Tuesday, May 11, 2021 2:00 PM – 3:00 PM EDT

The National Telecommunications and Information Administration (NTIA) will distribute more than $2 billion in new broadband funding through three new programs created by the 2021 Consolidated Appropriations Act…and that’s just the start of the new funding opportunities coming our way. If your organization or institution will be eligible to apply for one or more of these programs, you shouldn’t wait for the rules to start thinking about the opportunity. While each of the upcoming programs will have different rules and requirements, your strategic approach to preparing an application will be vital.

This webinar will address how you can start preparing the broad outlines of your projects now – so you’re ready to submit a competitive application when the funding window’s open later this summer.

This webinar is a conversation between Heather Mills, CTC’s Vice President, Grant and Funding Strategies, and Heather Gold, CEO of HBG Strategies.

Register for the FREE webinar here.

Scott County, Kentucky, released an RFP to identify private sector entities interested in providing an analysis of the current availability of broadband services in the County and formulating a plan outlining the design, construction, and operation of a broadband services network to unserved and underserved areas in Scott County.

This RFP is meant to allow the County to continue the significant steps already undertaken by a previous RFI process to build an environment that is conducive to investment and broadband expansion, including a strategic effort to identify and analyze unserved and underserved areas and potential solutions. The County hopes to build on this foundation with a partner to fully meet its connectivity needs.

Responses are due July 1st by 2 p.m. local time.

To read the full RFP and attachments, click here.

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

The National Telecommunications and Information Administration (NTIA) will distribute more than $2 billion in new broadband grant funding through three new programs created by the 2021 Consolidated Appropriations Act. (Read more about the programs here.)

If your community or institution will be eligible to apply for one or more of these programs,[1] don’t wait for NTIA to issue rules later this spring. Start preparing the broad outlines of your proposed projects now—so you’re ready to submit a competitive application when the window opens this summer. While the programs will have different rules and requirements, your strategic approach to preparing an application will share these key steps:

Understand and document your community’s broadband needs

While many communities have a range of broadband needs, grant applications require a targeted proposal. So, first things first: Now is the time to identify a specific need you want to address.

Define your project area and evaluate your market. We know the Promote Broadband Expansion Grant Program will favor applicants who can serve the greatest number of households in an eligible service area. The other programs’ applications will include questions about the communities to be served, too.

If you’ve been studying your local broadband gaps, you may already have a handle on those demographics; if not—or if you need more granular detail—now is the time to develop data and a market narrative.

Now is also the time to draw a line around your proposed project area. You can fine-tune as you finalize your application, but for now you want a general sense of the service area—because that will drive your technical design and cost estimates.

As you write your application, you will need to explain the state of the market in the service area. For many grant programs, you must demonstrate that your services will be better and no more expensive than other services offered nearby; and you should be prepared to present a narrative discussion of why the proposed services will be both marketable and affordable.

Watch out for existing federal funding. We know NTIA will be coordinating with the FCC and the USDA to ensure grant funds are not expended unnecessarily in areas that are already receiving funding through those agencies. It will be important to verify that your proposed project routes don’t run afoul of any funded areas.

While NTIA has not yet released information about whether Rural Digital Opportunity Fund (RDOF)-awarded areas will be eligible for funding through the new programs, you should be prepared in case they are not. CTC’s interactive RDOF Auction Results tool is a good starting point for developing an alternative service area if necessary.

Develop a technical analysis and cost estimates for construction, equipment, and operations

Once you have the outlines of a project that will address your community’s broadband needs, start developing your technical and programmatic approaches—and, most importantly, the estimated capital and operating costs for implementing your plan.

As NTIA issues its rules and requirements, and as we develop a better understanding of the relative size of the awards NTIA might make, you will need to fine-tune the design and cost estimate to improve your application’s likelihood of securing funding. But the sooner you start, the better off you’ll be.

Keep in mind that you may need to implement your grant-funded project quickly, so be realistic about your proposed timeline. For example, the Promote Broadband Expansion Grant Program has a one-year expenditure timeline for construction projects (though a one-year extension is possible on a case-by-case basis).

Also, recognize that even if you have to scale back a design for one of these applications, that original application could be the basis for another grant application you develop later.

Develop a business strategy

Regardless of the program to which you apply, or the specifics of your proposal, NTIA will be looking for applicants that demonstrate a strong, business strategy. They want to award funds to financially viable programs—so your application needs to make the case that you are investment-ready and sustainable. In our experience, that means the following:

Build partnerships. For localities that do not have experience operating their own networks, partnerships with established ISPs are a way to demonstrate operational capabilities. (NTIA will be specifically looking for public-private partnerships for the Promote Broadband Expansion Grant Program.)

Public–private collaboration is also a key way for many local, state, and Tribal applicants to achieve their broadband goals while reducing their financial risk. That’s because, in a well-designed partnership, localities and Tribes are able to trade revenue potential for community-focused results. In this type of scenario, the goal is for private partners to expand the availability and affordability of broadband services to residents whom the market has previously overlooked.

Start talking to potential partners now. While the Tribal program doesn’t require a partner, the Promote Broadband Expansion Grants Program does. This is intentional and meant to enable fast deployment of proposed projects. You’ll need proof of an intended relationship.

Develop a sustainable business model. Grant programs are fundamentally designed to deliver limited funds where they will do the most good. For NTIA, that means identifying applications for solid projects that will continue delivering benefits long after the grant award has been spent. Just as you would if you were developing a project to be funded with bonds or as part of a local budget appropriation, now is the time to take your cost estimates and other inputs, and prepare a business model to demonstrate cost-effectiveness and sustainability.

One key element to keep in mind: Financial matches. While NTIA will not be requiring Tribal Broadband Connectivity Program applicants to provide a match, the other two programs may require some match. If past NTIA grant programs are any indication, we anticipate this could be anywhere from 20 to 50 percent. Plan accordingly.

Create a grant checklist and start marking off the basics

We expect NTIA’s grant application windows to be relatively short—so the more you can do to get ready now, the better off you’ll be. Start with the basics. For example, do you have Sam.gov and Grants.gov accounts? You’ll need both to apply to any of NTIA’s programs—and you can imagine how many other entities will be applying for credentials when the application rules are released. Do not wait until the last minute to set up these accounts.

Start gathering the many other types of information and support materials you’ll need for your application, too. In our experience, you’ll need a range of data and numbers to not only establish eligibility for the program you are applying to, but also to provide content for the grant narrative. Start thinking now about supporting materials, ranging from letters from your governor to documents that demonstrate the support of local government, prospective customers, and the business community.

Our recommendation, as with other programs like this, is to go above and beyond; additional letters (such as from your congressional delegation or the Chamber of Commerce) can only help to demonstrate the breadth of support in the community for your project.

The CTC Grant and Funding Strategies team will update this space with more information about these programs as it becomes available. In the meantime, please contact us if you have questions or would like to discuss how CTC can assist you.

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[1] The three programs are the Tribal Broadband Connectivity Program ($1 billion), the Promote Broadband Expansion Grant Program ($300 million), and the Connecting Minority Communities Pilot Program ($285 million). Read more about the programs in this post.

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

President Biden signed the American Rescue Plan Act into law on March 11, 2021. Included in the $1.9 trillion package is significant funding that can be used to support expansion of broadband infrastructure. We’ll provide updates and analysis in this space as we learn more. Based on our initial review of the new law, here are some of the key broadband-related funding provisions:

• Economic Development Administration (Department of Commerce): $3 billion in additional funding to the Public Works and Economic Adjustment Assistance (PWEAA) program through September 2022
• Coronavirus Capital Projects Fund (Department of the Treasury): $10 billion for “capital projects directly enabling work, education, and health monitoring, including remote options, in response to the public health emergency”; in addition to capital projects, eligible efforts include ancillary services (such as broadband mapping) to increase efficiencies of capital projects, and cost support efforts (such as subsidies)
• Emergency Connectivity Fund (FCC): $7.2 billion for E-Rate support to reimburse schools and libraries for provision of eligible equipment and advanced telecommunications and information services during the pandemic, including for locations other than schools and libraries
• Coronavirus State Fiscal Recovery Fund: $219.8 billion for investments in water, sewer, or broadband infrastructure
• Coronavirus Local Fiscal Recovery Fund: $130.2 billion for rural community development block grants (CDBG) ($45.6 billion), rural areas ($19.5 billion), and counties ($65.1 billion, population-based), including for investments in water, sewer, or broadband infrastructure
• Local Assistance and Tribal Consistency Fund: $500 million ($250 million per year for 2022 and 2023) for Tribal use only “for any governmental purpose other than a lobbying activity”

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

CTC is proud to announce the State of Georgia’s publication of our groundbreaking analysis of fixed wireless options for reaching residents and students unserved by broadband. At the direction of the Governor, CTC prepared the study in collaboration with the Georgia Department of Education and Department of Community Affairs, the Georgia Technology Authority, and the Carl Vinson Institute of Government at the University of Georgia.

CTC’s analysis is a key step toward identifying and implementing a comprehensive statewide solution, particularly for K-12 students. Our report documents CTC’s technical analyses of Citizens Broadband Radio Service (CBRS), Educational Broadband Service (EBS), and unlicensed spectrum solutions throughout the state—as well as technical and cost studies in three representative counties selected by the State. It presents clear conclusions about the factors that would affect a potential technical solution’s capital and operating costs.

The full study is available here.

Scott County, Kentucky, released an RFI in late January 2021 to identify private sector entities interested in collaborating with the County to expand broadband to unserved homes and businesses. While parts of Scott County currently are served, residents in many areas cannot access internet service at broadband speeds. A speed test and survey conducted in the County revealed that residents are eager for expanded access.

This RFI is meant to allow the County to undertake significant steps to build an environment that is conducive to investment and broadband expansion, including a strategic effort to identify and analyze unserved and underserved areas and potential solutions. The County hopes to build on this foundation with a partner or partners to fully meet its connectivity needs.

To read the full RFI, click here. To read the Q&A the County issued on February 18, 2021, click here.

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

Cat Blake, Civic Technology Analyst

The Consolidated Appropriations Act that became law in late December 2020 created the largest federal broadband grant opportunity in a decade. Because the funding is intended to alleviate the economic and other challenges created by the pandemic, the funds will be distributed quickly once the rules are released. In some cases, grant applications will be accepted immediately and awards will be made within weeks rather than months.

Even without detailed rules from the agencies that will administer the programs, now is the time to develop strategies to benefit from the relevant funding streams. The links below lead to our preliminary guidance on the new programs. Please don’t hesitate to contact us if you’d like to learn more about how we can help.

• Emergency Broadband Benefit Program: The Federal Communications Commission (FCC) will administer $3.2 billion in broadband service subsidies for eligible households. The FCC has 60 days from the day the Act was signed to stand up the program. We recommend local and state governments begin planning now to help residents maximize this benefit.
• Connecting Minority Communities Pilot Program: The Department of Commerce’s National Telecommunications and Information Administration (NTIA) will administer this $285 million grant program, which will fund broadband services and equipment for minority-serving institutions and their surrounding communities. NTIA has 45 days from the day the Act was signed to develop rules for the program.
• Promote Broadband Expansion Grant Program: NTIA will administer this $300 million grant program for broadband infrastructure, with a focus on public-private partnerships and rural project proposals.
• Tribal Broadband Connectivity Program: NTIA will administer this $1 billion program for tribal broadband infrastructure and expanded access to remote learning, telework, and telehealth resources.
• Secure and Trusted Communications Network Reimbursement Program: The Act allocates $1.9 billion for the removal and replacement (generally known as “rip and replace”) of communications equipment obtained from a company that poses a national security threat to the country.

CTC’s Grant and Funding Strategies Team will continue to analyze these opportunities in the weeks to come. Please contact us if you have questions or would like to discuss how CTC can assist you.

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

Cat Blake, Civic Technology Analyst

Among the many broadband funding streams included in the federal appropriations package that became law in late December, the new Emergency Broadband Benefit Program will have the most immediate impact on the digital divide—and could help families in rural, suburban, and urban communities across the country.

We explain the basics of the new program below; to learn how localities and state governments can play a key role in helping their residents maximize the program’s benefits, see our post here.

CTC’s Grant and Funding Strategies Team will continue to analyze this opportunity in the weeks to come. Please don’t hesitate to contact us if you have questions.

What is the Emergency Broadband Benefit Program?

The program is designed to provide a broadband subsidy for eligible households that will appear as a discount on their monthly bills. Once the program is up and running (we expect to see at least the rules for the new program by the end of February), the FCC will reimburse internet service providers up to $50 per month per eligible household ($75 per month for households on tribal lands). The program will continue until six months following the official end of the Covid-19 public health emergency.

Notably, the program also subsidizes the cost of a laptop, desktop computer, or tablet for each eligible household; ISPs can be reimbursed up to $100 for a connected device, as long as they charge the recipient no more than $50 for it.

Who is eligible to receive the subsidy?

The Emergency Broadband Benefit will subsidize broadband service for low-income families and households that have lost income during the Covid-19 pandemic. As we describe here, though, the FCC’s rules will address two intertwined issues: Who is eligible, and how will those participants be able to prove their eligibility?

First, who is eligible? The law defines eligibility broadly as a household in which at least one member:

• Qualifies for Lifeline (i.e., has income at or below 135 percent of the federal poverty guidelines; receives benefits from Medicaid, the Supplemental Nutrition Assistance Program, Supplemental Security Income, Federal Public Housing Assistance, or a Veterans and Survivors Pension Benefit)
• Participates in the National School Lunch Program or the School Breakfast Program
• “[h]as experienced a substantial loss of income since February 29, 2020, that is documented by layoff or furlough notice, application for unemployment insurance benefits, or similar documentation”
• Received a federal Pell grant during the current award year
• “[m]eets the eligibility criteria for a participating provider’s existing low-income or Covid-19 program”

Verification of a customer’s eligibility to participate in the program is a key point the FCC will need to define during its 60-day comment period.[1] The appropriations bill spells out some clear approaches around the existing Lifeline program verification process, but gives the FCC latitude on accepting other methods.

Participating ISPs will be able to verify household eligibility in one of three ways:

1. Based on the National Verifier or the National Lifeline Accountability Database
2. Based on a school’s verification of a household member’s participation in the National School Lunch Program or the School Breakfast Program
3. Based on the ISP’s “alternative verification process” (which must be deemed sufficient by the FCC “to avoid waste, fraud, and abuse”)

Who can deliver subsidized services?

Eligible telecommunications carriers (ETC) are automatically eligible to participate in the program. ISPs that are not ETCs will need to go through an approval process before they can participate. The approval process for ISPs is another one of the issues the FCC is addressing during its comment period; the law stipulates the approval process be “expedited,” given that the program is intended to quickly help bridge the digital divide.

How will residents sign up for the program?

As with the federal Lifeline service and other established subsidy programs (such as the State of Alabama’s “ABC for Students” program), the enrollment process is expected to be straightforward: An eligible resident of your community should be able to call a participating ISP and provide information that verifies their eligibility—then the ISP should enroll the resident, deliver service, and apply the $50 or $75 monthly subsidy to their account. The ISP will then request reimbursement from the FCC.

The law establishing the program has some built-in consumer protections: The National Verifier is required to approve an eligible household within two days of a request for verification. ISPs cannot require a household to pay an early termination fee if the household enters into a contract in order to receive the service. And households cannot be subject to a waiting period to receive service based on having previously received service from the provider.

How long will the Emergency Broadband Benefit Program last?

The law states the program will run six months beyond the end of the public health emergency, but that is only if the funding is sufficient to cover the ISPs’ charges for all of the participants. We are optimistic the $3.2 billion allocated to the program might provide a year’s worth of funding. That said, we anticipate there will be appetite in Congress to appropriate future funds to keep the program operating—given the enormous need for broadband that has so clearly been illuminated by the Covid crisis. We already have observed lobbying in Washington to make the program permanent, but we have real doubt whether the political will for that exists.

What are the long-term benefits of this program?

The short-term impacts of the Emergency Broadband Benefit Program are clear: Participating households will save $50 to $75 per month on their broadband service. But beyond the important financial implications of the subsidy, this program also might have a positive long-term effect on broadband adoption rates among households that have never had broadband service before (or who have had to give up broadband because it became unaffordable for them). To the extent that cost has been the barrier preventing residents from subscribing to available services, this program might convince non-adopters to try broadband—and, if they find value in the service, potentially to keep the subscription once the subsidy sunsets.

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[1] https://www.fcc.gov/document/fcc-seeks-comment-new-emergency-broadband-benefit-program

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

Cat Blake, Civic Technology Analyst

Localities and states can take action now—before the FCC even issues its rules—to begin to help residents maximize their potential benefits under the new Emergency Broadband Benefit Program. For more details on the program, see our explanation here. Please don’t hesitate to contact us if you have additional questions.

What challenges will emerge from the FCC’s rulemaking?

We do not yet know what guidelines and requirements the FCC will enact for this program—but we believe there are areas of concern in the statute depending on how the FCC structures the program. Most notably, we are concerned there could be a significant burden on families to prove their eligibility and ensure their subsidy is appropriately applied.

A family may, for instance, need to call their provider to ask for service and determine how to apply the subsidy. This is not an insignificant burden for the families this subsidy is intended to help, nor is the potential financial risk to those families a minor point (i.e., they might be responsible for paying $50 or $75 more per month if the subsidy is not accurately applied). That potential uncertainty alone may prevent some eligible residents from adopting service.

A second potential pain point is the burden on small ISPs, which will have to verify families’ eligibility under the FCC rules. For large ISPs this task will be relatively easy; they have access to the federal Lifeline verifier, for example, and many have streamlined processes to verify eligibility for their own low-income programs. But for small ISPs, that could be a potentially insurmountable task.

The federal statute suggests, for example, that an ISP can confirm a customer’s eligibility by calling the local school to verify their participation in the National School Lunch Program. While well-intentioned, this could place a significant burden on small ISPs (not to mention schools). The eligibility verification process could prevent small ISPs from participating in the program—and thus deny their existing or potential customers the opportunity to get the subsidy.

The delay in the availability of the subsidy is a third potential pain point for participants. The law went into effect in late December, and requires that the FCC stand up the program rules within 60 days. They should, at that point, announce the timeline for the initial program launch. While they are well on their way, having issued proposed rules and a request for comments, any delay is an additional burden on many families waiting to enroll. Additionally, it is reasonable to assume the FCC will make the program’s impact retroactive—so, for example, an ISP can bill the FCC for the January and February reimbursement amounts once the program launches in March; however, final rules will bear out the extent of eventual support.

How can local, state, and tribal governments help their residents?

On the surface, the Emergency Broadband Benefit program involves only ISPs, customers, and the FCC: A customer calls the ISP, the ISP verifies their eligibility, and the ISP is reimbursed by the FCC. The reality is that local and state governments can play a key role in helping their residents make the most of this opportunity—rather than assuming the FCC and large ISPs will take on those responsibilities—and in the process, narrow the digital divide in their communities.

Develop consumer education and outreach materials

One lesson learned from programs designed to subsidize broadband service for low-income households is how challenging it is to reach eligible families—and, in many cases, to convince them that the opportunity is real, valuable, and worth their time. The barriers to participation include some of the root causes behind the lack of broadband adoption in general, including language challenges, trust deficits, and fear of hidden costs.

Local and state efforts to develop a public outreach and support strategy could thus be critical to maximizing enrollment in the Emergency Broadband Benefit program. We recommend every local, state, and tribal government think about how to build out a strategy and support residents’ participation in this program. Tactics could include:

• Developing public communications tools and information campaigns
• Conducting outreach to community groups, non-profits, and individual residents
• Staffing a call center of broadband ambassadors that would be trained to help eligible residents understand their options, navigate the process, and engage with ISPs to subscribe

Each of these efforts would be designed to help residents understand and overcome their very prudent and reasonable considerations with regard to hidden fees and other risks of participation. In the event that residents do encounter problems with enrollment or billing, the government role could be the type of consumer protection that it provides in other spheres (such as licensing and monitoring home improvement contractors).

Engage with ISPs—particularly small, local operators—to support their participation

If a local ISP does not elect to participate in the program, their customers will not be able to get the subsidy—because the FCC will reimburse ISPs directly, rather than sending a monthly check to consumers.

In urban and suburban neighborhoods served by large national ISPs, that likely will not be an issue. Indeed, this program will be a windfall for large ISPs that already participate in Lifeline or offer their own low-income or Covid relief programs; those ISPs will automatically be eligible to participate, and will already have the verification processes in place.

But in rural areas and in other communities served by smaller ISPs, residents will only get the Emergency Broadband Benefit subsidy if the ISPs participate. Local and state government efforts to act as a coordinator between ISPs, school districts, and the FCC could help alleviate the burdens and lower barriers to entry for small ISPs that might otherwise decline to participate.

We recommend local, state, and tribal governments develop a strategy for how they can support smaller ISPs and help them not only navigate the FCC’s eligibility requirements for their own participation, but also find the most expeditious possible ways to validate customers’ eligibility, subject to the FCC’s forthcoming rules.

For example, it would be exceptionally burdensome for an ISP to have to call a local school district to verify that a child participates in the National School Lunch Program (not to mention the privacy issues inherent in that scenario). But a state department of education could conceivably stand up a tool (subject to appropriate privacy rules) that would seamlessly and quickly provide that verification for smaller ISPs that do not have the same resources as large phone and cable companies. The tool could be some sort of IT infrastructure (e.g., a website) or a call center staffed by representatives that have access to a suitable database.

Consider offering bridge funding for ISPs and residents

Given the months-long delay in the FCC’s implementation of the Emergency Broadband Benefit program, states and localities could consider implementing a bridge program and entering into contracts with ISPs to provide service to families in February. The contract would protect the public investment by requiring the ISPs to become qualified for the FCC program if they are not already qualified. Then, in March, the companies would be required to shift their invoicing to the FCC to the greatest extent possible—and applying for retroactive payment to reimburse the government entity for its January and February payments, if possible.

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

Cat Blake, Civic Technology Analyst

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

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

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

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

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

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

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

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

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