Going for Google Broadband Gold (one NC community’s approach)

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Google recently turned the broadband world on its ear by announcing it’s going to set up fiber-to-the-home (FTTH) networks for a handful of lucky communities that will deliver 1 gigabit per second speeds. Dozens of cities large and small are lining up to apply.

I wanted to get a perspective on what’s motivating communities that survived NOFA 1 to endure a different frenzied race for broadband gold. Hunter Goosmann, General Manager of ERC Broadband in Western North Carolina, recently received their Opportunity to Re-Apply letter from NTIA and RUS. ERC’s not only going for Google gold, but also a chance at Round 2 funding (sleep must not be a valued commodity in that part of the world).

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NOFA 2 – It Does Matter How You Say It

I listened to the NTIA/RUS workshop in Denver as these folks spelled out what makes for a good grant application, interpreted rules, etc. My ears perked up when they started on why projects got rejected. Specifically, when they explained that, for apps to get graded well in the Purpose (of the proposed network) category, “you have to be compelling, credible and clear.”

There have been some bitter and justifiable commentary about the first funding round, it’s lack of transparency in key areas and the lack of feedback throughout the process. I’ll add my 2 cents on this, but since the agencies gave some specific feedback, albeit in a general audience rather than to specific applicants, I want to jump on the key lessons.  

Months ago I wrote a column on how vital it is for you to write a really outstanding mission statement and executive summary. I believe readers thought I was loony giving them writing tips while they were trying to sort out engineering issues, 122-pages of hell and other seemingly more important issues.

Listen up folks! This is important. Today’s workshop spent significant time relating how reviewers rejected apps right off the bat – before due diligence – because of what was said, not said or how it was said. I point you later to a document with advice you probably want to heed. But first, a summary from the people who hold you future in their hands about what can kill your good, even great, idea for a network.

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Mo’ Money, Mo’ Money, Mo’ Money

Morning folks.

NTIA just announced another batch of lucky broadband stimulus winners. Check it out!

I’ll have analysis at midnight. My new book should be available for order this Friday. My publisher and I are frantically trying to get this into your hands to help with your broadband planning and grant application.

Stay tuned.

Handicapping NOFA 2

The good news is that the new NOFA rules are out. The bad news, if you have Attention Deficit Disorder, is that there are two of them and each one seems as long as the first NOFA rules. But at least there are welcome changes. Here’s an overview and a look at who does well as a result of these. 

First, I think it’s wise to let each group have its own rules. Many of the frustration people have had with the NOFA, Round 1 stem from the rules being a quick blending of procedures from agencies with two different purposes and ways of doing business. That led to the rules contradicting each other in places, or otherwise breeding confusion.

In terms of focus, NTIA is addressing middle mile primarily and this makes sense because it gives NTIA a bigger bang for their buck, allowing them to bring broadband to large geographical areas through each award. Rather than spend time reviewing 30 proposals for $1 million each, better to review one proposal for $30 million. There’s less administrative hassle on the backend where NTIA has to manage each funded project to completion.

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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.  

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NTIA Awards First Four Grants for Broadband Mapping

I was almost too giddy to speak. The first four stimulus grant awards for broadband mapping were announced yesterday for the states of California, Indiana, N. Carolina and Vermont. If a majority of the remaining states that receive grants employ similar mapping procedures of these four, NTIA and taxpayers stand to get plenty of bang for their stimulus buck.   

The California Public Utilities Commission (CPUC) gets approximately $1.8 million to collect and verify the availability, speed, and location of broadband across the state, plus $500,000 for the cost of statewide broadband planning activities over four years. The Indiana Office of Technology (IOT) receives approximately $1.3 million.

In N. Carolina the Rural Economic Development Center, Inc. (e-NC Authority) is awarded approximately $1.6 million plus about $435,000 for the cost for broadband planning activities in that state over five years. The Vermont Center for Geographic Information (VCGI) is awarded approximately $1.2 million.

This is a victory of sound mapping processes over the straightjacket of the  conventional wisdom regarding mapping that makes broadband advocates ill. These four awardees were selected because their proposals met or exceeded program requirements in three key areas: data collection, verification and collaboration. In a minute I’ll show how this leads to greater ROI for broadband investments.

The conventional wisdom, driven in large part by incumbent telcos and cable companies, is that you can’t get good broadband mapping data unless service providers (incumbents) give it to you. And because incumbents don’t want to give you the data you need, this mapping process has to be tedious, expensive and nearly void of independent verification. Indeed, when some critics said $50 million is adequate, $350 million was set aside for states to do mapping because of the expense of prying the data loose.   

For seven months, community broadband supporters watched with increasing trepidation as the embodiment of this flawed conventional wisdom, Connected Nation, secured deals to pursue mapping on behalf of states such as Texas, Florida and Minnesota. NTIA’s announcement today indicates that the agency is going to, as much as is possible, fund states that do mapping right.

 Why these award winners matter to community broadband 

I believe that, by selecting these particular four states for initial awards, NTIA establishes the benchmark by which future applications will be reviewed and grants awarded. Other states can view these winning procedures to modify their own proposals. And I believe NTIA will actually push back on those applications that follow the conventional wisdom, again, using the first awardees as the models for what should be.

California and N. Carolina have been at this game longer than most states (I assume the same for Indiana and Vermont as I learn more about them). Early on they rejected the notion of relying solely on service providers and have been collecting data from other sources, including directly from constituents through telephoning and in-the-field surveys. You cannot collect more accurate data than when you go straight to the people who do or don’t have broadband. N. Carolina plans to use Web and GIS tools to collect additional extensive data in a process they expect to be effective and surprisingly inexpensive.

Verification is critical to a superior mapping strategy and subsequent broadband deployment. The lack of independent verification leads to situations such as you have in West Virginia. Connect West Virginia (Connected Nation) produced a map showing 90%, 95% broadband penetration while the state ranks nearly last among U.S. states for broadband adoption. NTIA’s awardees will use multiple methods and independent verifiers to conduct data verification work. 

Collaboration is the third important ingredient for mapping success. The four awardees are pulling together state and local partners to execute the mapping exercise with maximum efficiency and minimizing some of the process implementation costs. Unlike the incumbents that shroud all of their data in non-disclosure agreements, these collaborative efforts create for the public a true, comprehensive picture of broadband availability.

When states use what e-NC Authority’s Ex. Dir. Jane Smith Patterson refers to as a multi-modal broadband data collection, you get better-detailed, accurate maps. This in turn enables you to make decisions that lead to (hopefully) the most appropriate broadband technologies going into appropriate communities in a way that yields the best results for your broadband investment. 

Ultimately, these state maps will be woven into a national broadband map that should be the cornerstone for the FCC’s national broadband strategy. I don’t expect that all state maps will be perfect, though I may bet you beer that my state’s map (CA) will be better than your state map. I’m sure some mapping awards will make me want to wretch. But I do have greater confidence in getting a decent number of high-quality maps than I did a couple of months ago. 

 Shout out

I have to send a special shout out to e-NC Authority. Here is a state agency that in July of this year was sold down the river in favor of Connected Nation by some of its own state legislators (at the behest of AT&T). You can read the ugly details here. Luckily for the good guys and gals, the state’s governor wasn’t swayed. She gave the nod to e-NC to represent and go after the NTIA grant.

I talked to Ms. Jane on the phone soon after I heard the news about the award and my office lit up from her smile. She and her team’s worked hard since 2001 developing good broadband maps. They had to fight naysayers, AT&T obstruction, serious budget cuts and treacherous political hacks (but I repeat myself), yet they came out on top. Karma rocks! e-NC won’t be gloating, though. They’re already working towards making their stimulus fueled project a model for the nation, then having NTIA and RUS come on down for some southern hospitality and technology showcasing.

I’ll be writing more about these states and their respective efforts in a week or so. Stay tuned.

A Little Self-Promotion Always Helps

If you’re planning to build a community broadband network, call me (510-536-4522) or e-mail. I have a ton of knowledge that can help you create a great plan, write a great NOFA app and implement your plan.

“Incumbents Do Not Have a Veto!”

With those words, Asst. Sec Lawrence Strickling, head of NTIA, enables many applicants and others worried about the NOFA’s incumbent challenge clause breathe a little easier. And for those of us who’ve railed against this potentially destructive clause , there is also a bit of satisfaction for not giving up the fight.

Mr. Strickling and Jonathan Adelstein, Administrator for RUS, were responding to questions from the House Subcommittee on Communications, Technology & the Internet when Congresswoman Anna Eshoo (CA) pushed for answers about the clause. “I want to make sure there’s competition. If the incumbents can just knock out people because they don’t want any to come in, I don’t really think that’s the way for us to go.” (gotta love our Calif Congressional delegation)

Mr. Strickling gave a reassuring response from both gentlemen and a clearer picture of how this process will run.

Applications with infrastructure proposals have proposed to cover areas where there isn’t broadband coverage. Maps are being generated for these areas through a publicly accessible database so you can see the proposed coverage area. During the review period anyone, including incumbents, can submit a message on the site saying they agree or not that the areas currently are not receiving adequate broadband.

Because applicants had to provide detailed information to justify their claim that these areas need broadband, “incumbents have to provide a lot of information to overcome the presumptions that have been established by the applicants.” NTIA will evaluate the challenge if it feels the challenge and supporting material throws the proposal into dispute, but NTIA and not the incumbent will have final say in determining whether the app moves to final review.

Mr. Adelstein added, “We will demand real substantiation with any challenge. But also, we want to be sure that what applicants present is accurate. Claims have to be verified and substantiated.” Furthermore, RUS has over 400 offices across the U.S. and they will send people into the field to areas that incumbents challenge to test and assess the validity of any challenges.

Where does that leave us?

This isn’t a final knockout blow to the clause. Yet there is cause for some joy here.

First, NTIA/RUS is giving applicants the high ground and the presumption that you hold an unassailable position. The burden of proof to the contrary lies with the incumbent. If you’ve done your homework, and are continually gathering whatever data you can to reinforce the fact that people in your proposed coverage area don’t have adequate broadband, you can better fight off any challenge.

Second, political pressure matters here. When members of Congress such as Rep Eshoo say to NTIA/RUS they’re not going to be happy if they see proposals in their districts knocked out by incumbent challenges, you better believe this becomes a factor. Same holds true if governors start making phone calls. The Congressional and gubernatorial cards are in play.

Third, this challenge process will play out in a fishbowl. If, for example, incumbents are required to submit details on actual speeds delivered to make their case, there’ll probably be few challenges. Incumbents don’t want it proven in such a public fashion just how big the gap is between what’s advertised and what’s delivered. Can you imagine the kind of fallout that would generate?

Fourth, you can run a preemptive counter-challenge in thi fishbowl. Anyone can post a challenge on the Web site. But that means anyone can post a note saying “I live here and let me tell you how bad coverage really is.”

So what you do is round up a whole passel of people around computer in the libraries, community centers, the schools, and get their comments. Be sure they submit enough of the right information, such as address, who the incumbent is, etc. so their comments carry weight.

What can we expect?

In the end, everything comes down to how detail-y is NTIA/RUS’ definition of “substantiation.” I think any mid-sized incumbent will be hard pressed to respond if they have to do a lot of legwork in a short period of time (2 or 3 weeks) because they don’t have a lot of staff.

For the bigger ones, such as Verizon and AT&T, a lot depends on the specific requirements for making a challenge. Remember, these folks didn’t apply in the first place because they don’t want to open their kimonos for public inspection.

Another factor is whether or not the applicant can rebut the challenge. With the amount of work a lot of applicants have presented to make their case for an area not being served, incumbents have to realize they’re at a disadvantage. I think incumbents would fear the publicity of losing a public counter challenge, so in this case there would be few challenges.

On the flip side, if these public statements from NTIA about requiring lots of substantial are mostly posturing, and the eventual required data to make a challenge is minimal (i.e. presenting only advertised speeds), then all bets are off. Skimpy requirements will likely lead to lots of challenges. I’m banking on stronger.

Either way, your work is not yet done young warriors.

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