Sunday, January 06, 2013

Suggested amendments to proposed Community Connect Broadband Grant program rules

Too many American communities lack adequate Internet telecommunications infrastructure, a situation President Barack Obama deplored in his 2012 State of the Union speech.  Lots of these communities would like to build their own fiber to the premises networks that can connect every home and business and provide fast, future proof service while keeping local dollars in the community.

A major stumbling block facing these communities is financing the cost of retaining engineers and consultants to do the necessary initial design and business planning work before any fiber infrastructure can be deployed.  The U.S. Department of Agriculture's Rural Utilities Service (RUS) is in a position to help with its Community Connect Broadband Grant program by creating provisions for technical assistance grants to defray these costs.

RUS is currently soliciting comment on proposed rules governing the Community Connect Broadband Grant program.  As written, the proposed rules contain no provisions for technical assistance funding.   The proposed rules also fail to take into account the often spotty, hit or miss availability of wireline connectivity that exists in many of these poorly served areas. Communities have the opportunity to file comment in the rulemaking by January 15 and request these deficiencies be remedied.

Below is sample comment language communities can file with the RUS suggesting amendments to the proposed rules to allow for technical assistance grants.  This funding will help enable communities to move forward with these sorely needed projects to ensure their citizens and business owners have the 21st Century telecommunications infrastructure they need now and in the future.  Comments can be filed electronically by the January 15 deadline by clicking on the "Comment Now" button in the upper right hand part of the rulemaking proceeding page linked above.
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Sec.  1739.11  Eligible Community Connect Competitive Grant Project.

 
    To be eligible for a Community Connect competitive grant, the 
Project must:
        (a) Serve a PFSA in which Broadband Service does not currently 
exist. served by a telephone central switching office or similar facility where at least one premise is not 
offered wireline, facilities-based broadband service;
    (b) Offer service at the Broadband Grant Speed to all residential 
and business customers within the PFSA;
    (c) Offer free service at the Broadband Grant Speed to all Critical 
Community Facilities located within the PFSA for at least 2 years 
starting from the time service becomes available to each Critical 
Community Facility; and
    (d) Provide a Community Center with at least two (2) Computer 
Access Points and wireless access at the Broadband Grant Speed, free of 
all charges to all users for at least 2 years.
 

Comment: This amendment is necessary because broadband service is highly granular even in rural areas where availability of facilities-based, wireline service is spotty and can vary within communities and from premise to premise. 

Sec.  1739.12  Eligible grant purposes.
 
    Grant funds may be used to finance the following:
    (a) The construction, acquisition, or leasing of facilities, 
including spectrum, land or buildings, used to deploy service at the 
Broadband Grant Speed to all residential and business customers located 
within the Proposed Funded Service Area and all participating Critical 
Community Facilities, including funding for up to ten Computer Access 
Points to be used in the Community Center. Leasing costs will only be 
covered through the advance of funds period included in the award 
documents;
    (b) The improvement, expansion, construction, or acquisition of a 
Community Center and provision of Computer Access Points. Grant funds 
for the Community Center will be limited to ten percent of the 
requested grant amount;
    (c) The cost of providing the necessary bandwidth for service free 
of charge to the Critical Community Facilities for 2 years.
 
 (d) As technical assistance for the retention of consultants and experts for economic research and engineering and business planning and community outreach.
(e) Applications for technical assistance pursuant to Subsection (d) shall not be subject to Section 1739.17.

Comment: This amendment is necessary in order to assist communities cover initial diligence costs and to aid in the preparation of applications for Rural Utilities Service broadband loan and grant programs.  Proper diligence in the early stage of a project will help ensure the financial viability of planned projects and repayment of loan proceeds.

Sec.  1739.14  Matching contributions.
 
    (a) At the time of closing of the award, the awardee must 
contribute or demonstrate available cash reserves in an account(s) of 
the awardee equal to at least 15% of the grant. Matching contributions 
must be used solely for the Project and shall not include any financial 
assistance from federal sources unless there is a federal statutory 
exception specifically authorizing the federal financial assistance to 
be considered as such. An applicant must provide evidence of its 
ability to comply with this requirement in its application.
    (b) At the end of every calendar quarter, the award must submit a 
schedule to RUS that identifies how the match contribution was used to 
support the project until the total contribution is expended.
 
(c) No match shall be required for technical assistance funding pursuant to Section 1739.12(d)

Comment: This amendment is necessary because raising matching funding for diligence and planning purposes is considerably more difficult than for construction costs of deploying a project that has undergone diligence demonstrating its likely technical and financial feasibility.  It will help increase the likelihood of more community-based projects being undertaken and expanding the availability of broadband services.

Sec.  1739.15  Completed application.
 
Add new subsection (m) as follows:    

(m) Applications for technical assistance funding pursuant to Section 1739.12(d) shall include only 
those items delineated at subsections (a) and (b)(1) through (3).

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