CTC plays a crucial role in helping states that administer broadband grants using federal funds
manage their obligations related to the National Environmental Policy Act (NEPA) and Section
106 of the National Historic Preservation Act (NHPA). We deliver expertise, tools, and capacity
to help states ensure compliance and effective monitoring of grantees throughout the grant cycle.
We also support grantees that are implementing broadband programs using these public funds.
We help states and grantees manage their permitting and environmental and historic preservation
obligations to ensure smooth project execution that is compliant with applicable federal rules for
broadband infrastructure deployment.
Environmental and Historic Preservation (EHP) reviews
Managing EHP risk starts with initial project evaluations focused on understanding risks, timelines, and obligations. To that end, CTC leverages screening tools to sort projects into appropriate assessment processes and risk categories. This helps state broadband office, other grant-making public sector entities, and those seeking broadband funding to analyze potential project impacts on the front-end. This analysis may suggest a project will be costly and difficult. On the other hand, combining this analysis with strong program design may inform project design, reduce risk, and allow projects to take advantage of expedited EHP procedures like categorical exclusions and program comments, when those procedures apply. As part of our EHP analysis, CTC leverages our GIS capabilities to map proposed projects, environmental conditions, and known federal, state, and local historic sites for internal analysis, risk assessment, and oversight.
Program design and compliance framework
CTC works with state broadband offices to develop compliance frameworks that integrate NEPA and NHPA obligations into broadband grant programs from the outset. This includes establishing policies and guidelines that align with federal requirements and tailoring them to state-specific contexts. CTC’s subject matter experts support grant application designs and award procedures to ensure grant recipients are aware of their environmental and historical preservation responsibilities and understand how to meet their obligations. This early-stage support reduces issues down the line and ensures our state clients understand and can manage environmental and historic concerns from the moment a project is proposed.
Similarly, we work with grantees to incorporate EHP monitoring and oversight practices into their deployment strategies. We support environmental reporting and efforts to incorporate monitoring and mitigation requirements into field operations, including construction oversight and inspections. Working with oversight agencies, we strive to accelerate deployment while mitigating the financial and timeline risks associated with EHP compliance.
Training and capacity building
Many state agencies and grantees lack the expertise to address the technical requirements of NEPA and NHPA reviews. CTC provides training and capacity-building services, helping clients
understand EHP obligations and subsequently ensuring they have processes in place to monitor compliance with NEPA and NHPA requirements.
These services include workshops, development of guidance documents, and training on how to evaluate environmental and historical impacts, how to conduct consultations with stakeholders like State Historic Preservation Officers (SHPO) and Tribal Preservation Officers (TPO), and how to manage the technicalities of monitoring compliance throughout the life of broadband projects.
This support is equally advantageous to state teams and grantees. We regularly develop program-specific training materials for awardees, support technical assistance presentations and webinars, and support implementation activities.
Project-level reviews and documentation
CTC assists states by conducting project-specific NEPA and NHPA reviews of grant applications and awarded projects, helping state teams review the environmental and historical assessments submitted by subrecipients. This includes preparing necessary documentation to comply with NEPA and Section 106/NHPA requirements and coordinating with relevant federal, state, and tribal organizations as needed.
CTC also assists states and grantees with the analysis of individual projects. Our experts work to verify the potential impacts of broadband projects on historic properties, historic areas, known biological resources, wetlands, protected waterways, federal and tribal lands, and other potentially sensitive regions. By managing these technical tasks, CTC works to ensure that any necessary state, federal, and tribal consultations occur, and that any resulting recommendations and requirements are implemented, tracked, and reported.
Monitoring and reporting
NEPA and NHPA compliance are not one-time events: Grant-funded projects typically are monitored throughout their implementation and any changes in circumstance or finding will need to be managed.
CTC sets up proactive compliance monitoring programs for states and grantees, allowing you to track each project’s environmental and historic preservation obligations and risks. Our approach includes conducting periodic site visits, establishing specific reporting requirements, tracking mitigation and implementation activities, and developing mechanisms for addressing any issues that arise.
CTC also assists in preparing reports that must be submitted to federal agencies (such as the FCC, NTIA, USDA, or their partner agencies and governments) to document compliance with NEPA and NHPA obligations. These reports are critical to demonstrating that both states and grantees are responsibly managing federal funds and complying with their obligations. In addition, by closely tracking project progress and maintaining documentation, our approach
ensures that all parties are audit-ready when it becomes necessary to demonstrate compliance to federal officials.
Coordination with federal and state agencies
CTC serves as a liaison between applicants, awardees, state broadband offices, and the federal agencies (such as Treasury, the FCC, NTIA, or USDA) that administer grant funding for broadband projects. CTC facilitates communication between these groups, responds to inquiries about compliance, and helps ensure that any concerns raised by government oversight agencies are promptly addressed.
We work with federal, state, and tribal agencies to streamline workflows for project consultations and move projects through the review process as expeditiously as possible, while ensuring adherence to all regulations. CTC also coordinates with state agencies (such as departments of environmental protection and historic preservation offices), as well as tribal governments and other entities, to streamline compliance efforts. This coordination ensures that the state’s broadband grant program remains aligned with federal expectations and that any compliance issues are handled efficiently.