How to prepare for an application to the FCC’s Affordable Connectivity Outreach Grant Program

Ziggy Rivkin-Fish, VP for Broadband Strategy

Heather Mills, VP for Grant & Funding Strategies

CTC Technology & Energy

Recognizing that cost can be a barrier to subscribing to broadband services, Congress created the Affordable Connectivity Program (ACP) to subsidize subscriptions for low-income residents.[1] To increase enrollment in the program, a new FCC-administered Affordable Connectivity Outreach Grant Program will distribute $70 million to eligible entities that will raise awareness and help eligible residents sign up – potentially as part of an ongoing digital equity effort.

Each eligible state and territory, as well as Tribal entities as a group, will be allocated a set amount – for states, it is $500,000. Actual funding will be awarded by the FCC based on competitive review of all applications. Coordination between states and their localities and other eligible applicants will be essential (and is specifically encouraged by the FCC).

Applications for projects ranging from $50,000 to $1 million[2] – with no match requirement – will be accepted through January 9, 2023 (which means applications must be completed over a very short timeline). While ISPs are not eligible, the program will still be highly competitive, so state, local, and Tribal governments should begin planning their applications or providing support to eligible entities now.

Overview of the opportunity

According to the first notice of funding opportunity (NOFO), the FCC has allocated $70 million for competitive grants, with $60 million reserved for states and U.S. territories (i.e., the National Competitive Outreach Program, or NCOP) and $10 million for Tribal governments and organizations (i.e., the Tribal Community Outreach Program, or TCOP).

The NCOP reserves $27 million for minimum allocations to each state[3] ($500,000) and U.S. Territory ($250,000). That leaves the remaining funding for all other eligible NCOP applicants, which include social service providers, community anchor institutions, and public housing agencies. ISPs are specifically named as ineligible for this program.

The FCC will issue a second NOFO in the future to define two $5 million, one-year pilot programs: Your Home, Your Internet and the ACP Navigator Pilot Program.[4]

In addition to general educational outreach (which would include digital campaigns), the FCC is looking for proposals that include hands-on, in-person outreach and support for potential ACP customers. The NOFO and the ACP NCOP Order make clear that no funding from the NCOP can be used for remote application assistance.

Application strategy

The NOFO spells out the program’s goals and priorities – which indicate that an applicant would be wise to discuss how their proposal will effectively and efficiently reach eligible consumers who do not know about the ACP. Beyond that key point, the application asks specific questions to gauge the efficacy of the applicant’s plans. As you plan your application, consider the following:

What is the applicant’s background and experience with the ACP? That includes anything important to an outreach solution, such as expertise and history, high-level planning of a project timeline, and profiles of who is (or could be) on the team (including partners, if any). Having this information gathered before you embark on the application narrative will save considerable time in writing the application.

How will you measure success? It’s important to think creatively about how you will define success. What metrics are measurable and how? How else can you demonstrate that the outreach will be successful? The NOFO includes performance measures that applicants should speak to in their narrative, such as:

  • Awareness measures
    • Outreach activities/events by type
    • Number of individuals/households reached by outreach type
  • Enrollment measures
    • Number and type of in-person enrollment events held
    • Number of households enrolled during the events

What data will you collect? Building on the awareness and enrollment measures, the NOFO refers to the FCC’s plan to measure success through the “ongoing collection, analysis, and reporting of data” related to grant recipients’ programs. These data analyses may also enable a roadmap for decision-makers to consider when ACP funds run out. In that light, how will you gather data to help inform the FCC’s analysis of ACP eligibility criteria, subsidy amounts, and funding levels? For example, can you gather data to assess what level of subsidy might best balance the ACP’s limited funds and the needs of eligible enrollees (i.e., is that $30 or might $20 suffice)? In your outreach efforts can you evaluate whether enrollees have considered ISPs’ existing low-cost service tiers?

How can you leverage your existing programs to support the mission of the NCOP? As described in the Order, the FCC is looking for both large- and small-scale solutions that will leverage existing programs at the local and national level. That means your ongoing digital equity programs may be able to benefit from the outreach funded by the NCOP, making those programs more effective. How can you quantify and qualify the ways your existing programs might benefit from this funding?

How can you stand out? This is a competitive process. Putting in an application does not guarantee an award. The FCC requires that a portion of the NCOP allocation be distributed to each state while also prioritizing projects that are regional or national in nature and engaging other community resources or existing programs. That means that any applicant can expect competition from at least one application per state and territory. Expect high demand for limited funds – and strategize how to stand out.

What grant funding amount will enable you to deliver the most impact? The FCC will accept applications for projects as small as $50,000 and as large as $1 million. (Those requesting the maximum should aim to propose programming that is strategically “multi-state, national-level, and/or regional level, with the ability to passthrough to local-based eligible entities, as applicable.”[5]) And unlike many funding opportunities, there is no match requirement for this program. Applicants don’t have to provide cash/skin in the game as part of their proposals. That indicates that the FCC wants to cast a wide net to see what kind of solutions are proposed. It also means they are serious about making between 200 and 400 awards overall. As you develop your plans, think about the impact you might deliver at varying levels of grant funding.

Next steps

As with applications to the ACP program itself, the FCC has done no favors here for grant applicants: This application will take real effort to pull together, and your efforts are not reimbursable if awarded a grant. Given the level of effort required – and the FCC’s encouragement of coordination among states and other eligible entities – state broadband offices should consider taking the lead (or designating alternative state agencies) and engaging with other eligible entities in the state to develop a primary, high-impact application.

CTC’s Grant & Funding Strategies and Broadband Strategies teams 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] The Emergency Broadband Benefit (EBB) became the ACP as part of the American Rescue Plan Act (ARPA) and was then funded further with the Infrastructure Investment and Jobs Act (IIJA).

[2] If exceeding the state-allocated amount, the application must be for a multi-state region.

[3] The District of Columbia and Puerto Rico are included here.

[4] The Your Home, Your Internet Pilot Program aims to reach 5 million households in public housing or receiving federal assistance. The ACP Navigator Pilot Program will help public entities conduct outreach.

[5] See Page 9 of NOFO, Item B, “Recommended Funding Floor and Ceiling.”

Published: Monday, November 28, 2022 by CTC Technology & Energy