Author Archives: CTC Technology & Energy



Mason County and the City of Maysville, KY, Issue Broadband RFP

Mason County and the City of Maysville, KY (the City/County) seek a partner to review the current status of broadband availability in the community; plan for the construction of an expanded network to address underserved, unserved, and unreliably served areas; and construct and operate the broadband infrastructure.

The City/County seek to empower residents and local businesses to be network economy producers and believe this project will enable economic diversification and create new job opportunities. The City/County intend to support this vision with a fiscally sustainable, scalable, and long-term solution. Responses to this RFP will ideally consider community needs not just of today, but for 10 to 15 years in the future.

 Responses are due Monday, January 17, 2022, at 2:00 PM local time.

The full RFP is available here.

Published: Tuesday, December 21, 2021 by CTC Technology & Energy



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



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 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 accessed October 24, 2021.

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



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



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



Ithaca Area Economic Development Issues Broadband Connectivity RFP

Ithaca Area Economic Development (IAED), working closely with Cayuga Data Juice, has released an RFP seeking a qualified partner to design, build, and operate a middle mile fiber optic network for use by Ithaca-area companies, internet service providers, and other stakeholders.

As communities in New York seek to modernize their economies, high-speed internet connection is proving to be a necessity. IAED, a 501(c)(6) economic development organization, is actively engaged in developing initiatives to improve broadband internet in the Ithaca area for purposes of economic and other development. IAED is working closely with Cayuga Data Juice which plans to build a regional data center that – along with broadband providers and other institutional clients – is expected to be a potential client of this infrastructure.

Responses are due November 22, 2021, 5PM EST.

Download the full Broadband Connectivity RFP below.

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



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: by CTC Technology & Energy



New Opportunities from the Maryland Office of Statewide Broadband to Connect Your Community to the Internet

Ziggy Rivkin-Fish, CGEIT, V.P. for Broadband Strategy
Barbara Fichman, Principal Analyst and Researcher
Taylor Brown, MSW, Civic Technology Analyst

If you are looking to expand your community’s internet access in Maryland, you need to prepare for the funding opportunities created by the Digital Connectivity Act of 2021 (the Act)[1] and the Office of Statewide Broadband (OSB). OSB, which replaces the Office of Rural Broadband, seeks to ensure access to high-speed, affordable broadband service to all residents by 2026 by administering the $300 million Maryland has allocated for broadband. OSB’s initiative includes a variety of programs supporting adoption, affordability, and infrastructure. It includes at least $8 million toward spurring adoption and at least $75 million to address affordability support for subscription fees and computing devices. More than $200 million will be targeted toward programs to build out additional broadband infrastructure. The following table outlines a draft of how these funds will be allocated by category:[2]

Table 1 – Draft Funding Breakdown

CategoryTypeValueCategory Subtotal
Digital Inclusion FundAdoption$2,000,000 
Digital NavigatorsAdoption$2,000,000 
Tech ExtensionAdoption$4,000,000$8,000,000
Device SubsidyAffordability$30,000,000 
Service Fee SubsidyAffordability$45,000,000$75,000,000
Broadband and Digital ConnectednessInfrastructure$23,720,000 
Gap NetworksInfrastructure$5,000,000 
Local Government Infrastructure Fund (LGIF)Infrastructure$15,180,000 
LGIF Fiscal Year 2021Infrastructure$30,000,000 
Municipal BroadbandInfrastructure$45,000,000 
Network InfrastructureInfrastructure$97,600,000$216,500,000
Total $299,500,000 

OSB will institute new grant programs and upgrade some older ones. Here is our analysis of OSB’s planned activities:

  • OSB will facilitate listening sessions with internet service providers (ISP) and counties to get feedback on grant requirements. Such requirements may govern service speeds, award ceilings, low-cost or discount programs, and matching.
  • OSB is developing plans and guidelines for some of the categories. The details of which eligible services fall into which categories still need to be fleshed out. Digital connectedness may provide coverage for last-mile infrastructure, and some of the funds that were retroactively allocated for broadband in fiscal year 2021 may be channeled for additional broadband planning and federal grant application support.
  • OSB is also expecting to develop new requirements for the program funds, including for infrastructure, to reflect changing needs, funds, and statutory restrictions. Some requirements regarding matching funds and eligibility would be the result of the listening sessions mentioned above, but some are tied to the source of funding. The State is using funds from the American Rescue Plan Act of 2021 (ARPA) for its broadband program, and the U.S. Department of the Treasury has provided guidelines and restrictions on how those funds can be used.

If you are not prepared to apply for these funds, you need to get ready—fast. Although we expect many proposals to receive funding because of the State’s significant investment in broadband, you and your potential partners should already be prepared to apply for funding. In drawing your routes, you should prioritize unserved areas in your jurisdiction, which are clearly a priority. However, keep in mind that ARPA gives some leeway regarding your boundaries, allowing you to build out service to served areas along your route to unserved areas. That flexibility is attractive to ISPs because it allows them to provide better broadband to poorly served areas along with the targeted unserved areas. Again, OSB will provide clarification on how best to accomplish your broadband goals.

We are here to help

CTC can help you get up to speed on the new broadband funding landscape in Maryland. We can guide you through a full range of tasks related to 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 – whether for building new infrastructure, developing and organizing a device-lending program, or developing a project to promote and subsidize the adoption of broadband or any other digital-inclusion elements
  • Form a collaboration between you and partners
  • Create a checklist of required project documentation and application requirements
  • Prepare technical and financial models for your proposed project
  • Edit and refine your draft application packages
  • Submit your application

Please do not hesitate to contact us if you have questions. CTC’s funding strategies and grant-writing team stands ready to assist you, your public partners, and your private collaborators with expanding your community’s broadband infrastructure.

[1] HB97/SB66

[2] This table was adapted from Maryland’s Supplemental Budget No. 5 – Fiscal Year 2022 and informed by the Governor’s staff.

Published: Thursday, July 8, 2021 by CTC Technology & Energy



A Deep Dive into the Scoring Metrics of the NTIA’s Broadband Infrastructure Program

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

On May 19, 2021, the National Telecommunications Information Administration (NTIA) released rules for the Broadband Infrastructure Program (BIP). The highly anticipated rules contained a few surprises (a recommended, but voluntary 10 percent match) and at least a few non-surprises (RDOF areas are not eligible unless you are traversing them with middle mile). The NOFO also outlined how grant applications will be scored, prioritized, and ranked in order to make award decisions. If you came away a little confused about how your point score relates to the programs stated priorities, and possibly reflecting that you might have better luck applying for admission to an Ivy League school despite having terrible grades, you weren’t the only one. 

Our team spent some time analyzing the scoring and prioritization processes based on the NOFO. While we believe that NTIA will likely make some clarifications to smooth out some inconsistencies, our below explanation and example will hopefully help you position your application for a high-priority review with a high score. 

Here is the quick (and dirty) explanation of the general scoring and prioritization schema:

  1. Your application will be reviewed for completeness.
  2. Your application will be scored AND assigned into one of the priority categories:
    a. Any application scoring over 70 points will be judged “qualified” and considered for funding.
    b. Applications scoring less than 70 points will be judged “unqualified” and denied funding.
  3. Your application will be ranked in the assigned priority category based on your score and any other favorability additions (more on that later).

But first, let’s set a few things straight:

  • Priority is not an assurance of an award. If you read the NOFO thinking that you just needed to propose a rural project that maximized the number of households your project serves while meeting a few of the other priorities, we recommend you take a closer look at the scoring requirements and pick a priority area in which to rest your application. This is because you will likely only get one priority area review and if you aim for just the rural priority, you may not get any funding.
  • Non-Rural areas are absolutely eligible. While the law and the NOFO list five priority areas, there is no language in the law or the NOFO that says urban areas that are unserved are ineligible. In fact, a higher density unserved area that is more likely to be found in an urban setting is ripe for high placement in the first priority group for consideration. In other words, the highest number of unserved households proposed to be served garner first priority group placement. 
  • You want to score as many points as possible to get a high placement in your assigned priority group. As noted earlier, throwing in the match, be it in-kind or cash, will garner you not only points, but additionally favorability in the rankings. Be strategic!
  • Serving the highest percentage of the unserved in the census blocks within your proposed service area is the most important aspect of your score. That first priority is literally “[c]overed broadband projects designed to provide broadband service to the greatest number of households in an eligible service area.” 
  • While a match isn’t required, you’ll not only get extra points for including a match, you’ll get additional favorability in the ranking within your application’s assigned priority group. 
  • The voluntary match can be in-kind – and that is easier than you think to make happen given the constructs of the program per the NOFO. The match can include third-party in-kind contributions as well.

The Administrative and Eligibility Review is the easy part of the scoring process. The review team will simply be confirming that the applicants are eligible to apply, that their application is complete (meaning it appears to have all the required elements), and that the documentation, narrative, and budget justification are responsive to the basic programmatic elements of the application requirements. In other words, make sure you have created a list and checked it twice. An incomplete application is not an immediate disqualification, but it may potentially put your application in peril if you happen to miss a request from the NTIA review team for missing information. You will only have seven calendar days to reply with responsive materials unless they give you more time. Indeed, “failure to remedy” any deficiencies when requested in the time allotted is cause for the NTIA to deny your application.

In the Merit Review, your application will be scored on a scale of 0 to 100 points. Those points are derived from the reviewers’ analysis of the project purpose and benefits (up to 30 points), the overall project viability (up to 40 points), and the project budget and sustainability (up to 30 points).

The Project Purpose and Benefits score is broken down between the overall level of impact the project will have on the proposed service area (up to 20 points) and the affordability of services offered (up to 10 points). This score will be derived from how many connections will be made and will be impacted by the amount of funding the provider partner has received from other federal sources to deploy broadband service in the proposed service area. In other words, choose your partner wisely. And keep in mind that if you are proposing a last-mile solution, you have to propose to connect 100 percent of the total unserved households in the proposed service area in order to receive all 20 of the service area points. That means the more tightly you can draw boundaries around your proposed service area to exclude served addresses, the better. Keep in mind that you can connect your unserved clusters with middle-mile infrastructure to make it contiguous without adversely impacting your scores. You may want to work with your partner to conduct selective field visits to delineate and document unserved areas to strengthen your unserved metrics and prevent challenges from incumbents in the area that could lower your unserved metrics and, therefore, your score.

Proposed subscription pricing will be compared to existing services and pricing in the area or nationwide averages. Your application should propose competitive rates for the target market. Hot tip: municipal applicants could offer services for free to qualified families struggling to afford broadband, garnering not only the full 10 points for affordability, but also a favorability bump in the programmatic and final review. 

The Project Viability score is made up of two areas: the overall technical approach/related network capacity/performance (up to 20 points) and the applicant’s organizational capability (up to 20 points). In your project narrative and planning elements, this is where capacity and performance, clear planning, and communication of timelines will matter most. In other words, what is the technical solution you propose to solve your stated broadband needs? Your application needs to show that the proposed network solution will provide enough capacity and scalability (they have absolutely thrown around the phrase “future proof”) to meet the needs of all the households, businesses, and community anchor institutions in that area, simultaneously at peak usage. Latency will also matter. 

Don’t forget that how you present your organizational expertise and overall abilities is essential to the application. Part of the purpose of requiring a covered partnership is to make this part easier overall. Your provider partner should be able to demonstrate a deep track record of successful projects of similar size and scope. Even more important is the ability to hit the ground running. Hot tip: if you have the materials on-hand to ensure you can start work immediately upon award, brag about it in your application narrative. It will matter for points, and it will get you a little more favorability in the Programmatic Review. 

The Project Budget and Sustainability score is the last section of the Merit Review and is broken out into three areas: 1) “Reasonableness of the Budget,” 2) project sustainability, and 3) if you are providing the voluntary match. 

Reasonableness of the Budget literally means if you prepared a budget document and narrative that is clear, detailed, and comprehensive in approach, and generally makes sense (“appropriateness”), given the technical approach proposed. In other words, does the cost fit the solution? The proposed solution itself is the subject of the Project Viability score —so make sure you do your homework there. 

You’ll get a full 15 points if you can successfully demonstrate that the project will be viable beyond the award period (for example, high operational costs combined with unrealistic take-rate assumptions could drag down your score). This should be a fairly low bar, but you may stumble if you can’t clearly communicate your business plan, market projections (take-rate matters!), and any other information that will show longevity of the project. Hot tips: don’t propose a solution that will need significant upgrades in the near future and don’t forget that part of the reason for a partnership with a public entity is to ensure there are enough community commitments to help with sustainability. 

If you can, you should absolutely include a match of at least 10 percent. You’ll not only get at least 10 additional points; you’ll get a favorability bump in the Programmatic review. The simplest way to do this is via a match from the private partner. Depending on the partner, this should be a very low bar. 

Take a sip of that coffee. We’re getting to the “Squishy” part.

Before we jump into the last steps of the application scoring and review process, here’s a hypothetical scenario. Let’s say your proposed project encompasses two census blocks in an “urban desert” in a moderately sized city. The size of each census block is 1,000 residential homes and a smattering of businesses. The businesses are served well because they are along a main road, but the homes are getting less than 25/3 reliably. Let’s further assume that 75 percent of the homes in the two census blocks are unserved. That means that the hypothetical application should propose to serve 100 percent of those 1,500 households that are unserved. The application will list the percentage unserved (75 percent) and the percentage of the unserved you are proposing to serve (100 percent of the 75 percent), as well as the actual numbers. If all other elements of the application are satisfied and the application is scored to receive 70 points or more, it should be categorized in the first priority review area by merit of its proposal to serve 100 percent of the unserved. 

Assuming the application narrative has satisfied the initial Administrative and Eligibility Review and scores above 70 points in the Merit Review, it will then undergo a Programmatic Review, where it will be reviewed for “conformity with programmatic objectives, requirements, and priorities.” This is where the review team will rank qualified applications that scored over 70 points in order of the priority groups in which the applications have been assigned. 

In other words, your application is categorized, scored, and then ranked in its category. 

This is also a deep due diligence time. If you get a call in the fall from NTIA for more information, it’s a good sign your application is being ranked in its priority category and they are seeking further information to finalize that ranking and determine if they will recommend an award. The team at the NTIA may also do a little deal-making during this time period. As with other agencies, they may ask you to alter to your proposal to make an award possible. Be ready and be open to changes.

When describing this process to clients, I often use the term “squishy.” To be clear, the scoring and ranking process is quite fair, but it isn’t uncomplicated. In part, that complication is the last step in the award-decision process as defined: Once the Programmatic Review is complete, the Office of Telecommunications and Information Applications (OTIA) Associate Administrator will make rank recommendations within each priority group to the Selecting Official (SO).

This is the squishy part: The SO will then consider the following nine factors in making final decisions:

  1. The application score and comments from the expert reviewers during Merit Review.
    This is why your score matters!
  2. How the NTIA Program Staff felt/analyzed your application during the Programmatic Review
    Your grade on presentation and concept
  3. If your application satisfied any of the five program priorities defined by the Act
  4. If your application proposes to include any cost share (remember, the match is voluntary)
    This is a “favorability” bump. If it is down to you and one other application, and yours gave the match but the other didn’t, you’ll get a higher ranking
  5. Where your proposed project is located and if, when considering the award, it will generate a geographically equitable distribution of the considered/awarded grants
    This feels like a massive challenge, right? Essentially, it means that proposals for funding in the same area will set up a Highlander scenario (“There can be only one!”), so get it in early if you can.
  6. If your project, as proposed, is necessary given the likelihood of a private provider expanding service without the need for federal grant support
    In other words, how long have you been waiting for that broadband service to get to you, but the providers just seem uninterested? How likely is it that a provider would build it without grant support? Why haven’t they done so before?
  7. If your project will incorporate “strong labor protections into the performance of the construction project, including paying prevailing wages.”
  8. If your project avoids potential duplication of other federal initiatives
  9. If there is enough funding

That’s the “squish.”  And it’s a lot of gray area when the stakes are so high. 

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: Wednesday, June 23, 2021 by CTC Technology & Energy



Where to Draw the Line: Guidance on Proposals for NTIA’s Broadband Infrastructure Program

Ziggy Rivkin-Fish, CGEIT, V.P. for Broadband Strategy

If you’re like us, you might be confused about what the National Telecommunications and Information Administration (NTIA) accepts as service coverage data for their new Broadband Infrastructure Program (BIP). In BIP’s Notice of Funding Opportunity (NOFO), NTIA states the following:

The term “eligible service area” means a census block in which broadband service is not available at one or more households or businesses in the census block, as determined by the Assistant Secretary on the basis of: (A) the maps created under section 802(c)(1) of the Communications Act of 1934 (47 U.S.C. 642(c)(1)); or (B) if the maps described in subparagraph (A) are not available, the most recent information available to the Assistant Secretary, including information provided by the Federal Communications Commission (FCC).

NTIA, Section I.A, p. 4

So, does that mean we can use our own GIS data and maps? Yes and no. Here is our analysis of this section of the NOFO:

  • NTIA consults the National Broadband Availability Map (NBAM) when considering proposals. Essentially, NBAM adds state-provided data and speed test data to the old 477 maps. Although the final rules have not been published yet, we believe that NTIA consults the map at three points:
    1. To do a quick and rough validation at application intake to ensure that the reporting of estimated unserved addresses passes the smell test
    2. During the programmatic review, when NTIA analyzes all submitted documentation to verify project details like construction planning and financial viability
    3. To respond to a challenge from an incumbent

If NTIA’s GIS data and maps are inconclusive, it may send auditors to verify challenger and/or project claims regarding served and unserved areas included in the proposed service area. Although it has not been explicitly stated, we believe—and NTIA recently indicated in a webinar—that any documentation of served and unserved areas generated by/for a project can be included in a project submission. If you have conducted a study or mapping process, this data can play a key role in allowing NTIA to dismiss challenges without needing to complete a comprehensive inspection.

  • NBAM maps are not public, although you can access them if your state is an NBAM participant. To see if your state is participating in NBAM, click here. If your state is a participant, your state contact should be able to give you more information.
  • The proposed service areas can be part of census blocks and do not have to be contiguous. Middle-mile infrastructure is eligible for funding. Therefore, the boundaries for the proposed funding service areas drawn by you and your partner(s) can consist of clusters if they’re connected by middle-mile.
  • Including some served locations in your proposal should not be a problem. NTIA’s criteria for an unserved area is that at least one address in a census block is unserved. However, a higher number of unserved addresses, as well as a high unserved-to-served ratio, will positively impact the project’s score.
  • Fixed wireless coverage counts for BIP could potentially eliminate a census block from funding since physical inspection is difficult and field testing is unreliable. NTIA has not indicated how it plans to test fixed wireless claims, but its first go-to resource is its own NBAM map. If you have independent speed test or survey data to document no service, below-average broadband speeds, and/or unreliable service, your project will be less vulnerable to exaggerated fixed wireless provider claims. If your state participates in NBAM, you should also contact your state broadband office to consult NTIA’s map.
  • Prior federal or state broadband funding in a census block does not necessarily preclude an area from consideration but must be disclosed in the grant application. NTIA will consult its maps to determine if a census block should be excluded. A census block that has been previously funded with state or federal funds such as the Connect America Fund II (CAF II) would not—if there are still unserved households—preclude an applicant from including such an area, but it could weaken the overall score of the project and could potentially exclude it. While the status of RDOF, including SpaceX-awarded areas, is uncertain, we suspect that low-speed, fixed wireless, CAF II projects would be disregarded by NTIA.

For our first-take analysis of the NOFO, you can check out our previous post here. Be on the lookout for more expert analysis of the Broadband Infrastructure Program and everything else you need to know for efficient, affordable, and equitable broadband infrastructure. If you have any questions or need assistance in the meantime, please feel free to contact us.

Published: Friday, June 18, 2021 by CTC Technology & Energy