Re: possible grant?

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Nathan Borson

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Jun 21, 2013, 7:11:12 PM6/21/13
to Ringham, Nathan, s burd, Bates, Katherine, gcn, gustavus...@googlegroups.com
GCN Board and others:

I have read the new Community Connect program regulations (7 CFR part 1739, subpart A) and the June 11, 2013 Notice of Funding Availability (NOFA), as well as the helpful analysis from ICF. My conclusion is that we cannot apply for this grant this year, but may be able to next year.

Here are the obstacles that I think make it impossible for us to apply for or get a Community Connect grant this cycle:
  • We are probably ineligible because of the AT&T 4G service installed on May 30, 2013.
    • I'm guessing neither the clinic's new service nor the service at the library, school, nor NPS offices is a problem because their dedicated service does not disqualify us ("the area is still eligible for grant funds... if a business in an area has a T1 line from the local exchange carrier"). And for the clinic, their extremely expensive service is made possible, if I understand correctly, by a VA grant that will eventually run out. However,
    • I agree with Nathan Ringham that the NOFA is clear about the Broadband Service Speed. If any part of our proposed service area has service with a combined download and upload speed of 3 megabits/second or more, whether fixed or mobile, we are not eligible. First indications are that the new AT&T service does deliver those speeds. In a grant application we would have to explain why we think we have no service meeting that speed, and RUS (the granting agency) will attempt to verify our findings. It is possible AT&T's speed is not as fast as one customer reported, but it will take a significant effort to demonstrate that. Each year the Broadband Service Speed is re-evaluated, and it may well be higher next year, so we might be eligible then even if we are not now.
  • We don't have enough time to prepare the application. Having now studied the application requirements, I can see that there is no way to meet the July 11 submission deadline.
    • We do not have the required 15% match. It's possible the city might increase their pledge from $120,000 to $360,000, or that we could find the other 10% from the Denali Commission, Rasmussen Foundation, Alaska Legislature, or some other source. But I cannot imaging getting that done by July 11.
    • It will take a very substantial effort to prepare all the required parts to the application. Even though the hardest work was already done during our broadband planning effort, it will take too long to fill in the missing parts such as demonstrating that the AT&T service does not make us ineligible, making a plan for the required provision of 2 years of service to community facilities, etc.
Much as it pains me, my staff recommendation to the GCN Board is to skip this funding opportunity and prepare for it next year, while we continue searching for matching funds that could be used for either this program or an EDA award.

Regretfully,

Nate


On Fri, Jun 21, 2013 at 5:25 AM, Ringham, Nathan <Nathan....@icfi.com> wrote:

I’m pretty confident that it’s “plus” but we can definitely confirm that.  We can also review how USDA determines whether existing service actually meets these requirements.  In the other USDA broadband programs – both of which we’ve worked on – incumbent providers have to respond during a notice period stating that they serve areas included in grant applications.  So you may be able to fly under the radar. You may also be able to contest incumbent responses, but I can’t remember the exact process.

 

The clinic’s connection may also problematic.  It may not make you ineligible since it’s a dedicated line, but it will complicate the application.  One of the primary scoring factors is the ability to serve community facilities (schools, libraries, clinics, etc).  If Gustavus’ community facilities already have qualifying service you run into both the issue of existing service and the fact that the proposed network may not serve these facilities.  We could investigate the savings GCN would provide and hopefully that would carry some weight during the application review process.  I know the USDA staff that run this program and they tend to be very literal in their reading of regs, so unless the regs include something referring to the ridiculous expense of existing service to community facilities this may be a tough obstacle to overcome.

 

The last bit of bad news…the program requires a 15% match and it has to be in hand when the application is submitted (having other funding committed is something the USDA staff draws a hardline on).  So unless you can persuade the City commit 15% of the budget prior to July 11, I don’t think you’ll be successful in this application round.  On the plus side, a 15% match is a lot less than EDA requires so it seems like it should be easier (I’d think) to cobble together that amount from the state and/or foundations. 

 

This program seems to have a lot of support in Washington, so I doubt it’s going anywhere.  Maybe we should reinvestigate it in order to prepare for next year’s funding round.  This is the ideal program for Gustavus if we can guarantee eligibility. 

 

From: Nathan Borson [mailto:na...@borson.net]
Sent: Thursday, June 20, 2013 7:33 PM
To: Ringham, Nathan
Cc: s burd; Bates, Katherine; gcn
Subject: Re: possible grant?

 

Hi Nathan,

 

Well, that's exciting!

 

So, that's download plus upload? In other words, exceeding, say, 2 Mbps down and 1 Mbps up? Or is it download and upload, as in 3 Mbps down and 3 Mbps up?

 

If the former, the timing of the new (5/30/13) AT&T 4G service could be a major bummer for our project -- disqualifying us without meeting our needs (since it covers at most two thirds of the community, does not offer connectivity to a LAN, etc.). Below is the fastest speed test result that has been forwarded to me from that service. I don't know how accurate or reproducible it is; no one else who has forwarded results has come close to this, and the new service was experiencing outages. AT&T told one of their customers to expect the new service to be fixed 6/17 and I haven't heard how things are since then. It sounds like I'd better try to get a handle on the actual service delivery ASAP if it's the former criterion (down plus up). If it's the latter, it sounds like we are eligible since even this test shows less than 3 Mbps up. Perhaps Don could help evaluate the service by defining a testing methodology that I could carry out.

 

It will be a mad scramble to get an application in by July 11, but the timing is good for me; I have quite a few days between now and then that I can devote to this. But it's not in the scope of my contract, so I would hope to have ICF do as much of the application preparation as possible.

 

Here's the fastest speed test I have ever seen for Gustavus, not necessarily a reliable number:

 

A detailed image for this result can be found here: http://www.speedtest.net/iphone/557617950.png

Test Date: Jun 2, 2013 11:22 AM
Download: 6.41 Mbps
Upload: 1.18 Mbps
Ping: 210 ms
Connection Type: Cellular
Server: Wichita, KS
External IP: 166.147.82.50
Internal IP: 10.177.83.111
Latitude: 38.0000
Longitude: -97.0000
http://maps.google.com/maps?f=q&q=38.000000,-97.000000

 

Nate

 

On Thu, Jun 20, 2013 at 12:19 PM, Ringham, Nathan <Nathan....@icfi.com> wrote:

Hi Nate –

 

We may be onto something here as the regs for this program actually did change recently.  The threshold for area eligibility has changed from 200 kilobits/second to a speed that is defined in each funding notice published.  The current notice for Community Connect states that areas with at least three megabits per second (download plus upload speeds) are ineligible.  Does GCN or AT&T surpass this?

 

Nathan

 

From: Nathan Borson [mailto:na...@borson.net]
Sent: Thursday, June 20, 2013 4:03 PM
To: s burd; Ringham, Nathan
Cc: Bates, Katherine
Subject: Re: possible grant?

 

Hi Sandy,

 

Thanks for that article!

 

Here is what our broadband planning contractor wrote about the Community Connect program earlier this year:

"This may be the ideal funding source for Gustavus except that the city’s efforts to make broadband access available have likely rendered it ineligible for award.  If any part of the proposed service area already has access to a connection of at least 200 kilobits/second both down- and up-stream, then the application will be deemed ineligible.  Both GCN’s broadband services and ACS’s mobile broadband services [and now AT&T's 4G service -nb] likely surpass 200 kilobits/second."

 

However, the rules and eligibility of these programs do change, so this may be worth another look; I am copying ICF on this message. Nathan, could you check whether our eligibility has changed?

 

Again, thanks for looking out for us!

 

Nate

 

 

On Thu, Jun 20, 2013 at 11:01 AM, s burd <san...@hotmail.com> wrote:

 

 


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