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

If you’ve glanced at the scoring metrics for USDA’s ReConnect Round 3, a few big changes probably jumped out at you. Most notably, the eligibility requirements related to available speeds have changed in a very forward-thinking and game-changing way (all hail 100/20!). Areas that receive inadequate 25/3 Mbps service are now eligible.

But the program balances this expanded eligibility criteria against rurality and lack of service. What does this scoring approach mean for your ReConnect grant strategy? To maximize your points, you need to include areas that:

• Are rural: Maximum points are awarded for Proposed Funded Service Areas (PFSA) with population densities of six or less and PFSAs located 100 miles from a city or town with 50,000 people
• Do not currently receive 25/3 Mbps services: Points are awarded based on the number of households without 25/3 that will be served

Also, don’t look to ReConnect as a solution for your middle-mile woes. This program is designed to deliver last-mile service. While middle-mile can be included, it’s only allowable as a means to a “fiber-to-the-premises” end. If you are looking to leverage the ReConnect program for middle-mile, your proposal must include last-mile services.

These are just one of the strategic approaches you should consider in light of the new ReConnect rules. Let’s dive into the rules to uncover additional strategies.

Base scores are calculated automatically, thanks to “AI”

To maximize your score, you should first recognize there are two sets of ReConnect scoring criteria: those you can influence with narrative writing, and those that are set in stone because they are calculated automatically. The application portal USDA commissioned for the ReConnect program was designed with a certain amount of “AI” to help calculate your base scores. (More on that later.)

Generally, here is how the scoring process for the ReConnect program will work for Round 3:

1. Your application will be grouped with all the applications in your category (grant or grant/loan or tribal/socially vulnerable grant).
2. Your application will then be reviewed for financial feasibility and sustainability as a matter of eligibility.
3. Your ‘AI’ score will be confirmed.
4. The remainder of your score will be calculated and will include:
   1. A merit review of the required materials submitted with your narrative to ensure they satisfy the evaluation criteria. The Final Rules include a healthy list beginning at section § 1740.60 on page 13 (page 11,615 of the printed document) that every potential applicant should take the time to review.
   1. A review of the scoring sheet on which you have the opportunity to discuss the scoring criteria as they pertain to your proposed project. Use the opportunity to address each scoring element directly and explain how your project satisfies the requirements.
   1. A merit review of the technical feasibility of your project.
   1. A merit review of the financial feasibility of your project (beyond the basic eligibility review).
   1. A possible site visit and creation of a Management Analysis Profile (MAP).

Awards will be made based on score and availability of funding.

So what goes into the ‘AI’ score?

Scores for certain evaluation categories are automatically calculated. For example, you will be required to upload mapping information that will, among other things, validate the eligibility of your PFSA—and will calculate your score for 75 of the possible 175 points.

A trip to the Evaluation Criteria webpage will give you an ordered list of criteria by point value, with the most point-worthy items listed first. For the purpose of understanding where you need to spend the most energy, let’s start with the ‘AI’ items (with links to the mapping tool):

• Rurality of PFSA (25 points) – for serving the least dense rural area as measured by the population of a square mile OR if the PFSA is at least 100 miles from a city or town with a population of greater than 50,000 inhabitants. Multiple service areas will have a combined density calculation as if they were a single area – not the average of individual area densities.
• Economic Need of the Community (20 points) – this is based on the county poverty percentage of the PFSA. They have provided the mapping from the US Census Small Area Income and Poverty Estimates (SAIPE) program.
• Tribal Lands (15 points) – the requirement is not only to be a tribal government, but to propose services to an area that includes 50 percent tribal lands.
• Socially Vulnerable Communities (15 points) – if you include a PFSA where at least 75 percent of the PFSA is proposing to serve Socially Vulnerable communities (defined as those areas with an SVI score of 0.75 or higher (see the map at the link), you’ll get up to 15 additional points.

How is the rest of your score determined?

The rest of the scoring is based on your ability to demonstrate the following throughout the application narrative and other required materials:

• Level of Existing Service (25 points) – points awarded based on the number of households in the PFSA lacking 25/3 service. Expect this to be a straight calculation of total possible points multiplied by percent of PFSA lacking 25/3 Mbps.
• Affordability (20 points) – points awarded based on how affordable the resulting services will be for the target markets as well as the completeness of information regarding the offerings. Low cost options and a willingness to commit to participating in the FCC’s Lifeline and Emergency Broadband Benefit programs will be looked at favorably.
• Labor Standards (20 points) – While it’s not a requirement, it will get you points if you can commit to strong labor standards and give details about:
  • How the project will incorporate strong labor standards
  • If workers will be paid wages at or above the prevailing rate
  • If there will be labor agreement
  • What safety training, professional certifications, in-house training and licensing will be required of workers (contractors AND subcontractors)
  • If locally based workers will be used
  • If work will be done by employees or contractors/subcontractors and if there are policies in place to make sure contractors and subcontractors are qualified
  • If there have been any safety violations by you or your contractors/subcontractors in the last five years
• Local, governments, non-profits, and cooperatives (15 points) This is a bump for the municipal/non-profit/coop groups in points.
• Net neutrality (10 points) Committing to net neutrality gets you some extra points.
• Wholesale broadband service (10 points) Offer wholesale broadband service at reasonable rates/terms and you will get 10 points. You will have to provide evidence that you are actively marketing those services.

How much funding is available, and when are applications due?

As we noted in our post earlier this week: The program will make available $350 million for grants (25 percent match required); $250 million for 50/50 grant-loans; $200 million for loans; and $350 million for new 100 percent grants (no match required) for Tribal and socially vulnerable communities.

The funding application window/portal will open on November 24, 2021 and will close on February 22, 2022.

CTC’s grant writing and broadband strategies team are ready to assist with your grant writing and strategy needs. Please contact us if you have questions or would like to discuss how CTC can assist you.