, antennas, or revenues received as payments for conduit occupancy rights or dark fiber leases. 5) Implement the second phase of the Policy Roadmap
to facilitate external participation.
Once a broadband-friendly policy environment has taken hold in the City, it can encourage external participation in these processes by incentivizing participation – and disincentivizing isolation. These “carrots and sticks” can be established through formalizing four key processes: broadband expansion integrated into CIP projects, public and private utility coordination, developing and adopting a dig once/joint trench ordinance and street moratorium, and utilizing development agreements to expand public broadband assets on major projects.
These are longer-range policy shifts that will enable the City to expand its publicly-owned broadband assets at fractional cost (or even at developer cost), reduce the cost of excavating within the public ROW for all utilities (public and private), and allow the City to incrementally and opportunistically build out its own fiber network without incurring debt or significant capital expenditures.
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ENTRUST Solutions Group March 12, 2026 City of Lincoln, CA Appendix A: Preliminary Network
Equipment List
This document defines the networking equipment that would be required to support management of leased dark fiber. The proposed equipment list would support the conceptual enterprise IT Wide Area Network depicted below. The concept design has two data centers for redundancy at city hall and a fire station. The costs detailed in the equipment list are only preliminary estimates. A complete network assessment would be required to obtain actual costs that could be used for project budgetary purposes. 1263
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ENTRUST Solutions Group March 12, 2026 City of Lincoln, CA PoP's
City Sites
IT Data Centers
Maintenance
Pro Services
Role Assumptions Unit Cost Qty Total Unit Cost Qty Annual Core/Aggregation Network 48x1/10GE SFP+; 4x100GE QSFP; MPLS/L3 $ 30,000 4 $ 120,000 $ 14,400 1 $ 14,400 Edge Routing 24x1/10GE SFP+; 2x100GE QSFP; MPLS/L3 $ 10,000 2 $ 20,000 $ 2,400 1 $ 2,400 Access Network use aggregation switches for access $ - 0 $ - $ - 0 $ - LAN Switch CPE 48x1GE; 2x10GE SFP+; L3 $ 2,500 80 $ 200,000 $ 24,000 1 $ 24,000 Security NGFW; 1/10GE SFP+; 10Gbps througput $ 12,000 2 $ 24,000 $ 2,880 1 $ 2,880 Management Solar Winds Observability; Kiwi $ 15,000 1 $ 15,000 $ 1,800 1 $ 1,800 IP Services Solar Winds IPAM $ 5,000 1 $ 5,000 $ 600 1 $ 600 Compute/Storage server + VMWare $ 20,000 2 $ 40,000 $ 4,800 1 $ 4,800 Transceivers MM/SM SFP/SFP+ $ 7,500 1 $ 7,500 $ 900 1 $ 900 Spares Critical spare components $ 2,500 1 $ 2,500 $ 300 1 $ 300 $ 434,000 $ 52,080
Pro Services onsite plan; design; install; docs; train $ 78,120 1 $ 78,120 $ - $ - Total Network $ 512,120 $ 52,080
IPTV $ - 0 $ - $ - 0 $ -
CPE $ - 0 $ - $ - 0 $ -
Voice $ - 0 $ - $ - 0 $ -
IP Transit $ - 0 $ - $ - 0 $ -
Ethernet Transport $ - 0 $ - $ - 0 $ -
Total Content Services $ - $ -
Billing $ - 0 $ - $ - 0 $ -
Subscriber/Provisioning $ - 0 $ - $ - 0 $ -
Fiber Management $ - 0 $ - $ - 0 $ -
Workforce Management $ - 0 $ - $ - 0 $ -
Backoffice Management $ - 0 $ - $ - 0 $ -
Total BSS/OSS $ - $ -
New data center Pre-fab shelter $ - $ - $ - 0 $ -
Retrofit data center ISP racks; fiber distribution; power $ 25,000 1 $ 25,000 $ - 0 $ - Retrofit data center power Power system; installation; batteries $ - $ - $ - 0 $ - Pre-fab shelters/cabinets 2 remote powered cabinets $ - $ - $ - 0 $ - Retrofit shelter ISP CRAC; rack; fiber distribution $ - $ - $ - 0 $ - Retrofit shelter power Power system; installation; batteries $ - $ - $ - 0 $ - Total Data Center and PoP $ 25,000 $ -
Vehicles Bucket truck $ 150,000 $ - $ - 0 $ -
Fiber tools OTDR; power meters; splicing euqipment $ 125,000 $ - $ - 0 $ - Network tools Cable testers; power meters; network diagnostics $ 20,000 $ - $ - 0 $ - Field tools Assume contractor-supplied for most of these$ 15,000 $ - $ - 0 $ - Total Tools and Equipment $ - $ -
CSR walk-in, phone $ - 0 $ -
TSR 2 shifts $ - 0 $ -
NOC 4 on 12 hour shifts, provisioning/trouble $ - 0 $ - Field splicer, installers, trouble $ - 0 $ -
Engineering network, sales $ - 0 $ -
Backoffice scheduling, voice, Q/A $ - 0 $ -
Sales manager, business $ - 0 $ -
Marketing $ - 0 $ -
Total Staffing $ -
Total Capital and Operating Budget Year 1 $ 537,120 $ 52,080 Capital Operations
Startup Cost for Lincoln CA Network
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ENTRUST Solutions Group March 12, 2026 City of Lincoln, CA Appendix B: Broadband Policy Context
Local broadband polices exist within the allowances and limitations of federal and state policies, including the fundamental rationale for the policies. In the Infrastructure Investment and Jobs Act (IIJA)95, Congress made specific policy findings:
(1) access to affordable, reliable, high-speed broadband is essential to full participation in modern life in the United States. (2) The persistent ‘‘digital divide’’ in the United States is a barrier to the economic competitiveness of the United States and equitable distribution of essential public services, including health care and education. (3) The digital divide disproportionately affects communities of color, lower-income areas, and rural areas, and the benefits of broadband should be broadly enjoyed by all. (4) In many communities across the country, increased competition among broadband providers has the potential to offer consumers more affordable, high-quality options for broadband service. (5) The 2019 novel coronavirus pandemic has underscored the critical importance of affordable, high-speed broadband for individuals, families, and communities to be able to work, learn, and connect remotely while supporting social distancing.
The IIJA provides generational funding of broadband infrastructure and digital equity and adoption programs and sets a defined minimum speed of broadband to 100 Mbps download and 20 Mbps upload for its programs. This policy direction exemplifies the new local, state, and federal broadband policies being implemented to bring better, cheaper, and faster wireline broadband connections to citizens on a universal basis, for use in many important segments of modern life including education, health care, public safety, economic development, and entertainment. Included are utility coordination policies to reduce infrastructure costs by coordinating placement of broadband infrastructure among cities’ departments and capital improvement/development projects, development of improved broadband mapping, implementation of digital equity plans and affordable connectivity programs, and requiring consumer choice of internet service provider in multi-tenant buildings.
However, the Trump administration has signaled that it believes the IIJA is “governmentfunded overbuilding of existing networks”96 so there is uncertainty surrounding whether Broadband Equity Access and Deployment (BEAD) funding, for example, will be awarded as planned by state broadband offices. In particular, there may be a switch in emphasis from broadband via fiber optic facilities toward broadband delivered by satellite.
On the wireless side, the Federal Communications Commission (FCC) has implemented new policies to address deployment of 5G wireless antennas, including implementation of streamlined procedures for “eligible facilities requests,” shortened “shot clocks” for the local authorities handling siting requests, and limitations on fees that can be charged. In 95 Public Law 117-58, 117th Congress, Division F – Broadband, November 15, 2021. This section of the IIJA funds broadband infrastructure and digital equity programs among other things.
96 Project 2025, Mandate for Leadership, Federal Communications Commission, Chapter 28, Brendan Carr et al. 2025_MandateForLeadership_CHAPTER-28.pdf, page 856. 1265
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ENTRUST Solutions Group March 12, 2026 City of Lincoln, CA response, local authorities have enacted “small cell” and other wireless ordinances and implemented small cell design standards and guidelines as well as Master License Agreements. The wireless providers are promoting fixed wireless home internet offerings97 using 5G wireless capacity, which Lincoln residents may find to be an appealing alternative to landline services especially where it promises higher speeds.
Fiber as the Foundation for Broadband
Both wireline and wireless broadband services require fiber optic cable to transmit ever increasing amounts of data. Consumers and businesses rely on the internet “cloud” for rapidly increasing numbers of applications, and that reliance is accelerating further through rapid advances in the application of Artificial Intelligence.98 The IIJA and Senate Bill 156 in California have made large amounts of funding available to invest in fiber optic technology and digital equity—addressing the digital divide—to ensure affordable access to 100 Mbps upload/100 Mbps download speeds.
Additional policy actions by the City can contribute to expanding the reach of fiber optic connections. Generally, it is advisable to incorporate fiber, or at least conduit, into all City capital projects and plans. It has become critical to ask the question at the planning stage for each capital project: How can this project support expansion of broadband infrastructure in the City? This question should be asked in the context of capital improvement projects and utility coordination among all City departments.
The Evolving Definition of “Broadband”
A sizeable portion of the IIJA funds infrastructure and programs to facilitate access to and availability of reliable broadband connections, defined as those that provide a minimum of 100 Mbps download and 20 Mbps upload speeds.
The FCC’s benchmark for broadband speed has been 25 Mbps download and 3 Mbps upload since 2015. Congress requires the FCC to annually assess whether “advanced telecommunications capability” is being deployed to all Americans, which requires defining that capability. In its annual study of this question under Section 706 of the Communications Act, the FCC analyzed the data in 2024 and determined it was necessary to increase that benchmark speed to 100 Mbps download and 20 Mbps upload as the definition of 97 AT&T’s Internet Air Wireless Home Internet, Verizon’s 5G Home Internet and Fixed Wireless Access using the C-Band, and T-Mobile’s 5G Home Internet. Note that these may not be intended to be long term service offerings. For example, see Fixed Wireless Access About Verizon
98 Cloud infrastructure is an alternative to on-site data centers for computing workloads.
Cloud infrastructure is connected by telecommunications networking. Artificial intelligence applications are a large and growing driver of cloud services. According to Amazon, “about 90% of Global IT spending [is] still on-premises and yet to migrate to the cloud.” CEO Annual Letter to Shareholders, page 7. 2022-Shareholder-Letter.pdf (q4cdn.com) 1266
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ENTRUST Solutions Group March 12, 2026 City of Lincoln, CA “broadband.”99 There is now no variance in the broadband speed definitions and benchmarks used by the various federal agencies for funding and analytics.
Leadership Transition at the Federal Communications
Commission
Political control of the FCC changed because of the presidential election. Commissioner Brendan Carr, wrote Chapter 28 on the FCC in Project 2025100 and has been selected by President Trump to serve as Chairman of the FCC. That chapter likely can be used to anticipate policy changes at the FCC, including:
• Reducing and redirecting BEAD funds for broadband infrastructure. Project 2025 envisions redirecting funds “to communities without adequate internet infrastructure instead of places that already enjoy broadband connectivity.”101 It is not clear what additional requirements might be imposed but clearly BEAD funds are in danger of being delayed and redirected or diluted. The incoming Chairman of the Senate Commerce Committee (Sen. Ted Cruz) has also said there will be “substantial changes” to BEAD.
• “Unleash economic prosperity” by returning to previous spectrum policies, which means increased cadence of spectrum auctions and freeing airwaves for commercial use; and establishing spectrum coordination policy.
• “Reining in Big Tech”: Chapter 230 of the Communications Act was enacted in 1996 when computer bulletin boards were common. It has been interpreted to extend immunity for platform providers and users of “interactive computer services” for information published on their website by third parties and protects those platform operators from liability for good faith removal or moderation of third-party material.
Some view these platform operators as corporate behemoths that are abusing a dominant position and censoring content. The FCC will likely seek to limit protections from liability extended under Section 230 to contemporary social media platforms such as Facebook, X (formerly known as Twitter), Google, and YouTube, including seeking legislation to change Section 230. Social media platforms have been removing or moderating content that they deem obscene, lewd, lascivious, filthy, excessively violent, harassing, or otherwise objectionable, and fact checking content. • Requiring “Big Tech” to contribute “fair share” to the Universal Service Fund (USF).
The fund is $9 billion but is funded by a surcharge on voice services which are in steep decline rendering the present mechanism unsustainable. There is considerable effort at the FCC and Congress to revamp the USF mechanism to make it sustainable. One option that has been put forward is assessing revenues of content 99 2024 Section 706 Report, Inquiry concerning Deployment of Advanced Telecommunications Capability to All Americans in a Reasonable and Timely Fashion, GN Docket No. 22-270, FCC 24-27, Released March 18, 2024.
100 Project 2025, Mandate for Leadership, Federal Communications Commission, Chapter 28, Brendan Carr et al. 2025_MandateForLeadership_CHAPTER-28.pdf 101 Project 2025, Chapter 28, page 855.
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ENTRUST Solutions Group March 12, 2026 City of Lincoln, CA providers and social media companies, as well as companies that connect to the network for cloud services and artificial intelligence. • Protect national security from threats posed by the Chinese Communist Party, including ban of TikTok, ban telecommunications gear (such as Huawei) from use in the telecommunications network, and stop aiding China’s “malign AI goals.”102 The future of TikTok in the US is currently uncertain.
Court battles are anticipated in an attempt to axe FCC rules regarding consumer protections, digital discrimination, and data breaches, with the sponsoring agency no longer supporting those rules. Other initiatives that may wither include any ban for bulk billing arrangements, disclosure requirements for AI-generated content in political advertising, and blocking early termination fees for satellite and Community Antenna Television (CATV) services. In January 2025 the Sixth Circuit Court of Appeals overturned FCC’s ability to classify broadband service as a “telecommunications service,” which enabled the FCC to ensure privacy protections, bar digital discrimination, promote broadband deployment and maintain rural and low-income programs. While the FCC can no longer act in these areas individual states may enact and enforce such provisions.
Utility Coordination and “Dig Once” Practices
Broadband has attained status as the “fourth utility” along with gas, water, and electric services. Like other utilities, broadband substantially impacts public rights of way through required placement of fiber optic transmission cables and antennas for wireless 5G services that enable broadband internet access services. State and federal policies are establishing coordination of utility work in the public rights of way to foster efficient and cost-effective placement of fiber whenever the public rights of way are opened for any project.
Utility coordination has numerous substantial benefits, including promoting and supporting the placement of broadband infrastructure (e.g., fiber optic cable and conduit), reducing public inconvenience and dangers from disruptions of repeated excavations (traffic disruption, road deterioration, service outages, and wasted resources), and enhancing service reliability and aesthetics.
Utility Coordination (or “Dig Once”) accomplishes the goal of minimizing costs of constructing separate trenches and facilities, via shared costs of construction. The cost savings are significant. The Federal Highway Administration (FHWA) estimates it is ten times more expensive to dig up and then repair an existing road to lay fiber than to dig support structure for fiber (e.g., conduit) when the road is being fixed or built. According to a study by the Government Accountability Office, dig once policies can save 25-33% in construction costs in urban areas and approximately 16% in rural areas.103 In addition, development of dig once standards and guidelines for deployment of conduit and fiber will facilitate economic development and growth, as it enables cost-effective staged or gradual deployment of broadband infrastructure by local authorities.
102 Project 2025, Chapter 28, page 853.
103 Technology & Innovation | Congresswoman Anna Eshoo (house.gov) 1268
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ENTRUST Solutions Group March 12, 2026 City of Lincoln, CA When subsurface utility work occurs, it presents opportunities for the City to install new fiber and/or conduit in the right of way at reduced costs via coordination of work. Utility coordination policies allow the City to take advantage of other subsurface utility projects for the installation of fiber. This enables the City to expand its ownership of fiber anytime subsurface utility work occurs, at lower costs to new construction.
The concept can also extend to requiring conduit to be placed for fiber optic whenever the ground is opened, as expressed in recent congressional legislation. This concept was embodied in the Broadband Conduit Deployment Act of 2018, which required the inclusion of broadband conduit during construction of any road receiving federal funding. Dig once and utility construction coordination is an effective way to reduce the cost of broadband infrastructure construction with opportunities for joint trenching and sharing of construction overheads such as maintenance of traffic, staging construction activity, and restoration expenses.
Transportation Projects and Broadband
The FHWA implemented a new rule104 in March 2022 to facilitate installation of broadband infrastructure. This new rule includes provisions requiring a state department of transportation to identify a “broadband utility coordinator” to be responsible for accommodating broadband in the right of way associated with federal highway projects.
Caltrans has done so and lists contact information for broadband coordinators by district.105 Caltrans also has addressed utility coordination with its “Accommodation of Wired Broadband Facilities within Access—Controlled State Highway Right of Way”106 dated March 14, 2022, that addresses state legislation and considers the new FHWA rule. This is a substantial change of policy direction at the federal level, toward allowing the use of federal highway funding to expand broadband infrastructure and encouraging broadband utility coordination while working on projects involving work in the right of way.
Transportation and utility infrastructure are getting smart, which requires connectivity to operate, improving traffic and reducing impact on natural resources. Network assets can be economically incorporated into other infrastructure. Fiber for traffic signal interconnects can include additional fiber and conduit for other applications, including broadband services, Smart City applications, and cell site backhaul. The IIJA provides more funding for traditional infrastructure programs (e.g., roads and bridges, public transit, water infrastructure, power grid reliability and resiliency) than specifically for broadband.
Advanced Traffic Management Systems (ATMS)
Broadband services and ATMS are based on fiber optic infrastructure occupying the same space in the public rights of way. Therefore, planning for broadband services should be cognizant of planning for ATMS and vice versa. In some cities planning for these two fiber104 See, 23 CFR Part 645.307(a). 105 Caltrans Broadband Coordinators, Caltrans. Caltrans Broadband Coordinators | Caltrans 106 Attachment A Wired Broadband Facility Accommodation in Access -Controlled Highway Right-of-Way (ca.gov)
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ENTRUST Solutions Group March 12, 2026 City of Lincoln, CA based broadband applications do not consider each other and proceeds as functionally separate infrastructures. The general rationale for such disconnects is that traffic signal interconnection needs to be physically separate for control and security reasons. This logic is faulty because (a) multiple physically separated networks can be easily accommodated by a single, integrated fiber infrastructure, (b) it is more economical to build and maintain, and (c) having multiple infrastructures complicated security and creates additional, unnecessary risks.
An ATMS project includes installation of CCTV and Vision Detection Systems (VDS) cameras, deployment of fiber optic communications facilities for interconnection, and upgrade and integration of traffic signals with a Traffic Management Center. ATMS will enable real time reactivity and improvement of traffic monitoring, retiming, and coordination of the City’s traffic signal system among other things. Also, traffic management is an example of infrastructure that benefits from a regional approach to fully realize the community benefits.
The City is planning an Advanced Traffic Management System but not in the near future.
There are no signal interconnects or traffic fiber at this point although there are some coordinated signals along Lincoln Boulevard. As mentioned below, special development conditions requiring conduit and fiber for traffic systems can advance the City’s progress toward ATMS.
Placement of fiber and conduit for traffic management should be coordinated with placement of broadband fiber and conduit for the City to capture efficiencies and synergies and reduce costs for both solutions, while expanding broadband capacity faster.
Multi-Tenant Environments (MTE)
The FCC modified its regulations for MTEs multiple times to support consumers’ increasing reliance on broadband internet access “for employment and educational opportunities, access to health care services, civic and social engagement, and entertainment.”107 The FCC sought to accelerate deployment of broadband internet access in MTE environments and increase access to MTEs for internet service providers. MTEs present unique considerations for installation of broadband infrastructure because there are three interested parties: the consumer, the service provider, and the owner of the premises. MTE regulations are important because “thirty percent of Americans live in apartments or condominiums, and millions more work every day in office buildings.”108 Furthermore, “MTEs disproportionately 107 Improving Competitive Broadband Access to Multiple Tenant Environments et al. , GN Docket No. 17-142 et al., Notice of Proposed Rulemaking and Declaratory Ruling, FCC 19 - 65, released July 12, 2019, ¶ 2. Multiple Tenant Environments or “MTE” is an evolution from the term “MDU” or multiple dwelling units. MTEs are defined as commercial or residential premises such as apartment buildings, condominium buildings, shopping malls or cooperatives that are occupied by multiple entities. 108 Id., at paragraph 1.
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ENTRUST Solutions Group March 12, 2026 City of Lincoln, CA serve residents in lower-income and marginalized communities.”109 It is widely recognized that the COVID pandemic brought sharply into focus the importance of broadband internet access and the dimensions of the digital divide.
However, the FCC rules on MTE are unlikely to continue under the current federal administration. Therefore, cities can look to ordinances adopted in other jurisdictions to provide for consumer choice of broadband provider in MTEs.
Communications Service Provider Choice Ordinance
The City of Oakland has a service provider choice ordinance which was passed in 2021.
Chapter 8.66 of the Oakland Municipal Code is based on findings that “Oaklanders expect to be able to choose among different [communications services] providers” but “some customers only have one option for service. This is particularly true for occupants of residential and commercial multiple occupancy buildings.” Oakland found it “can use its police power to facilitate opportunities for access to multiple occupancy buildings by communications service providers to enable occupants to obtain communications services from the providers of their choice, while respecting the rights of property owners.”110 The Choice ordinance further provides:
• The property owner shall not interfere with an occupant’s choice of service provider. • The property owner shall not retaliate against the occupant for requesting or obtaining service from a chosen service provider.
• A process by which a communications service provider inspects the building to determine feasibility of providing service.
• A process and requirements by which a communications service provider provides notice to the property owner of intent to provide service. • Circumstances under which the property owner is allowed to refuse access to a communications service provider.
• Permitted limitations and conditions which may be required by a property owner for access of a communications service provider to the property. • The just and reasonable compensation a property owner is entitled to from a communications service provider.
• Requirements for notification to occupants.
• Enforcement and penalty provisions.
The City of San Francisco also has a similar ordinance. The City may wish to consider such an ordinance for MTEs in Lincoln.
109 Improving Competitive Broadband Access to Multiple Tenant Environments, GN Docket No. 17-142, Report and Order and Declaratory Ruling, FCC 22-12, released February 15, 2022, ¶ 1. (MTE Revenue Sharing and Exclusive Marketing Agreements, Sale and Leaseback Arrangements Order, or 2022 MTE Order.)
110 Chapter 8.66—COMMUNICATIONS SERVICE PROVIDER CHOICE ORDINANCE | Code of Ordinances | Oakland, CA | Municode Library .
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ENTRUST Solutions Group March 12, 2026 City of Lincoln, CA Wireless Policy
FCC Regulation of Radio Frequency Emissions
The placement of wireless facilities is governed by an interrelated legal framework characterized by shared jurisdiction between state (e.g., cities and counties, and the California Public Utilities Commission) and federal authorities (the FCC and Congress).
However, from time to time, the FCC (and Congress) has preempted or sought to preempt the authority of state and local jurisdictions over wireless matters. In one specific area—radio frequency (RF) emissions—the FCC has been assigned complete regulatory jurisdiction by Congress.
the 1996 Telecommunications Act preempted local regulation of RF safety standards in favor of a uniform national RF safety standard under FCC jurisdiction.111 Local authorities can require demonstrated compliance with these national FCC RF standards during evaluation of 5G siting applications. Applicants often make this demonstration part of the application package, and many cities have ordinances or standards and guidelines provisions that require RF compliance to be demonstrated by applicants. Local authorities may not, however, deny wireless communications facilities siting applications based on RF emissions.
Congress has preempted local authority on this subject and placed jurisdiction in the hands of the FCC.
The FCC determined in 2019 that no update to its guidelines for exposure to RF emissions was required for 5G equipment.112 This decision was appealed, and the Court of Appeals for the District of Columbia remanded that decision back to the FCC to provide “a reasoned explanation for its determination that its guidelines adequately protect against harmful effects of exposure to radiofrequency radiation unrelated to cancer.”113 The FCC has not yet made any decisions and findings on 5G RF emissions so there is a potential for change to the RF emission standards.
See the FCC’s Consumer Guide on Wireless Devices and Health Concerns for further information on safe levels of exposure to RF energy.114 See also A Local Government Official’s Guide to Transmitting Antenna RF Emission Safety for further information on the FCC’s RF emission rules.115
111 47 U.S.C. § 332(c)(7).
112 Resolution of Notice of Inquiry, Second Report and Order, Notice of Proposed Rulemaking, and Memorandum Opinion and Order, FCC 19-126, released December 4, 2019.
113 Environmental Health Trust, et al. v. Federal Communications Commission and United States of America, No. 20-1025, Decided August 13, 2021 (DC Cir.), at page 30. 114 Consumer Guides, Wireless Devices and Health Concerns, Federal Communications Commission. Wireless Devices and Health Concerns | Federal Communications Commission (fcc.gov) (viewed April 12, 2024).
115 A Local Government Official’s Guide to Transmitting Antenna RF Emission Safety:
Rules, Procedures, and Practical Guidance; Local and State Government Advisory Committee, Federal Communications Commission, June 2, 2000. FCC LSGAC RF Guide for Loc. Off'l's (cabq.gov)
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ENTRUST Solutions Group March 12, 2026 City of Lincoln, CA FCC Small Cell Order and “5G Upgrade” Declaratory Ruling As 5G wireless service began to emerge, the FCC acted on petitions from wireless carriers and limited and preempted local authority in its 2018 “Small Cell Order.”116 The Small Cell Order limited local authority over whether 5G antennas could be placed, under what conditions, and also limited pole rental rates among other things. After the Small Cell Order, the FCC made a Declaratory Ruling which expands preemption of local authority regarding placement of wireless facilities. The Declaratory Ruling117 was issued on June 10, 2020, and clarifies existing FCC rules originally adopted in 2014 to implement eligible facilities requests defined in the Spectrum Act.
Specifically, our Declaratory Ruling clarifies our rules regarding when the 60-day shot clock for state or local government review of modifications of existing structures commences.8 We also clarify what constitutes a “substantial change” in the physical dimensions of wireless infrastructure under our rules, and the extent to which certain elements of a proposed modification to existing infrastructure affect the eligibility of that proposed modification for streamlined state or local government review under Section 6409(a).118 Under the Declaratory Ruling, applicants can now start the shot clock with the first procedural step required by the City (e.g., a pre-application meeting) and submission of documentation demonstrating the proposed modification is an eligible facilities request.119 The Declaratory Ruling also provides additional interpretation on what constitutes “substantial change” for height increases for towers outside the public right of way120, details 116 Declaratory Ruling and Third Report and Order; In the Matter of Accelerating Wireless Broadband Deployment by Removing Barriers to Infrastructure Investment; WT Docket No. 17-79; In the Matter of Accelerating Wireline Broadband Deployment by Removing Barr iers to infrastructure Investment; WC Docket No. 17-84; Released by the Federal Communications Commission, September 27, 2018. (“Small Cell Order” or “Order”.) 117 In the Matter of Implementation of State and Local Governments’ Obligation to Approve Certain Wireless Facility Modification Requests Under Section 6409(a) of the Spectrum Act of 2012, WT Docket No. 19-250 and RM-11849, FCC 20-75 (released Jun. 10, 2020) 118 Id., at paragraph 4.
119 If a city does not have a Section 6409 process in place, the applicant can start the shot clock by filing documents that are typically required for a zoning or siting review. 120 Section 6409 defines substantial change pertaining to modification of a tower located outside of public rights-of-way as one which “increases the height of the tower by more than 10% or by the height of one additional antenna array with separation from the nearest existing antenna not to exceed twenty feet, whichever is greater.” The Declaratory Ruling clarifies that “separation from the nearest existing antenna” means the distance from the top of the highest existing antenna on the tower to the bottom of t he proposed new antenna to be deployed above it.
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ENTRUST Solutions Group March 12, 2026 City of Lincoln, CA on equipment cabinets121, further explanation regarding “defeat” of concealment elements122, and siting approval conditions123.
The Spectrum Act and “Eligible Facilities Requests”
Prior to the Small Cell Order, the Spectrum Act enacted by Congress in 2012124 added new requirements and directives to the FCC for processing and approval of wireless antenna and facility deployments. The FCC issued new regulations to interpret and implement the Section 6409(a) requirements and directives of the Spectrum Act related to local authorities’ processing of applications for wireless communications facilities. In brief, the Act tightens the application of shot clock timelines. It requires local jurisdictions to approve certain collocations and modifications to existing wireless communications facilities under shortened explicit deadlines if it is an “eligible facilities request.” Eligible facilities requests include any for modification of an existing tower or base station that does not substantially change the physical dimensions of such tower or base station, involving (1) collocation of new transmission equipment; (2) removal of transmission equipment; or (3) replacement of transmission equipment. The new FCC regulations established defined standards for “substantial change” and implemented the statutory changes to shot clock regulations. Under these rules, a state or local government shall approve within 60 days any request for modification of an existing wireless tower or base station that does not substantially change the physical dimensions of such tower or base station. The rules adopted by the FCC are preemptive and apply to cities and other local authorities.
The FCC’s Site Modification Report and Order125
Based on petitions from the wireless industry, in November 2020 the FCC revised the definition of “substantial change” for modifications of existing towers outside the public right of way. An eligible facilities request may now include a modification of an existing tower outside the public rights of way that entails ground excavation or deployment of transmission equipment up to 30 feet in any direction outside the boundaries of a site. Other eligible 121 The Declaratory Ruling clarified that small pieces of equipment such as remote radio heads/remote radio units, amplifiers, transceivers mounted behind antennas and similar devices are not “equipment cabinets” if they are not used as physical containers fo r smaller, distinct devices. Also, the maximum number of additional equipment cabinets that can be added under the rules is measured for each separate eligible facilities request, rather than the cumulative number of equipment cabinets on the site. 122 The Declaratory Ruling stated to “defeat concealment,” the proposed modification must cause a “reasonable person” to view the structure’s intended stealth design as no longer effective after the modification.
123 The Declaratory Ruling clarifies a municipality may not impose and enforce conditions on approvals for wireless facilities that then prevent future modifications or upgrades that are otherwise eligible facilities requests.
124 See Middle Class Tax Relief and Job Creation Act of 2012, Pub. L. No. 112 -96, 126 Stat. 156, § 6409(a) (2012) (“Spectrum Act”), codified at 47 U.S.C. § 1455(a). 125 In the Matter of Implementation of State and Local Governments’ Obligation to Approve Certain Wireless Facility Modification Requests Under Section 6409(a) of the Spectrum Act of 2012, WT Docket No. 19-250, Report and Order, FCC 20-75 (Rel. Nov. 3, 2020) (“Site Modification Report and Order”).
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ENTRUST Solutions Group March 12, 2026 City of Lincoln, CA support structures besides towers outside the public right of way are not affected by this revised definition. This change by the FCC is intended to facilitate addition of equipment to existing towers to expand 5G capacity. It is expected this rule change will allow additional providers to collocate on towers and allow additional equipment (fiber terminations, cabinets and power supply, backup power, etc.) to be placed to expand 5G services.
The FCC also expanded on the definition of a “site” such that it “refers to the boundary of the leased or owned property surrounding a tower and any access or utility easements currently related to the site as of the date that the tower or base station was last reviewed and approved by a state or local government.”126
126 “Small Entity Compliance Guide”, Implementation of State and Local Governments’’ Obligation to Approve Certain Wireless Facility Modification Requests Under Section 6409(a) of the Spectrum Act of 2012, Report and Order, FCC 20-153, WT Docket No. 19- 250, Released November 3, 2020, dated January 4, 2021.
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SUBJECT: Wall of Recognition Concept Discussion. (Hope Ithurburn/Sean Scully)
SUBMITTED BY: City Clerk
DEPARTMENT: City Manager's Office
DATE: May 26, 2026
Item Number 15.B
STAFF RECOMMENDATION:
Provide direction to staff after discussion of program concept.
BACKGROUND/INTRODUCTION:
At Council's direction, staff has researched the concept of instituting a community recognition award program and is prepared to present options and best practices.
STAFF REPORT
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