WiMax.com article
Haste Makes Waste in the Broadband Stimulus Process
By Charles Bobo

The Broadband Stimulus program is the equivalent of a 'land grab', comparable to the Oklahoma Land Rushes of 1889 and 1893, events that coined the term, Sooners. Companies big and small are scrambling to grab their piece of rural America broadband real estate. Consider there are seven times more funding requests than funds to disburse in round one. At first glance it appears many of the applicants either misunderstood the NOFA (Notice of Funds Availability) guidelines, or just chose to ignore them. The question looms, how is a small organization, without the necessary manpower or resources, able to submit an application without being rejected due to the slightest violation of a guideline? Before we address that question, let’s review a few of the program’s basic facts and challenges.

An Excellent Program in Spirit
The Broadband Stimulus Program is an excellent program in spirit. According to statistics, more than 10-million residents in rural communities through this country are without high-speed broadband; which, according to the NOFA, is a very modest 768k. That’s a speed most of us upgraded from 10-years ago. But to rural Americans, it equates to exchanging the mule for a tractor. It provides farmers with access to agriculture markets, students with access to school, and families with access to an incredible array of tools and opportunities to improve their quality of life.

The broadband program is to primarily focus on 1) infrastructure, 2) public computing centers, and 3) sustainable broadband adoption projects. The most significant focus is the building of infrastructure, as that is the key ingredient to get rural communities onto the “Information Super Highway” (an old word for most of us, but a new reality for rural America). However, like most government programs, the NOFA’s more than 63,000 words are nearly indecipherable and reek of ambiguity when laying the guidelines to address such simple needs. To put that into perspective, a typical grant application, including signed legal attachments, is about 100 pages and perhaps 5,000 words. So, the government has provided applicants with a 63,000-word rulebook for a 5,000-word application, a ratio of nearly 13:1.

The vast array of application types and strategic approaches appears to indicate some confusion as to goals to be attained and reflects the government’s haste to get the program off the ground. There is confusion throughout the process. Just peruse the grants database for any state, and one will find a myriad of application types and strategic approaches. And each applicant organization can probably find a legitimate angle from which to justify its strategy. No doubt, this may result in difficulties for reviewers establishing “apples to apples” score cards in the selection process.

Vast Array of Obstacles in Application Process
One of the more significant obstacles is the NOFA’s definition of rural, non-rural, and remote. The meaning of any one classification can change based on several mitigating factors. One would assume it’s a simple process of elimination, but it is not. The biggest mistake the NOFA authors made in this regard was to require a remote-classified community to be no less than 50-miles from an urban area of at least 50,000. That might work well in most states west of the Mississippi, but not east, where the states are smaller and communities much closer. That distance requirement did not take into consideration the country’s vast differences in geography and topography, which plays a much more significant role in planning infrastructure deployment. This seemingly simple issue will reclassify many grants that should have remote status, pushing them down the scoring list. This is most unfair to residents within those communities and defeats the spirit of the broadband program.

There is a trap in the application process with the wording “contiguous census blocks”. Within a small community of only a few thousand, there are hundreds of census blocks. A census block can be as small as an individual neighborhood with 10-15 homes. According to the NOFA, if any list of contingent census blocks is found to have a single block that fails to meet the minimum definition for “underserved”, the entire application is rejected. That is a huge trap for applicants that submitted large sweeping-area requests that covered an entire state or multiple states. There is not a single state in the nation where the entire state is underserved. This is one of the NOFA’s better requirements, as it forces applicants to build strategies around individual communities. However, the humor in this is the method employed to determine broadband saturation. There actually is no method, because the national broadband map does not yet exist. Therefore, the method to determine the extent of broadband saturation is left up to the applicant, who can simply claim to have adequately researched the area. Unfortunately, the burden of proof shifts to the already-existing broadband provider within that community to prove otherwise.

One of the more disappointing aspects of the application is the 2-page limit for system design description. Potential success or failure of the project rests upon this. The project's budget is based squarely upon this valuable data. But the application process allocates more space to lobbying documentation than to requiring applicants to prove the legitimacy, cost-effectiveness, and budgetary needs of their system designs. As a result, if an applicant desires to share a bigger vision of how they intend to leverage a smaller grant to build an even larger network down the road, they risk having the application rejected simply due to providing too much information.

Let’s refer back to the original question: “How is a small organization, without the necessary manpower or resources, able to submit an application without being rejected due to the slightest violation of a guideline?”

Tips for Application Strategy
First off, it’s doubtful even the reviewers are able to competently decipher all the rules — score one for the applicant. From a more strategic approach, keep the application process simple and do not tackle too much at one time. Avoid any potential overload. Submit multiple, small applications rather a single sweeping request that covers the northern hemisphere. Approach projects and communities individually. This enables the applicant to tailor a solution and will minimize the potential for error and oversight. Also, the applicant should never bite off more than it has a history of accomplishing. A company with revenues of less than $1,000,000 has no business submitting a $120,000,0000 grant or grant/loan request. Employ a little common sense here — the grant program was not meant to fund companies’ entire start-up or expansion costs. It was designed to entice companies to undertake projects that it might not otherwise have undertaken. Nor, was this program intended to offset budgetary shortfalls for public entities. It was developed to bring broadband to parts of America that have tremendous needs. The key to reaching rural America is through solutions tailored to address needs. That is better done with a rifle approach, rather than a shotgun approach. Rural American incomes are also lower, so avoid projects that have an average household deployment cost anywhere near $1,000. The project will be too expensive for most subscribers and, if not ultimately fail, will encounter continuous cash flow and profitability challenges.

The intent of the Broadband Stimulus program to deploy infrastructure in America’s un-served and underserved communities is highly commendable. The program should have stopped with that first round single directive. Until that infrastructure has been fully deployed and proven operational, the other directives of the program seem useless. What good are public computing centers and sustainable broadband adoption projects, such as telemedicine and educational programs, when the infrastructure has yet to meet such bandwidth demands? Those challenges already exist in the cellular war of 3G versus 4G in large metropolitan regions. The NOFA’s minimal speed requirement of 768k is too low, and barely supports many of today’s web sites. Infrastructure is the foundation, to be later complimented with the services and programs to draw maximum benefits for users.

Conclusion
As a passing final thought, it appears the many “volunteer” reviewers sought by the Feds to score grants did not materialize. As a result, they immediately punted the initial review process down to the states, rather than waiting until step 2, as outlined in the NOFA (page 5, column 3, line 9). In today’s tumultuous economy, there are very few qualified professionals willing to put their own business and jobs on hold to extend such favors to Uncle Sam. The Feds couldn’t find a way to take a smidgen of the $7.2 billion to pay reviewers for their time? There is a particular state that hired 40 consultants to review 151 grants. That’s the line in which most reviewers were probably standing.

Hopefully, the NOFA guidelines will be simplified and more refined for the second round of funding in 2010. But at this point in the program, it seems the spirit of the Broadband Stimulus Program has been polluted by the government’s haste to get the program on the streets. If most of us employed such tactics to launch our businesses or careers, we’d be staring at an eventual pile of rubble, as we all remember that old saying, “haste makes for waste.”