NTIA Releases Middle Mile Scoring and Application Guidance

On September 28, 2022, NTIA released a series of blog posts providing additional information on the Middle Mile Program application requirements and review process.

In the first blog post, NTIA discusses the following:

  • NTIA’s 3 Phases of Review: Initial, Merit, and Programmatic
    • Initial Review: In the Initial Review NTIA will review applications for completeness, eligibility, and the applicant’s responsiveness with regard to curing any issues NTIA flags in the application.  Every application will be examined through the Initial Review and those that clear will make it to the Merit Review.
    • Merit Review: In the Merit Review, NTIA will assign up to 100 points to each application and then prioritize those applications that average 80 or more points and meet 2 of the 5 statutory criteria outlined in the Notice of Funding Opportunity (linked above).  If the prioritized applications amount to $1 billion or more, then NTIA does not guarantee that applications averaging less than 80 will be considered during the Programmatic Review.
    • Programmatic Review: In the Programmatic Review, NTIA will take applicants’ merit scores and apply a weighting factor based upon how well the applicant addressed specific details outlined in the NOFO.  Based upon this final weighted score, NTIA will make recommendations for selection.
  • First Major Section of the Application: Applicant Information
    • NTIA considers this section to be its primary opportunity to learn about the applicant’s experience, partners, nature of the partnership, and any agreements currently in place.
    • NTIA emphasizes that it wants to know about other projects of a similar size and scope, and applicant’s key personnel and support.
    • Applicants should ensure all required forms and documents are included

In the second blog post, NTIA discusses the second major section of the application: Project Information.  In particular, NTIA highlights the following:

  • Applicants must complete all three portions of this section, which include: the details and timeline of their project, an executive summary and level of need narrative, and a description of government and community involvement.
  • Applicants must demonstrate a binding commitment to prioritize one of the following: connecting middle mile infrastructure to last mile networks that service unserved areas; connecting non-continuous trust lands; or offering wholesale broadband at reasonable rates.
  • Applicants should commit to at least 2 of the following 5 criteria to be considered in the Programmatic Review stage:
    • Adopting fiscally sustainable middle mile strategies;
    • Committing to offer non-discriminatory interconnection to parties that request it;
    • Identifying specific terrestrial and wireless last mile broadband providers that have requested interconnection and demonstrated sustainable plans;
    • Identifying supplemental investment or in-kind support to accelerate completion of project; and
    • Demonstrating that middle mile grant infrastructure will benefit national security interests.
  • Applicants should demonstrate other key factors, such as how the project will result in a decline of costs to the consumer, rate plans for interconnecting providers, and how the project will provide substantial benefits to their community, among other things.

In the third blog post, NTIA discusses the final major section of the application: Budget Information.  In particular, NTIA highlights the following:

  • Applicants should showcase the financial success and sustainability of their project.
  • Applicants are not required to provide a letter of credit at the application stage, but must provide at least a letter from a bank that states the bank commits to making a Letter of Credit available if the application is selected.
  • Applicants that are participating as part of an informal partnership are only required to provide financial information for the primary applicant, though financial information for the sub-recipients is encouraged.  Formal LLC applicants, however, are required to send the financial details for all companies that form the LLC.
  • The reasonableness of the proposed budget and the ability of the applicant to deliver a project of the scope described will play a large part during the Merit Review.

Overall, NTIA reminds applicants that applications that focus on how the project will address the program’s needs, include all required forms, provide complete, detailed information in each section, and are consistent and accurate throughout each section will be the most likely to receive large scores and be granted funding through the Middle Mile Program.

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