Heather Mills, V.P. for Grant & Funding Strategies

Cat Blake, Civic Technology Analyst

The Consolidated Appropriations Act that became law in late December included a new grant program to be administered by the National Telecommunications and Information Administration (NTIA): The Promote Broadband Expansion Grant Program.

This program is intended to support partnerships between a state or local jurisdiction of a state and a service provider capable of providing fixed broadband service. This public/private partnership approach is meant to enable fast deployment of proposed projects (all grant funds must be expended within a year of award) while benefiting as many potential customers as possible.

We expect NTIA to issue rules by the end of February (60 days after signing of the bill) and anticipate the application window will open almost immediately when the rules are issued. Applications will then be taken on a rolling basis for 90 days. Given this timeline, we recommend our clients begin strategizing now about potential applications.

The grants will be highly competitive; NTIA’s rules will define a scoring system where ‘priority’ will be given to project proposals that:

• Are designed to provide broadband service to the greatest number of households in an eligible service area
• Will focus on rural areas (this doesn’t rule out a non-rural proposal)
• Demonstrate that they are the most cost effective, with rural projects being put at the front of the line
• Are designed to provide service of not less than 100/20 Mbps

These priorities do not rule out other project proposals that do not meet one or all of the priorities; however, any proposal not addressing some or all of the priorities will have less chance at an award.

The law did outline some important prohibitions to take into consideration as well. Grant funds cannot be used as collateral on loans, nor can they be used to repay or make payments related to a loan. Additionally, if awarded, no more than $50,000 may be utilized to pay for grant application preparation costs.

Finally, applying for this program should not impact applications to other broadband programs for the applicant entity. (That likely is not the case for the proposed project area, however. Applicants must include detailed information about other funding support for which they have applied with regard to the area included in the application.)

CTC’s Grant and Funding Strategies Team is ready to support clients now with strategic thinking and planning around potential project proposals for this new program. Keep an eye on this space for more detail and analysis of the program as the rules are released, and don’t hesitate to contact us if you’d like to discuss the opportunity.

Heather Mills, V.P. for Grant & Funding Strategies

Cat Blake, Civic Technology Analyst

The Consolidated Appropriations Act that became law in late December created the “Connecting Minority Communities Pilot Program.” We present here our preliminary guidance for maximizing the impact of this new funding opportunity, based on our analysis of the appropriations language. We will be developing in-depth analysis as program rules are developed by the U.S. Department of Commerce’s National Telecommunications and Information Administration (NTIA) over the next month.

What is the Connecting Minority Communities Pilot Program?

The $285 million Connecting Minority Communities Pilot Program will provide grant funding to eligible recipients to purchase broadband or eligible equipment, or to hire and train IT personnel. Entities eligible to receive grants through this program include:

• Historically Black colleges and universities (HBCU)
• Tribal colleges and universities (TCU)
• Minority-serving institutions (MSI), which include:
  • Hispanic-serving institutions (HSI)
  • Alaska Native-serving institutions (ANSI)
  • Native Hawaiian-serving institutions (NHSI)
  • Predominantly Black institutions (PBI)
  • Asian American and Native American Pacific Islander-serving institutions (AANAPISI)
  • Native American-serving, nontribal institutions (NASNTI)
• A consortium led by an HBCU, TCUs, HSIs or MSI, that also includes a minority business enterprise or a nonprofit organization in the anchor community

Of the total awards given through the program, at least 40 percent of grants must be made to HBCUs, and at least 20 percent of grants must be made to HBCUs, TCUs, and other minority serving institutions to provide broadband service or equipment to their students. Eligible equipment includes Wi-Fi hotspots; modem, routers, or combined modem/routers; laptops, tablets, or similar internet-connected devices; and any other equipment used to provide broadband.

What will the grants support?

For higher education recipients, grants are intended to support instruction and learning, including remote learning. For minority business enterprises and nonprofits, grants are intended to support the operation of the organization. Educational institutions that receive a grant to support student connectivity must prioritize students that:

• Are eligible to receive the Pell Grant
• Receive need-based financial aid from the federal government, state, or the institution
• Qualify for the FCC’s Lifeline program
• Earn less than 150% of the federal poverty line
• Have been approved to receive unemployment insurance since March 1, 2020

Anticipated elements of a competitive application

Based on our expectations for this program, we believe that competitive applications will be those that offer a high impact per dollar, and that lay the groundwork for program sustainability even after the life of the initial award. We believe that the program will be more conducive to providing equipment and service than to building new infrastructure, though there certainly may be infrastructure projects that would be a good fit.

We encourage clients to think creatively about applications that would serve high-poverty areas of the anchor community, and that could incorporate applicants’ student population into a programmatic element of the project. While the program details have not yet been developed, our initial analysis suggests that the following ideas may be examples of strong fits for this program:

• An eligible entity could apply for the equipment and broadband service needed to support a new fiber optic workforce development program at the college or university.
• An eligible entity could apply for the equipment and broadband service needed to outfit a tech lab or community center in a low-income area of the community. Students from nearby higher education institutions could be hired to provide tech support, skills training, or mentorship.
• An eligible entity could apply for eligible equipment needed to build or extend its wireless network into the community, and to enable connections at nearby homes in high-need areas to support remote learning. Laptops or tablets could also be provided to eligible households.

The new federal funding represents an exciting opportunity to support connectivity initiatives and includes hard-to-come-by programs for urban and suburban broadband support.

We encourage all clients to begin thinking creatively about how these dollars might best benefit their communities. Please do not hesitate to contact CTC’s Grant and Funding Strategies Team for assistance in developing a strategy.

By Cat Blake, Civic Technology Analyst

The criticality of broadband has never been more apparent than during the crises of the past year. At CTC, we’ve had many opportunities to see the urgency that states and localities around the country feel about improving connectivity—and we’ve been proud to be part of responding to that urgency.

In Delaware, which has been a leader in developing broadband collaborations for two decades, the state acted quickly to create Connect Delaware, a trailblazing program to deliver free broadband services to low-income students. The initiative built on Delaware’s long history of prioritizing broadband connectivity, including through inter-agency and public-private collaboration.

As Governor John Carney shared during his State of the State address on January 26, “During the pandemic, this work became more important than ever. The Department of Education and [the Department of Technology and Information] partnered to create the Connect Delaware program. Through this program, we provided over 25,000 low-income students with reliable internet access.”

Among the unique features of Delaware’s program are:

1. Its length: The free service was extended for 15 months, longer than even the federal Emergency Broadband Benefit program is anticipated to last, and hopefully far longer than the pandemic will last.
2. Its interagency collaboration: Connect Delaware was designed as a collaboration among the Department of Technology and Information, the Department of Education, local school districts, and charter schools. The collaborative structure enabled each entity to focus on its strengths. For example, the Department of Technology and Information developed the program and the contractual mechanisms, alleviating the administrative burden on schools—and enabling the schools to focus on working with students and families to acquire services.
3. Its public-private collaboration: The program includes a wide range of fixed and mobile internet service providers who responded to the state’s solicitation.

Learn more about the program on the state’s website.

By Shawn Thompson, V.P. for Analytics

For state and local governments and their partners, the results of the FCC’s three recent auctions for subsidies and spectrum will have a significant impact on long-term broadband planning. CTC developed interactive tools for analyzing the results of each auction.

The FCC’s reverse auction for the Rural Digital Opportunity Fund (RDOF) awarded ongoing subsidies to winning bidders who committed to delivering service at a certain speed and latency in eligible unserved census blocks nationwide. Our tool will allow you to analyze winners by state, county, bidder, tier (speed), and latency. (For additional insight, see our analysis of RDOF results, “FCC’s Rural Digital Opportunity Fund Auction Was Supposed to Significantly Reduce America’s Rural Broadband Gap,” published by the Benton Institute for Broadband & Society.)

The FCC’s Auction 105 awarded Priority Access Licenses (PAL) in the 3.5 GHz band, also known as the Citizens Broadband Radio Service (CBRS). The auction resulted in more than 20,000 licenses being issued to 228 entities across the country. Our tool will allow you to analyze the results by state and bidder.

The FCC’s C-Band Auction 107 is ongoing, with the final rounds scheduled for early January. The C-Band is being auctioned in three blocks, labeled A, B, and C. Our tool will allow you to analyze the results to date by state and block.

Heather Mills, Team Lead, Funding Strategies

Ziggy Rivkin-Fish, Principal Grant Strategist

October 29, 2020

All signs are pointing to a third round of the U.S. Department of Agriculture’s ReConnect funding program opening in spring 2021. It’s not too early to begin developing an application strategy to position yourself competitively for that opportunity.

We expect the program might open at the end of the first quarter of 2021 with a grant deadline 60 to 90 days later. As is always the case, competition will be robust for these funds, but developing your grant strategy and strategic partnerships now will prepare you to submit a stronger application.

The ReConnect program represents the most significant congressional appropriation of broadband funding since the Recovery Act in 2009. Previous rounds of ReConnect offered total funding of $500 million to $600 million, distributed as grants, loans, and 50/50 grant/loan combination awards. While the budget for this funding round has yet to be announced, we are anticipating a similar funding level to past rounds.

To be eligible for ReConnect, service areas must be rural and 90 percent unserved by 10/1 Mbps fixed, terrestrial service. Awards can be given to both public and private entities, but USDA will look for strong state and local support in all applications.

Through our work with clients who have successfully pursued broadband funding through the ReConnect program, CTC has developed best-practice strategies for preparing a competitive application. We believe the following are critical steps in mapping out your application planning process over the next several months:

1) Develop a grant strategy. Your goal is to maximize your application’s scoring given USDA’s stated criteria.[1] Every element of your application should speak to those criteria. Start by developing a comprehensive strategy that aligns your approach (with respect to technology, partnerships, business plan, and service levels) with what USDA is seeking to fund.

2) Consider applying for state funds, if available, to complement your grant strategy. Several states have announced grant programs that are meant to complement the needs of potential ReConnect applicants. If your state has such a program, you could potentially leverage that funding as the match for a ReConnect-funded project (e.g., a 25 percent match is required for a 100 percent grant ReConnect application). For this scenario to work, the state grant program must allow its funds to be leveraged as part of the cash match for ReConnect.

3) Gather the many types of information and support materials required. You’ll need a range of data and numbers—such as population statistics and market research—to establish eligibility under the program rules and to provide content for the grant narrative. You’ll also need supporting materials, ranging from letters from your governor to documents that demonstrate the support of the local government, prospective customers, and the business community. Our recommendation here is to go over and above; additional letters (such as from your congressional delegation, the Chamber of Commerce, and so on) can only help to demonstrate the community’s breadth of support for your initiative.

4) Define and refine your proposed funded service area (PFSA). Define the PFSA with a count of the number of rural premises to be connected, including homes, farms, schools, libraries, healthcare facilities, and businesses (which are important because they confer additional points in the application). Then, document the engineering methodology used to demonstrate that the PFSA lacks service and is therefore eligible for funding.

You’ll also need to verify that no Connect America Fund II awarded census blocks are included in the PFSA and that your project area is not located in what is known as a Protected Broadband Borrower Service Area (i.e., the service area of a borrower that has an RUS broadband loan). Also note that if your PFSA includes even a part of an Opportunity Zone, your overall score will benefit. (The IRS offers a primer on Opportunity Zones here.) If you include an Opportunity Zone, discuss how economic development fits into the overall goals of your proposed project as part of the scoring criterion review/narrative.

5) Develop and review your project’s engineering plans and cost estimates. The critical engineering task after you have defined the PFSA is to develop a conceptual design for your network—including project plan, buildout timeline, design, and diagram—and cost estimates for materials and construction. The cost estimates will become a critical input to your business plan and pro forma financials. Both the design and the cost estimate will need to be certified by a licensed Professional Engineer under the ReConnect application rules.

6) Develop a financial pro forma and business plan. The pro forma should be prepared in the format provided by USDA (which is available only on the application portal) and should include subscriber projections and descriptions of planned services and pricing. To support the pro forma revenue projections, you’ll need very compelling data, ideally in the form of statistically valid market research, as well as empirical data about your or your partner’s historical success in achieving comparable market share. Projections should contain five years’ forecasted financial data. This is possibly the most critical item in the application, given USDA’s interest in funding projects it considers sustainable and low-risk.

7) Develop a market narrative, including discussion and data regarding service in the region. You’ll need to demonstrate that your services will be better and no more expensive than other services offered nearby—and present a narrative discussion of why the proposed services will be both marketable and affordable.

8) Collect the appropriate forms from businesses to demonstrate market interest and maximize points for that application item.[2] This is something that can be done through one-on-one conversations or by mailing the forms (with a cover letter and a stamped return envelope) to all the businesses in the PFSA.

9) Set up accounts and then navigate Sam.gov and the USDA portal site, to be ready to enter the grant application into the online grants system. (You may already have accounts in place, but we recommend you check to be sure the accounts are current and that someone on your team is comfortable navigating the portals.) The USDA application portal requires additional effort and may require some users to go to a USDA office in person for verification. Don’t wait until the last minute to set up your online access to the application portal.

10) Commission the required legal opinion and reviews.

11) Write compelling grant and budget narratives. The application doesn’t require a large amount of narrative writing; however, this means the narrative elements of the application are all the more important to make your case for funding.

12) Get in touch with your USDA regional representative.

ReConnect Success Stories

CTC was pleased to support our friends in John Day, Oregon, and at Easton Utilities in Easton, Maryland, with their successful ReConnect applications. The City of John Day partnered with the Oregon Telephone Corporation, which was awarded $6 million to build 89 miles of fiber through rural parts of Wheeler and Grant counties. Easton Utilities was awarded $13.1 million to build broadband throughout a 122-square-mile region in rural Maryland, encompassing nearly 3,500 households and 144 farms. Congratulations to both of these communities for their impactful awards and projects!

Please don’t hesitate to contact us if you have questions. CTC’s funding strategies and grant-writing team are ready to assist you with your ReConnect application planning.

[1] “Evaluation Criteria,” ReConnect Loan and Grant Program, USDA, https://www.usda.gov/reconnect/evaluation-criteria

[2] “ReConnect Program: Pre-subscription Form for Other Businesses,” ReConnect Loan and Grant Program, USDA, https://www.usda.gov/sites/default/files/documents/reconnect-business-pre-subscription-form.pdf

Cat Blake, Civic Technology Analyst

In late September, USDA’s Rural Utilities Service (RUS) opened the FY2021 funding round for its well-regarded Community Connect broadband funding program. Community Connect is a competitive grant program that distributes awards to rural, unserved communities demonstrating economic necessity. Awards range from $100,000 to $3 million and require a 15 percent cash match.

Expect the program to be competitive—historically only about 10 percent of applicants have received awards. Additionally, time is of the essence: The application window is currently open and closes December 23, 2020.

The Funding Opportunity Announcement (FOA) does not include a program budget, suggesting that there is some flexibility to the amount of funding available. In previous years, the program budget has been about $35 million. RUS has indicated that it expects to award 20 grants this funding cycle.

The FOA can be found here and the program application guide here. The following is a brief summary of the opportunity; please do not hesitate to contact us if you have any questions.

Who is eligible to apply?

State, local, and tribal governments, nonprofits, and private companies are all eligible to apply for Community Connect. RUS has a history of making awards to all of these types of entities and a strong track record of granting funds to public entities.

Under program rules, the applicant will be required to own the infrastructure and operate the service. If you are a public entity but would prefer not to own and operate the infrastructure yourself, you can build a collaboration with a private sector partner to leverage this opportunity. Your private partner would be the applicant and your role would be to improve the likelihood of success by working with them to develop a compelling application, secure letters of support, demonstrate financial viability, and otherwise strengthen the case for grant funding that would benefit your jurisdiction.

What geographic areas are eligible?

Eligible service areas must be contiguous and entirely within a rural area, which is defined for the purposes of this program as an area not located in an incorporated area that has a population of more than 20,000 people, nor in an urbanized area adjacent to a city or town that has a population of more than 50,000.

Further, an eligible service area must have no existing service at 10/1 Mbps speeds, excluding mobile and satellite service. This extremely high bar means that only very rural communities will be eligible for this program.

On the plus side, applicants can themselves define a proposed service area rather than being required to adhere to jurisdictional or other boundaries that may complicate eligibility.

What are the requirements of the program?

The Community Connect program includes important service commitments focused on community interests: Awardees must use their grant-funded facilities to offer broadband service at 25/3 Mbps or greater speeds to all residential and business customers within the defined service area. In addition, awardees must provide free service to all Essential Community Facilities (such as schools, public hospitals, emergency responders, etc.) within the service area for at least two years, and must also provide a community center with two computers and wireless access free of charge to users for at least two years.

Priority is given to areas that demonstrate “economic necessity,” which is evaluated based on factors such as persistent poverty, patterns of out-migration, and degree of rurality; planned service to substantially underserved trust areas; and planned service to community members with disabilities. Program scoring also includes consideration of economic characteristics, educational challenges, health care needs, and public safety issues in the community.

What is a compelling application strategy?

We recommend prospective applicants first analyze the unserved regions of their jurisdiction, then target the portions with the highest need in order to identify competitive potential service areas. A competitive application will demonstrate that the grant will have great impact on the community. We anticipate grant awards to favor applications that take a multi-jurisdictional and multisectoral approach, such as involving schools, a post office, and/or other institutions critical to the functioning of rural communities, and to have a strong economic development aspect, such as to stop migration outflows or attract new residents.

In our experience, RUS frequently makes awards to areas that are low-income, but we have also seen Community Connect grants awarded for areas with somewhat higher incomes so long as there is a convincing showing of the need for connectivity for such purposes as education or health care. Generally, a geographically modest project in a high-need community with good traction for community engagement would be a strong fit for this opportunity.

We are available to help

CTC can help with the full range of tasks related to Community Connect grant applications, from articulating a project concept to preparing an application package. Please let us know if we can help you:

• Develop a grant strategy and refine a project concept
• Develop a public-private collaboration that enables your community to work with a private partner to leverage this opportunity
• Develop a checklist of required project documentation and application requirements
• Develop technical and financial models for your proposed project
• Draft narrative sections of your application
• Review a draft project budget
• Edit and refine draft application packages
• Assist you in creating an online application account (through SAM.gov and/or USDA eAuthentication) and submitting your application

Contact information for the CTC grants team

Please don’t hesitate to contact us if you have questions. CTC’s funding strategies and grant-writing team stands ready to assist you and your private sector collaborators with your Community Connect application planning and with your other broadband planning needs.

Cat Blake, Civic Technology Analyst: cblake@ctcnet.us

Heather Mills, Team Lead, Funding Strategies: hmills@ctcnet.us

Ziggy Rivkin-Fish, Principal Grant Strategist: ziggy@ctcnet.us

Andrew Afflerbach, PhD, P.E.

CEO & CTO

Now that a federal appeals court has largely upheld the Federal Communications Commission’s preemption of local authority over small cell siting, states and localities would be wise to rigorously document their costs of processing applications and hosting equipment on utility poles or light poles.

If they undertake such a process, they’ll have a basis for establishing application fees and recurring fees that reimburse them for their actual costs—and that will withstand potential challenges from the wireless industry.

On August 12, 2020, the 9^th U.S. Circuit Court of Appeals in San Francisco largely upheld three orders related to small cell deployment that the FCC issued in 2018. One of those orders set presumptive wireless facilities siting application and rental fees that localities can charge: $500 per application for up to five sites; $100 per site thereafter; and recurring fees in the rights-of-way limited to $270 per site per year.

But the FCC order and the court ruling provided a silver lining for states and localities. These dollar figures aren’t hard-and-fast numbers; the FCC also allows jurisdictions to charge a “reasonable approximation” of your “objectively reasonable costs.” This means you can set fees based on your actual costs—which, in our experience, are often higher than the FCC’s amounts. (State and local jurisdictions also retain some leeway over aesthetic aspects of the installations.)

Documenting your actual costs will help ensure you are not undercharging for application reviews and annual rights-of-way costs (and thus effectively subsidizing the industry). Even if your costs match or are less than the FCC’s numbers, you may still want to document them, because the industry can still contest your fees. Going through this exercise will also help you understand your processes—and, possibly, identify ways to improve them.

Last year we outlined in detail what this cost-documentation process looks like. We have also described 10 strategies that localities, state agencies, or utilities can adopt to protect public property—and have discussed what rigorous processes look like. Please feel free to contact us if you would like to discuss your jurisdiction’s needs in this new regulatory environment.

Cat Blake, Civic Technology Analyst

Local governments in Maryland have a short application window for a new grant opportunity that will fund broadband and other projects. Applicants that are interested in the State of Maryland’s FY 2020 Coronavirus Emergency Supplemental Funding Program must file their applications by September 23.

Overview

The State of Maryland currently is accepting applications for the FY 2020 Coronavirus Emergency Supplemental Funding Program (http://goccp.maryland.gov/grants/programs/cesf/). While construction of broadband infrastructure is not an eligible cost, this grant opportunity presents other avenues to address community connectivity needs. No match is required for this program.

CTC’s understanding is that projects that would increase the virtual availability and accessibility of critical resources and programs (i.e., enable those resources to be accessed via an internet connection) will be competitive.

Laptops and hotspots that are used to meet the program’s goals have been specifically identified (during technical training conversations related to the funding) as eligible costs, as have projects that would provide the technology needed for local government staff to continue to administer key programs remotely.

Program Focus

The State’s program is intended to address the following in preventing, preparing for, and responding to COVID-19:

• “Identified short- and long-term barriers that impact communities’ abilities to address the needs of vulnerable children and youth and their families,”
• “Identified short- and long-term law enforcement needs, including corrections, reentry, and courts,” and
• “Identified short- and long-term barriers that impact victim service providers, inclusive of domestic violence and sexual assault service providers, as well as child advocacy centers.”[1]

Eligible Costs

Proposed projects must support at least one of the following funding priorities. Boldfaced items could be broadband-related:

• “Equipment and supplies;
• Providing for the continuity of judicial operations and support for therapeutic or specialty court services;
• Providing for the continuity of youth development program operations for underserved populations, as well as for those programs that can remain open for children of essential workers;
• Emergency support for reentry partners to ensure safe transition from incarceration to community;
• Travel expenses (particularly related to the distribution of resources to the most impacted areas);
• Training;
• Victim housing assistance;
• Virtual projects that assist residents in connecting with online services; and
• Innovation and Technology Advancements, including:
  • Support to conduct virtual abuse intervention programs
  • Support to conduct evidence-based virtual youth development programming
  • Law enforcement virtual employee screening/fit for duty assessments.”[2]

Additional Guidance

The period of performance for this opportunity is April 1, 2020, through December 31, 2021; applicants can request reimbursement for costs incurred after April 1, 2020. One application is allowed per organization (so organizations with multiple proposed projects should submit a single application that collocates all requests)—though multiple agencies within a county may each submit applications.

The program’s total budget is $10.5 million, and there is no cap on individual awards. Awards are expected to be competitive; the State has indicated that it expects funding requests to amount to three to four times the program budget.

The window for this program is short: Applications are due by September 23 at 3 p.m., and applicants must request a User ID via the Governor’s Office of Crime Prevention, Youth, and Victim Services by September 16, if they do not have one already.

Our team is available to provide further guidance and assistance preparing applications. Please do not hesitate to reach out if we can help.

[1] NOFA: http://goccp.maryland.gov/wp-content/uploads/FY2020-CESF-NOFA.pdf

[2] NOFA: http://goccp.maryland.gov/wp-content/uploads/FY2020-CESF-NOFA.pdf                         

With the Covid-19 pandemic demonstrating the critical need for communications connectivity, local governments are striving to improve local broadband service and fill broadband service gaps. At the same time, localities may be able to generate much-needed revenue from broadband and telecom assets they already own, including towers, fiber optics, rooftops, conduit, and poles.

Indeed, many cash-strapped communities possess a range of assets, including fiber strands and tower and conduit space, that have spare capacity and could be maximized. Given the challenging economic environment, some localities have been approached by investors looking to snap up attractive investment opportunities—or even capitalize on economic hardship to get favorable terms.

Based on our experience with such deals, we urge caution and careful consideration before localities sell or otherwise monetize their broadband-enabling assets. These assets represent valuable tools for meeting short- and long-term broadband goals that will be challenging to replace in the event the locality strikes a bad deal with an investor and loses control of its own assets.

A cautionary example: Some cities have sold to investors the rights to place communications equipment on city-owned rooftops – and have inadvertently compromised their own rights to use those rooftops for public safety and public access broadband.

This is not to say that the revenue-generation opportunity should be discounted. To the contrary, that opportunity may be very attractive in the current climate – and it can be explored with an eye toward simultaneously advancing the locality’s broadband goals. Stated otherwise, localities can build a monetization strategy that ensures that these twin purposes – revenues and broadband expansion – complement each other rather than undercut each other.

To evaluate this potential, localities should answer two questions: First, what is the revenue generation and asset monetization potential for my communications network assets? And, second, how can I realize that potential—and involve the private sector—while protecting the public interest and serving my community’s broadband goals?

To analyze these possibilities, CTC Technology & Energy, which specializes in network strategic planning for the public sector, has partnered with Rebel, an international infrastructure advisory firm. We suggest a process of assessing the technical, financial and legal considerations of potential revenue generating initiatives; comparing alternatives; and structuring transactions that serve the public interest.

As a first step, a quick and cost-effective review, which we refer to as the Broadband Asset Scan, provides an initial understanding of the feasibility of revenue generation and asset monetization. The Broadband Asset Scan includes four steps:

• A high-level technical condition assessment of the assets;
• A high-level financial business case evaluation of the possibility for revenue generation;
• A comparison of different viable approaches to structuring private sector involvement in the commercialization or management of the assets; and
• A roadmap for the implementation of the preferred approach.

To view our webinar on this topic, please submit your name and email address:

Heather Mills, Team Lead, Funding Strategies
Ziggy Rivkin-Fish, Principal Grant Strategist

The recently passed Coronavirus Aid, Relief, and Economic Security (CARES) Act added $1.5 billion to an existing grant program of the US Department of Commerce’s Economic Development Administration (EDA).

This is a significant opportunity, both because of the size of the allocation and its breadth of eligibility. The grants are available to local and state governments, non-profits, and other non-commercial entities that have a compelling case for using infrastructure projects (including broadband initiatives) to ameliorate the economic effects of the coronavirus crisis.

This is also an opportunity that demands quick action. EDA will receive applications and make awards on a rolling basis, so applicants with projects in advanced planning stages (and even those with a strong concept and an ability to quickly develop a project plan) should move rapidly to submit their applications.

Broadband Projects That Will Help Address Coronavirus Challenges Are Eligible

The EDA’s significant funding allocation—announced in an addendum to EDA’s notice of funding opportunity (NOFO) on May 7^th—can be used for broadband projects (in addition to other types of projects) that will strengthen economic resilience, diversify the economy and workforce, or support recovery in the face of the coronavirus pandemic. (Examples of successful past projects can be found on EDA’s website—though we anticipate the new funding to be awarded to a broader range of broadband projects.)

Under EDA’s rules, awards could range from relatively small ($100,000) to substantial ($30 million), though we anticipate that more modestly sized applications (of a few million dollars rather than tens of millions) will be most competitive.

All localities, no matter how rural or urban, are eligible to apply for these grants. For purposes of the CARES Act funds, EDA has determined that the economic impact of the coronavirus pandemic constitutes a “special need,” and has extended eligibility to all areas of the country. (By comparison, EDA’s non-CARES Act funding is available only for economically distressed areas, as demonstrated by higher than average unemployment or low per capita income.)

Applicants Need to Demonstrate How Their Project Will Create Jobs

While the nationwide special need designation lowers one significant barrier for eligibility, applicants must still explain how their project would mitigate the effects of the pandemic on the economy and, specifically, how it will create jobs. Funded projects need to “prevent, prepare for, and respond to coronavirus” or respond to “economic injury as a result of coronavirus,” according to the NOFO addendum (which reflects the language of the CARES Act).

In other words, applicants will need to clearly demonstrate how their proposals will benefit businesses—and the sooner, the better. That means applicants should seek to engage the business community in their application planning. Ideally, an applicant would be able to submit letters from businesses that can attest to direct, quantifiable potential benefits of the proposed project—such as a certain number of jobs to be created or retained. Letters of support from the business community might also describe the operational challenges that the proposed project could ameliorate. The more specifically an applicant can project the economic development outcomes of a proposed project, the stronger the application.

Grants are Also Available for Planning and Technical Assistance Efforts

Economic Adjustment Assistance grants can support planning and technical assistance projects necessary to plan and implement new solutions for economic resiliency. Eligible broadband projects could include broadband planning efforts for the deployment of infrastructure.

EDA’s NOFO addendum does not clearly define the type of planning and technical assistance projects that would be eligible for funding, but encourages potential applicants to engage with their regional EDA representatives prior to submitting an application to discuss the proposed project’s “alignment with EDA’s mission and Investment Priorities.”

Local and State Governments Are Eligible—as Are Nonprofits and Higher Education Institutions

Eligible entities include city, township, county, or special district governments; state governments; federally recognized tribal governments; nonprofits, aside from institutions of higher education; private institutions of higher education; and public and state-controlled institutions of higher education.

Importantly, nonprofits must partner with a local government jurisdiction or other “subdivision of a State” in order to apply.

While for-profit private entities are not eligible for the grants, there is a critical role for private companies because the program is designed to create benefit to private sector employment. As EDA puts it, the funding should “help communities catalyze public-private partnerships to foster collaboration, attract investment, create jobs, and foster economic resiliency and prosperity.” As a result, viable applications will demonstrate support for the proposed project by the business community in the area to be served, as well as job creation benefits by the private sector.

Rolling Applications Mean Time Is of the Essence

As with much of the CARES Act funding, time is of the essence. EDA is already processing applications for the new funds, and is expected to continue making awards until its funds are depleted. While the funding pool is large, we expect the money to be allocated quickly—so applications should be prepared and submitted as quickly as feasible.

Applicants Need to Commit Matching Funds

For purposes of the new CARES Act funding, EDA requires a 20 percent match. Though EDA will reduce that amount under unique circumstances, our sense is that applicants that cannot commit to the full match will struggle to compete for these funds. State funding can serve as the match—as can in-kind services and other expenses.

Applicants Need to Reference a Pertinent Economic Development Strategy

Another requirement defined by the statute is a Comprehensive Economic Development Strategy (CEDS) for the applicant or the region or state in which the applicant is located. Essentially, EDA wants to see that the state, region, or locality has one of these formal economic development plans that contemplates the type of project the applicant is proposing. In other words, broadband had to have previously been on the local or state government’s radar.

If an applicant does not have a CEDS, there is still hope. If a locality, region, or state has an economic development plan in place, the EDA will consider using that plan in place of a formal CEDS. For the purposes of the CARES Act funds, EDA has suggested that it will be flexible in accepting alternatives to what otherwise are a strict set of requirements for CEDS equivalency.

We Are Available to Help

CTC can help with the full range of tasks related to EDA grant applications, from articulating a project concept to preparing an application package. Please let us know if we can help you:

• Develop a grant strategy and refine a project concept
• Engage with an EDA regional representative at the start of the application process
• Develop a checklist of required project documentation and application requirements
• Develop technical and financial models for your proposed project
• Draft narrative sections of your application
• Review a draft project budget
• Edit and refine draft application packages
• Assist you in creating an online application account (through SAM.gov and/or Grants.gov) and submitting your application

Contact Information for CTC’s Team

Please do not hesitate to reach out with questions about EDA grants, other funding streams, or your other broadband planning needs.

Heather Mills, Team Lead, Funding Strategies
hmills@ctcnet.us, 202.701.4526

Ziggy Rivkin-Fish, Principal Grant Strategist
ziggy@ctcnet.us, 859.608.4043