Dept of Commerce  USDA and NTIA by malj

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									                             Broadband Workshop – 14 July 2009


                            Dept of Commerce – USDA and NTIA
                      Notes to the Broadband Workshop – 14 July 2009

Representative Beverly Helton

Introduced values associated with broadband - need access to broadband for jobs and economic
growth to bring economic development to rural communities. Broadband is a necessity, not a
luxury, and is the new utility as essential as electricity and water. Broadband increases
competiveness. Notes projects providing broadband access over fiber and electric power lines to
assist telemedicine, expand and improve mental health services and offer distance learning grants
to connect schools. Implementation must be as a collaborative to prevent duplication of funding.
She gave a personal story about her rural hometown and changes as a direct result of USDA
funding. Notes that the USDA grants help create opportunities for rural communities where there
is no business case for loans. Notes support for first responder services and distance education.
The USDA works with individuals and organizations to create partnerships at state and local
level in order to provide rural communities the same opportunities as urban communities.
However, the speed of the Internet is still slow and needs upgrading to bring broadband services
to multiple communities.

Rep Patricia Todd – Alabama Rep

Key to writing a BTOP proposal is collaboration – bring people together. There is positive value
in building coalitions and bringing in partners. Broadband is a means of combating poverty.
Need to bring resources to schools – they have access to broadband at school but not at home.
All kids are important and need access to the same technology.

Mark Seifert - NTIA

Important to partner with small rural and poor communities - make sure anchor tenants are
participating with you in your proposal. Help all eligible entities participate in broadband
programs – BIP and BTOP. The program is moving very quickly – clarifications will be posted
on the web on an ongoing basis. See: www.broadbandusa.gov
Notes the transformative power of broadband – can improve health care, education, energy and
government services. Every American can benefit –can lay foundation for long time prosperity.
Pay attention to the five purposes of ARRA. The major takeaway is FUTURE GROWTH!
Note the breakout of funds – pay attention to criteria for funding. BIP/BTOP is a coordinated
federal government approach to increase broadband access in rural America. Focus on how to
turn the ARRA bill into a “living and breathing” program. Project proposals should spur job
creation and ensure long term growth – this is the basic outcome expected.
Notes the single NOFA combined USDA and NTIA. There is a common, streamlined application
and common criteria for both BIP and BTOP. Hopes the unified program will ensure that federal
funds will be used efficiently.
Three rounds of grants – first deadline is August 14. Next window will be in December 2009 and
the third in April 2010.


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                              Broadband Workshop – 14 July 2009

Pay attention to the definitions section – last mile, middle mile, rural area, underserved area,
unserved. The broadband definition was set at the low end for economic reasons to allow
spreading a little broadband among a lot of people. Consider it as a floor. NTIA prefers faster
speeds. Proposals should indicate how broadband speeds will increase over time.
Note the nondiscrimination and interconnection requirements. An open Internet connection is a
basic requirement. Applicants must disclose their interconnection and nondiscrimination and
network management practices with application. This requirement applies to infrastructure
projects, but not public computing or adoption programs.
Congress mandated that BIP funds not fund BTOP projects at the same time, but all projects will
be reviewed for BIP and BTOP. Projects with 75% rural will automatically be reviewed by for
BIP first, but must also apply to BTOP separately. Projects with less than 75% rural will be
rejected by BIP and sent to BTOP. NTIA (BIP) may make awards that are meritorious if USDA
(BTOP) rejects an application initially.
Funding is at least $250 million for broadband adoption. Sustainable broadband adoption should
focus on education, training, access and support where broadband is underutilized.
Plan for multipurpose applications – apply for other programs. Meet more than one objective of
ARRA. Complete all relevant objectives. Addressing more objectives will gain points in the
proposal.

David Villano – USDA Rural Development

Internet service vital – basis of growth of rural communities. The USDA loan program problem –
cannot make business case for rural communities so can now make loans, grants and loan-grant
combinations. Now, USDA and NTIA are working together through one common program, one
application, one web portal to submit proposals. The NOFA published in Federal Register on
July 9 = binding document. Making awards on November 7.
Definition of remote rural area may change. Will clarify definition in Federal Register in the next
week or so. Will be posted on website and will clarify changes to definition.
Pointers to successful application: Deadline in August 14. Late application on August 15 will be
rejected. No extra points for filing early. Fifty pieces of information in NOFA. If only 49 pieces
it will be rejected. See grant guidance guide for BIP and BTOP. What pointers or red flags to
watch out for:
      Missing documents
      Document / Executive Summary does not make sense. Proposal must make sense.
      Make as many partnerships as possible.
      All points outlined in NOFA – use self-scoring sheet to evaluate your own opportunity to
       success. Must be competitive. Make scoring sheet with BTOP to enhance score.
      Financial statements must match build out schedule – evaluators will be looking for
       mismatches.
      Two step application process –too late to change application in step two. Make sure what
       is in step one is validated in step two.



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                               Broadband Workshop – 14 July 2009

Infrastructure 1 Breakout

Eligibility: See key topics regarding eligibility for BIP versus BTOP. Need to know rural nature
of program – RUS/BIP is for rural areas only, NTIA/BTOP includes rural and non-rural under
definitions. NTIA will consider both BIP and BTOP applications. If not rural – consider
submitting to NTIA only. Rules will not allow duplication of service.
Eligibility Factors
   a. Note requirements from ARRA – six eligibility factors for BIP/BTOP plus four
      additional for both BIP and BTOP. Must meet or be rejected.
   b. Fully completed application – COMPLETE all sections. All information must be
      substantiated – not incomplete but will score poorly.
   c. Must complete project in 2-3 years.
   d. Applicants must offer broadband service at speeds proposed.
   e. Projects must be technically feasible. Note engineering statement of feasibility.
   f. Non-discrimination and network interconnection obligations. Must show how policies
      will be followed. See FCC principles. Note competition among network providers!
   g. Must favor any lawful application or content.
   h. Display network management policies in a website
   i. Must connect to the public Internet.
   j. Must meet the needs of law enforcement
BIP Eligibility
   a. 75% of service area = rural area with access to broadband – unserved or underserved
   b. Only one grant/loan to serve one area.
   c. All project costs must be funded
   d. Must be financially feasible.
BTOP eligibility
   a. Advance at least one BTOP statutory purpose
   b. Matching 20% requirement (Cash is best, greater percentage match is better)
   c. “But for” requirement (“but for” federal funding, project would not be built)
   d. Financial feasibility
Check definitions of rural – Make sure RACECs match this definition. (Line 455 ff in NOFA):
 Rural area means any area, as confirmed by the latest decennial census of the Bureau of the Census,
 which is not located within:
    1. a city, town, or incorporated area that has a population of greater than 20,000 inhabitants; or
    2. an urbanized area contiguous and adjacent to a city or town that has a population of greater than
    50,000 inhabitants. For purposes of the definition of rural area, an urbanized area means a densely
    populated territory as defined in the latest decennial census of the U.S. Census Bureau.


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                               Broadband Workshop – 14 July 2009

Check definitions for unserved versus underserved: At least one factor must be met for
eligibility. Note 3 Mb speed criterion. Or – 40% or less subscribe – underserved is defined as a
proxy for economically poor areas. (Line 473 ff in NOFA)”
 Underserved area means a proposed funded service area, composed of one or more contiguous census
 blocks meeting certain criteria that measure the availability of broadband service and the level of
 advertised broadband speeds… Specifically, a proposed funded service area may qualify as
 underserved for Last Mile projects if at least one of the following factors is met, though the
 presumption will be that more than one factor is present:
     1. no more than 50 percent of the households in the proposed funded service area have access to
     facilities-based, terrestrial broadband service at greater than the minimum broadband transmission
     speed (set forth in the definition of broadband above);
     2. no fixed or mobile broadband service provider advertises broadband transmission speeds of at
     least three megabits per second (“mbps”) downstream in the proposed funded service area; or
     3. the rate of broadband subscribership for the proposed funded service area is 40 percent of
     households or less.
 A proposed funded service area may qualify as underserved for Middle Mile projects if
     one interconnection point terminates in a proposed funded service area that qualifies as unserved
     or underserved for Last Mile projects.
 Unserved area means a proposed funded service area,
     composed of one or more contiguous census blocks, where
       at least 90 percent of households in the proposed funded service area lack access to facilities-
       based,
       terrestrial broadband service, either fixed or mobile,
       at the minimum broadband transmission speed.
 A household has access to broadband service if the household can readily subscribe to that service upon
 request.
Check the definitions of broadband speed, last mile and middle mile. View minimum
broadband speed as a floor – the proposal should project higher speeds in future development.
More points are given to higher speeds and the ability to upgrade. (Line 2275 ff in NOFA):
 RUS and NTIA conclude that “broadband service” should be defined as the provision of two-way data
 transmission with advertised speeds of
     at least 768 kilobits per second (kbps) downstream
     and 200 kbps upstream to end users,
     or providing sufficient capacity in a Middle Mile project to support the provision of broadband
 service to end users.
Last Mile projects include any infrastructure project the predominant purpose of which is to
provide broadband service to end users or end-user devices (including households, businesses,
community anchor institutions, public safety entities, and critical community facilities) via
network, wireline or wireless services.
   Last mile factors – identify census blocks and must commit to provide access to all census
   blocks. Will be posted on Web with served or underserved. If not enough documentation or if
   wrong, classification can be changed.




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                               Broadband Workshop – 14 July 2009

Middle Mile projects may include interoffice transport, backhaul, Internet connectivity, or
special access, but do not connect consumers directly, do not provide broadband service to end
users or to end-user devices or connect to anchor tenants.
  Anecdotal comment: I was advised by a staff member at NTIA that Middle Mile
  proposals are preferred in this round of proposals.
Statutory purposes:
More points will be given to proposals that include more than one ARRA funding mechanism.
At a minimum proposals, must provide access to underserved or underserved populations.
Budget
Funding Match – Greater success if can match 20% - cash or in kind. (Cash is better.) If cannot
make match – must demonstrate financial need for waiver. Must identify assets, liabilities and
other information for financial need.
“But for” argument - Must persuade NTIA that the project could not proceed without federal
funding. Must make argument that the project needs the federal grant to go forward.
Documentation could include denial of funding from either public of private sources.
Budget reasonableness – Proposal must show that the budget is appropriate and that it can
complete project.
Eligible costs – Must know what can be paid for and what cannot. Any application using funds
for ineligible costs will be rejected. Costs must be reasonable for the goods and services
required, necessary to carry out project, allocated correctly and appropriate for the project. Pre-
application expenses can be reimbursed for an engineering design, if incurred after July 1.
Inclusion of Ineligible costs will result in rejection of the proposal. For example, operating
expenses or costs incurred prior to the application, funds to purchase assets of an affiliate, allow
fund a merger of entities or acquire spectrum. Applicants must provide detailed information on
all costs incurred.
Application – Process is in two steps – first to NTIA, then to state then back to NTIA. The
proposal business plan will be scored by NTIA reviewers – if accepted, applicants will be asked
to submit additional information to NTIA before sending proposal on to states. Proposals should
include:
   a. Background information and eligibility check.
   b. Executive summary present a high level overview, but be clear and to the point.
   c. A broadband map of the funded service areas.
   d. A description of the service offerings and pricing being proposed.
   e. A proposed technical solution with professional engineering approval included.
   f. Partnerships are highly valued for the application. Describe all of the partnerships.
   g. An itemized budget and financial analysis are required. Need to identify support for non-
      recurring costs.
Complete an entire application of BIP and BTOP for dual consideration - may need to complete
two separate budgets for a loan and/or grant. Proposals will be reviewed by USDA under BIP at


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                              Broadband Workshop – 14 July 2009

the same time as being reviewed by NTIA under BTOP. If proposing last mile and middle mile
projects, must complete separate applications and address the predominant purpose for each.
Points will be given for projects that take a comprehensive approach.
Applicants who are selected for second round will be asked for more information. More details
about technology, budget, construction build out schedule, environmental questionnaire and
complete documentation to substantiate proposal.
For BIP – must provide measurable service metrics and ongoing service quality.

Questions:

Apply to both BIP and BTOP?
   a. Apply to both to maximize success. Must address questions on each program.
Marketing costs ineligible? Operating costs ineligible? Qualify for match?
   a. Yes and No. Must be eligible cost to match 20%
Can match BTOP with RUS loan?
   a. Cannot use other federal money as a match in another program. Existing RUS loan –
      must not use for match.
Wireless service provider – What criteria to prove that 40% do not have access to 3Mb service?
   a. 40% threshold – applicant must come up with that documentation.
   b. Telephone survey?
   c. Must prove the population.
Use of census blocks to justify access – not a geography used by telco. In order to do that must
make assumptions. In absence of state mapping program – what level of scrutiny to validate
assumptions?
   a. Valid reason not to go into census block – how to split households in census block?
Looking at broadband penetration – telcos know their penetration but not other telcos. Telco
boundaries do not match up with census blocks. May have remote end office covering multiple
census blocks with varying percentages of each census block. Must make assumptions. Willing
to accept approximation?
   a. Yes – will look at assumptions. Will look at assumption that the unserved people will be
      served. Assumptions must match proposal.
BTOP joint projects – middle and last mile. How to deal with different companies providing
different services? Joint program.
   a. If middle mile project to serve multiple last mile service areas – must file separate
      application and reference last mile application. If stand alone business plan, then file
      separately.
With BIP and BTOP must submit two separate budgets. How to deal with this?
   a. Separate budgets for BIP and BTOP.


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                              Broadband Workshop – 14 July 2009

If budget changes between BIP and BTOP to reduce scope of BTOP – must be demonstrated in
BTOP application.
   a. Should cascade through whole application. Make application consistent.
Multi-purpose project – separate budgets?
   a. Yes. BTOP allocated separately, so need separate budgets, but can reference both
      projects. Stronger proposal for bringing projects together.
What predominates? Cost?
   a. Looking at where is the benefit – who gets services for the investment.
How to document 75% population?
   a. Will look at census information. Will break down to smaller metric. Will have to look at
      where they fall into unserved or underserved.
Denial of funding – from institutions?
   a. Would need better business case – cost of serving market. Goal is to serve business cases
      in areas where one does not now exist. The more detail, backup and documentation you
      can provide will help your proposal.




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                               Broadband Workshop – 14 July 2009


Infrastructure Session 2

What happens after submitting application? Scoring will be used to identify the Best of the Best
projects – looking for excellence across all categories. The BTOP scoring process will score on
four categories:
      Purpose
      Benefits,
      Viability
      Sustainability - need a clear business plan showing how applicant will leverage funding.
Each application will be scored against objective criteria not against others.
Proposals are evaluated based on advancing the five BTOP purposes and must maximize how
projects will include them. The five objectives are (Line 227 ff in NOFA):
   a. To provide access to broadband service to consumers residing in unserved areas of the country;
   b. To provide improved access to broadband service to consumers residing in underserved areas of
      the country;
   c. To provide broadband access, education, awareness, training, equipment, and support to
      community anchor institutions (e.g., schools, libraries, medical facilities), or organizations and
      agencies serving vulnerable populations (e.g., low-income, unemployed, aged), or job-creating
      strategic facilities located in state- or federally-designated economic development areas;
   d. To improve access to, and use of, broadband service by public safety agencies; and
   e. To stimulate the demand for broadband, economic growth, and job creation.
Applicants must demonstrate that the project addresses a compelling problem – put this into a
narrative. Make a compelling argument for the need for broadband and how your solution
squarely addresses the problem. Applicants gain more points for addressing more than one
statutory purpose. A holistic approach will have better sustainability and will score better.

Guidelines for the Application

Project Purpose
The Project Purpose is where applications are differentiated. Much as a capital investor would
look at a business plan before committing to invest. Very important to show that all of the
applicant’s initiatives are in line with multiple purposes. Applicant’s Project Purpose will be
evaluated with the following metrics:
      How well it leverages other ARRA programs and aligns with other investments.
      How well you prove your collaboration for better efficiencies.
      Identifying meaningful strategic planning around collaboration,.
      Whether it includes additional support for enhancing health care, education and children.
Real data are required in the narrative. Applicants must specify how they plan to target markets.
Applicants gain additional points for working with socially and economically disadvantaged
small businesses.
Project Benefits


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                               Broadband Workshop – 14 July 2009

Last mile – Looking at cost effectiveness, performance and affordability. Cost effectiveness =
total cost per households passed. Prove with data and demonstrate why solution is the best. Last
mile must exceed minimum requirements for nondiscrimination and interconnection. Applicants
can demonstrate this through
      public notice,
      wholesale access to project,
      commitment to binding arbitration,
      allowing more than one service provider to deliver services.
Performance – Speed, latency and scalability - Speed is important. Bandwidth can be upgraded
– show path to better speed.
Affordability – To the extent that pricing is reasonable based on demographics based on market
profile. Show marketing strategy for affordable service.
Project Benefits – Evaluation will consider the number of end users reached by the project as a
measure of its impact.- especially note the number of people affected in unserved areas.
Narrative must include:
      Level of need for broadband services
      Network capacity – must be scalable for the future
      Affordability must be demonstrated for users in area
      Nondiscrimination and interconnection must be demonstrated and benefits
Project Viability - Applicants should note that the technical applicability of the proposal must
be demonstrated or the application will be rejected. The narrative must demonstrate
      Organizational capability
      Community involvement
      Timeline
      Key contractors
The evaluation team will look at the applicant organization’s management team, any projects it
has done in the past and how prior projects have been successful. The proposal must show how
the organization will accommodate project construction and operation. It must also show
partnering with small business and collaboration with stakeholders. Demonstrate that key
contractors are lined up once project is funded
The applicant should also consider how soon it plans to purchase equipment and get network
ready to go if funded. Are license approvals complete? Is spectrum allocated before the project
starts? Are all of the licenses in place required to operate a project for wireless access? Include a
comprehensive list of licenses and legal agreements needed for the project.
Budget and Sustainability
Reasonableness of Budget – Want details and clarity. Enough detail to show proposal will not
exceed the cost of the estimate, and is not misusing resources or making inefficient use of
resources. Budget reasonableness is an eligibility criterion. Must show costs are reasonable,
but comprehensive.




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                                 Broadband Workshop – 14 July 2009

All projections must be credible. Applicants should provide detailed financial and market
projections. All of these will be used in the evaluation. Important to show debt mitigated for
undertaking debt. Also, it is important to demonstrate a positive cash flow at the end of five
years in the project. If the project will not be sustainable, can the applicant ensure a 3rd party
funding commitment ongoing?
Matching funds Applicants should bring their match to the table to gain more points. Cash is
better than in-kind contributions. Avoid a waiver if possible.

BTOP Selection Process

      Screened by reviewers
      Scored by reviewers – scores averaged and moved to step 2, reviewed by representatives of the
       Governor’s Office.
      Applicants in step 2 will submit more information and will be reviewed for consistency with
       original application. (Plan ahead when writing application – plan for second round.)
      If applicants try to change the application, it will be rejected.
      NTIA may contact the applicant regarding differences between the proposal and NTIA’s
       willingness to fund. NTIA might offer different funding if some population is ineligible.
      After the due diligence of completing step 2, NTIA will submit a package of grants to the
       Assistant Secretary of NTIA for funding.
      ARRA mandates NTIA provide funding to all 50 states. Avoiding redundancy. Looking at the
       availability of funds. Will also consider the recommendations of states. Will make award based
       on the best use of funds.

BIP Requirements

      BIP takes a different approach to scoring. Note equal weight given to each category. Note
       breakdown. Evaluate proposal on a line item basis.
      Note items tied back to statute.
      Unserved areas – For every 10,000 households served, get one point. At 50,000, maxed out.
      75% rural areas – must demonstrate percentage. Can get more points if more rural. Application is
       geared toward rural areas.
      Remote area targeting – Will look at service area most distant from urbanized area. How far away
       from non-rural areas?
      Project purpose – Title II borrower? = Infrastructure borrower. If borrower under Title II, then an
       additional five points.
      Partnering with other ARRA projects?
      Reward applicants that go beyond the minimum speed. E.g., if providing 20 Mb through cable,
       can get extra points. If wireless, then at least 2 Mb.
      Affordability – Must justify pricing by area. If no competition, then a reason why no providers.
       Explain.



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                                Broadband Workshop – 14 July 2009

      Choice of service providers - Can be one of the service providers, but must allow others to
       provide service.
      Critical community facilities – Offer discount plan to public facilities – will get points.
      Organizational capability – A lot of weight on management of the project. This is highly
       important. Teamwork and credibility essential.
      Essential to start the project – must be shovel-ready. Line up contractors, licenses, collaborators.
      Community involvement – Must be involved in the community.
      Reasonableness of the budget - Will look at costs and determine if they are reasonable.
      Collaboration – Want to see coalitions form.
      Loan versus grant? Would prefer loan over grant because can get more bang from the buck with a
       loan.
Questions
Indian tribe – Dealt with differently? No relationship with state. Will state prioritize application?
Relationship is with federal government.
   a   Will get back to him.
Appeal for volunteers to review grants – Need competent people with no conflict of interest.
How to determine competence? What if there are no volunteers?
   a   Established process for conflict of interest, but can determine competence.
What is standard of expertise to evaluate reviewers?
   a   Will look at background of reviewers.
How to compete with big business for smaller firms to partner?
   a. Additional consideration for small businesses. Onus of applicant to demonstrate small
      business.
Asks for list of resources for consideration.
   a. Cannot put list up on the web – can’t favor one over another. Up to applicant to make that
      determination.
Projecting construction – must be bid out competitively? Or can identify contractor?
   a. Will lessen requirements from competitive bidding. Can use individual forms, not RUS
      forms. Will loosen things up. Will get competitive requirements out.
Can obtain potential pricing from contractor to get a reasonable budget?
   a. Provide details on how numbers were developed – as clearly as possible. Differences are
      understandable.
If two companies are building infrastructure together – how to do one application? Power
company has cable, telephone company has services.
   a. First company will own all services funded. Applicant will own under BIP.
In BTOP with small firm – Will get extra points?


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                              Broadband Workshop – 14 July 2009

   a. Yes. But under BIP only if small firm is the applicant will it get points.
If both BIP and BTOP – how to work both in? Build infrastructure, then sustainability? For
example in education they can build a network but the end users may not know how to get the
most of it.
   a. Will look at components. Look at applicability of project.
How to deal with overlapping projects in BTOP. Can one county be included in more than one
project? Can it compete in two projects?
   a. Will only fund one project for that county. If approved must choose one – otherwise will
      throw off application.
   b. County can apply for both but will not receive award under both applications.
   c. BIP – Will score both projects. One coming out best will be awarded funding.
Feasibility question.
   a. Would like to publish formal answer. Want projects where technology is scalable and
      upgradeable. As far as usage – if technology is launched in a particular community, will
      look at how it can be applied to other communities. Will put answer on the website.
Non-profit corporation in Mississippi – Community computing center. Wants to partner with a
group to achieve their goal. Will gain points of partnering? Looking for partners in Southeast.
Are all of the applications involving rural areas put through BIP?
   a. Yes.
If people give permission and list all people attending this seminar – can make that list available?
   a. Didn’t set things up for that.
Scoring – Can save jobs rather than creating jobs?
   a. BIP - Will not come into play. Not part of BIP program. May be considered in other
      rounds. F
   b. BTOP – Jobs are one part of the goals of the program. No distinction between creating
      and saving jobs.




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                              Broadband Workshop – 14 July 2009


BTOP Discussion

Final considerations when completing proposals.Think broadly about how to provide benefits in
the communities addressed.
      Stress put on health care and children.
      Public safety – 911 and first responders.
      At risk populations – people with disabilities, e.g., the elderly. How can broadband
       benefit them? Have strategy for reaching out to these groups.
NTIA Looking for proposals that create relationships with small and economically
disadvantaged businesses. Meet requirements in the statute - will look at this in evaluation.
NTIA will make one award in each state wherever possible, though not all in first round and not
in all categories. There are no limits in the amount of the application. (But Mark Seifert notes
that it will be hard to justify a $500 million project.) Be careful what you ask for. Must follow
the same rules for a $500 K grant as for a $5 million grant.
States have an important advisory role in evaluating projects. At end of the process NTIA will
send a list of proposals to the chief executive of each state and let states comment on the
proposals.
Eligibility and selection factors outlined in the NOFA. NTIA expects a pool of really good
applications and portfolio of projects.
Reporting requirements for projects:
      Progress in achieving goals, objectives and milestones
      Expenditure of grant funds and award remaining
      Amount of non-federal investment
      Progress toward timely completion
      Number and types of entities receiving new or improved access
      See specific reporting requirements.
Infrastructure reporting:
      Interconnection agreements
      Traffic exchange metrics
      Also note reporting requirements for middle mile versus last mile reporting.

Questions

See: BTOP@NTIA.DOC.GOV for questions
BTOP versus BIP – Apply to BIP first? Asking for waiver for 20%.
   a. Apply to BIP first – will be reviewed for BIP and BTOP simultaneously
NOFA does not say you specifically apply to BIP. If 75% rural – must apply to BIP. But apply to
BTOP and by default will apply to BIP.
No. Must do budget process for BIP and for BTOP.


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                              Broadband Workshop – 14 July 2009

   a. BIT and BTOP have different requirements – must answer both. “Automatically
      required” to apply for BIP if 75% rural.
Can 20% match be operating expense or construction?
   a. Matches must be for eligible expenses. Operating expenses are not eligible.
Where do I show operating costs until revenue from subscribers?
   a. Business plan.
Under the Community Connect program – allow $250,000 to be put into grant to cover salaries
of people in computing center. But public computing center cannot include operating costs?
   a. No. Under computing center and sustainable adoption, operating costs and salaries can be
      included.
Question about operating costs being excluded. Guy is exasperated.
   a. See NOFA – Eligible costs are listed. Match will not include ineligible costs.
BTOP – Only grants? Or loans and grants?
   a. Grants only
If not accepted for Round 1, can apply to Round 2 or 3?
   a. Yes, but won’t be immediately accepted.
Confusion about BIP and BTOP. What if applicant wants a 50% loan/grant package from BIP,
but is sent to BTOP. But do not have money for 80/20 match for project. What if BIP is not
accepted and must adjust to 20% match?
   a. If funded first by BIP, then assumed you will take the money.
Must have the 20% match prior to BTOP grant?
   a. No. Do not need 20% ahead of grant.
Man has dark fiber and can extend it, but need funds to do so. Question about valuing that asset
at fair market value as 20% match.
   a. Technical question – must talk to accountants to find answer. Will send question to the
      website.
Under what component of evaluation are points given for number of jobs created or sustained?
   a. Project purpose – see statutory requirements.
Jobs can be short term construction versus long term jobs?
   a. See new OMB circular on jobs from June 22. Gives formula for calculating jobs. See
      circulars on accounting requirements. General rules that apply across government and for
      ARRA.
When sending state applications for review – will scores and evaluations be sent too?
   a. Don’t know. Not there yet.
Proposal to justify 34 jobs per million? Do not care about type of job (operations) – just about
the job?


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                              Broadband Workshop – 14 July 2009

   a. See OMB Circular.
Will BIP and BTOP review simultaneously? What if both accept? How to integrate?
   a. BIP will review before BTOP.
If subbing out technical support does that qualify for job creation?
   a. Yes, it should.
If proposal is in both BIP and BTOP – what if BTOP team doing more things than the BIP team,
how to deal with that?
   a. Review By BIP and BTOP independently. Must discuss linkages in project narrative.
Majority of states do not have a map yet. Is FCC 477 data available to states or applicants who
would like that data? Should be ready in March.
   a. Write down your question and send it in.




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