July 16, 2009

Thank you to all service providers that participated in the process of coordinating Vermont’s broadband stimulus requests.  Your cooperation is helping us provide potential applicants with information you will need to justify your requests for funding and will help us get as many service expansions as possible funded in Vermont.  As you know, one of the key steps in submitting an application to BTOP and BIP is to define one or more service areas made up of contiguous census blocks, and to provide analysis that each service area is “unserved” or “underserved”.  (Based on our reading of the applications and Q&A at the Dedham workshop, applications to BIP can have a quarter of their service area by area comprised of served Census Designated Places within the service area, and still qualify.)

Vermont has undertaken mapping of broadband service availability for some time, and while not perfect, it is much better than most states have.  We are attempting to refine the information we had as of the last published update (end of 2007/beginning of 2008) to account for major known broadband expansions in 2008 and to better reflect the definitions contained in the NoFA.  However, to allow you to get started in your analysis of census blocks, we have posted a Census Block Package for Vermont Infrastructure Applicants to http://recovery.vermont.gov/broadband.   The package includes a draft analysis of broadband availability by census block, based on the last published map in Vermont.  This includes a PDF of the Vermont Census Blocks.  There are GIS layers containing the source data for all census blocks, and a smaller set including just the census blocks in the Standard Service Areas.  Also included are a list of the census blocks in Vermont with their ID number, and a list of the blocks included in the Standard Service Areas.  We do expect at least some change in the “% served” for many census blocks upon further review.  (Please note some blocks contain no data on availability; these are most often blocks with few or no structures.  We expect the refined map to include fewer of these)

One of the key steps to ensure that projects in as many areas as possible can be funded is to achieve geographic coordination among applicants.  All applicants in rural areas must apply to BIP if they wish to be considered for either BIP or BTOP funding, and a decision by BIP to fund one project that partially overlaps another proposed project (de minimus overlap excepted) will eliminate that project from further BIP consideration.  Therefore, we believe it will increase all applicants’ chances of being funded and best assure that all of Vermont ends up funded if you all make proposals that do NOT have geographically overlapping service areas.

Here’s an example based on the referenced maps: If provider A applies for all of service area 12 but adds coverage to Stratton, Somerset, and and Searsburg in Service area 13 and provider B applies for service area 13 alone, one of these two grant requests will be rejected because of the overlap. Unless there are other applicants involved, either all of service area 12 or most of service area 13 will end up without coverage. If the applications don’t overlap, both can be approved and full coverage of both service areas will be achieved. Of course two applicants may end up requesting the same service area; hopefully the best application will be chosen in that case, but it won’t affect applications for neighboring areas. 

To this end, based on the responses we have received in our earlier requests for comments, and our related conversation, we strongly recommend that all applicants from Vermont for last-mile infrastructure projects submit applications that do not mix geographic areas from different “standard” service areas. Although our maps are available for all applicants to use, we will not recommend projects which overlap service areas boundaries (or meet other applicable conditions) and will take service area boundaries into consideration ourselves when applications are returned to us for review and recommendations after the first stages of federal review. If applicants are interested in making  proposals to serve more than one service area, we would ask that they submit them as separate applications.  This will minimize the instances when an application from Vermont is not funded due to a decision to fund a project in a neighboring area.  These service areas have been drawn to take into account these criteria:

• The responses of potential Vermont applicants regarding where they are interested in providing additional service.
• Where possible, segregating of “remote” and “non-remote” areas (remote areas qualify for greater BIP grant funding).

In some instances there may be only one or two service providers with an interest in submitting in a particular standard service area.  If there is limited interest in applying for funding for particular areas, it may be possible to combine some standard service areas in a single application, reducing the burden on applicants, and increasing the number of unserved households which can be reached in a single application.  For this reason, we ask that you please confirm with our office as soon as possible which standard service areas you plan to apply for so we can provide further guidance.

Some of these standard service areas may qualify for BIP or BTOP funding in their entirety, and others may only qualify if some number of more highly served census blocks within them are excluded from the application.  We leave it to applicants to determine which better-served census blocks to exclude from an application in order to qualify, but we strongly recommend that applications include all of the unserved locations within the standard service areas.  Covering these areas are our highest priority and we believe will produce higher-scoring proposals as well.   We are conducting further analysis to determine whether the whole of each standard service area in total can qualify as “unserved” or “underserved,” or, if not, which fraction of it would.

Some applicants may choose to apply for some additional areas next to a standard service area which are not assigned to any of the standard service areas, especially since NTIA and RUS will be evaluating applications based on the current extent of service, and not pending expansions.  As long as these additions are modest neighboring additions, and do not cross into a neighboring standard service area, we think it is unlikely that this will produce problematic overlaps.  However, we ask you to let us know as soon as possible if you plan to submit an application that includes any territory not in a standard service area so that we can work with applicants to eliminate overlaps that could cause your application to be rejected because a neighbors’ was approved.  Achieving coverage within the unserved parts of the standard service areas is our highest priority.

We know you are all working hard to understand the complicated set of rules that these programs are operating under, and we commend that effort.  Now is the time for the final push.  This is a great opportunity for Vermont to meet our critical need for broadband service throughout the state.