Sometimes change is good and that seems to be the case with USDA’s new rules for ReConnect funding. CTC Technology and Energy report…
The NOFA includes a significant shift in application scoring metrics. RUS has included a preference for local governments, non-profits, and cooperatives as applicants and additional points to those applications (“including for projects involving public-private partnerships where the local government, non-profit, or cooperative is the applicant”).
Further, RUS includes metrics to score the affordability of the services being offered; whether wholesale services at non-discriminatory rates will be offered; compliance with net neutrality requirements; and willingness to include strong labor standards.
RUS has also included points for applications with service areas that encompass Socially Vulnerable Communities and those that address areas with defined economic need. (Our grants team is still evaluating these issues and will post a deep dive soon.)
However, don’t forget that this is a rural program and rurality still matters. Available speeds also matter. As such, points are awarded for serving the least dense rural areas as well as serving areas that lack 25/3 Mbps.
Any areas with less than 100/20 Mbps, even those with DSL or fixed wireless, are eligible
RUS is expanding eligible areas beyond the FCC’s 25/3 definition of broadband. The RUS’ definition of an eligible Proposed Funded Service Area (PFSA) is now one that is not currently receiving speeds of 100 Mbps download and 20 Mbps upload, a considerable and welcome change from its previous definition of 10/1. Further, in the scoring process, extra points (25) will be awarded to those applications that will serve areas that currently have less than 25/3 Mbps available. This includes the service areas of existing RUS borrowers without sufficient access to broadband.
This new approach follows the policies of the Biden Administration and the Commerce Department in moving away from the FCC’s longtime definition of broadband as 25/3 Mbps, essentially eliminating any claims from DSL and fixed wireless providers—which can generally not reach those speeds—that their services qualify as broadband. Going forward, the Administration appears to be saying, only cable and fiber can deliver the speeds necessary for communities to compete in the post-pandemic world.
After being shut out of Round 2 due to the need to coordinate with the FCC’s auction, RDOF areas will be included in PFSAs for Round 3. The NOFA explains that this is because “RDOF funds both operational expenses and capital expenses, while ReConnect funds only capital expenses.” Another rationale given is that the six-year timeline for RDOF funds is not sufficiently fast enough to respond to the needs created by the pandemic. The goal is to get communities wired as fast as possible.