Tag Archives: grant strategy

MAY

17

BEAD and Digital Equity NOFOs put states in charge of broadband funding allocations—but local governments have a role

NTIA’s Notice of Funding Opportunities (NOFO) are out for the State Digital Equity Planning Grant Program and the Broadband, Equity, Access, and Deployment (BEAD) program[1]—and the rules indicate that state governments will decide how to allocate the funding (within certain parameters). Local governments should engage with their state decision-makers during the preliminary planning processes for both programs to offer support on data collection and to advocate for their critical broadband projects.

Below is an overview of our initial takeaways on the two NOFOs in order of the most pressing deadlines. (Don’t worry, we’ve got thoughts on the Middle Mile program as well; we included key points in our timeline below – and watch this space for more on that program soon.)

State Digital Equity Planning Grant Program: Applications due July 12

As directed by the Infrastructure Investment and Jobs Act (IIJA), NTIA will distribute $60 million to states, territories, and tribal groups to fund the creation of Digital Equity Plans. (Tentative allocated funding amounts for each state are listed in the NOFO.[2]) States must submit a planning application by July 12, 2022, to begin the process.

These plans are a critical first step for two reasons.

  1. The Digital Equity Plan is the key to receiving the state’s portion of the $1.44 billion State Digital Equity Capacity Grant Program, which NTIA will open sometime in the future. That funding will enable the state to execute the programs identified in the state’s Digital Equity Plan.
  2. The Digital Equity Plan is expected to complement applications for BEAD grants to fund network deployments. Projects and priorities identified in the state’s Digital Equity Plan will dovetail with BEAD planning.

What does this mean for localities looking to benefit from State Digital Equity Planning Grant funding? Fundamentally, state governments are in charge of developing their Digital Equity Plans.

But local governments will still play a key role in this process—and local priorities should be considered in state-level planning. 

For starters, collaborating with local stakeholders is a statutory requirement. States are expected to include local governments when developing and implementing their Digital Equity Plans and Five-Year BEAD Plans (see below for more on that).

Any local entity that wants a seat at this table should identify who in state government is leading the charge on these efforts. (NTIA provides information about appropriate contacts in each state.) And localities should keep a close eye on which agency the governor selects as the Administering Entity for the Digital Equity Plan. Reaching out to these decision-makers to open dialogues and build relationships will be critical to local government efforts to get their projects funded.

BEAD: Letter of intent due July 18

NTIA’s IIJA BEAD program will provide federal funding directly to the states to support broadband deployment, mapping, and adoption projects. The states must complete a multi-step process by which they plan and then propose how to allocate the funds to eligible sub-recipients (all of which must be approved by NTIA for funding to flow). As with the State Digital Equity Planning Grant Program, states are required to engage with local stakeholders on BEAD planning. These activities will provide localities and other stakeholders with opportunities to express their local needs and shape the state’s process—including through the development of highly accurate broadband availability data.

States must submit a letter of intent for BEAD funding by July 18, 2022, and an application for $5 million in initial planning funds by August 15, 2022. Planning efforts can include research, data collection, surveys, and broadband mapping efforts related to broadband availability, adoption, affordability, and equity issues across the state. After that, however, the process will slow down considerably while NTIA waits for the FCC to release updated broadband availability maps. So local governments should engage with their state decision-makers now (the letter of intent will indicate who the governor selects as the administering agent for the program)—and be prepared to continue engaging over the planning process.

Be sure to take a look at the NTIA’s program info sheet for a quick overview of the basics. In short, the overall BEAD process looks something like this:

  • Letter of Intent – Due July 18, 2022 
  • Request for Initial Planning Funds – Due August 15, 2022 
  • Initial Planning Funds released after approval of Request for Initial Planning Funds (no timeline commitment in NOFO) 
  • Five-Year Action Plan – Due 270 days after receipt of Initial Planning Funds 
  • Program Fund Allocation and Notice of Available Amounts released
  • Initial Proposal – Due 180 days from release of Notice of Available Amounts 
  • 20 Percent Funding Release – Upon approval of Initial Proposal
  • Challenge Process – Required before subgrantee selection 
  • Subgrantee Selection Process
  • Final Proposal and Release of Remaining Funds 

Here are some key takeaways localities and other stakeholders should keep in mind as they engage with their state regarding the BEAD funding:

• Local coordination with stakeholders is required: Throughout the planning process, states are obligated to collaborate with local, regional, and Tribal organizations, including representatives of underrepresented communities, civil rights organizations, community anchor institutions, and unions and worker organizations. This required outreach will provide stakeholders with opportunities to submit feedback and data regarding existing broadband assets, broadband deployment and adoption needs, barriers to deployment, existing broadband adoption and digital equity programs and related gaps, and existing and planned economic development and other community planning efforts. NTIA expects that this local engagement and outreach process will inform each element of the state’s required submissions for the BEAD funding.

Interested localities and organizations should reach out to their state’s broadband office to discuss both their communities’ needs and existing broadband strategies and efforts. This extensive local coordination obligation requires that the states document their efforts transparently and maintain an ongoing dialogue, which will produce a public record of localities’ involvement and efforts to improve local broadband opportunities. This effort can be complemented by the similar engagement requirements of State Digital Equity Planning Grant Program, which will also be happening over the next year.

• The state designs the grant program for distribution of its BEAD funds: The BEAD program sets out a framework for a subgrantee program to be administered by each state, but the state will decide the details. As such, it’s important that local governments and other potential applicants understand how to strategize around the framework (and pay close attention to final rules from each state).

For example, areas that do not have access to broadband services that offer at least 100/20 Mbps are eligible for funding. Generally, areas that have received federal or state funds to begin broadband deployment projects to meet that 100/20 Mbps threshold may not be eligible for funding. However, BEAD rules specify that areas slated to receive funds under the Rural Digital Opportunities Fund (RDOF) may still be eligible for funding under BEAD if the RDOF grant is not yet ready-to-be-authorized or authorized by the date of the challenge process or if RDOF funding was awarded for satellite technology to deliver service.

In another example, BEAD funding requires a 25 percent match (see below for more on the required match) of a specific project cost by the state or project applicant. But states are encouraged by the BEAD framework to design their grants programs to provide additional points in their application scoring criteria to encourage applicants to provide more than the minimum 25 percent match.

• Affordability proposals could be a significant opportunity for input from local entities, community organizations, and digital equity groups: States must also design a grant program that requires recipients to allow qualifying families to participate in the Affordable Connectivity Program (ACP) and provide a low-cost service option as part of the funded project. However, BEAD rules also allow states to design low-cost plans that will meet the state’s needs—with the input of local entities. Those plans will then be submitted to NTIA for approval.

• A financial match is required: Applicants seeking BEAD funding from their state must provide at least a 25 percent funding match. This can be cash or in-kind (where the value of services or goods is substituted for cash), but applicants should keep in mind that states are “required to incentivize matches of greater than 25 percent from subgrantees wherever feasible” (NOFO, p. 21). The most likely means of meeting this requirement is for a state, in designing their grant program, to include extra points or weight to applicants that offer to provide more than 25 percent in match.

Further, the IIJA provides some guardrails regarding use of certain federal funding as the match. While generally federal funds related to the Covid pandemic (for example, ARPA funds) with the purpose of expanding broadband can be used as match, the terms and requirements of those funds will apply in addition to requirements set forth by the BEAD program. For In-kind matches, seek out guidance if you have questions. NTIA suggests to states that they should ”thoroughly consider potential sources of in-kind contributions” (NOFO, p. 22). That means, consistent with federal cost principles, applicants for subgrants from the state could include waivers of pole attachment fees, access to conduit, or the value of an easement as part of the required match.

• The NTIA provided for an additional challenge opportunity: The BEAD program requires that states establish an opportunity for local governments, nonprofits, and ISPs to challenge a determination made by the state as to whether a particular location should be eligible for BEAD funds under the state’s newly designed program. With this BEAD challenge process, states are directed to incorporate additional eligibility criteria that fall outside the FCC’s broadband availability data, such as reliability, affordability, proportion of served units, and technology types. Only after this challenge process is complete can a state finalize the areas that will be eligible for funding.

This challenge process is separate from the FCC DATA Act map challenge process, which focuses on mapping data of served and unserved addresses. For example, an apartment building with reliable service only to some of the units may be classified as “served” under the FCC’s map. During a BEAD challenge process, a local government could provide data showing that several units are “unserved” and should be eligible for funding. Our team is closely monitoring the development of the frameworks for both the FCC’s and NTIA’s challenge processes. Watch this space for a full analysis of how local entities can participate in both processes to support broadband deployment to meet community needs.

• Start planning now: Interested local entities and other stakeholders should not wait to start gathering data, talking to their communities, and strategizing about broadband needs and deployment plans. From almost the first stage of the BEAD program, states are required to seek out broadband availability, adoption, and digital needs information from local jurisdictions and regional and community-based organizations.

Your efforts, and the work within your communities, should help to shape how this once-in-a-lifeline funding opportunity is utilized. To be well-prepared to be an active and substantive participant in this unprecedented level of coordination across federal, state, local, and organizational perspectives, it is now time to develop the latest data and understanding of what is happening in your community.

Keep up to date with our insights at ctcnet.us/blog and feel free to contact info@ctcnet.us with any questions.

[1] “Internet for All: Programs,” https://www.internetforall.gov/programs.

[2] See Page 13 of NOFO for State Digital Equity Planning Grants, Section II.C.2.

Published: Tuesday, May 17, 2022 by CTC Technology & Energy

NOV

03

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

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

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

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

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

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

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

Base scores are calculated automatically, thanks to “AI”

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

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

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

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

So what goes into the ‘AI’ score?

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

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

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

How is the rest of your score determined?

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

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

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

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

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

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

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