Tag Archives: grant

NOV

03

ReConnect Round 3 scoring rules are the key to planning a competitive application: What you need to know

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.

Published: Wednesday, November 3, 2021 by CTC Technology & Energy

OCT

26

USDA’s new ReConnect broadband grant rules dramatically expand eligible areas and effectively redefine broadband

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

With the October 25 release of a Notice of Funding Availability (NOFA), the USDA’s Rural Utilities Service (RUS) has made important changes for Round 3 of its Rural eConnectivity Program (commonly known as ReConnect).

Significant new scoring considerations include a preference for local governments

The NOFA includes a significant shift in application scoring metrics. RUS has included a preference for local governments, non-profits, and cooperatives as applicants and additional points to those applications (“including for projects involving public-private partnerships where the local government, non-profit, or cooperative is the applicant”).

Further, RUS includes metrics to score the affordability of the services being offered; whether wholesale services at non-discriminatory rates will be offered; compliance with net neutrality requirements; and willingness to include strong labor standards.

RUS has also included points for applications with service areas that encompass Socially Vulnerable Communities and those that address areas with defined economic need. (Our grants team is still evaluating these issues and will post a deep dive soon.)

However, don’t forget that this is a rural program and rurality still matters. Available speeds also matter. As such, points are awarded for serving the least dense rural areas as well as serving areas that lack 25/3 Mbps.

Any areas with less than 100/20 Mbps, even those with DSL or fixed wireless, are eligible

RUS is expanding eligible areas beyond the FCC’s 25/3 definition of broadband. The RUS’ definition of an eligible Proposed Funded Service Area (PFSA) is now one that is not currently receiving speeds of 100 Mbps download and 20 Mbps upload, a considerable and welcome change from its previous definition of 10/1. Further, in the scoring process, extra points (25) will be awarded to those applications that will serve areas that currently have less than 25/3 Mbps available. This includes the service areas of existing RUS borrowers without sufficient access to broadband.

This new approach follows the policies of the Biden Administration and the Commerce Department in moving away from the FCC’s longtime definition of broadband as 25/3 Mbps, essentially eliminating any claims from DSL and fixed wireless providers—which can generally not reach those speeds—that their services qualify as broadband. Going forward, the Administration appears to be saying, only cable and fiber can deliver the speeds necessary for communities to compete in the post-pandemic world.

RDOF areas are eligible for inclusion in PFSAs

After being shut out of Round 2 due to the need to coordinate with the FCC’s auction, RDOF areas will be included in PFSAs for Round 3. The NOFA explains that this is because “RDOF funds both operational expenses and capital expenses, while ReConnect funds only capital expenses.” Another rationale given is that the six-year timeline for RDOF funds is not sufficiently fast enough to respond to the needs created by the pandemic. The goal is to get communities wired as fast as possible.

There are some nuances to those applicants applying for funding in areas where they have also received – or expect to receive – RDOF awards. Expect a lot of questions to be asked and answered regarding the nuances, but generally, those applications including RDOF areas will need to provide additional insight into why that additional funding is needed. And if applicants are RDOF awardees, they must commit to keeping RDOF and ReConnect funding separate for tracking and reporting purposes.

This also means that those Round 2 applications that were left to die due to the sudden rule change in the curing process could resubmit in Round 3 if discussion is included on why the RDOF-awarded areas should be included in light of the pandemic.

As for existing USDA grantees or borrowers, they’re also protected as long as their protection hasn’t run out.

New Tribal/socially vulnerable set aside is a big deal – but there are strings!

New to the program is a separate funding option in which applicants can seek up to $35 million for Tribal and socially vulnerable areas. Socially vulnerable areas are those with “100 percent of locations within areas classified by the USDA Economic Research Service as FAR Level 4.” Criteria for Frontier and Remote (FAR) Level 4 areas are extremely rural or remote areas that are:

“15 minutes or more from an urban area of 2,500-9,999 people; 30 minutes or more from an urban area of 10,000-24,999 people; 45 minutes or more from an urban area of 25,000-49,999 people; and 60 minutes or more from an urban area of 50,000 or more people”[1].

Take the time to consult ReConnect’s mapping tools to confirm eligibility for these areas. And remember: It is essential to include discussion in the narrative on how the pandemic has further effected those areas and how the project will help address those issues.

It doesn’t matter what the Form 477s say, so long as the applicant can demonstrate that geographic eligibility

The NOFA includes a very clear statement that should guide your thinking on defining eligible areas:

“Applicants are not required to treat the publicly available FCC current Form 477 data as dispositive of what speed service currently exists.”

In other words, communities need to know that they’re not excluded from consideration just because Form 477 data indicates connectivity. But they need to show that they are under the 100/20 threshold.

Although the burden is on them, it’s a huge opportunity for those areas that have had bad fixed wireless networks to now participate in federal grant programs.

How should applicants prove their PFSA(s) is/are eligible if the Form 477 data isn’t “dispositive?” Use of existing mapping from NTIA (the NBAM) is an option, but is possibly limiting (because it, too, relies to some extent on the Form 477 data). Our recommendation is to act quickly (before the end of December) to do one or two essential data collection tasks:

  1. Have the potential PFSA(s) surveyed by a qualified outside plant engineer to determine:
    • Availability of services
    • Status of need for make-ready (for potential aerial installations)
  2.  Issue an online speed test survey to collect:
    • Information about those with service and real-time speeds
    • Information from those who wish to report they do not have service

These efforts would immediately provide your application with the necessary backup required to validate the efficacy and eligibility of your PFSA. It will also help the RUS application reviewers make easy work of your application.

Like other broadband funding programs, the application should be pandemic-centric

Applicants should focus their narratives on not only the need for broadband, but the need for broadband in light of lessons learned from the Covid-19 pandemic. Be sure to include discussion and reference to the need to “build back better.”

Additional considerations as you prepare to prepare your application:

Don’t underestimate the effort required to complete and submit your application. As we mentioned in our previous blog posts on the ReConnect program: it’s never too early to start planning and, even if your eventual application is not selected for an award, the planning will not be wasted. There are more funding opportunities for broadband infrastructure coming soon!

The ReConnect application resides on the USDA’s application portal (not grants.gov) and requires a second Level E-Authentication for all users. This means users may have to make in-person appointments at USDA field offices if an online verification is not possible. Additionally, many applicants had significant trouble setting up their accounts for Round 1 and Round 2 due to technical issues. Make account and user set-up a priority task.

It’s time to start preparing!

While we await the comprehensive application guide to be posted on the ReConnect website, here are some strategic thoughts on starting the planning process:

  1. Develop a grant strategy. Your goal is to maximize your application’s scoring given USDA’s stated criteria. 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. Gather the many types of information and support materials required. You’ll need a range of data and numbers—such as population statistics—to establish eligibility under the program rules and to provide content for the grant narrative. You’ll also need a wide range of 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 breadth of support in the community for your initiative.
  3. 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.
  4. 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 and will need to be certified by a licensed Professional Engineer under the RUS rules.
  5. Develop a financial pro forma and business plan. The pro forma is perhaps the most important (and arduous) part of your application—it should be prepared in the format provided by USDA (which will hopefully be available soon) and should include subscriber projections and descriptions of service 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. This is possibly the most critical item in the application, given USDA’s interest in funding projects it considers sustainable and low-risk.
  6. 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.

The recently regulated 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.

[1] See https://www.ers.usda.gov/data-products/frontier-and-remote-area-codes/documentation/ accessed October 24, 2021.

Published: Tuesday, October 26, 2021 by CTC Technology & Energy

OCT

21

NTIA’s Connecting Minority Communities Pilot Program Is a Broadband Funding Opportunity for Local Governments and Minority Serving Institutions

Heather Mills, V.P. for Grant & Funding Strategies
Lydia Weinberger, Civic Technology Analyst

Local governments and minority serving institutions (MSI) have a unique partnership opportunity in the Connecting Minority Communities (CMC) Pilot Program—which has a fast-approaching application deadline on December 1, 2021. Now is the time for local governments to speak to their MSI partners to identify potential projects.

The $285 million CMC grant program was established by the Consolidated Appropriations Act of 2021 to support MSIs and their surrounding communities. The program will fund purchasing broadband services and equipment, hiring information technology personnel, and upgrading on-campus facilities. In other words, this is not a broadband infrastructure program—it is an opportunity for local governments to fund workforce development, curriculum development, and service with their higher education partners.

Local governments can apply in partnership with eligible applicants

For purposes of applying to the CMC pilot, eligible institutions include:

  • Historically black colleges and universities (HBCU)
  • Tribal colleges and universities (TCU)
  • Minority-serving institutions (MSI), which include:
    • Alaska Native or Native Hawaiian-serving institutions (ANNH)
    • Asian American and Native American Pacific Islander-serving institutions (AANAPISI)
    • Hispanic-serving institutions (HSI)
    • Native American-serving nontribal institutions (NASNTI)
    • Predominantly Black institutions (PBI)

The CMC pilot program also covers qualifying surrounding communities as a way to provide further support for low-income students and businesses. NTIA was purposeful with its definition of “anchor community”: Any area within a 15-mile radius of an HBCU or other MSI (other than some TCUs) that has an estimated median annual household income of no more than 250 percent of the poverty line.

For TCUs located on land held in trust by the United States that are also located within a reservation, the reservation boundary will create an area of interest (AOI) for each institution. The AOI will be used to define the institution’s anchor community boundary.

You can check out the eligibility status of your communities by consulting the CMC Anchor Community Eligibility Dashboard. If you believe the Dashboard is in any way incorrect, plan to submit supplementary information. A list of eligible HBCUs and TCUs can be found on the National Center for Education Statistics (NCES) College Navigator Website. The Eligibility Matrix for MSIs is available on the U.S. Department of Education Office of Postsecondary Education website.

Eligible costs

Take the time to understand what the CMC pilot will fund. Eligible costs include:

  • The purchase of broadband internet services
  • The installation and upgrade of campus facilities on a one-time, capital-improvement basis
  • The hiring and training of IT personnel
  • The purchase or lease of equipment and devices for student or patron use

What’s missing from this list? You cannot use the CMC pilot to fund an infrastructure build for broadband services. While the program will fund one-time upgrades to facilities, the intent is to outfit existing structures, not create new ones. The rules prohibit ground disturbance (construction) activities that require state or federal historic preservation or environmental review approvals. However, general in-building or classroom wiring, deploying fiber through existing conduit or trenches, installing wireless equipment (e.g., access points, routers), and installing wireless transmission equipment are not considered construction and therefore can be included.

Be strategic in what you include in your proposed project and its budget. The CMC pilot has an expected award range of $500,000 to $3 million. Competitive applications will most likely fall in that range. If you are asking for more than $3 million, be prepared to provide justification as to why your application is reasonable. Keep in mind that 20 percent) of grant funding is earmarked to provide broadband service or equipment to students. It makes sense that you should craft your application to mirror that structure.

Application scoring considerations

In CTC’s initial analysis of the Connecting Minority Communities Pilot Program, we noted that strong proposals would include workforce development, equipment lending, and education components, and should prioritize low-income students and community members. That is still an important framework. A well-rounded application will score better with the reviewers.

It’s worth your time to understand the scoring. The CMC Pilot will include a programmatic review to verify the proposed project’s eligibility. Then, during the merit review, NTIA’s reviewers will score each project as follows:

  • Project Needs and Benefits (up to 35 points): Level of demonstrated community need and how the project will address those needs
  • Project Purpose (up to 25 points): How the project aligns with the program’s purposes
  • Project Viability and Innovation (up to 20 points): The project’s technical feasibility and the organizational capability of the applicant
  • Project Budget (up to 15 points): The reasonableness and sustainability of the budget
  • Project Evaluation (up to 5 points): How the results of the project will be assessed

The two-year award period (i.e. when funds will become accessible to an awardee) is expected to begin in March 2022. More information on the CMC Pilot (including webinars and FAQs) can be found on the BroadbandUSA website.

CTC’s Grant and Funding Strategies team continues to analyze the latest developments in federal funding. Please contact us if you have questions or would like to discuss how CTC can assist you.

Published: Thursday, October 21, 2021 by CTC Technology & Energy

OCT

21

States and Localities Have Updated Guidance for Treasury’s Coronavirus Capital Projects Funds

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

The Treasury Department released new guidance on its long-awaited, $10 billion Coronavirus Capital Projects Fund program—an extremely flexible opportunity that will deliver funds to each eligible state, territory, and tribal entity. State governments will now work with Treasury to receive their allocations—so now is also the time for local governments to advocate at the state level for their key broadband projects.

What can these funds be used for?

As we noted back in May, this program will deliver guaranteed funding to the states for the purpose of ensuring “access to the high-quality modern infrastructure, including broadband, needed to access critical services.” (See Treasury’s Allocation Information for a list of allocations by state, territory, and tribal area.)

The updated guidance issued gives us a clear picture of the kinds of projects Treasury has in mind—and that state governments will thus be considering as they decide how to allocate their funds:

“The COVID-19 public health emergency highlighted that access to high-quality internet can enable work, education, and health access, and that individuals and communities that lack affordable access to such high-quality internet are at a marked disadvantage. Investing in broadband for communities sensitive to or that have historically experienced these inequities will be critical for improving digital equity and opportunity, especially in the case of communities that currently lack access to the affordable, reliable, high-quality broadband internet that is necessary for full participation in school, healthcare, employment, social services, government programs, and civic life.”

The program will allow funds to be used for costs that fit in one of three main categories:

  1. Broadband Infrastructure Projects: “[C]onstruction and deployment of broadband infrastructure designed to deliver service that reliably meets or exceeds symmetrical speeds of 100 Mbps so that communities have future-proof infrastructure to serve their long-term needs.”
  2. Digital Connectivity Technology Projects: “[P]urchase or installation of devices and equipment, such as laptops, tablets, desktop personal computers, and public Wi-Fi equipment, to facilitate broadband internet access for communities where affordability is a barrier to broadband adoption and use.” You read that right: Affordability matters. Those who can’t afford to pay for services, even if available, are considered unserved.
  3. Multi-Purpose Community Facility Projects: “[C]onstruction or improvement of buildings designed to jointly and directly enable work, education, and health monitoring located in communities with critical need for the project.”

Proposals for all projects need to address the ability to do work, education, and health monitoring remotely. While fulfilling these requirements may feel intuitive for category 1 (Broadband Infrastructure Projects) and category 2 (Digital Connectivity Technology Projects), category 3 requires expansion of our concept of libraries, community centers, and health centers—as well as a retooling of the scope of services these institutions can offer.

Devices funded by the program can’t be locked with filters and they can’t have usage caps that would hinder household needs.

Multi-purpose Community Facility Projects will require legwork by agencies involved in the design to institute appropriate privacy and confidentiality controls. This process would include both virtual and physical considerations and should ultimately make it easier for patrons to access healthcare, education, and work.

Affordability and Speed as a focal point

Unique to this program is the focus on determining where affordability is a barrier to broadband adoption and use and an emphasis on the importance of providing 100 Mbps symmetrical speeds. If you haven’t done so already, make sure you incorporate affordability in your planning. It will be essential to your project justification and documentation of community need, as well as the way you track the project’s progress in addressing those needs. Additionally, an eligible area is defined simply as one that cannot receive affordable, reliable, fixed wireline service of at least 100/20 Mbps. Further, RDOF-awarded areas are eligible if the service being provided is not affordable or at or above 100/20.

For infrastructure projects, the unit of analysis is not individual households, but communities. This means low-income and other communities not being well served by the private sector can be targeted without worrying about exact boundaries of served and unserved. Treasury suggests providing a list of federal sources (such as census data) to document the need, but if you have local data on social and health indicators, that would be even better. Your mapping should utilize a community focus to aid in analysis of priority areas.

How can your locality benefit from this program? And what should you be doing now?

Keep in mind that this is not a competitive grant program at the source (Treasury). Rather, the prioritization and distribution of allocated funds will occur at the state, territory, or tribal government level. For localities with candidate projects, a lot will depend on the states, territories, and tribal governments, and their decisions to apply for the funding.

Also, while it feels like a done deal that every eligible entity will apply, there may be exceptions. And while there is time for localities to get their ideas to their state governments to be considered a “subrecipient” of funding, the states are not required to reach out for ideas from localities. Make sure you get in front of your state broadband office or equivalent lead agency; get your needs in front of them and get a sense of their initial thoughts on the process.

Funds are block-grant type, so they are “guaranteed” allocations for your state or other governing body. Your state has enormous freedom in structuring the process for which projects to fund. This could mean that it either intentionally or unintentionally restricts the funding by applying outdated procedures and rules.

If a broadband office, for example, decides to award funds through its existing grant program it could end up reintroducing a funding match requirement—or an old definition of “unserved” (e.g., limiting unserved areas to those that can only receive less than 25/3 by any technology; ignoring reliability, affordability, and technology (wireline)  components; or, conversely, allowing funding of projects with fixed wireless design and not taking affordability into account).

These would end up locking out the very communities that the Treasury program is aiming to serve. Make sure you talk with your state office to ensure your community’s needs are considered; that the funding process is adopted fairly; and that the process reflects the funding source’s flexibility and intentions.

So, what happens now?

Eligible entities must apply to Treasury for the funding by December 27, 2021. Once they have done so, Treasury will issue a grant agreement (remember, if the eligible state, territory, or tribal entity wants the money, they have a right to it per the ARPA law). Once the grant agreement is signed, most eligible entities will have 365 days to file a grant plan for approval by Treasury on how the funds will be used. The exception is for Tribal governments; their grant applications will serve as their grant plans. The grant plan can be revised during the 365-day period, if needed.

All funds must be expended by no later than December 31, 2026.

CTC’s Grant and Funding Strategies team continues to analyze the latest developments in infrastructure funding. Please contact us if you have questions or would like to discuss how CTC can assist you.

Published: by CTC Technology & Energy

OCT

12

New Federal Grant Opportunity for Broadband Economic Development Projects: $500 Million in New Funding with Applications Due Early in 2022

Heather Mills, V.P. for Grant & Funding Strategies
Lydia Weinberger, Civic Technology Analyst

A promising federal grant program has new funding and creates the potential for securing broadband funding to support economic development. The American Rescue Plan Act added $500 million in funding to the Economic Adjustment Assistance (EAA) program run by the U.S. Department of Commerce’s Economic Development Administration.

With the new funding, EAA represents a wide-ranging $500 million program to support planning and technical assistance projects in support of a strong and stable economy. Of that $500 million figure, $200 million is allocated to coal-impacted communities, leaving $300 million in the general pot.Grant awards will range from $500,000 to $5 million.[1]

While the EAA program has not traditionally had application deadlines, the notice of funding opportunity (NOFO) recommends submitting application packages before March 31, 2022. We recommend you treat that date as a hard deadline;the EDA team needs time to review and process applications before their funding window closes at the end of September 2022.

Eligible entities include:

  • Cities, townships, counties, or special district governments
  • State governments
  • Federally recognized Tribal governments
  • Nonprofits (excluding higher education) in partnership with a local government
  • Private institutions of higher education
  • Public and state institutions of higher education

Eligible applicants that applied for EAA CARES Act funding opportunity but were denied due to lack of funding can resubmit under the ARPA opportunity. As with the CARES Act funding opportunity, the economic impact of the coronavirus crisis is considered an eligible “special need,” and all areas of the country are eligible to apply.

If you are interested in applying, note that a Community Economic Development Strategy (CEDS) or acceptable equivalent must be in place for the intended project area; the CEDS must discuss the need for broadband; and you will need to show support from the business community.

 Applicants will need to explain what steps they will “take to ensure that the economic benefits of the project will be shared by all communities in the project region, including any underserved communities.”And most important: Applicants must explain how their proposed projects will ease the economic effects of the pandemic and how they will encourage job creation—or, even better, directly create them. This program’s emphasis is the economy, jobs, and more jobs.

The grant will fund 80 percent of a proposed project. As such, applicants should be prepared for at least a 20 percent match. Higher matches will make proposals more competitive in the review process. Keep in mind as you start your planning that a wide range of technical, planning, workforce development, and public works projects are eligible for funding under this program. Building, designing, or engineering infrastructure and facilities to advance economic development strategies, or planning efforts to implement such solutions, are all considered eligible costs.

CTC’s Grant and Funding Strategies team continues to analyze the latest developments in federal funding. Please contact us if you have questions or would like to discuss how CTC can assist you.

[1] This funding is in addition to $1.5 billion added to the program by the CARES Act last year, which was earmarked for projects to address pandemic recovery.

Published: Tuesday, October 12, 2021 by CTC Technology & Energy

MAY

05

Developing a Grant Strategy in an Evolving Funding Landscape

By Ziggy Rivkin-Fish, CGEIT, VP for Broadband Strategy

Are you trying to get more secure footing in a shifting broadband landscape? You’re not alone. Between existing and potential funding programs, it’s very challenging to plan in the current moment.

For example, as we discussed in a previous paper, the results of the Rural Digital Opportunity Fund (RDOF) reverse auction and the pending rules for a range of new federal broadband funding programs have created some uncertainty about whether RDOF-awarded areas will be eligible for other streams of federal broadband funding.

This uncertainty leaves many communities’ grant planning efforts in flux at a time when Congress has allocated historic amounts of new funding for broadband infrastructure. Based on what we know now, we offer the following preliminary guidance to communities about preparing for new federal funding opportunities.

The moving pieces

Two unknowns will determine how RDOF awards will affect communities’ eligibility for other federal funding programs:

  • Whether the FCC will ultimately certify RDOF awardees. While the FCC technically has awarded geographic areas to auction bidders, it is still going through the process of reviewing bidders’ detailed technical and financial information. The possibility remains that the FCC could retract awards if it is not confident that a bidder will meet its commitments. In particular, fixed wireless and satellite providers’ (e.g., SpaceX’s Starlink) network designs are likely to face scrutiny.
  • What the new funding programs’ rules will look like. Several new broadband funding streams have been created in the past few months, including multiple programs enacted by the Consolidated Appropriations Act of 2021 and robust funding allocations included in the American Rescue Plan Act of 2021 (ARPA).

These programs are so new that their rules are still being developed by the agencies that will administer them—so we do not yet know how they will consider areas that have already received federal funds (such as RDOF awards). Some existing broadband funding programs have chosen to disregard RDOF in their latest funding rounds. For example, the Appalachian Regional Commission is not considering RDOF awards at all in the current application cycle for its Partnerships for Opportunity and Workforce and Economic Revitalization (POWER) program.

Funding streams to consider

The legislation that enabled NTIA’s new broadband funding programs explicitly stated that NTIA should coordinate with other federal agencies to ensure that the same project area is not funded by more than one agency. While there is precedent for satellite-awarded RDOF areas to be exempt from such a rule, most areas that were awarded to RDOF winners likely will be excluded from receiving funds from NTIA’s new programs.

The various broadband-relevant allocations of ARPA stimulus funding could be more attractive opportunities. The legislation itself places few restrictions on the use of the funds, simply mentioning broadband infrastructure as an eligible expense.

The $220 billion State Fiscal Recovery Fund and the $130 billion Local Fiscal Recovery Fund leave spending guidelines entirely up to state and local authorities, respectively. For the $10 billion Capital Projects Fund, guidance from the Department of the Treasury is anticipated in the near future, and will provide further information regarding restrictions and parameters.

States and localities can certainly develop their own criteria for evaluating projects and distributing ARPA funding, though, and broadband projects will have to compete against other capital infrastructure proposals and priorities. Additionally, it is highly likely that the telecom industry will lobby to prevent funding of broadband projects that would compete in their existing service areas.

Despite these hurdles, the ARPA funding presents a chance to build fiber optic infrastructure that will last for decades in areas where RDOF commitments have a high risk of not materializing, or where existing coverage is spotty or barely meets broadband speeds. In other words, areas that face challenges in qualifying for eligibility within traditional broadband funding frameworks could be viable candidates for ARPA funding.

ARPA funding could also resolve a blind spot in FCC auctions and traditional grant frameworks such as ReConnect: These types of programs typically exclude backhaul and middle-mile infrastructure that could lower barriers of entry for ISPs—which in turn could facilitate not only the extension of service to unserved areas, but also competition in already-served areas. ARPA funding could also potentially be used to pay for broadband strategic planning, including granular mapping and the development of programmatic solutions to facilitate broadband adoption.

Finally, we can consider the second round of RDOF. The FCC may fix and retain the reverse auction format, particularly if there are sufficient non-awarded areas after the first round—areas that either were ultimately rejected in the first round of RDOF or those that the FCC newly deems eligible. The auction format may yet be salvageable—if designed and executed correctly, with full and robust enforcement of bidder obligations. (That said, we hope that reverse auctions will be supplemented by more robust merit-based grantmaking at both federal and state levels, to address the inherent limitations of the reverse auction mechanism.)

The second round of RDOF, in whatever form it may take, will have a longer timeline than other federal funding sources since it will rely on the implementation of the FCC’s new address fabric and mapping data.

Even prior to the auction itself, former FCC Chairman Ajit Pai was criticized for rushing to design and execute the process, and for relying on poor and misleading mapping data to determine eligible areas. Former Chairman Pai argued that it was preferable to work quickly to solve the problem for most areas in need, and tackle the remaining areas later when better mapping data became available. This decision to conduct the auction before more accurate maps were ready has created a patchwork of isolated unserved areas, which are no longer fit for an auction format because only nearby incumbents would have a viable business case to serve them.

What should communities do?

In light of these moving pieces—and the potential funding streams—we recommend communities take the following steps to develop a funding strategy and position themselves competitively for federal dollars:

An RFP or RFI can also be an excellent vehicle for addressing community priorities. For example, it could address affordability concerns by capturing ISPs’ proposed fees and willingness to participate in subsidy programs. These elements could be considered as a scoring element for potential partners.

  • Explore potential partnerships. If you already know the areas of your community that are served and unserved by broadband, reach out to potential partners directly or write a request for proposals (RFP) or a request for information (RFI) to get a better understanding of potential partnerships. It can be a good strategy to target larger geographic areas at the outset and refine the service area later to reflect factors such as partner priorities, community need, and funding eligibility.

    Additionally, any critical anchor institutions such as public housing, community centers, or first responder units that lack adequate connectivity can be included as priorities in the RFP or RFI. Lastly, the RFP/RFI document or the contract agreement with a partner can include performance and auditing requirements as a partnership condition.

    Additionally, any critical anchor institutions such as public housing, community centers, or first responder units that lack adequate connectivity can be included as priorities in the RFP or RFI. Lastly, the RFP/RFI document or the contract agreement with a partner can include performance and auditing requirements as a partnership condition.

    Throughout this process, do not limit yourself to working with incumbent service providers. If there are RDOF areas in or near your community, you can use the FCC auction results portal to see which ISPs bid in various auction rounds. Even if they did not win the auction, these providers may be willing to build in your community if sufficient support is available.
  • Develop a community mapping initiative. If a broadband mapping effort is not already underway in your community, it would be a valuable project to pursue. In some cases, especially if there is a potential partnership on the table, incumbent ISPs will share their actual network maps. The local school district may also have data about which neighborhoods have broadband gaps.

    Creating a robust mapping effort to identify served and unserved areas is not just critical for identifying areas eligible for federal funding, but also for having the capability to challenge provider claims when the new FCC mapping program—which will rely on providers’ data—comes online. The FCC’s draft rules for the process explicitly give local governments the ability to challenge providers’ service claims.
  • Watch for updates from the FCC. It is prudent to keep a close eye on FCC announcements of RDOF bidder certifications or denials, to understand whether any areas will open up for second-round bidding (or other funding) in your community.
  • Build support for a broadband project. Finally, make sure your executive stakeholders are in the loop and supportive of project priorities. At minimum, you may need their approval, and you may need a pool of matching funds available, too, depending on the funding program. It is never too early to start having internal conversations about how to gather community resources behind a potential broadband initiative.

CTC’s Grant and Funding Strategies team continues to analyze the latest funding developments. Please contact us if you have questions or would like to discuss how CTC can assist you.

Published: Wednesday, May 5, 2021 by CTC Technology & Energy