Current through Register Vol. 49, No. 9, September, 2024
EXECUTIVE SUMMARY
Purpose and emergency need
The Arkansas Economic Development Commission and the Arkansas
Broadband Office have promulgated an emergency rule that amended the Arkansas
Rural Connect Broadband Grant Program (ARC). The purpose of the rule is to
revise the procedure for disbursing ARC funds so that grant recipients will
receive grant funds in quarterly installments based on expenses incurred and
submitted to the Arkansas Broadband Office and verified by UAMS.
AEDC and the Arkansas Broadband Office have determined that an
emergency rule is necessary to continue to disburse funds to rural areas of
Arkansas for the deployment of broadband infrastructure. Broadband is a
critical tool for Arkansans to access telemedicine, distance learning, and
telework.
Key points
* The emergency rule allows the Arkansas Broadband Office to
award grant funds to recipients in quarterly installments. This reverts the
disbursement process to what it was at the inception of the ARC program and
before the CARES Act.
* There are no upfront payments.
* These installments will be based on expenses incurred by the
grantees and submitted to the Arkansas Broadband Office for reimbursement after
review and verification by UAMS.
* The Arkansas Broadband Office will promulgate a permanent
rule through the Administrative Procedures Act.
Effective date
The emergency rule is effective on November 19, 2021.
ARKANSAS RURAL CONNECT BROADBAND GRANT
PROGRAM
Emergency Rule
Section
1.
Purpose
The purpose of this proposed Rule is to help implement polices
advanced in the "Arkansas State Broadband Plan," (hereafter, the "Broadband
Plan Report") as issued by the Office of Arkansas Governor, Asa Hutchinson, on
May 15, 2019. The proposed rule is intended to establish requirements for
governmental entities to participate in the Arkansas Rural Connect Broadband
Grant Program (hereafter, "ARC," or the "ARC Program") in order to provide or
expand broadband services consistent with the Broadband Plan Report, resulting
in increased educational opportunities, healthcare opportunities, and economic
development opportunities and ensuring all Arkansans have equal access to the
services they can use to improve their quality of life, their community, and
this State.
Section 2.
Introduction
As broadband access becomes more necessary to normal modern
life, there is growing concern about a digital divide, whereby some areas are
cut off from opportunities for economic development by a lack of adequate
broadband service. To help close that digital divide, the ARC Program is being
instituted to help communities incentivize providers to deploy adequate
broadband service to their residents. The program will provide funds to
internet service providers (ISPs) to serve target municipalities at the request
of those municipalities. ARC funds will be allocated on a competitive and
transparent basis, with efforts made to maximize the impact of scarce state
funds.
Section 3.
Authority
This proposed Rule is issued by the Director of the Arkansas
Economic Development Commission ("AEDC") under Ark. Code Ann. §
15-4-209(b)
(5) which provides that AEDC may promulgate
rules necessary to implement the programs and services offered by AEDC. On or
about August 9, 2019, Governor Asa Hutchinson authorized a transfer of funding
for the implementation and administration of the ARC Program to AEDC. Pursuant
to Ark. Code Ann. §
15-4-209(a)(1),
AEDC is authorized to administer grants to assist with the economic development
in the State. The ARC Program is therefore authorized to administer the ARC
grant and authorized to establish administrative rules under Ark. Code Ann.
§
15-4-209(b)
(5) as a service offered by AEDC.
Section 4.
Definitions
(1) "25/3" means
minimum speed 25 Mbps download/3 Mbps upload.
(2) "AEDC" means the Arkansas Economic
Development Commission.
(3) "ARC"
means Arkansas Rural Connect.
(4)
"ASBO" means Arkansas State Broadband Office.
(5) "Available" means, in the case of
broadband service, that a provider stands ready to provide broadband service to
a location within thirty (30) days of a request for service being
made
(6) "Broadband" means, for
purposes of these rules, an internet connection by fiber optic cable, coaxial
copper wire, DSL, or fixed wireless with at least 25/3 speeds, latency less
than 100 ms, and no data usage caps or throttling below 150 Gb per
month
(7) "Community" means a
municipality, unincorporated community, or county
(8) "ESRI Shapefile" means a geospatial
vector data format that can be utilized by ESRI or other GIS software
(9) "Interdependent projects" means projects
which are part of a set of projects involving the same ISP, each of which the
ISP commits to implement only if all of the projects in the set get funded, and
will be assumed for purposes of project selection to be less desirable to
implement if some of the projects in the set are not funded. This may occur,
for example, if deployment involves creating shared assets that need to recover
costs from multiple projects to be economically justifiable. The ASBO will take
note of the interdependent nature of the projects, and avoid approving any
interdependent project if the other projects in the interdependent set are not
also funded.
(10) "ISP" means
Internet Service Provider, its successors or assigns
(11) "Location" means any structure that is
legally fit for occupancy as a commercial or residential dwelling.
(12) "Mbps" means megabits per
second
(13) "Municipality" means a
legally incorporated municipality under Arkansas law
(14) "Project cost" is the entire capital
cost of a broadband project
(15)
"Project footprint" is the geographic territory within which a project will
provide broadband coverage
(16)
"Project organizers" means public officials, ISPs, civic groups, or anyone else
who takes a leading role in developing an Arkansas Rural Connect broadband
project. While projects may be catalyzed, initiated, organized and developed,
in principle, by anyone, the set of people who can actually submit applications
for Arkansas Rural Connect grants is more limited, as explained in Section
7.
(17) "RFA" means Request for
Applications
(18) "State grant" is
the amount of money that grant applicants request from Arkansas Rural Connect
in order to close the business case for a project, and which they will receive
from the State if their project is approved and deployment proceeds as
anticipated.
(19) "Unincorporated
community" means a population center with historic boundaries that are
understood in local custom and amenable to mapping, but which is not legally
incorporated as a municipality. Census-Designated Places recognized by the
United States Census Bureau are automatically recognized as unincorporated
communities, while other unincorporated communities' status and boundaries must
be established by maps and narratives, as explained in 6.H.1.
(20) "Unserved" means that a location lacks
access to broadband service by fiber optic cable, coaxial copper wire, DSL, or
fixed wireless at any price.
Section
5.
Arkansas Rural Connect Grant Program Funding
A. The AEDC may utilize any funds
appropriated to the AEDC for purposes of expanding high-speed broadband
services to rural communities. Likewise, the AEDC may utilize those funds in
conjunction with the ARC Grant Program to provide grants to ISPs, in return for
commitments from applicants to make broadband service, as defined by these
rules, available to residents of those communities.
B. Funds will be used to reimburse ISPs on a
proportional basis for capital expenditures on approved projects, such that
they will be owed by the State an amount of money equal to their capital
expenditures on the project, multiplied by the ratio of the approved State
grant to the total project cost, and capped at the grant award, with 80% of
this debt paid as quarterly reimbursements and the remaining 20% upon
completion of the deployment and the achievement of project goals.
C. To receive reimbursement, ISPs shall
submit receipts for all reimbursable expenses, and a concise quarterly project
narrative of less than 1,000 words, accompanied, if necessary, by photographs,
maps, tables, or timelines, explaining their investment activities. Quarterly
project narratives and receipts are due within sixty (60) days of the end of
the quarters ending on March 31, June 30, September 30, and December 31 of each
year. The receipts shall be labeled with unique numbers, and the project
narrative should allude to receipts by number and explain, in the context of
the project, the purpose of the expenditure. The narrative shall be
sufficiently detailed to be verified by physical inspection of the sites where
investment activities took place. It shall also update the ASBO on the number
of locations connected to broadband and the likelihood that the project will be
completed on schedule. Known delays in the project timeline should be noted.
Within thirty (30) days of the receipt of these materials, the ASBO shall
either approve the reports or request more information. Funds shall be
disbursed to ISPs within fourteen (14) days of the approval of the quarterly
project narrative.
D. Allowable
expenses do not include the following:
(1)
ongoing pole attachment fees, as distinct from Make Ready expenses, which are
allowable,
(2) full purchase price
of capital equipment that is used for the build phase of the project and that
will have value for other construction work after the project is
complete,
(3) operating expenses not
related to the project build, or
(4) any other operating expenses that will be
incurred on an ongoing basis after project completion.
E. Allowable expenses are costs directly
related to the construction of broadband infrastructure, including but not
limited to the following:
(1) Make Ready
expenses for attaching broadband facilities to poles,
(2) reimbursement for rental or depreciation
costs for capital equipment that represent the real opportunity cost of using
that capital equipment for construction activities on the project,
(3) wages of workers physically deploying
infrastructure,
(4) engineering
costs related to project design,
(5) legal costs related to the acquisition of
rights needed for broadband deployment, and
(6) the costs of fiber optic cable, modems,
and other necessary plant for the delivery of 25/3 broadband services,
(7) costs of obtaining construction
permits,
(8) purchases of
indefeasible rights of use in dark fiber, and
(9) installation and testing of broadband.
Also allowable are expenses for conducting outreach and training for customers
and potential customers living in the project footprint, to educate them on the
value of the internet and how to use it and encourage them to
subscribe.
F.
Participating municipalities, unincorporated communities, and counties shall
assist ISPs in the acquisition of rights needed for broadband deployment,
including all leases, permits, or easements necessary for the purpose of
construction and placement of broadband infrastructure on public property. In
connection therewith, participating municipalities and counties shall not
charge ISPs fees for pole attachments or permits.
G. Notwithstanding any other provision of
this ARC Rule, the Arkansas Rural Connect Coronavirus Rule (as amended), the
Supplemental Arkansas Rural Connect Coronavirus Rule, or any addenda relating
thereto, grants made under the ARC Grant Program receiving approval of
appropriation by the Arkansas Legislative Council, or by the Joint Budget
Committee if the Arkansas General Assembly is in session, on or after November
19, 2021 shall be disbursed to awardees in accordance with this Section 5 of
the ARC Rule.
Section 6.
Process Overview
A. Each round of
ARC grant funding will begin when the ASBO releases an RFA. The RFA will
include a list of major dates for the round, including:
1. A deadline for receiving from ISPs maps of
broadband coverage from them that is either currently available or scheduled to
become available under the terms of federal or State programs from which they
have accepted funding. (Approximately 4 weeks after RFA announcement)
2. The planned date of the release by the
ASBO of a map of the areas in Arkansas currently enjoying broadband coverage or
scheduled to receive broadband coverage with federal support. (Approximately 8
weeks after RFA announcement)
3.
The date when an application window opens. (Approximately 12 weeks after RFA
announcement)
4. The date when an
application window closes. (Approximately 20 weeks after RFA
announcement)
5. The date when
grant awards will be announced. (Approximately 32 weeks after RFA announcement)
The ASBO may adjust the dates at the time of the RFA
announcement to work around major holidays. The ASBO may postpone dates and
deadlines especially when unforeseen circumstances arise. The ASBO shall give
fourteen (14) days' notice at its discretion.
B. At the same time as the RFA announcement,
the ASBO will request that ISPs operating in Arkansas submit maps of the areas
in which they either provide broadband coverage (25/3, low latency, no data
usage caps or throttling < 150 Gb/month, as stated in Section 4.
Definitions) or have made commitments to governmental agencies like the USDA,
the FCC, or the ASBO (in the event of subsequent rounds of ARC grant funding)
to establish broadband coverage in return for financial support. The goal of
this data collection is to target funds to areas that currently lack and are
not publicly scheduled to receive broadband service. For ISPs which do not
submit broadband coverage maps, the ASBO will use data from the most recent
release of the FCC Form 477 data to map their coverage. ISPs are not required
to submit broadband coverage maps, and are encouraged not to do so if the most
recent release of FCC Form 477 data to the public adequately describes their
current broadband coverage. But ISPs that have expanded their broadband
coverage footprint too recently for the expansion to be captured in public FCC
Form 477 data are encouraged to submit coverage maps, both in the public
interest, to prevent subsidies being targeted to areas of lesser need, and in
their own private interest, to avoid a risk of facing a publicly subsidized
competitor.
C. After ISPs submit
maps of current broadband coverage and government-backed commitments to
broadband deployment, the ASBO will combine this information with FCC Form 477
data to create a map of current and scheduled broadband coverage in the state
of Arkansas. This will assist mayors and county judges to ascertain whether the
municipalities, unincorporated communities, and counties they represent will be
eligible for ARC broadband grant funding. Municipalities, unincorporated
communities, and counties are eligible for ARC broadband grant funding if (a)
no more than 80% of their populations are served, (b) they have at least 500
people, and (c) they have at least 200 people unserved. For more details on
service area eligibility, see 7.A.
D. Project organizers who aspire to bring
broadband to an unserved area with the help of an ARC grant shall develop an
implementation plan, with a budget, and define roles for all stakeholders. The
necessary stakeholders in every project are a local government, county or
municipal, as represented by a public official, which may be a mayor or county
judge in the case of an incorporated municipality or a county judge in the case
of an unincorporated community or county, and the ISP or ISPs who will deliver
retail service to consumers. Other stakeholders might include businesses or
nonprofits that commit to provide funding or purchase service. The public
official shall first serve as a spokesman for the preferences and the economic
development ambitions of the community that will receive broadband service,
then later, if a grant is awarded, assist the ASBO in monitoring the ISP's
performance. The ISP or ISPs, and not the public official, will be responsible
for building the facilities and providing broadband service to customers. Other
allocations of responsibilities between local governments and ISPs may be
considered by the ASBO on a case by case basis.
E. Each ARC grant project shall identify a
specific municipality, unincorporated community, or county that will receive
broadband coverage. The public official who co-applies for the grant must
represent that community. To be eligible, the municipality, unincorporated
community, or county applying for an ARC grant shall have:
* At least 500 people.
* At least 20% of its population currently lacking broadband
coverage.
* At least 200 people lacking broadband coverage.
Interdependent projects involving the same ISP (see section 6.P
and following) are exempt from these eligibility criteria as applied at the
level of a single community. Instead, the criteria will be applied to the
combined territories of the communities covered by the interdependent projects.
Communities with less than 500 people may apply through their counties or by
developing joint projects with other communities.
F. Each ARC grant project shall have a
well-defined planned geographic service area, henceforward the "project
footprint." The project footprint shall include the entire territory of the
municipality, unincorporated community, or county targeted for service that
currently lacks broadband coverage. It may also include other contiguous areas
that help to strengthen the business case for the project. The project shall
include a plan to make broadband service available to all locations in the
project footprint, where service is considered available if a location can be
connected within thirty (30) days of a request for service being
made.
G. Project footprints may be
defined which extend beyond the boundaries of the municipality, unincorporated
community, or county that is applying, and such extended project footprints can
expand the range of allowable expenses under the grant. However, enlarging the
project footprint will not raise the cap for the grant request or make the
project more competitive for funding. It is expected that extending project
footprints to include anchor clients or areas of consumer density that happen
to be located outside the borders of a town or county will sometimes attract
paying stakeholders, help to make the project financially self-supporting after
deployment, and/or provide the convenience of making the grant project
footprint coincide with the technical project footprint. Residents of an
extended project footprint not resident in the applicant community will enjoy
the same rights to broadband coverage as residents of the applicant
community.
H. If the project
footprint corresponds exactly to the legal boundaries of a municipality or
county, or with the established boundaries of a Census-Designated Place, no
proposed coverage map shall be submitted with the application. But maps in KML
or ESRI Shape file format are required as part of the application in the
following cases:
1. For unincorporated
communities that are not coextensive with Census-Designated Places, maps shall
be provided indicating where the boundaries of the unincorporated community
are, along with a narrative of less than 1,000 words describing the character
and history of the unincorporated community.
2. Where a community is partially served with
broadband, project organizers may submit maps distinguishing areas that already
enjoy broadband coverage currently, and where, therefore, the ISP applying for
ARC grant funding will not be obligated to provide broadband coverage, from
areas where broadband coverage is currently lacking and will be provided by the
applicant ISP as a result of the proposed project.
3. Where a project involves more than one
co-applicant ISPs, maps must be provided clearly displaying which ISP will have
a service obligation at each point in the project footprint.
4. Where project organizers choose to extend
the project footprint beyond the borders of the applicant municipality,
unincorporated community, or county, maps should be provided which clearly
establish the boundaries of the project footprint.
I. Project organizers shall estimate the
total capital expenditures that will be needed in order to implement the
project and document these projected costs for inclusion in an
application.
J. Project organizers
shall also estimate the ongoing operating expenses that are anticipated in
order to provide broadband coverage after deployment is complete, as well as
the revenues that can be expected. Based on these estimates, they shall
forecast whether the project will be financially self-supporting after
deployment is complete. If not, the project is not suitable for ARC grant
funding. If so, the expected revenues and costs of the project after deployment
shall be documented for inclusion in an application.
K. Project organizers may make efforts to
secure resources locally to help support the project. A municipality or county
wanting to apply for Arkansas Rural Connect funding may assess what funds it
has available that might be contributed to the project. Local businesses and
other anchor clients may be contacted to see whether they might join the
project in the role of stakeholders and commit funds. The ISP itself shall
consider whether the anticipated net income resulting from the project
justifies the ISP in making a commitment to private co-investment, and if so,
how much. Funds distributed through federal universal service programs, if they
have not already obligated the ISP receiving them to deploy broadband as
defined here (especially 25/3 speeds), may also contributed to the overall
financing of an ARC grant project, reducing the state grant needed.
L. As project capital costs and net income
after deployment are calculated and local funding sources are identified,
project organizers shall consider the size of the State grant that will be
needed to make the project acceptable to all parties and arrive at a decision
before applying. As general guidance for project organizers in setting the
State grant request, ARC seeks to make, for each project, the minimum State
grant needed to close the business case and make all stakeholders willing to
participate. But the ASBO will not attempt to verify whether the State grants
requested actually correspond to this minimum, relying instead on the
competitive character of the overall grantmaking process to discipline the size
of grant requests. While the project narrative provided with the application
shall include at least a brief description of how the State grant request was
set, and obvious improprieties might potentially be disqualifying, project
organizers may exercise considerable discretion.
M. Project organizers shall estimate the
number of currently unserved households living in the target municipality,
unincorporated community, or county that will receive broadband coverage as a
result of the project. This number of households should then be multiplied by
$3,000, yielding the maximum State grant that can be applied for by the target
community. Also, ARC grant requests cannot exceed the maximum of two million
dollars ($2,000,000) or 20% of the total funding available for a round. If the
State grant deemed necessary to make the project viable is greater than the
relevant maximum, project organizers may either look for other funding sources
or abandon the project.
N. Each
project must include exactly one municipality, unincorporated community or
county as an applicant, and at least one but potentially multiple ISPs. Each
eligible municipality, unincorporated community or county may submit multiple
(up to three) applications. Each application shall be for one project, i.e.,
one strategy (even if it involves more than one ISP) for achieving the goal of
broadband service to all locations. At most one project per municipality,
unincorporated community or county can be approved.
O. If a municipality, unincorporated
community, or county applies for multiple projects, it shall choose which
projects it wants most, second most, and third most, and indicate the rank
order of each project with respect to its preferences. The ASBO's selection
process will fund, for each community, the most preferred project that can be
funded within the budget constraint for the ARC round. If applications are
received both from a county and from municipalities and/or unincorporated
communities within a county, the countywide project will be prioritized, and
projects for municipalities and unincorporated communities within it will be
eligible for funding only if the county wide project is rejected.
P. If an ISP wants to launch a project that
would cover multiple eligible municipalities, unincorporated communities,
and/or counties, it shall divide the project into subprojects that each cover a
single eligible municipality, unincorporated community or county, and then
consider whether the sub-projects would be worth implementing if they were
funded separately. If the sub-projects are commercially feasible as separate
projects, the ISP may choose, if the public officials representing the affected
communities are willing, to co-submit separate applications for each
sub-project. Otherwise, the ISP may choose to alert the public officials of the
interdependent character of proposed projects, and, with their agreement,
cosubmit the projects as interdependent projects. The interdependent projects
option may also be used to achieve eligibility for ARC grants by combining
communities that are too small to be eligible on their own.
Q. When an ISP co-applies with multiple
communities on interdependent projects, the ISP shall indicate to the community
that the project is interdependent with one or more other projects, such that
they cannot be funded and executed separately. The community, if it still
wishes to apply for that project, shall then indicate on the application that
the project is interdependent with other projects, and which other projects it
is interdependent with. The ISP will have the opportunity to view the
community's portion of an application before it is submitted, and it shall
check to confirm that the community has accurately represented whether the
project is interdependent, and with which other projects it is interdependent.
The ASBO's project selection process, described below, will then ensure that
projects which form an interdependent set are either all approved or all
rejected.
R. In choosing whom to
apply with and how to rank projects, public officials representing
municipalities, unincorporated communities and counties shall prioritize a
reasonable conception of the public interest of those communities over any
private interests they might have in the ISPs. They shall disclose all
ownership, family ties, campaign contributions or other substantial ties they
may have to the ISPs applying for grants which might be suspected of biasing
them in favor of one ISP over others, and shall not co-apply with an ISP on
behalf of a community if their private interest in that ISP is substantial.
Public officials co-applying for ARC grants shall provide a narrative
explanation of less than 1,000 words about how they developed the application,
emphasizing efforts to make the process transparent, competitive, and in the
public interest. This narrative shall be submitted with the
application.
S. All official
stakeholders in the project, at the application stage, shall indicate their
awareness of ARC rules, read and affirm the accuracy of all information in the
application, and declare their consent and commitment to perform the roles
allotted to them in the implementation plan.
T. If there is doubt whether a municipality,
unincorporated community, or county meets the eligibility criteria for ARC
grants, based on data about population and/or the quality of current internet
service, applicants may submit, along with their applications, evidence that
they believe will help to establish their eligibility for an ARC grant-funded
project. The ASBO maps of current broadband coverage described in 6.C will help
applicants anticipate whether their eligibility can be assumed or will need to
be established with the help of extra evidence.
U. After the application window closes, the
ASBO will arrange for eligibility review, as explained in 9.B, process review,
as explained in Section 9.C, and technical review, as explained in Section 9.D,
of all applications received to ensure that projects are feasible and
implementation plans are sufficient to achieve project objectives. Applications
that pass technical review, and which are the most preferred project from their
county or, in case of no county projects, their municipality or unincorporated
community, will then be ranked in ascending order of the project score, as
calculated using the rubric in 9.E.
V. An iterative process will eliminate
projects that lie outside the budget constraint or are interdependent with
other eliminated projects. The process shall substitute for eliminated
projects, where available, less preferred projects according to the ranking
provided by the county or, where countywide projects were not proposed or have
been eliminated, by municipalities or unincorporated communities. This process
shall culminate in a list of awardable projects with grant requests totaling to
less than the available funds. Section 9.F elaborates on this, and full details
of the selection process for the round will be provided along with the
announcement of grant awards.
W.
When interdependent projects are awarded funding, they shall be treated as a
single project to the extent possible for purposes of reporting requirements,
certifying completion of deployment, assessing penalties, etc.
X. After grant awards are announced, ISPs
will begin to deploy, collecting receipts and submitting them to AEDC for
proportional reimbursement on a quarterly basis, along with a project
narrative, as explained in sections 5.B and 5.C.
Y. When broadband coverage is available to at
least 95% of the locations in the project footprint, and all other project
objectives have been achieved, the ISP may alert the ASBO and the municipality,
unincorporated community, or county of the fact, and initiate the process by
which deployment is certified to be complete and the remaining reimbursements
are released. The responsible public official shall then collect, or cause to
be collected, information to confirm that deployment has been completed and
broadband service is available to at least 95% of locations. If necessary, the
ASBO shall provide a process how to collect this information. At this point,
the portion of the reimbursement that has been held back by AEDC to ensure
project completion may be released to the ISP. The ISP may wait to establish
service to the remaining 5% of the locations in the project footprint until it
is getting positive net income from the project, but it shall not transfer any
net income from the project to shareholders or other projects, reinvesting it
instead, until 100% of locations have been served.
Z. After deployment is complete, the ASBO may
request reports on project status from the ISP up to twice per year, as
explained in section 11.G, and the municipality, unincorporated community, or
county shall submit biannual reports to the ASBO, as explained in section
11.H.
AA. If service is never
established, or is suspended, without a waiver from the ASBO, penalties will be
assessed against the ISP, as described in Section 8.C.5.
AB. Full project closure will occur on
January 1, 2030 for all ARC projects, unless otherwise specified in the
application materials, and obligations to report and to provide service will
cease at that time. If the ISP and the co-applicant public official agree to a
different project closure date in the original application, project closure
without penalties may occur at an agreed upon date earlier, but not later, than
January 1, 2030.
Section
7.
Eligibility Criteria
A. Municipalities, unincorporated
communities, and counties, or interdependent sets of these jurisdictions as
described in section 6.P and following, will be eligible for ARC grant funding
if they meet the following criteria:
* No more than 80% of the population currently has broadband
coverage.
* The population is at least 500.
* The population unserved with broadband is at least
200.
The determination of eligibility shall be made, in the absence
of special data collection efforts, using the best available data sources that
are consistent across geographies and sufficiently granular, which at the time
of writing are the FCC Form 477 data for broadband coverage and the most recent
Census data for the block level. Where special data collection efforts are
organized in order to establish ARC grant eligibility, the ASBO shall assess
the validity of the data and make an eligibility determination with full
disclosure of its reasons for finding an area eligible or ineligible, by the
criteria, on the basis of the evidence provided in combination with public data
sources.
B. ISPs will be
eligible to participate in ARC grant funded projects if they:
* Have a one-year track record of providing broadband coverage
(meaning at least 25/3 speeds, at least 150 Gb of data usage per month without
throttling, and no more than 100 ms latency, see Definitions) to at least 500
retail customers.
* Have enough working capital to carry on construction
activities in pursuit of project goals in advance of quarterly reimbursement
from AEDC, as demonstrated by appropriate financial statements (see section
8.C.7).
Section
8.
Application Submittal Process
A. Each application shall be initiated by the
municipality, represented by a mayor or county judge, or unincorporated
community or county, represented by a county judge, that stands to gain
broadband service as a result of the project. Applications shall include the
following documents.
B.
Municipalities, unincorporated communities and counties will be required to
submit:
1. The name of the community applying
to get service.
2. The rank of the
application in the community's order of preference if multiple applications
would qualify for funding, since no more than one application can be funded for
each community.
3. The provider or
providers to whom residents will be able to apply for consumer broadband
service after the project is completed.
4. Any caveats about the interdependence of
projects that may be applicable.
5.
A statement of any cost sharing or facilitation that the community commits to
do in order to assist the deployment process.
6. If applicable, statements from any
nonprofits or local businesses of any financial or other support that they have
offered to provide to assist the project.
7. If applicable, statements of any
commitments that the ISP has made on pricing in return for the community
agreeing to co-apply for ARC grant funding.
8. The name and office of the public official
who will submit biannual reports to the ASBO.
9. Disclosure of any conflicts of interest on
the part of public officials representing the community.
10. A narrative explanation of less than
1,000 words about how the community developed the application, emphasizing
efforts to make the process transparent, competitive, and in the public
interest.
11. A declaration of the
project closure date if it is earlier than January 1, 2030.
12. An affirmation that all the information
submitted by co-applicants has been reviewed and is acceptable.
C. ISPs shall be required to
submit:
1. An implementation plan that
explains how broadband will be deployed to reach all residences in the
municipality, unincorporated community or county, including the technology that
will be used.
2. A project timeline
that includes a date of anticipated completion of project deployment and
establishment of service availability no later than November 2022.
3. A map of the project footprint if it
extends beyond the community's legal boundaries or involves multiple ISPs
serving different parts of the town.
4. A narrative of less than 500 words
describing the company's experience providing consumer broadband service, which
may include total numbers of customers served and revenues earned. The purpose
of this narrative is to establish that a company has a one-year track record of
providing consumer broadband.
5.
Unless otherwise specified in accordance with section 6.AB, a commitment to
continue providing broadband service through January 1, 2030 after the project
is complete, or pay penalties in accordance with a predetermined schedule,
unless the ASBO, in consultation with the relevant local government, agrees
that it is in the public interest to waive the penalties because the service
has been overbuilt and/or become obsolete or superfluous. The penalties are as
follows:
a. If service ceases to meet
standards, between 1/1/2029 and 1/1/2030, the minimum of 5% of the total ARC
grant and the total funds disbursed by ARC for the project
b. If service ceases to meet standards,
between 1/1/2028 and 1/1/2029, the minimum of 10% of the total ARC grant and
the total funds disbursed by ARC for the project
c. If service ceases to meet standards,
between 1/1/2027 and 1/1/2028, the minimum of 15% of the total ARC grant and
the total funds disbursed by ARC for the project
d. If service ceases to meet standards,
between 1/1/2026 and 1/1/2027, the minimum of 25% of the total ARC grant and
the total funds disbursed by ARC for the project
e. If service ceases to meet standards,
between 1/1/2025 and 1/1/2026, the minimum of 35% of the total ARC grant and
the total funds disbursed by ARC for the project
f. If service ceases to meet standards,
between 1/1/2024 and 1/1/2025, the minimum of 55% of the total ARC grant and
the total funds disbursed by ARC for the project
g. If service ceases to meet standards before
1/2024, the minimum of 75% of the total ARC grant and the total funds disbursed
by ARC for the project
h. If
service never meets standards, the minimum of the total ARC grant and the total
funds disbursed by ARC for the project Service may cease to meet standards
either by being canceled altogether, by ceasing to provide the required speeds,
latencies, and data caps, or by ceasing to offer service to at least 95% of
households. Penalties can be triggered by sustained degradation of network
performance due to intensive utilization.
6. An affirmation that all the information
provided by the co-applicant public official, inasmuch as it relates directly
to the ISP's intended activities under the project, is correct and acceptable.
This requirement is intended to prevent any misunderstandings of the project
between the ISP and public officials representing the communities to be
served.
7. Except in the cases
below specified, financial statements for the three most recent years, with CEO
and CFO certification, including the following:
a. Balance Sheet
b. Income Statement
c. Depreciation Schedule
d. Debt Schedule
e. Accounts Receivable Aging
f. Accounts Payable Aging
The financial statement for the most recent year must be (a)
audited for grant requests exceeding $2 million, and (b) either
audited or reviewed for grant requests exceeding $500,000. For
grant requests under $500,000, financial statements shall be provided but ASBO
shall have discretion to accept financial statements that have not been audited
or reviewed as sufficient evidence of the company's working capital adequacy.
These financial statements may demonstrate to the ASBO that the ISP has
sufficient unencumbered resources to pay for planned investment activities
under the ARC project, in advance of receiving reimbursements from grant funds,
with a reasonable buffer of cash and other liquid assets in case of cost
overruns. Note that the ASBO cannot guarantee that financial statements of ISPs
applying for ARC grant projects will enjoy immunity from being required to be
released to members of the public under Freedom of Information Act requests.
Alternatively, ISPs may provide the following in lieu of complete financial
statements.
* Option 1.
(a) An estimate of the working capital needs
of the project, and
(b) a sworn
statement by the CFO of the ISP and a third-party CPA that the ISP has at least
that amount of unencumbered funds.
* Option 2. Documentation showing that the ISP
has provided internet service to at least 1,000 subscribers in Arkansas for at
least five years. Note that such documentation can also be used to establish
the ISP's capacity to deploy broadband so as to remove the need to get a
Professional Engineer stamp (see 9.G).
8. Disclosure of any conflicts of interest
that might affect, or be suspected to affect, the decisions of the public
officials involved in the project.
D. Stakeholders listed as co-applicants on a
grant other than public officials representing the applicant communities and
ISPs shall submit the following documents:
1.
A declaration that they have read all the application materials and affirm
their accuracy.
2. A declaration of
their commitment to perform the roles allotted to them in the implementation
plan.
3. Evidence of their capacity
to perform the roles allotted to them in the implementation plan.
4. Disclosure of any conflicts of interest
that might affect stakeholders' support of the project.
Section 9.
Application
Review and Approval Process
A. The
application review and approval process will consist of four (4)
stages.
B. First, the ASBO will
determine, for each application or set of interdependent applications, the
eligibility of the municipality, unincorporated community, county, or group of
these for which a project is proposed. It will use the best generally available
and sufficiently granular data sources, which at the time of writing are the
FCC Form 477 data for broadband coverage, and the most recent Census data for
population. If other evidence related to eligibility is provided with the
application, it will be assessed at this time. On this basis, a determination
will be made by the ASBO about whether the project covers an eligible area or
not. Projects from ineligible areas will be eliminated from
consideration.
C. Second, the ASBO
will conduct a process review by studying the project development process
documentation in an effort to discern possible conflicts of interest, examine
the financial information about the applicant ISP to confirm that they have
sufficient working capital to carry out the project in advance of
reimbursement, and have a one-year track record of delivering consumer
broadband service. The ASBO may eliminate projects where public officials
representing municipalities, unincorporated communities or counties appear not
to have acted in the public interest, or one or more ISP applicants appear to
be undercapitalized or insufficiently experienced.
D. Third, technical reviewers selected by the
ASBO will examine the implementation plan and budget for the project, as well
as information on the service track record and financial situation of the ISP,
and affirm or deny that the project is feasible and sufficient to achieve
project objectives, and that the budget is appropriate. Technical reviewers may
request more information from ISPs in order to assist with their
determination.
E. The ASBO will
assign a score to each project, using the following rubric:
Points |
Measure |
Calculation method |
60 |
Grant request per household connected |
($3,000-state grant requested/number of unserved
household connected) |
25 |
Current service deficiency |
25 if 90% of project footprint is unserved by
10/1
Else 0 |
15 |
Poverty |
15 × (100 - Percentile of income per
capita)
Example: poorest town receives 15, richest town
receives 0 |
The project score for each project will be the sum of the
points awarded for cost effectiveness, current service deficiency, and
poverty.
F. For each
application that passes technical and process review, the ASBO will calculate
the percentage of the maximum state grant that the project will request. It
will then perform the following process iteratively:
1. Compile a candidate list of all
non-eliminated projects that are ranked by applicant counties, or
municipalities and unincorporated communities that are partly or wholly located
in counties that did not apply for ARC grants or have been eliminated, as their
most preferred among non-eliminated projects, in ascending order of project
score. If multiple projects have equal project scores, they will be ranked in
descending order of the number of locations to be served.
2. Compute, for each project, the cumulative
grant request for that project and all those ahead of it in the
queue.
3. Eliminate all projects
for which the cumulative grant request exceeds the available budget for the ARC
round.
4. Eliminate all projects
which are interdependent with eliminated projects.
5. Check whether each eliminated project
comes from a municipality, unincorporated community or county that also has
less preferred projects, and if so, place less preferred projects into the
candidate list, to replace eliminated projects.
6. Also, if a county project is eliminated
and there are no other project proposals from that county, check whether any
municipalities or unincorporated towns fully or partly contained within that
county have projects, and if so, add the most preferred projects from each
municipality or unincorporated town to the list.
7. If the total grant request for all
projects remaining in the candidate list is less than the budget constraint,
stop. Otherwise, return to step 1.
This process will result in a list of projects for which the
grant requests are less than the budget for the ARC round, and which will tend
to economize state tax dollars and maximize their impact.
G. After each ARC grant is
approved, the ISP receiving the grant will have 45 days to send it to a
licensed Professional Engineer for confirmation that the plans are technically
adequate. The resulting PE stamp shall be provided to the ASBO before any
further grant funds are disbursed. Projects that fail to win PE approval will
be canceled, but the grant recipient can still pay the PE from the grant funds
before the remainder of the funds reverts to Arkansas Rural Connect. ISPs can
be exempted from the PE stamp requirement if they provide documentation that
they have provided broadband coverage to at least 1,000 subscribers in the
state for at least five (5) years.
Section 10.
Federal
Complementarity
A. In addition to state
and private efforts to deploy broadband, the federal government is making
extensive, well-funded efforts to promote rural broadband deployment,
principally through the FCC and the USDA. It is likely that federal funding for
rural broadband in Arkansas in the next decade will much exceed any funding
from the State.
B. In order to make
ARC broadband grants impactful, many state officials recognize the need to
consider the ways that ARC will interact with federal funds. There are
plausible scenarios in which ARC broadband grants leverage federal funds, and
plausible scenarios in which ARC broadband grants crowd out federal funds.
Announcements of new federal programs, rules, dates and deadlines, etc., are
hard to predict, and coordination between state and federal programs is
difficult and may be incompatible with due process at the state
level.
C. In view of the difficulty
of explicit coordination, the ASBO shall have discretion to adjust program
rules relating to project footprints, technological specifications, and service
obligations, on a case by case basis, in consultation with and in the interests
of affected communities and ISPs, in order to make the ARC program as
complementary as possible to federal programs that fund rural
broadband.
Section 11.
Project Monitoring and Dispute Resolution
A. During the build phase of the project, the
ISP shall not be required to deliver broadband service to premises in the
project footprint.
B. During the
build phase of the project, the ISP shall be required to submit quarterly
reports to the ASBO reporting their activities in fulfillment of grant
objectives. These reports will be submitted within sixty (60) days of the
quarters ending on March 31, June 30, September 30 and December 31 of each
year, and reviewed as explained in section 5.C.
C. When the ISP has completed deployment to
95% of locations in the project footprint, it shall notify the ASBO and the
municipality, unincorporated community or county of that fact. At that time,
the ASBO shall do a desk assessment of whether the ISP is in fact advertising
the services that it promised to deliver so that citizens living in the project
footprint could discover and sign up for the service. The responsible public
officials shall collect, or cause to be collected, with the advice of the ASBO
as needed, information sufficient to affirm that the project appears to be
complete and broadband service has been made available to at least 95% of
project footprint residents, and it shall publish the contact info of an
official tasked with hearing complaints from citizens who believe that their
homes are still not being offered service as required by the ARC grant. The
ASBO shall review this information as well as evidence from its own desk
research, and if the evidence is sufficient, shall announce that the project
has completed the main deployment phase, and authorize the release of any
remaining disbursable grant funds.
D. After deployment to 95% of locations has
been completed, the ISP may cease broadband deployment activities within the
project footprint until its cumulative revenues exceed its cumulative operating
costs within the project footprint. If this never happens prior to full project
closure on 1/1/2030, the ISP will never be required under the terms of the ARC
grant to make broadband service available to the remaining 5% of locations. But
if revenues exceed operating costs in the project footprint, resulting in
positive net income, this net income shall be reinvested in deployment to the
remaining 5% of locations, until 100% of the locations in the project footprint
have broadband service available. When 100% of locations have broadband service
available, any further net income is at the ISP's disposal to return to owners
as profit or invest in other projects.
E. If the ISP fails to deploy to 95% of
locations in the project footprint by November 2022, the ISP is obligated to
return all ARC grant funds disbursed to it for that project, unless this
requirement is waived by the ASBO. The ASBO may waive up to 80% of penalties if
a substantial proportion of locations in the project footprint have received
broadband coverage, and the ISP exerted bona fide best efforts to achieve
project goals but was prevented from doing so by adverse
circumstances.
F. From the
completion of deployment until project closure, the ASBO shall continue to
conduct desk research from time to time to ensure that 25/3 broadband service
is still available from the grant-funded ISP within ARC project
footprints.
G. From the completion
of deployment until project closure, the ASBO may request a report from an ISP
concerning any ARC project up to twice a year. Upon receiving such a request,
the ISP shall provide, within 90 days:
(1) a
confirmation that 25/3 broadband service is still available in the project
footprint,
(2) information about
pricing schedules,
(3) numbers of
subscribers,
(4) take rates,
(5) information about any known
service interruptions, and
(6) any
other information the ISP may deem relevant.
H. From the completion of deployment until
project closure, each municipality, unincorporated community, or county shall
submit biannually to the ASBO a report that may include (1) an overall judgment
of whether the ISP is fulfilling its service obligations, (2) complaints about
non-provision or poor quality service that may have validity, and (3)
information about service interruptions that are known to have occurred. They
are also encouraged to include (4) positive feedback from the public about the
ARC project and (5) instances of the economic development impact of the ARC
project. Such reports shall be submitted within 30 days of the ends of the
six-month periods from January to June and July to December of each
year.
I. In case of succession in
the offices of mayor or county judge for a community that has received an ARC
grant funded project, the mayor or county judge shall notify his or her
successor of his or her rights and obligations as the responsible public
official for an ARC grant project area.
J. Early project closure may be requested by
the ISP or initiated by the ASBO based on evidence that broadband service is no
longer being provided by the ISP to 95% or more of the locations in the project
footprint. If early project closure occurs, the ASBO and the municipality,
unincorporated community or county, as represented by a mayor or county judge,
shall consult and decide whether or not the ISP may be required to pay
penalties as described in Section 7.C.5. If they determine that it is in the
public interest for the service to be terminated because it is obsolete or
superfluous and is no longer desired by customers, they may agree to waive
penalties.
K. No penalties will be
assessed against an ISP that ceases to provide broadband in an ARC grant funded
project footprint due to ownership changes, if the successor entity continues
to provide the service.
Section
12.
Severability Clause
A. Any section or provision of this rule held
by a court to be invalid or unconstitutional will not affect the validity of
any other section or provision.
Section 13.
Effective Date
This Emergency Rule is effective November 19, 2021.