CPF Infrastructure Debrief and Lessons Learned Presentation from KOBD
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The CPF program is providing funding to make broadband connections in critical areas of the state that lack access to high-speed internet. The $83.5 million total CPF investment, combined with almost $42 million in matching funds, will result in more than 24,500 homes, businesses, schools, health care facilities, and other public institutions being connected to fast, reliable internet for the first time. This program was developed to bring broadband infrastructure that will deliver speeds that meet or exceed symmetrical speeds of 100 Mbps to unserved areas across Kansas.
|Awardee||County||Grant||Matching Funds||Total Investment||Number of Premises|
|Butler Rural Electric Cooperative||Butler, Cowley, Sedgwick, Sumner||$9,815,894||$10,633,885||$20,449,779||4,303|
|Cox Communications||Jackson, Shawnee, Wabaunsee||$6,373,948||$5,284,360||$11,658,307||1,308|
|Craw-Kan Telephone Cooperative||Anderson & Allen||$4,584,590||$1,528,200||$6,112,790||385|
|GBT Rural||Pawnee, Stafford||$6,782,694||$1,565,144||$8,347,838||530|
|IdeaTek||Finney, Haskell, Scott, Seward||$7,943,385||$1,062,720||$9,006,105||1,121|
|KwiKom (2 projects)||Franklin, Lyon, Osage||$1,810,941||$963,554||$2,774,495||1,333|
|Mokan Dial (2 projects)||Franklin, Miami||$12,538,318||$1,460,684||$13,999,002||1,463|
|MT Networks LLC||Coffey||$2,581,932||$322,379||$2,904,311||326|
|Nex-Tech (3 projects)||Thomas, Decatur, Saline||$11,306,020||$3,386,980||$14,693,000||1,152|
|PGB Fiber, LLC||Finney||$1,811,463||$572,04||$2,383,504||137|
|Total Communications||Montgomery, Chautauqua||$3,244,793||$1,000,000||$4,244,793||500|
|WANRack||Johnson||$400,000||$1,056,925||$1,456,924.65||26 + middle mile|
|WTC||Geary, Pottawatomie, Riley, Shawnee||$3,599,749||$3,599,749||$7,199,498||814|
The Capital Project Fund program is intended to address the following priorities:
We’ve added new FAQs (8/08/22)
The Capital Project Fund: Broadband Infrastructure Program opened on July 25, 2022
“The investment in Kansas’ broadband infrastructure has been a top priority for me to deliver to the people of Kansas since day one. No one in our state should be without the means to connect to the world – whether it be for business, education or quality-of-life purposes – and this new grant program will help ensure that it happens.”Governor Laura Kelly
Capital Project Fund Program Guidelines
The objective of the Capital Project Fund: Broadband Infrastructure Program is administered through the Kansas Office of Broadband Development is to provide access to high-quality, reliable broadband in Kansas with priority given to applications that address unserved areas, economically distressed communities, and areas of compelling need. Applicants are expected to engage community leaders and stakeholders in the development of projects that are strategic, scalable, and bridge critical access gaps to support quality of life considerations and economic viability for Kansas citizens and communities.
* – Note: Projects over $10M may be submitted but will only be considered as a multi-phased approach with a maximum of $10M awarded in the first phase. If the initial phase is funded, the Kansas Office of Broadband Development does not guarantee future phases will be automatically funded as each successive project phase will need to be re-submitted for award consideration.
Applicants must be authorized to provide broadband services in the area proposed to be served. Eligible applicants include:
Service providers will be required to be an active participant in federal subsidy programs prior to application submission to optimize digital inclusivity and adoption including partnering with school districts and colleges to raise awareness of subsidy programs. (i.e., Lifeline, Affordable Connectivity Program, Emergency Connectivity Fund). Service providers are also encouraged to partner with local housing agencies to take advantage of programs that benefit multi-dwelling units. Applicant must be an established service provider that has been operating for a minimum of three years in the State of Kansas.
The purpose of the grant is to facilitate broadband access to unserved and underserved areas with demonstrated need and may include residential, business, and community anchor institution locations. Unserved is defined as a designated geographic area in which households or businesses are without a fixed, terrestrial connection supporting at least 100 Mbps download and 20 Mbps upload speeds. An underserved area is defined as a designated geographic area in which households or businesses are without a fixed, terrestrial connection supporting less than 100 Mbps download and 100 Mbps upload speeds and greater than 100 Mbps download and 20 Mbps upload. Proposed service areas are not required to be contiguous. However, non-contiguous areas more than 10 miles apart must include an explanation of how the economic and community impact is the same for the proposed areas. Middle-mile expenses are eligible for grant funding only when they are necessary for the provision of last-mile services described in the application. All projects must directly enable work, education, and healthcare monitoring.
Applications may be considered for areas with certified awards through the FCC Rural Development Opportunity Fund (RDOF) served by wireless with less than 100/20 Mbps speeds enabled (Minimum Performance Tier (<25/3Mbps) and Baseline Performance Tier (<50/5Mbps)). Recipients must ensure there is additional public benefit and a justification for using additional public funding to deploy to those locations. Service areas with certified awards through the FCC with more than 100/20 Mbps wireline/fiber will be considered ineligible for grant award.
Applications must include a proposed service area map with proposed service locations clearly identified. Applications must include a spreadsheet listing the Census Block Identifiers (2020 Census Data) for the proposed project area as outlined in the Project Proposal and the Technical Project Plan.
Areas already receiving funding for broadband expansion from other sources are ineligible. Ineligible areas include but are not limited to:
Note: Areas where applicants forfeited grant awards will remain eligible
Previous Kansas Office of Broadband Development programs that have been awarded to a municipality to serve community anchor institutions for public safety or an enterprise-focused award will not be disqualified for a new residential proposal. Applicants falsifying location eligibility may be subject to grant rescindment and/or restricted from future program participation.
The Capital Project Fund project funds up to $83.5M of the eligible broadband infrastructure deployment costs for an eligible broadband project. Eligible broadband project expenses are capital expenses directly related to the deployment of a qualified broadband project, including pre-project development costs and uses, including data gathering, feasibility studies, engineering design, work related to environmental historical, and cultural reviews, permitting, materials, supplies, equipment and construction of “last-mile” infrastructure expenses. Last-mile is defined as the final leg connecting a broadband service provider’s network to the end-user customer’s on-premises telecommunication equipment. Broadband infrastructure must provide access to additional residential, business, and community anchor institution locations. Middle-mile expenses are eligible for grant funding only when associated with last-mile services described in the application. Grant expenses must be incurred, and funds expended during the project period per the official grant agreement.
Ineligible costs include, but are not limited to:
Potential applicants should submit an Intent to Apply within 1 week after Guidelines are published. The Intent to Apply is for communication purposes and capacity planning for the grant administration process. It does not eliminate potential grantees from applying should the deadline be missed, nor does it commit an applicant to apply.
To ensure transparency and the best use of taxpayer funds, the application and selection process will include a two-week public comment period followed by a two-week applicant response period. This period is intended to provide an opportunity for providers, elected officials, and constituents to either express support or to inform the Kansas Office of Broadband Development of any issues or concerns with an application or its proposed service area. All comments collected during the public comment period are subject to public disclosure, except for the specific location of infrastructure assets deemed “proprietary.”
The application information allows potential applicants to begin formulating a response to the grant opportunity. The application window will be open for four weeks. After initial applications have been reviewed and grant funds awarded, if additional funds are available then a new round of application period will be implemented. The Kansas Office of Broadband Development reserves the right to modify the program guidelines as needed to generate an adequate number of viable projects.
The application contains three primary sections: Project Proposal, Technical Project Plan, and Project Budget. The submission will include documents designated for public posting during a public comment period. A Technical Planning Guide and templates will be posted to assist applicants. If there are multiple applications that cover the same service area, the Kansas Office of Broadband Development will select the project that provides the greatest benefit to Kansans.
Key project data will be captured for the applicant and the project including:
The Project Proposal should provide a compelling case for a project and includes:
1. EXECUTIVE SUMMARY OF THE PROJECT – This narrative overview should include the goals of the project, needs addressed, a description of the proposed service area, community partners, stakeholders involved, and the intended impact.
2. PUBLIC PROPOSED SERVICE AREA MAP – For the proposed service area including detail for the proposed service locations.
3. COMMUNITY PARTNERS, ROLES & LETTERS OF COMMITMENT – Applicants will be asked to provide a list of partners involved, along with a description of their role.
4. JUSTIFICATION FOR THE PROJECT – Applicant must provide evidence of how the project will address the compelling need, provide economic and community impact, and meet overall program requirements including directly enabling work, education, and health-monitoring. Project must also address a critical need that resulted from or was made apparent or exacerbated by the COVID-19 public health emergency.
5. ADOPTION, AFFORDABILITY AND DIGITAL INCLUSION EFFORTS – Adoption is a key aspect of the success of these projects. Applicants will be asked to describe activities planned to increase adoption awareness. Applicants are encouraged to demonstrate the affordability of the products and services within the proposed service area and how this will address current barriers to broadband access in their project proposal. Applicants are expected to participate in ACP.
The Technical Project Plan details the technical elements of the proposed build including:
An Application Planning Guide will be posted online to assist applicants in developing this portion of the grant application.
Levels of participation through matching funding and other co-investment mechanisms is expected to vary statewide on a project-by-project basis in recognition of the variable costs of installing broadband infrastructure. Applicant matching levels are based on percentages of the total project cost and establishes the minimum match an applicant must contribute to a project. Applicants can contribute more than the minimum match for additional consideration during the evaluation process.
Project budget and financial submission requirements include Budget Narrative, Project Budget Spreadsheet, and financial validation documentation.
The Kansas Office of Broadband Development will conduct a webinar informing potential applicants of the Coronavirus Capital Projects Fund for Infrastructure grant opportunity and the guidelines will be posted online for applicants to review. Technical guidelines will be posted to assist with the application submission process. To apply for the grant award, applicants will be invited to submit information on an established online portal. This information will then be reviewed by an executive committee. This process will evaluate the project proposal, the technical project plan, and the proposed budget. Business, economic, and community development professionals and technical experts will be enlisted to review project submissions. Applicants being considered for the award will participate in a final interview to be held via an interactive meeting platform. Once the final recommendation has been developed, the Kansas Department of Commerce leadership will review and finalize the award recommendations.
Application evaluation will be based on the overall quality of the application including the Project Proposal, Technical Project Plan and Financial information presented. The Kansas Office of Broadband Development will be evaluating applications based on projects that optimize stewardship of public infrastructure dollars through collective investment and include:
The Coronavirus Capital Projects Fund for Infrastructure will provide structured reimbursements for validated grant expenditures submitted. Grantees are expected to submit supporting documentation for expenditures (i.e., invoices, receipts) and proof of payment if requested. Grantees must submit all required legal and contractual agreements/ documents prior to funds disbursement.
The Kansas Office of Broadband Development will provide a collaborative partnership, and overall support for Coronavirus Capital Projects Fund for Infrastructure Grantees in this effort by offering technical support related to report and compliance requirements as listed in the following paragraphs.
In addition to periodic Grantee meetings, the Kansas Office of Broadband Development will streamline reporting by providing baseline reporting templates and clear expectations for grantees participating in the program.
Closeout reporting will be required within 45 days of project completion. Project completion and submission of the closeout report are required prior to the final payment. Closeout reporting includes, but not limited to, the following:
Grantee shall create, maintain, and preserve sufficient records to demonstrate their compliance with the requirements of this program. Grantee shall provide such records to the Kansas Office of Broadband Development promptly upon written request. The Kansas Office of Broadband Development requests may include, but not be limited to, the following:
Adoption goes beyond access to high-speed internet and speaks to the ability of individuals and communities to harness access for quality-of-life implications. These efforts may include digital literacy training, low-income assistance programs (for equipment and/or broadband service), partnerships with co-working or entrepreneurship organizations, awareness or marketing campaigns, service provision to community anchor institutions and/or additional programing, and other programs designed to meet the needs of the local community.
At the time of application submission, the applicant must demonstrate available cash reserves in an account(s) of the applicant equal to at least the required amount specified in the sliding scale match table. Matching funds 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. (www.ecfr.gov)
Broadband or high-speed Internet access allows users to access the Internet and Internet-related services at significantly higher speeds than those available through “dial-up” services. Broadband speeds vary significantly depending on the technology and level of service ordered.
For additional information, visit the source of this information: Getting Broadband Q&A | Federal Communications Commission (fcc.gov)
Any funds provided by sources other than the applicant such as local, county, and eligible state programs or other contributors.
Community Anchor Institution
Community anchor institutions means schools, libraries, medical and healthcare providers, public safety entities, community colleges and other institutions of higher education, and other community support organizations and agencies that provide outreach, access, equipment, and support services to facilitate greater use of broadband service by vulnerable populations, including low-income, unemployed, and the aged (www.usac.org).
Economically Distressed Community
An area is economically distressed if it has a per capita income of 80 percent or less of the national average, or if it has an unemployment rate that is, for the most recent 24-month period for which data are available, at least 1 percent greater than the national average unemployment rate. (http://www.statsameri- ca.org/distress/distress.aspx)
Last mile refers to the network infrastructure that carries signals from the network to and from the end-user premise. Depending on the network design and density of the area served, the actual distance of the last mile can be relatively short or may be considerably longer than a mile.
Middle mile refers to the portion of the telecommunications network that connects a network operator’s core network to the local network (last mile) plant. Middle-mile facilities provide fast, large capacity connections and can range from a few miles to a few hundred miles. Grant funding can only be used for middle-mile related costs if it is necessary in order to provide last-mile service.
A formal relationship between two or more parties that enter into an agreement for the sake of advancing broadband enablement.
All projects over $10M need to be broken down into a series of project stages to spread awards over multiple stages. There will be future funding opportunities to potentially cover remaining stages that have not been awarded in the current grant program.
Required Applicant Match
The percentage of funds required by the applicant for the program.
The capacity to change the size or scale of the broadband architecture to achieve substantially higher speeds (up to 10Gbps) with minimal to no investment.
A measure to determine the contribution level required by the State of Kansas based on cost per location passed.
Assistance program applicants are enrolled in to assist with the monthly cost of services. Federal programs include the Affordable Connectivity Program (ACP), Emergency Broadband Benefit (EBB), or Lifeline.
For purposes of the Coronavirus Capital Projects Fund for Infrastructure program, an underserved area is defined as a designated geographic area in which households or businesses are without a fixed, terrestrial connection supporting less than 100 Mbps download and 100 Mbps upload speeds and greater than 100 Mbps download and 20 Mbps upload. (https://home.treasury.gov/system/files/136/Capital-Projects-Fund-Guidance-States-Territories-and-Freely-Associated-States.pdf)
For purposes of the Coronavirus Capital Projects Fund for Infrastructure program, an unserved area is defined as a designated geographic area in which households or businesses are without a fixed, terrestrial connection supporting at least 100 Mbps download and 20 Mbps upload speeds. (https://home.treasury.gov/system/files/136/Capital-Projects-Fund-Guidance-States-Territories-and-Freely-Associated-States.pdf)
Q. Will Kansas prioritize the grant applications it receives for this program, and if so, how?
A. Yes. In trying to ensure that every Kansas resident has access to broadband, our first priority is to focus on grant applications that will serve households and businesses in unserved areas – those with broadband speeds of less than 100 Mbps / 20 Mbps.
Q. Can a government/business partnership be considered eligible?
A. Partnerships Public/Private are welcome and encouraged.
Q. When is the last possible date to enter applications?
A. The last day to submit an application will be Friday August 19 at 5 PM central time. The earlier it is submitted the quicker we can review the information. If there is a delay to the start, we will adjust the dates.
Q. Please clarify, did you say you will review applications as they are received? Or wait until the deadline to begin evaluating the applications?
A. Applications will be reviewed as soon as they are received.
Q. How will they work the rolling window if not everyone submits at the same time?
A. The earlier it is submitted the quicker we can review the information. All applications will receive equal consideration through the 4-week application window.
Q. Apart from the phase one and phase two is there another application window?
A. For this grant, there are no other application windows planned. The application window is 4 weeks in which to submit applications for this grant program.
Q. Are applications from the first phase (2-week window) prioritized in terms of awards?
A. All applications will be treated equally for the evaluation. Those submitted in phase one will be considered sooner but no awards will be made until all applications have been submitted in the 4-week application window.
Q. Friday August 19th at what time of day is the official deadline for submission?
A. 5 PM Central time is the deadline on Friday 8/19/22
Q. Are we able to submit multiple applications?
A. Multiple applications are allowed. If you intend to do so, please let us know which of them is ranked #1, #2 etc.
Q. Would you rather see a project that includes a small community and a rural area as one application or keep those separate in two applications. Jade mentioned keeping the higher cost areas for this program and more populated areas for BEAD
A. Either way is acceptable. We would like to see any multiple projects submitted by the same applicant be prioritized by the applicant at time of submittal.
Q. Do we have to submit all documents at once? Specifically, if a community wants to invest in our project but it needs council/commission approval, the 4-week timeline may be difficult.
A. If an applicant is in a situation requiring council/commission approval, it is recommended an application be submitted and let us know that more information will be coming. That way an initial program review can take place and we will then connect with the applicant to discuss any missing or delayed information such as described in this question.
Q. I assume you are using the “Submittable” system for applications? Is the “one at a time” restriction still there, or can we work on multiple applications at the same time?
A. This is a function that is inherent to Submittable. A team can collaborate on one project but only one project submission can be open for the responsible persons login. However, if you set up multiple email addresses for an end user, you could theoretically have multiple submissions going.
-For example, I could create multiple email addresses to point to me and monitor those boxes. [email protected], [email protected]… when creating the submission create a different login/email address for each project you wish to have open at once. This should allow you to work on multiple project submissions at the same time.
Q. For the filing of an “Intent to Apply”, the data gathering process for small and rural providers will take a bit of time.
A. The filing of an “Intent to Appy” is optional and is not a requirement for submitting an application. All applications must be submitted within the 4-week application window.
Q. If we are planning a Middle Mile Grant Application through NTIA, and plan to apply to this fund, and the plan would hinge on fiber placement through Middle Mile, would we go ahead and apply for fiber placement on this grant as a whole as we won’t know grant status on the Middle Mile Grant yet.
A. You can apply via this grant program to have a Middle Mile component of your plan, but you must also have a last mile component. The terms of this grant do not allow for a stand-alone Middle Mile application.
Q. If a project has just begun and is already under construction is it ineligible for this grant process?
A. Any project already started prior to this grant program would be ineligible for this grant.
Q. Can you explain the 24-month project period compared the statement where we have to have build out completed by 2026?
A. The goal is to keep the funded projects in a concise period of project development/construction, thus the 24-month window. If, however, there are circumstance that could cause a project to not meet that window, there may be room for some flexibility to be determined on a case-by-case basis. The requirement from Treasury is that all grant funds must be expended by December 2026.
Q. Is there a scoring criterion?
A. The application is divided into three areas and will have an overall “weighting” per area as follows: Approximately 50% will based on technical components, approximately 15% on financial components and approximately 35% on project components. Please refer to the posted guideline document for a more definitive breakdown of the subparts for each area.
Q. Is there any guidance that can be provided on the submittal of confidential information?
A. Anything an applicant marks as Confidential and Proprietary will not be posted. If we have questions about the material, we will initiate discussion with the applicant prior to posting any documentation.
Q. Will challenge results be announced?
A. We will work with the applicant and challenger to come to a resolution for each challenge that is received.
Q. If a proposed project partially infringes on an area already served with 100/100 (as found during a challenge process), would the entire application be rejected, or would the applicant have a chance to redraw their proposed project area?
A. We would give the applicant the opportunity to resubmit their application so their proposed project would not cause an over-build into an area already served at 100/100.
Q. Would you happen to have a copy of the presentation today or will it be posted on the website?
A. The entire webinar was recorded and should be on the KOBD web page shortly. The actual deck used for the webinar will also be posted.
Q. If we have further questions about anything on this grant program, who do we send our questions to for a response.
A. Use this email for all CPF Questions: [email protected] The question will be directed to someone to log, review and then respond.
Kansas Broadband Capital Project Additional Questions
Q: On page 9 of the CPF Program Guidelines document, the instructions state to use 2020 census block identifiers in defining the proposed service area. In the “Determination Of The Available Broadband Service” section, we are instructed to use FCC Form 477 and NBAM data to determine “served” status within the proposed service area, but the FCC Form 477 data is in 2010 census block format. Which census block format should we use for defining the proposed service area and determining broadband service availability status?
A: After further review, the 2010 census block data format should be used to define the proposed broadband service area, in lieu of the guidance on page 9 of the CPF Program Guidelines. The 2010 census block data format should also be used to determine broadband service availability status when populating the “Form 477_NBAM” spreadsheet.
Q. Are the staff labor costs to prepare the grant an eligible cost?
A. No. Grant preparation staff costs are not eligible expenses. Please see the posted guideline document for eligible and ineligible costs.
Q. With the 5-87% match on the sliding scale, what are some determining factors in where an applicant might land in that range?
A. Cost per location passed is the determining factor. There is a calculator in the guidelines to assist in determining this match.
Q. Are you accepting in kind match as a part of the % match?
A. Yes, up to 50% can be in-kind.
Q. Will county ARPA funds be allowed to be used as part of the match?
Q. what mapping is the state using to determine under and unserved? NTIA most recent data or FCC latest 477? Is there state specific mapping available?
A. Both the FCC 477 data as well the NTIA Broadband USA Data and Mapping tool (NBAM) will be required to be used by the applicant to verify their project area will not cause an overbuild into an area already served at 100/100. These same two resources will also be used by KOBD to validate the information contained in the application. At this time, a Kansas Office of Broadband Development map is not available.
Q. Regarding eligible areas: In areas covered by wireless service is the requirement that ALL households covered in the wireless coverage footprint must be able to simultaneously access the internet with a minimum of 100/20 to be considered underserved?
A. All areas served by the existing service provider must be able to offer their advertised speed in their entire area served. If there is a concern about simultaneous delivery of service at the advertised speeds, that situation will need to be validated by empirical data.
Q. what about technology? fiber focused?
A. The grant requires a focus on technology to deliver 100/100. We are open to looking at specific circumstances where that is not feasible. Further the project is required to deliver the same speed through out a proposed service area. Obviously, that is a challenge for fixed wireless.
Q. As an applicant, if an area is over-reported in terms of speeds available, does the majority rule for customer testimonials also apply? Is it also an either-or on the applicant side (i.e., speed tests or customer testimonials)?
A. Yes, the majority rule would apply. As noted in the program section, it is one or the other, not both.
Q. Challenge for fixed wireless areas that claims they serve the area with 100/20, if a tower site serves 75 locations and only can provide 100/20 to 2 or 4 locations but not the other locations, is this considered served at 100/20 or is the requirement to provide the 100/20 simultaneously to all locations? Is the requirement 100% or 90% of locations at 100/20 to be considered served?
A. It is a 100% requirement for 100/20 based on Treasury’s Guidance for the Grant. See earlier comment regarding simultaneous connections at advertised speeds.
Q. If the 477 shows an area is served with 100/20, but the NTIA NBAM shows the median test speed for the same area is much less than 100/20, is this considered unserved, or do we need to submit additional supporting documentation (speed tests, testimonials, etc.) proving the area is unserved?
A. We believe this situation would be unlikely, but any discrepancies will be handled on a case-by-case basis. Any additional supporting speed test data or any additional documentation would be helpful if this situation arises.
Q. For challenges where provider already exists, will Speed Tests AND Consumer Testimonials, or one or the other?
A. One or the other
Q. On the 477 map, if a provider is showing 1,000M down and 15M up, is that considered unserved? With having the download speed but not the upload, I wasn’t sure how that fit into the definitions.
A. Unserved: For purposes of the CPF Program, an unserved area is defined as a designated geographic area in which households or businesses are without a fixed, terrestrial connection supporting at least 100 Mbps download and 20 Mbps upload speeds. (https://home.treasury.gov/system/files/136/Capital-Projects-Fund-Guidance-States-Territories-and-Freely-Associated-States.pdf)
Q. What if it’s an area that has a 100/20 wireless company with no plans of building fiber, but the rural area has partnerships/funding to work with a provider to build the fiber capabilities?
A. Yes, in general this would be eligible as it is less than the desired 100/100. Please Note: While we are going to focus on unserved areas, that also means we will be looking for the degree of being unserved as compared to other projects being submitted. In other words, we will look at applications that are going to improve the offered speeds in unserved areas (less than 100/20) but we will provide more focus on areas like 25/3 that need to get upgraded to 100/100 vs an area that is at 100/15.
Q. Can end-of-line tests be used for to validate network performance on a challenge response?
A. Yes. This is essentially the speed test we are referencing. We would expect there to be a modem involved to represent the customer experience and that the maximum speeds shown for the end of line test to be offered as an available service. This is in line with the 477 data requirements.
Q: If we propose multiple projects under the same application, is the match request the same for the entire application based on the total customer count and cost or does it vary based on the cost and customer count for each individual project within the application?
A: The applicant match is calculated based on the entire application submission, not individual projects within the submitted application. The application must reflect the total application cost and total number of locations passed within the proposed service area(s). With this in mind, it may be more beneficial to submit separate applications for high-cost projects and low-cost projects.
Q: In one of our potential service areas, most of the census blocks show as unserved per the 477 and NBAM, but a couple of census blocks show as served, even though they are not. Would we only have to provide survey data/customer testimonials for half of the consumers in just the census blocks showing served in order to refute the 477 data? Since the rest of the census blocks already show as unserved on the 477 and NBAM, I assume that this would be sufficient data for them.
A: Supporting documentation is only required in the event you are challenging the accuracy of available mapping data. Survey data / consumer testimonials would be needed only for the disputed census blocks showing served according to the FCC Form 477 data. Survey data / consumer testimonials would not need to be provided for the remaining census blocks that show as unserved.
Kansas Broadband Capital Project Additional Questions
Q: Is $10M the maximum project size or grant amount? If a company is contributing $5M, can they apply for a project that is $15M? This assumes they are meeting and or exceeding the required match from the calculator.
A: The $10 million maximum applies to the grant award. Feel free to submit larger projects with the provider match taking the total over $10 million.
Q: 10 M project max and must happen in phases. Subsequent phases need to be resubmitted for grant applications. Would we have first consideration over other providers?
A: If approved for a $10 million grant, then that part of the grant is all that is approved. If more than $10 million is requested, then the additional amount over $10 million would need to be reapplied for in a future grant program with no guarantee that it would be funded. Please see the applicable language below from the program guidelines:
From the Program Guidelines:
* – Note: Projects over $10M may be submitted but will only be considered as a multi-phased approach with a maximum of $10M awarded in the first phase. If the initial phase is funded, the Kansas Office of Broadband Development does not guarantee future phases will be automatically funded as each successive project phase will need to be re-submitted for award consideration.
Q: The Program Guidelines state that eligible costs include 5% of pre-project development. Is that 5% of the total pre-project costs that we incur can be included or 5% of the total project award amount can be pre-award costs?
A: Eligible pre-project development costs can be included up to 5% of total project costs.
Q: When I try to access the application, I get the following error: “You are logged in as [email protected] but not have access to this page…” Please advise how I can access the application.
A: When a user arrives at the landing page that generates the following error “You are logged in as [email protected] but not have access to this page.”, there are three weblink options below the error statement that can be selected:
Kansas Broadband Capital Project Additional Questions
Q. If a public entity applies and is awarded a grant, can the network later be transferred to a private provider?
A. If a public entity receives an award and needs to transfer to a private provider, it must follow the 2 CFR 200.311 guidance which states that property purchased/improved with federal funds must be used for the originally authorized purpose as long as needed for that purpose. When the property is no longer needed for the purposes of the Federal award, the nonfederal entity must obtain disposition instructions from the Federal awarding agency (Treasury) or pass-through entity (KOBD). KOBD is awaiting additional guidance on property ownership from Treasury.
Kansas Broadband Capital Project Additional Questions
Q: How can we learn more about existing KDOT construction “Dig Once” efforts? And identify govt owned broadband networks? Is there opportunity to re-connect with the energy provider in GKC to save us costs?
A: Utilities such as energy companies or electric cooperatives should be contacted directly regarding potential partnerships. The Kansas Electric Cooperative, a statewide service organization for 26 KS Electric cooperatives can also provide information or assistance. Our primary contact there is Doug Shepherd who can be reached at [email protected].
Mike Floberg is the contact for Dig Once projects. He can be contacted via email at [email protected]. KDOT related Dig Once projects can be found here: Projects – KDOT IKE Program (ksdotike.org)
Local public works departments are also an important partner for right of way, locates and local build coordination. Having partnership support from these critical partners are helpful in advance as well.
Q: Does each census block that has a service provider offering speeds at 100M x 20M or greater require justification documentation? I am requesting clarification on the instructions written on page 16, § Justification Requirements Documentation, 1.) & 2.). As written, this appears to request a separate document for each census block and census tract inside the proposed project area. If this is accurate, the volume of documentation would be quite large and extremely repetitive. Since our project areas may contain several contingent blocks/tracts, the justifications for one block/tract would be the same for all.
A: The initial guidance was that justification documentation would need to be provided on a per census block basis for those census blocks in which carriers are offering at or greater than 100M x 20M services. After further review, in order to reduce the justification documentation and application submission time, justification documentation will be required for each unique group of census blocks that demonstrate the same characteristics. See details below:
Q. Service Partners list and Service Partners Letters of Support – Can you define who a Service Partner will be? Does this include contractors who may be doing the work? If so, does that include both construction and engineering firms?
A. A service partner is any entity outside your organization that has been contracted or enlisted to support the overall project. Partners for broadband infrastructure projects typically include, but are not limited to, engineering and construction firms, surveyors and / or equipment providers. For those partners involved with designing and placing infrastructure, it is important to have a document project timeline commitment from these firms.
Q. Maps – On the application it says to submit GIM Map of Proposed Service Area Publicly Posted. Should we also submit a Confidential GIS Map of the Project and if so where should we include it on the application?
A. Yes, there is a requirement to provide a map we will post online that does not have confidential information on it. The second map will provide details that you may not want other service providers to see. The detailed maps are needed to confirm plans and validate census block level data.
Q. Grant Amounts – Is the $10 Million total for a Grant per application or per company? For example, would a company be eligible to receive more that $10 Million if 3 of their applications are approved?
A. The $10M total for a grant is on a per application basis. Companies may submit multiple applications and are eligible to receive multiple grant awards.
Q. Budget – On the High-Level Budget Funding Template there is a section 1) Pre-Project Development Costs that has categories of: Data Gathering, Feasibility Studies, Engineering Design, Environmental, Permitting, Other and says that the total should not exceed 5% of the total project budget. In the webinar it was said that “Grant preparation staff costs are not eligible expenses”. What would be considered eligible Pre-Project Development Costs?
A. To clarify, allowable Pre-Project Development Costs consist of: Data Gathering, Feasibility Studies, Engineering Design, Environmental and Permitting and other direct costs in developing the project. The pre-project development costs total should not exceed 5% of the total project budget. This would not include staff costs necessary to prepare your grant application.
Q. The Program Guidelines state that eligible costs include 5% of pre-project development. Is that 5% of the total pre-project costs that we incur can be included or 5% of the total project award amount can be pre-award costs?
A. 5% of the total project award amount can be pre-project development costs.
Q. I was hoping we could get some clarification on the eligibility criteria regarding locations within RDOF blocks. Many of the blocks within our project area have not yet been authorized by the FCC. These blocks would be offering Gigabit service, but we don’t know when or if these providers will be authorized to receive RDOF funds to serve these locations. If a block has not yet been authorized for RDOF funding would the locations within those blocks be considered eligible for funding through the CPF Broadband for Infrastructure Program?
A: On page 16 of the CPF Program Guidelines document, it states that areas already receiving funding for broadband expansion from other sources are ineligible. One of the ineligible areas specifically called out are areas with certified awards thru the FCC Rural Development Opportunity Fund (RDOF) with more than 100/20 Mbps wireline/fiber speeds enabled. To clarify further, “certified award” means that the FCC has issued a public notice announcing authorization of support for the winning bidder AND directed USAC to begin disbursing payments to the RDOF winning bidder. Additionally, any winning bidder awarded RDOF census block(s) in which the FCC has not issued a public notice announcing authorization of support for the winning bidder AND not directed USAC to begin disbursing payments for, is an eligible area within the CPF Program. RDOF winning bidders with census blocks in any applicant’s proposed service area(s), but not yet authorized and receiving payments from the FCC, are encouraged to file comments through the public comment process regarding the “served” status of their defined RDOF project(s) areas. Public comments should be submitted in accordance with the instructions starting on page 6 of the CPF Program Guidelines Program document, as listed on the Kansas Department of Commerce website (https://www.kansascommerce.gov/program/capital-project-funds-broadband-infrastructure-program/).
Q. Could an applicant submit an application requesting that just the drops be funded? Would this be an allowable expense if the drop capital has not been planned or spent?
A. Fiber drop-only projects would be an eligible project when viewed as a stand-alone project. For a drop-only project to receive an award, it will be assessed and scored along with all other applications to ensure the funding would meet the grant program guidelines and achieve the desired outcome of awarding grant funds under this grant program. Existing speed-of-service offered in a proposed service area is a key evaluation item and the availability of existing service via a main line fiber greater than the minimum requirements will be carefully reviewed. Applicants submitting a drop only project should provide a compelling case that clearly justifies why Capital Project Fund grant funds should be invested in areas of the State where providers already own established infrastructure but have not yet connected homes or businesses.
Q. On page 11 of the program guidelines under the heading “Letters of Commitment, Letters of Support” there is mention of letters of commitment from partners for Planning, Engineering, and/or Construction. Are these letters required to be considered for the grant, if for example, a construction company has not been selected for the project?
A. If no engineering company has been selected then no letter of commitment can be secured. The guideline language was to assist the applicant in knowing what was to be included if an engineering partner had already been secured.
Q. Can the network architecture diagram be a .pdf file? Is this the same as a plant map showing fiber routes and electronics?
A. Yes, the network architecture diagram should be a .pdf file. A network architecture diagram is not the same as a plant map showing fiber routes and electronics. As referenced on page 13 of the CPF Program Guidelines document, the network architecture diagram should include “….network connection point / connection to point of presence, router(s) types, optical line termination units, optical network termination devices, central office / controlled environmental vaults, middle mile and associated fiber/ physical connectivity types”. To provide additional clarity, the network architecture diagram should include the equipment that forms the components of the network, the identified media that physically connects the hardware devices on the network and the overall topology showing how the devices are all connected together to form the network that will support the solution in the proposed service area. The architecture diagram should include the topology inclusive from the customer premise to the internet point of presence connection.
Q. How would you like us to present different territories within the application in order to prioritize them? Do we just include that in the narratives, or do we need to submit separate budget templates as well?
A. The preferred approach is to have the applicant submit separate applications for each community or territory solution. If, however, the applicant proposes services across multiple communities / territories in one application, separate narratives and associated budget templates should be provided for each community / territory project to ensure the project justification and demonstration of need is clearly articulated. Within the multi-project application, an applicant needs to specify if each project can be funded separately, if a certain set of projects must be funded together, or if the application can only be funded as a whole set of projects. Also, an applicant should prioritize different community / territory solutions or projects based on a 1 to n priority, with 1 being the highest priority to fund and “n” being the lowest priority.
To further clarify Program Guidelines on page 4, (Eligible Areas paragraph), applications that contain non-contiguous areas that are more than 10 miles apart should include separate narratives and associated budget templates to ensure the project justification and demonstration of need is clearly articulated for each respective community/territory. For definition purposes, a community would be generally defined as a group of people sharing a common geographic location within a reasonable proximity to each other; a territory would be considered a geographic area larger than a community and as large as a county.
Q. There are a couple of places that the Form 477 states our company serves customers within the area we are proposing to serve (because the whole census block is reported as served even though we are only in part of it). Do we need to submit a official letter on letterhead confirming that those locations cannot currently be served or can we just include that in our narrative discussing the results of the competitive analysis.
A. In areas that the FCC Form 477 states that service is available and there is credible evidence that the entire census block is not served from an applicant who is also the incumbent, please describe the specific circumstances and present the summary evidence in the narrative. Additionally, any census blocks meeting this criteria must still be included in the list of census blocks defining the proposed service area.
Q. Quick technical question on the FCC 477 form. I know we are to list all census blocks we intend on serving. If the FCC 477 data for the blocks don’t list any provider offering speeds of at least 100/20, do we have to list them? I couldn’t remember if we were to list ALL providers or just those that meet the speed threshold.
A. The census blocks defining the proposed service area need to be listed in the “Form FCC Form 477 Results” worksheet located within the “Form 477_NBAM080122.xlxs” spreadsheet. If there are no service providers offering 100 / 20M services in a census block according to FCC Form 477 data, leave the associated “Service Provider Offering 100 / 20 Mbps or Faster” column blank for that census block, no other documentation is needed for this census block. If, however, a service provider is offering speeds at or greater than 100 / 20 Mbps speeds in a census block, an “x” must be placed in the column labeled “Service Provider Offering 100 / 20 Mbps or Faster” and the “Service Provider 1, Max Speed” column should be populated according to the examples found in worksheet.
Q. Does 250/100 cover the 100/100 requirement or does it have to be synchronous?
A. Minimum speeds of 100/20 are required per the guidelines and scalable to at least 100/100. Anything over that qualifies as acceptable. Page 1 in the guideline states:
“The CPF Program will deliver speeds that meet or exceed symmetrical speeds of 100 Mbps. If it would be impracticable, because of geography, topography, or excessive cost, for a Broadband Infrastructure Project to be designed to deliver services at such a speed, the proposed project must be designed so that it reliably meets or exceeds 100 Mbps download speeds and between 20 Mbps and 100 Mbps upload speeds and be scalable to a minimum of 100 Mbps symmetrical for download and upload speeds.”
Q. Where do we find the census tract map as I see we have to list all census tracts also?
A. For the FCC 477 required information use this link: https://broadbandmap.fcc.gov/#/. For NBAM required information use this link: https://broadbandusa.ntia.doc.gov/resources/data-and-mapping These links were also provided in the webinar. That webinar deck can be found on the Kansas Broadband Web page under Program Resources. Go to slides 19 and 20 on the PowerPoint deck.
Q. Is an active SAM.gov registration required to apply for this grant award?
A. Since the Broadband Infrastructure Program is funded by the Capital Project Fund plan under the American Rescue Plan Act (ARPA), an active SAM.gov registration is required to receive your grant award under this program. Your organization must have an active “entity registration” with the Federal System of Award Management (SAM or SAM.gov). SAM.gov is an official website of the United States government. You do not need an active SAM registration to submit you application but strongly encourage to begin the process as soon as possible.
Please see the additional SAM.gov registration resources below:
Kansas Broadband Capital Project Additional Questions
Q. On the Capital Project Fund application, do we have to prioritize all non-contiguous areas even if they are part of one application and follow the 10-mile, $10million constraints per application? Or, are we submitting the multiple areas within the common application as one proposed funded service area?
My understanding is that we don’t need to prioritize if the multiple areas are included on one application… but, if we submit multiple applications, then those applications need to be prioritized.
A. The preferred approach is to have the applicant prioritize all non-contiguous areas even if they are part of one application. If the applicant proposes services across multiple communities / territories in one application, separate narratives and associated budget templates should be provided for each community / territory project to ensure the project justification and demonstration of need is clearly articulated. Within the multi-project application, an applicant needs to specify if each project can be funded separately, if a certain set of projects must be funded together, or if the application can only be funded as a whole set of projects. Also, an applicant should prioritize different community / territory solutions or projects based on a 1 to n priority, with 1 being the highest priority to fund and “n” being the lowest priority. If multiple applications are submitted, those applications would need to be prioritized on a 1 to n priority as well. For definition purposes, a community would be generally defined as a group of people sharing a common geographic location within a reasonable proximity to each other; a territory would be considered a geographic area larger than a community and as large as a county.
Q. On the Budget Spreadsheet to the very right are cells for Plant Miles and Passings Proposed. These cells are password protected so wasn’t sure if that was something we need to enter or not. Please let me know how to enter the information if it is needed.
A. These cells were locked in the original version of the spreadsheet that was available in Submittable. A new version of the spreadsheet is now available in Submittable with these cells unlocked. Please download and use the current version of the spreadsheet that is available in Submittable.
Q. On our build dates – when does our window of time for completion begin?
A. The completion window for a project will be explained at the time your award kick-off meeting is conducted. That end date will be provided in that kick-off meeting.
Q. Would you please clarify the award reimbursement expectations? Will the awards be disbursed all up front, at certain milestones, or all at project completion?
A. The reimbursements for the CPF Infrastructure grant program will be processed quarterly through the Submittable portal. Progress reports will be due on the 5th of every month. Supporting documentation (invoices) for expenditures included in the progress report will need to be uploaded to the portal to validate reimbursements every month. Once invoices are successfully validated and the reports are showing progress, reimbursements will be processed quarterly on/near the following dates:
December 5th, 2022
March 6th. 2023
June 5th, 2023
September 5th, 2023
This reporting process will continue on this cycle until the project completes. 10% of the Grant amount will be held until the final completion of the Project and will be paid out upon the successful closeout of the project.
Q. a. In both of our proposed project areas, FCC 477 data reports these areas (census blocks) as served 100/20 Mbps by Mercury Broadband (FW). However, the NBAM speeds (census tract level) reported are significantly less.
b. Since both of these sources are required for the application, how will the BB office evaluate these discrepancies? Do we need additional supporting customer testimonials/speed tests? We are confident that given the terrain in these areas (heavily wooded, terrain variation in terms of height), that 100/20 FW service would not be available.
i. If additional supporting documentation is required, the majority requirement seems like a lot in this scenario.
A. The Kansas Office of Broadband Development will evaluate these discrepancies by comparing all objective evidence provided by the applicant who is disputing that the proposed service area is served (i.e. – provides at least 100/20 Mbps to all locations within the proposes service area census blocks). Yes, additional supporting customer testimonials / speeds tests would be expected if the FCC Form 477 data suggests a significantly different service level capability compared to the NBAM census tract results. In summary, expected evidence would include FCC Form 477 data, the NBAM census tract results, speed tests from locations within the service area as well as broadband testimonials from individuals living within the service area. Concurrently, The Kansas Office of Broadband Development will be evaluating the evidence provided during the formal Public Comment period from any person or organization affirming that the service area is served (by definition) and comparing that information to the applicant’s submitted information. Information expected from the current service provider challenging the applicant’s unserved opinion to demonstrate served status (i.e. – to refute derived unserved status according to the applicant) would include but not be limited to speed tests, infrastructure drawings showing physical capabilities, RF design and heat maps showing signal frequency distribution across the proposed service area with the relevant information overlayed onto a map with all identified locations within the respective census blocks to be served. The Kansas Office of Broadband Development will render a served / unserved status based on the evidence provided by both parties.
Q. For our financial verification letter, would it be acceptable to provide a letter that verifies our current available sources under our borrowing facilities that we could use for all 5 of the applications we intend to submit? Trying to determine if we can avoid requesting 5 separate letters?
A. One bank verification letter per organization is sufficient so long as it includes the collective amount of “required applicant match” that is being proposed for all projects submitted.
Example: If 3 projects are being submitted and the required applicant match for EACH project is $100,000- the bank verification letter will need to state that the organization has a minimum balance of $300,000.
Q. Could you please define “social vulnerability index”?
A. The social vulnerability index can be found here: https://www.atsdr.cdc.gov/placeandhealth/svi/index.html
There is additional information regarding the social vulnerability index here: https://svi.cdc.gov/Documents/Publications/CDC_ATSDR_SVI_Materials/SVI_Poster_07032014_FINAL.pdf
Q. We are working to on 2 grants to submit for the capital projects. Based on the timeline published are these grants due on Aug 15 or Aug 17 or Aug 25?
A. All applications for the CPF grant will need to be submitted by 5 PM Central this Friday, August 19. This will be at the end for the 4 week application period which was started on Monday, July 25.
Q. What are you looking for in the second text box? How is it different from the first?
A. Yes, you are correct. This should be a text box and an upload section. This has now been corrected.
This map was developed for the Kansas CPF Broadband Infrastructure Grant Program and outlines the previous fiber and hybrid investments made through the Connectivity Emergency Response Grant, and the Broadband Acceleration Grant (rounds 1 and 2) as of 08/2022. This is not intended to be an explicit representation or a conclusive source for address-level data. Wireless wasn’t included because of the CPF Broadband Infrastructure Grant Program’s minimum requirement of 100/20 Mbps.