NTIA Memo to OMB Requesting Emergency Review and Approval

or in other rural areas or underserved communities. The Biden-Harris Administration is committed
to ensuring that high-speed Internet service is available for all Americans through the
implementation of the broadband provisions of the Infrastructure Act.
NTIA is now in the process of reviewing applications for the broadband connectivity grant
programs enacted by the CAA. The grant application forms for these programs used relatively
unstructured narratives to collect programmatic and project data from applicants. NTIA has found
that some applicants did not provide the detailed information necessary for NTIA to fully review
their applications and make award determinations. This has required NTIA to engage in significant
further communications with these applicants in order to obtain vital information, thereby
increasing burden costs for both applicants and reviewers. Many of these applicants are Tribal
governments or other entities associated with disadvantaged communities. This is because
disadvantaged communities often lack the financial and professional resources necessary for the
preparation of the complex narrative submissions that successful participation in broadband grant
programs can require. NTIA believes that these challenges could also limit the ability of such
applicants to participate meaningfully in future broadband grant connectivity programs, such as
the Middle Mile Program.
JUSTIFICATION
Emergency clearance of the new grant application forms is essential to the NTIA mission and
Infrastructure Act mandate of closing the digital divide with efficiency and accuracy in order to
meet the statutory deadlines in the Infrastructure Act. Given the challenges that the grant
application process can pose for disadvantaged communities, NTIA seeks to make this process
more equitable for all potential applicants of the broadband grant programs enacted by the
Infrastructure Act, including those with limited resources and/or technical expertise. In order to
do so, NTIA created new forms for use in the application process which will provide structured
questions and guidance concerning the kind of discrete and structured data required for successful
applications. The new forms will create greater efficiencies in the NTIA grant program, which
will likely result in enhanced timing and information accuracy beneficial to program applicants.
NTIA believes that a significant number of prospective applicants will be Tribal governments or
other entities associated with disadvantaged communities. NTIA further believes that the abovediscussed new forms would offer these applicants greater opportunities for meaningful
participation in the Broadband programs than they would otherwise enjoy. These new forms
would affect the grant application requirements contained in the upcoming Notices of Funding
Opportunity (NOFOs) NTIA will publish.
Under the Infrastructure Act, NTIA is statutorily required to publish the NOFO for the Middle
Mile Program and State Digital Equity Planning Program no later than May 16, 2022. In order to
meet this deadline, NTIA is requesting clearance for the new Middle Mile Program and State
Digital Equity Planning Program application forms by May 10, 2022 to ensure that applicants have
reasonable notice of the Middle Mile Program and State Digital Equity Planning Program funding
opportunities and that applicants have sufficient time to prepare and submit their applications.
Therefore, due to the urgent nature of meeting the Act’s statutory deadlines and establishing grant
application requirements that will offer greater opportunities for meaningful participation in the

application process to applicants from disadvantaged communities, NTIA is requesting emergency
review of the new application forms intended for use in the Infrastructure Investment and Jobs Act
Broadband Grant Programs.