USDA’s new ReConnect broadband grant rules dramatically expand eligible areas and effectively redefine broadband

With the release of a Notice of Funding Availability (NOFA), the US Department of Agriculture's Rural Utilities Service (RUS) has made important changes for Round 3 of its ReConnect Program. RUS has included a preference for local governments, non-profits, and cooperatives as applicants and added additional points to those applications. Further, 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. And 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. New to the program is a separate funding option in which applicants can seek up to $35 million for Tribal and socially vulnerable areas. Ultimately, communities seeking funding need to know that they’re not excluded from consideration just because FCC Form 477 data indicates connectivity. But they still need to show that they are under the 100/20 threshold. Applicants should focus their narratives on not only the need for broadband, but the need for broadband in light of lessons learned from the Covid-19 pandemic. Be sure to include discussion and reference to the need to “build back better.”

[Heather Mills is Vice President for Grant and Funding Strategies at CTC Technology & Energy.]