Taking Action on the New NOFA Rules

Welcome to NOFA 2 and the 60-day march through hell (for some) to $4 billion. After Friday afternoon’s sudden delivery of the preliminary set of NOFA rules, I made the comment that it is good that the agencies are going their separate ways. Trying to keep the NTIA/RUS marriage together for the sake of the kids didn’t make sense. 

Then I looked at draft of the NOFA for NTIA and RUS. That’s nearly 200 pages! My brain glazed over. No wonder they waited until Friday before a 3-day weekend! Then at midnight, I got an e-mail from the New America Foundation with incredibly thorough summaries of NOFA 2 highlighting changes from NOFA 1 and other valuable details condensed into 85% fewer pages. Read the summaries before the actual NOFAs.

Heartfelt thanks to New America are very much in order from all of us trying to slog through all this info. Dudes and dudettes – thank you!!

For my part, since New America breaks down what NOFA 2 is all about, I’m giving you some tips on what to do about these rules so you can get a good proposal across the finish line. There’s barely two months to the March 15 deadline for your proposal, so I’m not prettying this post up. This train’s leaving the station. You can complain to the Fed’s conductors later about whatever injustices you spot.  

You should pull up New America’s BTOP and BIP summaries because I’m going to track my comments along side of theirs as best as I can.

Because policy peeps and broadband advocates won’t stop fidgeting until they know how NOFA 2 affects their favorite causes, here’s a synopsis so I can get to the action recs.

Suggested plan prep – BTOP NOFA

1. NTIA’s focusing heavily on middle mile projects that touch communities’ major institutions. That means it’s time to partner you butts off. And call the Gates Foundation.
2. Cities can play in NOFA 2, but here’s the trick. You don’t have to prove you have unserved and underserved by criteria of less than 50% having those ticky-tack minimum speeds. But because un- and underserved have priority, you have to push heavy on the fact that your communities are un- and underserved by criteria that really matter to NTIA’s stated goals for these grants.
3. You’ve been freed from the shackles of providing data at the census block level. This probably knocks 10% off of your pain-time Misery Index. Nevertheless, you cannot underestimate the value of mapping! People with wireless projects in mind, you can recalibrate your brain now when you consider how to shape your proposed coverage area.
4. The Twitterverse suffered a minor aneurism as people saw that NTIA is giving extra points to those coming up with 30% matching funds. Chill. The minimum required is still 20%. But if you still want to have that blood pressure spike, go ahead. Then turn to this type of economic development fundraising effort.
5. You don’t have to prove conclusively with extensive spreadsheets your financial sustainability model at the time you submit your app. But you still have to do it! And it’s probably not going to do you any good to show some wild projections for profitability in you initial proposal, and then show a starkly different picture in the due dili session.                                                                       
6. There’s only going to be two reviewers in the first phase of evaluation, not three like last time. You’d better write some darn good, no-b.s. prose that clearly makes your case. Without that tie-breaker reviewer, you could be hosed if there’s a hung jury. (Think- I’m an NTIA executive reviewer, 100 apps in my In Box, 25 of which the reviewers can’t conclude if the app is a good one or not. That’s 25 fewer apps I’ll review.)
7. You have fewer attachments required in NOFA 2. You win! You and a gezillion others still have to file electronically. Beware the Ides of March!
8. Sticking with “Julius Caesar” for $400, Alex, Yond incumbents have a lean and hungry look. These birds can still challenge your app, and you should expect them to. However, for NTIA they only have 15 days to challenge, they have to defend by disclosing 7 categories of infomation and you get to defend yourself during due dili. On March 16 start collecting primary data from constituents on who doesn’t have what.
9. You get bonus points (figurative or actual) if you bring last-mile broadband to economically distressed areas. Big Cities, listen up! Most of you have economic development zones. Center your proposals on those. Everybody, listen up! Want to come up with 30% matching? Make the middle mile portion 70% of the project, get several providers to agree to build last mile to the extent it equals at least 10% of total project cost. You were going come up with 20% anyway. Forget asking for a waiver for the 20%, it only lowers your priority in the pack. 
10. A bunch of criteria have been eliminated or clarified, though you get bonus consideration if you have them. Think judiciously about which ones you chose to ignore.
11. Take note of the 7 criteria starting on the bottom of page 5 of New America’s summary, particularly you larger cities with police and fire departments. If you tackle the un- and underserved issue effectively, you should be able to meet some of these 7 criteria.
12. If you haven’t kissed up to the Governor’s office or your state legislatures since the holidays, pucker up, peeps. They still have a role to play. Besides your desire for an endorsement of your app, you don’t want them to evoke the “appropriate use of taxpayer dollars” clause against you (NOFA pg 83). Btw, a lot of governors are running for re-election this year, so it could be debatable whether you can rely on them to play an active role that plays favorites with some apps over others on the “Recommended” list.  

Suggested plan prep – BIP NOFA 

The RUS summary is shorter, as is the NOFA itself. It seems there aren’t many rule changes, but they are significant as you see in New America’s summary. So here are some tips on dealing with these.

1. Everywhere RUS has funded someone to build a network, even before the days of stimulus, is off limits. So check their maps first thing. Marked territory trumps QOS.
2. Broadband adoption and creating jobs through network building drove many discussions in NOFA 1. For RUS NOFA 2, transforming communities economic development is likely the be all and end all of this funding drive. Get your econ dev people in the room bright and early Tuesday morning.
3. Don’t forget your library card. Wiring them is a central theme. Just don’t forget your other institutions if you want the network to make money to sustain itself. Hospitals, local government as a whole, school districts, colleges, banks and your largest businesses are the entities with bigger budgets and greater capability to attract huge grants, all of which they can funnel into network operations and services.
4. The new speed limit should make targeting your potential service areas easier. But truthfully? You’d better find some middle mile friends because to ensure uniform 5Mbps delivery to everyone, someone has to solve the backhaul part of the equation. Remember, backhaul can’t be part of your proposal budget but they have to be part of the technology picture unless you already have middle mile to bring to the party. 
5. The new 75/25 grant-loan math helps. And even though you can ask for a higher grant percentage, my gut tells me that if you do you’ll drop to the bottom of the pile if 100 other apps are ahead of you. Stick to the 75%.
6. See my point in the BTOP section about the well-written business case. You only have one-step review, so either the first person reading your proposal gets it, or it’s Katy, turn out the lights. Another thing is, Administrators have discretion on how it awards points if you hit their hot button issues. Along with a tech writer, see if you can get some Hallmark Card writers to moonlight for you. 
7. See also my remarks on elimination of census blocks and need for good mapping.
8. Know your definition of “rural” as defined by RUS. No other definition matters.
9. I’d forget about this “if not-then” game which involves trying to get BIP money if NTIA bounces you to the curb, or vice versa. Look at Round 1 NOFA and you see how well that tactic worked out. Payout day’s gotta be by September 30. Do the math. You need to fall into one camp or the other and bust your chops to win there.
10. You get money for Technical Assistance (economic development strategy planning). Get some of this! With all the emphasis on completing the application correctly, don’t forget you need to do a thorough job at planning for the business aspects of the network. Furthermore, those T A plans can lead to future funding from RUS and other agencies. 
11. A painful – but helpful – pill to swallow is showing the cost per resident of your network infrastructure (can’t exceed $10K). It’s good for cost management, but it’s a tedious pain to calculate. Better have a good person, or persons, who produce accurate financial modeling. Expect your numbers to be challenged by someone if you don’t (and even if you do).
12. Don’t forget to think through all of the criteria for increasing points awarded to your proposal. For example, convince a smart grid stimulus grant winner to integrate your proposed technology with theirs, that’s 5 points. 

There’s more than can be said, and information Webinars will be coming out the wazoo starting in 48 hours. Add your two cents here. You should follow me on Twitter here.

For specific advice and assistance with your community’s plans to tackle NOFA 2, contact me today.