Friday, June 25, 2021
You’re reading the Benton Institute for Broadband & Society’s Weekly Digest, a recap of the biggest (or most overlooked) broadband stories of the week. The digest is delivered via e-mail each Friday.
This week, guest author Heather D. Mills of CTC Technology & Energy gives us insight into the new Broadband Infrastructure Program that we introduced last month in NTIA Has Millions for Broadband Infrastructure
Round-Up for the Week of June 21-25, 2021
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 (Rural Digital Opportunity Fund areas are not eligible unless you are traversing them with middle mile). The Notice of Funding Opportunity (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 at CTC Technology & Energy 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:
- Your application will be reviewed for completeness.
- 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.
- 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:
- The application score and comments from the expert reviewers during Merit Review.
• This is why your score matters!
- How the NTIA Program Staff felt/analyzed your application during the Programmatic Review
• Your grade on presentation and concept
- If your application satisfied any of the five program priorities defined by the Act
- 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
- 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.
- 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?
- If your project will incorporate “strong labor protections into the performance of the construction project, including paying prevailing wages.”
- If your project avoids potential duplication of other federal initiatives
- 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.
At CTC, Heather Mills guides clients on strategic funding for network planning, as well as applying for and complying with the requirements of major federal broadband and communications grant programs. She has particular expertise in the Federal Communications Commission’s E-Rate program, Lifeline program, and Healthcare Connect Fund. Mills has more than a decade of experience in project management and data analysis. She has exceptional skills in long-term strategic planning for broadband funding; execution of complex tactical funding plans; and grant administration, budgeting, and financial reporting.
Beach Reads (resist tl;dr)
ICYMI from Benton
June 28-July 1—Mobile World Congress 2021 (GMSA)
June 29—Are You #Pelligible for a Broadband Discount? (New America)
June 29—Now What?: Charting the Next Phase in Closing the Digital Divide (Multicultural Media, Telecom and Internet Council)
June 30—Not So Legacy: The Future of Voice (Public Knowledge)
July 1—July 2021 Open Federal Trade Commission Meeting (FTC)
July 13—July 2021 Open Federal Communications Commission Meeting (FCC)
July 14 & 15—Open RAN Solutions Showcase (FCC)
July 18—NARUC Summer Policy Summit (NARUC)
July 20—Broadband is the Electricity of the 21st Century: Let’s Light Up Every Community (Next Century Cities)
July 25—Fiber Connect 2021 (Fiber Broadband Association)