Community & Economic Development

FCC Releases New National Broadband Map – Understanding the Data Challenge Process 

On November 18, the Federal Communications Commission (FCC) released the first draft of its new National Broadband Map, a comprehensive, location-by-location view of high-speed Internet availability across the nation. The map is a more detailed and precise reflection of the availability of fixed and mobile broadband services across the country. 

The new map can be accessed here. 

While the FCC will not implement a deadline for data challenges, NARC strongly encourages communities to make submissions by January 13, the date by which NTIA will use the FCC map to determine each state’s allocation of BEAD dollars. 

Unlike its previous census block-based maps, this updated map is built on a location-based model developed through the FCC’s Broadband Data Collection process. The map will be continuously updated with each filing period’s set of data, with the next cycle expected to span from December 31-March 1. Each filing window will then take place six months thereafter. 

The new National Broadband Map and its future iterations are expected to be instrumental in determining the flow of funds for billions of dollars for broadband deployment from the Bipartisan Infrastructure Law (BIL). 

This includes the National Telecommunications and Information Administration’s (NTIA) Broadband Equity, Access, and Deployment (BEAD) program, which will provide over $42 billion to expand high-speed internet access by funding planning, infrastructure deployment and adoption programs in all 50 states and Washington D.C. NTIA has required states to conduct local coordination in order to receive these funds, and NARC encourages Regional Councils, Councils of Governments, Metropolitan Planning Organizations, and other regional organizations to contact and coordinate with their state broadband office to begin this process. 

Submission of Bulk Challenges

Regional Councils, COGs, and MPOs are encouraged to review and validate the availability data presented on the new National Broadband Map to determine whether to submit a challenge. If your organization or local districts determine that a challenge is needed, the FCC has provided steps to follow here. 

There is no deadline for data challenges, but submissions after January 13 will not be reflected in state allocations. 

Challenges to an individual location may include incorrect information on a particular location such as address or unit count, a location’s geographic coordinates, a location’s broadband serviceability is incorrectly identified, or a location that meets the definition of a BSL is missing from the Fabric. Consumers will be able to engage in this individual location challenge process to submit challenges for their own residences or small businesses. 

Understanding the Challenge Submission Process

Additionally, a walkthrough of the challenge process from a submitting entity’s perspective is available to watch here. Some key steps are included below.

  • Access the Broadband Serviceable Location Fabric dataset following these steps. Local governments must follow the steps provided in the link which include logging into the Broadband Data Center system and executing a limited end-user license agreement for the Fabric dataset. These licensing requests may take time to be processed so expect a processing window when submitting the access request. Delivery of credentials may take up to two weeks from the time your organization information is submitted. 
  • Familiarize yourself with the FCC’s definition of a “broadband serviceable location,” which will not necessarily include all structures at a particular location or parcel. More information can be found in the Bulk Fabric Challenge Specs Public Notice. 
  • Develop a strategy for requiring and validating the Fabric data in your geographic area. 
  • Align your data with the specifications set forth in the Data Specifications for Bulk Fabric Challenge Data document. Some of these specifications include, among other things, requirements to identify the name and contact information of the submitting entity, the Fabric location subject to challenge, the category of the challenge for each location, and evidence supporting the challenge. Further specifications require the challenge data file to include records for each location in a Comma Separated Value (CSV) format, all fields must be included in the file upload, and all values must conform to the descriptions, codes, or formats identified for each field in the Data Specifications document.  
  • Certify that the information you are submitting is true and correct (to the best of your actual knowledge, information, and belief) for each location that is part of the bulk challenge. 
  • Submit your challenge! 

Additional Resources

NARC will continue to monitor FCC updates and additional information will be provided soon. 

NARC Celebrating American Rescue Plan Act (ARPA) One Year Anniversary

This week marks the one-year anniversary of the historic investment in the nation from passage of the American Rescue Plan Act (ARPA). Throughout the week the White House has been celebrating the one-year anniversary by highlighting achievements made possible by the passage of the bill relevant information, fact sheets, and toolkits for communities. The $1.9 trillion coronavirus rescue package was designed to facilitate the United States’ recovery from the devastating economic and health effects of the COVID-19 pandemic. ARPA included $350 billion in aid to states, cities, tribal governments, and U.S. territories. 

ARPA authorized the Coronavirus State and Local Fiscal Recovery Fund, including $65.1 billion in direct, flexible aid to every county, parish and borough in America. It represents a strong federal-state-local partnership and an investment in localities on the front-line keeping communities healthy, safe and vibrant.  

Funding allocated under the State and Local Fiscal Recovery Funds (SLFRF) program is subject to the requirements specified in U.S. Department of the Treasury’s May 17, 2021 interim final rule, which became effective on that date and detailed whether a program, project or service was an eligible use. Treasury accepted public comments on the interim final rule through July 16, 2021 and after reviewing some 1,000 submitted comments adopted the final rule in early January 2022.  

On January 6, 2022 Treasury issued the Final Rule for SLFRF program adding clarifications and additional guidance not available under the interim rule. For an in-depth overview of the Final Rule check out the National Association of Counties (NACo) analysis.  

To date, Treasury has distributed more than $245 billion to state, local, and Tribal governments as a part of the SLFRF program, accounting for over 99% of funds eligible to be disbursed in 2021. Recipients of funds were encouraged to begin using funds under the interim final rule, which was released in May 2021 as the final rule does not take until April 1, 2022.   

KEEPING TRACK OF ARPA DOLLARS INVESTED

An analysis by the Center on Budget and Policy Priorities found that state governments have appropriated nearly 70% of their available funds as of November 2021. Their review of these spending decisions shows that many states are using the funds constructively: to offset declines in their revenue collections; to address the health, economic, and fiscal impacts of the pandemic and contribute to the economic recovery; and to start new long-term investments to address racial and economic inequities. 

In addition to this analysis of broad state– allocated ARPA spending, a partnership between Brookings Metro, the National Association of Counties (NACo), and the National League of Cities (NLC), aimed at highlighting innovative, evidence-based, well-targeted uses of SLFRF ARPA funds. They created the Local Government ARPA Investment Tracker. An online resource that compiles information from local governments to offer a detailed picture of how large cities and counties (with populations of at least 250,000) are deploying funding.  

This tool adds to other important efforts to understand local ARPA implementation, including Results for America’s ARP Data and Evidence Dashboard, and the Treasury Department’s analysis of highlights from initial SLFRF reports. 

Communities have until 2024 to fully plan for and commit their funds, and until 2026 to spend them. Local governments’ initial SLFRF expenditure reports contain useful roadmaps on where they are heading with ARPA funds; large cities and counties (those with populations of at least 250,000) have also delivered the first in a series of annual plans that outline their intended and actual uses of SLFRF dollars.  

Collectively, these reports and tools detail thousands of projects across dozens of eligible expenditure categories and form the data behind the Local Government ARPA Investment Tracker. 

NARC WANTS TO HEAR FROM REGIONAL ORGANIZATIONS

The National Association of Regional Councils (NARC) will be collecting information and tracking ARPA spending from regional councils over the next few months. If you have questions or information to share on how you are spending and planning for ARPA dollars please contact Jessica Routzahn at jessica@narc.org. 

Additional Resources:  

COVID-19 Communications Toolkit for Counties 
Utilize NACo’s COVID-19 communications toolkit, including top-level messaging, outreach ideas and templates to share how your county is investing ARPA Fiscal Recovery Funds. 

Explore NACo’s ARPA Fiscal Recovery Fund Resources 

Visit NACo’s ARPA Fiscal Recovery Fund Resource Hub to find tools to share your story, explore county best practices, access analysis and more. 

White House ARPA Anniversary Toolkit 

Join the White House and states, cities, counties, territories to amplify the successful, historic, and lasting impact of the American Rescue Plan in social media and your local press! 

 

Pioneer Valley Planning Commission’s Kim Robinson Testifies before the House Committee on Financial Services on CDBG Funding

Last Wednesday, the House Subcommittee on Housing, Community Development and Insurance held a hearing on the Community Development Block Grant (CDBG) Program and its impact on addressing local challenges. Kimberly Robinson, Executive Director of the Pioneer Valley Planning Commission (PVPC) testified on behalf of the National Association of Regional Councils (NARC).  Robinson was joined by Joseph Jaroscak, an analyst in Economic Development Policy at the Congressional Research Service; George Mensah, Director of the Miami, Florida, Department of Housing and Community Development; San Francisco Mayor London Breed; and Salim Furth, a Senior Research Fellow at George Mason University’s Mercatus Center.

CDBG has long been a critical source of funding for local projects that address poverty and inequality, especially through economic development and infrastructure programs. Regional councils often help to organize these efforts by providing technical support to communities who seek CDBG funding. PVPC, for example, both applies for and administers CDBG grants for member communities, while also facilitating cooperation between members in order to increase the amount of funding received and improve its efficiency.

While CDBG remains successful in its ability to provide for lower- and middle-income communities, shortfalls in funding over the last two decades have hampered the program’s ability to confront the economic development needs of the communities it serves. Robinson emphasized this point in her testimony, pointing to how CDBG’s funding of $3.44 billion in FY2021 is nearly $1 billion less than it was in 2004. Further, she pointed out that if the original allocation from 1975 were adjusted for inflation, funding for CDBG would exceed $10 billion today.

In her testimony, Robinson also highlighted how, although 70 percent of federal CDBG funds are allocated to larger entitlement communities — defined as principal cities of Metropolitan Statistical Areas, other metropolitan cities with populations exceeding 50,000, and qualified urban counties with populations exceeding 200,000 — the remaining 30 percent allocated to states is still crucial to the development of smaller communities, and CDBG thus cannot be viewed as just a “big city” program. As an example, she pointed to how PVPC aided 19 different communities with CDBG funding in FY2019, despite having just four members that qualify as entitlement communities.

Following the testimonies, Democratic Representative Joyce Beatty (OH-3) asked about how CDBG helps support affordable housing. Robinson responded by articulating how, although the funding cannot be used to construct new housing, it allows PVPC to undergo rehabilitation projects that keep vulnerable people — especially the elderly — in their homes. Representatives from both parties, as well as several of the witnesses, agreed that CDBG funds should not be prevented from going toward new construction and that restrictive zoning barriers limiting their effectiveness should be lifted.

Broadly speaking, there was bipartisan momentum at the hearing toward reforming the formulas used in CDBG allocation. While Democrats, including Chairman Cleaver, praised the flexibility of CDBG and supported increasing its funding in addition to reforming allocations, Republicans seemed hesitant to spend more on the program. Overall, discussion at the hearing suggested an increase in funding for CDBG is unlikely. However, restructuring the program to better serve non-entitlement communities and contribute more to affordable housing, without compromising flexibility appears to be a more attainable goal for the subcommittee.

Southern California Association of Governments adopts Racial Equity Early Action

The following is a Regions Lead guest post by the Southern California Association of Governments (SCAG):

The Southern California Association of Governments (SCAG), which serves as the metropolitan planning organization for nearly 19 million people – the largest metropolitan planning organization in the nation – adopted its first-ever Racial Equity Early Action Plan. This document will guide and sustain SCAG’s regional leadership in service of equity and social justice.

As in many other regions and communities that shifted attention to equity in summer 2020, SCAG’s Regional Council adopted a resolution affirming SCAG’s commitment to work in partnership with others to close the gap of racial injustice and meaningfully advance justice, equity, diversity, and inclusion. As a result, an ad hoc Special Committee on Equity and Social Justice was tasked with recommending a set of policies to the Regional Council and any necessary changes to the bylaws to the General Assembly to help SCAG meet these objectives.

The Racial Equity Early Action Plan was a critical step in ensuring SCAG’s equity-related work continues to advance and endure for years to come. The Early Action Plan details SCAG’s definition of equity and establishes goals, strategies, and a set of “early actions” to advance racial equity through SCAG’s policies, practices and activities. The Early Action Plan is a “living document,” with opportunities to identify new actions over time. The four overarching goals include:

  1. Shift the Organizational Culture, which is focused on SCAG’s internal work and practices.
  2. Center Racial Equity in Regional Policy & Planning, which refers to SCAG’s regional planning functions.
  3. Encourage Racial Equity in Local Planning Practices, referring to how SCAG can influence the local elected officials and planning professionals with which it works and partners.
  4. Activate and Amplify, in which SCAG commits to communicating more broadly its commitment to racial equity and joining with others in different fields and sectors to amplify impact.

Each of these goals is advanced through a focus on the following three strategies:

  • Listen & Learn – Develop a shared understanding of our history of discrimination and the structural barriers that continue to perpetuate the inequities experienced today.
  • Engage & Co-Power – Create an environment where everyone is included, able to share their experiences, and equipped to talk about racial equity and inequities.
  • Integrate & Institutionalize – Focus on systems change to improve racial equity. Center racial equity in all aspects of work. This involves internal and external systems change.​​

The framework of the Racial Equity Early Action Plan was informed by Equity in the Center’s publication Awake to Woke to Work: Building a Race Equity Culture, which provides insights, tactics and best practices to shift organizational culture and operationalize equity, and by consultation with Mr. Charles Brown of Equitable Cities.

In support of SCAG’s commitment to “early actions,” the General Assembly voted to amend the SCAG Bylaws to include an increase in representation of “communities of concern” in regional policy conversations.  More information on SCAG’s work regarding inclusion, equity, diversity and awareness, including SCAG’s definition of Racial Equity, can be found here.

Seeking a way to meaningfully engage with other metropolitan planning organizations around equity-related work, SCAG formed the Metropolitan Planning Organization (MPO) Equity Working Group in December 2020 in response to expressed interest from other agencies on Government Alliance for Racial Equity discussion boards. Since then, the group convened nearly 40 participants from 19 MPOs and 11 states and discussed equity-related performance measurement and monitoring. The MPO Equity Working Group will discuss equity-oriented project prioritization and integrating equity into long-range plans at the upcoming May 14 meeting. For more information, email Courtney Aguirre at aguirre@scag.ca.gov.  

Support the FCC Emergency Broadband Benefit Program!

The National Association of Regional Councils (NARC) recently became an outreach partner for the Federal Communications Commission’s (FCC) Emergency Broadband Benefit Program (EBBP). The Emergency Broadband Benefit is a program to help households struggling to pay for internet service during the pandemic. This new benefit will connect eligible households to jobs, critical healthcare services, and virtual classrooms. EBBP will provide a discount of up to $50 per month towards broadband service for eligible households and up to $75 per month for households on Tribal lands. Eligible households can also receive a one-time discount of up to $100 to purchase a laptop, desktop computer, or tablet from participating providers if they contribute $10-$50 toward the purchase price. The Emergency Broadband Benefit is limited to one monthly service discount and one device discount per household.

Here are some answers to some of the most common questions about EBBP:

Who Is Eligible for the Emergency Broadband Benefit Program?

A household is eligible if one member of the household:

  • Receives benefits under the free and reduced-price school lunch program or the school breakfast program, including through the US Department of Agriculture Community Eligibility Provision, or did so in the 2019-2020 school year;
  • Received a Federal Pell Grant during the current award year;
  • Experienced a substantial loss of income since February 29, 2020 and the household had a total income in 2020 below $99,000 for single filers and $198,000 for joint filers;
  • Meets the eligibility criteria for a participating providers’ existing low-income or COVID-19 program; or
  • Qualifies for the Lifeline program or participates in one of the following federal assistance programs:
    • Medicaid
    • Supplemental Nutrition Assistance Program (SNAP)
    • Supplemental Security Income (SSI)
    • Federal Public Housing Assistance
    • Veterans and Survivors Pension Benefit; or
    • A household’s income is at or below 135% of the Federal Poverty Guidelines for a household of that size.

How Do EBBP-Eligible Households Enroll?

If a household is already a Lifeline participant, they will not need to apply for EBBP or provide any new documents to prove eligibility. Applicants only need to opt-in to a plan provided by their current broadband provider or request enrollment in the program. Current Lifeline subscribers can keep their current Lifeline benefit while also adding a plan that is offered through the EBBP.  People who are not currently participating in Lifeline must apply for the EBBP through the National Lifeline Verifier.

When Can EBBP-Eligible Households Apply?

The FCC has not set a date for enrollment to begin. However, enrollment is expected to start by May 2021. The enrollment period is required to close six months after the Secretary of Health and Human Services determines that the pandemic emergency is over or when the $3.2 billion appropriated by Congress has been exhausted, whichever occurs first.

Who are Emergency Broadband Benefit Providers and Where can I Find them?

The FCC recently unveiled a downloadable data table consisting of all broadband providers who have elected to participate in EBBP. The list will be updated as more providers join the program. Individuals can search by state for fixed broadband services and mobile broadband services. Fixed broadband services are provided to your home, or a single location. These include cable, fiber optic, DSL, satellite, and fixed wireless services. Mobile broadband services are device-based and available throughout the service provider’s cellular coverage area, similar to cell phone services.

The National Association of Regional Councils will offer support and information to regional and local communities to help the FCC mobilize people and organizations and share important consumer information about the Emergency Broadband Benefit Program. To learn more about the FCC’s Emergency Broadband Benefit Program, please check out the resources provided by our national partners at the National Digital Inclusion Alliance (NDIA) and Next Century Cities (NCC).

NARC Analysis: American Rescue Plan

NARC Analysis: American Rescue Plan

Last week, President Joe Biden signed the American Rescue Plan Act of 2021 into law. The $1.9 trillion bill will provide additional relief to address the continued impact of the coronavirus pandemic on the economy, public health, state and local governments, individuals, and businesses. NARC has created a PowerPoint presentation that summarizes some of the major pieces of this new bill. Feel free to share with your colleagues and membership and reach out to the NARC staff if you have any questions about the legislation.

Triangle J Council of Governments to Host Summit Series Focused on Equity

The Triangle J Council of Governments (TJCOG), which serves as the regional government for almost two million people across Chatham, Durham, Johnston, Lee, Moore, Orange, and Wake counties in North Carolina, will be hosting its first-ever virtual Regional Summit Series. The summit’s theme is “What’s Equity Have to Do with It?” and events will dive deep into the impact of government policies and practices on equity in the region.

This is not the first time TJCOG has addressed equity, however the organization is now placing a much greater emphasis on concrete actions that can be made to improve equity throughout the region. According to Alana Keegan, TJCOG Engagement Specialist, the organization’s past work has brought them to the point where they have an abundance of information and data and now it is time to do something with it. Keegan explained, “the biggest question is how our region can act on this type of information to implement equitable policies and shift the statistics in the Triangle,” noting the important work of member governments helping to lead the way.

As in many other regions and communities, conversations about equity in the Triangle J Region were put into overdrive after the murders of George Floyd, Breonna Taylor, and many other Black Americans. Keegan emphasized that “the summit, and our growing emphasis on equity, was a direct result of staff-wide conversations about race and equity in the aftermath of the murders of George Floyd and Breonna Taylor, and countless other Black individuals.” The TJCOG team, Keegan added, are “dedicated public sector employees, passionate about improving our communities, who were unwilling to allow conversation alone to be the end result.” These discussions ultimately resulted in a collaborative statement issued by Lee Worsley, executive director at TJCOG, expressing the organization’s commitment to systemic change in the region. The statement outlines future actions the organization will be taking and emphasizes that the organization’s commitment must be “displayed through direct action, not just words.”

The summit series will start next Thursday, September 17th. Each of the sessions will provide tools and best practices. Participants can choose from five workshops, or attend all of them, and learn about the ways equity is directly linked to community engagement, supporting older adults and their health, policing, and growth. As Keegan mentioned there are so many ways local and regional governments are impacting equity in their communities, they may not even know it!

A breakdown of sessions and timeline is below:

TJCOG Regional Summit Series Outline of Events

Session 1 Local Government and Equity

September 17th, 10-11:30 am ET

In this first session TJOCOG will dive into the basics. They plan to explain and discuss how government and equity are related to one another; ideas for making policy and budgetary decisions through an equity lens; and lastly participants will hear from experts in Diversity, Equity, and Inclusion, and from practitioners working to institutionalize foundations of equity in their government organizations.  

Session 2 Development, Growth and Equity

September 24th, 10-11:30 am ET

TJCOG staff will present numbers that seek to answer the question “are we growing in an equitable and inclusive manner?” Staff will lead discussion with local communities and partner organizations working to rethink public sector approaches to growth.

Session 3 Community Livability for All

October 1st, 10-11:30 am ET

This session will teach participants about local efforts underway to increase and sustain services to the most vulnerable populations. Communities must rethink their approach for supporting our oldest residents, especially during these difficult times.

Session 4 Equitable Community Engagement

October 8th, 10-11:30 am ET

Speakers in this session will share successful efforts of engaging with residents for feedback and discuss ongoing challenges to ensure the community is represented. Getting that input from every resident, including harder-to-reach communities, takes intentional action and strategies that find people where they are (rather than expecting them to come to the table).

Session 5 Policing Equity

October 15th, 10-11:30 am ET

As departments face ongoing requests and demands for reform, they will be tasked with community-centered policing that not only requires increased interaction with the public, but direct implementation of community-requested ideas (evidenced by newly released policy frameworks). How can departments use data to track decisions and behavior, and ensure both align with community interests?

For more information Email Alana Keegan, akeegan@tjcog.org.

Below is NARC staff’s full interview with Alana Keegan from TJCOG:

Is this the first time in TJCOG’s history such an emphasis has been placed on equity?

Much of our work at TJCOG has always focused on providing access – to housing, transit, jobs, clean water, etc. – but we are putting a much greater emphasis on the fact that good intentions do not equate to equitable access. Building transportation… helping individuals find work… there are different levels/types of supports and policies that are needed to provide equal opportunities to vulnerable or disadvantaged populations.

If not, what else has TJCOG done in the past? For example, special events, planning initiatives etc.

Previously (2013), TJCOG staff partnered with our neighboring COG Kerr Tar to work with the national organization PolicyLink on an Equitable Growth Profile for our combined region, highlighting an immense amount of data on demographics, growth, differing levels of access to prosperity, and much more. Linked here. The unspoken tagline of the summit should really be: “We have this information. Now what?” The biggest question is how our region can act on this type of information to implement equitable policies and shift the statistics in the Triangle. Luckily, many of our member governments are trailblazers in this work and are helping to lead the way.

How did the murders of George Floyd and Breonna Taylor shape the internal discussions about race and equity at TJCOG? Did these discussions have any influence on the summit sessions?

The summit, and our growing emphasis on equity, was a direct result of staff-wide conversations about race and equity in the aftermath of the murders of George Floyd and Breonna Taylor, and countless other Black individuals. Staff were understandably upset and concerned, and we all had the chance to talk through our feelings in small group settings. That said, our team is a group of dedicated public sector employees, passionate about improving our communities, who were unwilling to allow conversation alone to be the end result. Ultimately, a statement on TJCOG’s commitment to systemic change in our region was produced collaboratively with ED Lee Worsley that outlined what action will look like… to start. 

The summit series asks participants to learn about the ways equity is directly linked to community engagement, supporting older adults and their health, policing, and growth. Do you think there is still a lack of understand and acknowledgement of how these important issues are linked?

I think like any complex issue, we all make assumptions about what we do or do not understand or only learn bits of the whole concept. Especially with equity, a topic that is deeply important but can be sensitive, people may choose to stay silent instead of asking key introductory questions. The Summit will provide a space to answer those questions and build upon them.

Additionally, our focus is specific to equity and its relationship to local government. There are a lot of ways that governments already impact equity in their community but may not know it. One of our workshop leaders, Sharon Williams who is the Racial Equity and Inclusion Manager for the City of Durham, used the example of “ban the box” in a recent conversation we had. This initiative removes the question about previous felonies from job descriptions, improving access to jobs for those reintegrating into a community. Some governments already do this and may not even realize that is an equitable policy. Acknowledging why they are important and then actively analyzing and implementing other policies is the next step.

In what ways do you plan to show that the link between equity and the issues raised above is not only necessary but critical?

The structure of the summit is broken out into five sessions, with the first session as a workshop on local government and equity. Through this workshop, our hope is to lay a foundation of knowledge, outline the ways policy impacts equity, and discuss some tools to reanalyze or reexamine existing policies through an equity lens. The following sessions will highlight the ways that equitable practices improve engagement, older adult livability, economic development, and policies; some will also highlight the impact of current gaps and how improving equity benefits us all.

What does the team at TJCOG hope to gain through the summit and various sessions?

Selfishly, we are all just excited to participate and hear from the speakers. There are some incredibly knowledgeable individuals talking to attendees and all of us can learn more about the topic. Additionally, we hope to gain some tools that can be used in a lot of regional projects, such as our Comprehensive Economic Development Strategy underway, and for our own internal strategic plan for TJCOG. 

What do you hope participants will gain from the summit?

A network of individuals to connect with and continue conversations with after the event.

An understanding of what equity means and how it can be accomplished through their daily work. Most of our participants work in or with local government. Their jobs and programs are intricately linked to equity in the community.

Lastly, do you have any remarks or comments you would like to share on behalf of TJCOG about not only the process and work that went into organizing this event but about the organizations work on and around the issue of equity.

We are learning as we go, being intentional, and pulling in the expertise of individuals and organizations who have been dedicated to improving equity for some time, of which there are many. This could be said for a lot of different topics, but there is no reason to recreate the wheel. Learning from others’ best practices or mistakes (lessons learned) is key.

2020 Census Data Collection May Come to a Halt a Month Early

Earlier this week, U.S. Census Bureau Director Steven Dillingham issued a statement that 2020 census operations will be accelerated and field data collection completed by September 30, 2020.

NARC and other census advocates are concerned that wrapping up door knocking efforts and self-response options a month earlier than previously planned will lead to a significant undercount of our most vulnerable populations.

Given the many important ways that the census impacts regional, rural, and metropolitan planning, the National Association of Regional Councils (NARC), along with the National Association of Development Organizations (NADO) and the Association of Metropolitan Planning Organizations (AMPO), has developed a letter (NARC-NADO-AMPO Census Letter) to Congressional leaders which includes the following requests:

  • Request the administration reconsider its decision to complete field data collection by September 30 and provide additional time to ensure as comprehensive a

survey as possible is performed.

  • Ensure that Census Bureau efforts to protect respondent confidentiality via differential privacy (the process by which the Census Bureau is attempting to ensure the confidentiality of individual respondents) do not incorporate systematic biases that undermine the usability and reliability of census-derived data.
  • Work to ensure an accurate count in each community that houses a college, university, or other educational institution impacted by the COVID-19 pandemic.
  • Establish a Census Bureau working group with the Federal Highway Administration (FHWA) and the Federal Transit Administration (FTA) as a way to mitigate the concerns outlined in this letter once counts are completed.

The stakes are too high not to give the Census Bureau – whose census count operations have been seriously impacted by the coronavirus pandemic – additional time to ensure the completeness and accuracy of the 2020 census.

Moving up the date on which the Complete Count effort will end, from October 31 to September 30, will sacrifice data comprehensiveness and accuracy in the interest of speed. The shortened data collection period will result in a more significant undercount of so-called “hard to count” populations, including minority populations, young children, and those with no or poor internet access.

It is no exaggeration that the 2020 census count will significantly impact every city, county, and region in America for the next decade. For this reason, NARC opposes the condensed census operations timeline and asks Congress to extend the 2020 census statutory reporting deadlines by an additional 120 calendar days.

We invite you to add your organization as a signatory to this important letter. If you would like to do so, please fill out this Google Form to indicate how you’d like your organization’s name to appear.

Additionally we encourage you to reach out to your congressional delegations and urge them to support an extension of the 2020 census statutory reporting deadlines by an additional 120 calendar days.

We have drafted this template letter to assist you in your federal outreach. Even if you cannot do direct advocacy, we hope that you will help spread the word among your membership and community partners that are active in 2020 census outreach efforts.

If you have any questions or comments regarding these letters and NARC’s advocacy regarding the census, please send them to erich@narc.org.

Regions Addressing the National Broadband Gap

The broadband access gap is no new issue. In fact, research has proven the issue may be worse than what current federal data suggests. Research from both Microsoft and Pew Research indicates that the Federal Communication Commission (FCC) has vastly overestimated how many Americans have access to broadband. While FCC data suggests that 25 million Americans lack access to a broadband connection, Microsoft found that 162.8 million people do not use internet at broadband speeds. This comparison is displayed in the graph below:

Why is there such stark contrast between the maps? This is due in large part to the way census blocks map coverage. For example, if 1 out of 14 households in a given census block has coverage, the entire block will be marked as “covered.” This underserved census block would be denied federal funding from sources such as USDA ReConnect due to carve-outs meant to prevent over-building. This would deny the census block many of the federal financial resources that could be utilized to build out the infrastructure needed to cover the other 13 households.

Since the COVID-19 pandemic began, we have seen that basic access to internet is a necessity and not a privilege. Access to broadband is more important now than ever as our dining rooms turn into school classrooms and our home offices become our regular 9 to 5 location. Ensuring equitable access to broadband for all – including teachers, students, rural healthcare workers, and professionals attempting to work remotely – makes finding a way to pay for and build out broadband infrastructure in all our communities a top priority.

Regional councils are doing important work to better understand the broadband access gap within their regions and tackle the barriers head on:

Mid-Ohio Regional Planning Commission 

The Mid-Ohio Regional Planning Commission (MORPC), which serves the Central Ohio region, created a Smart Region Task Force to develop a shared vision for what it means to be a smart region, collaborating across communities to leverage emerging technologies and data to provide services more effectively. The task force is comprised of stakeholders including local government officials, university representatives, business leaders, transportation professionals, the National Digital Inclusion Alliance, and BroadbandUSA. Included in the task force’s vision is finding ways to connect currently disconnected communities. Connected Nation Ohio, a critical member of the task force, is working closely with broadband providers from across the state to develop a variety of broadband inventory maps for public use. MORPC has conducted additional mapping as part of the Smart Region Task Force which displays the percent of households with no internet access.

Houston-Galveston Area Council

The Houston-Galveston Area Council (H-GAC) in partnership with the Gulf Coast Economic Development District (GCEDD) recently published a Regional High-Speed Internet Strategy. The Strategy provides a roadmap for local governments looking to expand access to high-speed internet in the Houston-Galveston region. The strategy begins with general goals and recommendations for local governments and an explanation of high-speed internet technologies. The regional strategy shares seven steps that a community should take to expand their internet infrastructure: gaining leadership support, building community momentum, establishing goals, determining existing conditions, redefining policies, examining options for connectivity, and financing. The strategy also provides a compilation of potential federal financial resources.

Their report outlines the specific challenges the 13-county Houston-Galveston region faces in closing current gaps in broadband service, as well as potential solutions. The appendix shares the latest broadband mapping of the region. Two maps, one showing the broadband speeds of at least 25Mbps download/3Mbps upload and the other showing broadband speeds of at least 100Mbps download/10Mbps upload, are provided for each country in the Houston Galveston region. For example, snapshots for Austin county, TX are shown below displaying the decrease in broadband access for faster speeds:

Buckeye Hills Regional Council

In 2019, Buckeye Hills Regional Council conducted an eight-county study funded by the Appalachian Regional Commission in collaboration with Ohio University Voinovich School and The Athens County Economic Development Council. The study found that between 80% and 90% of households in the rural expanse, defined as areas with 20 or fewer households per square mile, had no access to broadband services. They found 75% of the study area lacks availability of broadband at the current FCC minimum of 25Mbps download/3Mbps upload. Mobile data and voice services are also largely absent from the rural expanse, and degradation of basic telephone services due to beyond end-of-life copper cables is leaving affected areas without crucial life and safety communications. The figure below from the study showcases the large digital deserts that exist within the region:

Buckeye Hills Regional Council revisited this important issue in the wake of COVID-19 alongside OhioSE Economic Development in the presentation “Cracking the Rural Broadband Puzzle.” Funding from OhioSE allowed both organizations to extend the original eight-county study to 37 counties. The organizations are advocating for a $2.3 billion fiber-to-the-premise project in Appalachia Ohio constructing 45,000 miles, creating 9,000 jobs, and generating $1 billion increase in GDP.

Brazos Valley Council of Governments

The Brazos Valley Council of Governments (BVCOG) successfully coordinated the development of a health care consortium to address the lack of connectivity in the region. Through this group BVCOG has been able to bring affordable, high-speed broadband to rural Brazos Valley healthcare providers. This was accomplished through the establishment of BVCOGNET. Healthcare facilities, schools, and businesses in rural areas are limited in their potential to provide public and economic services without high-speed, reliable internet access. BVCOGNET encompasses two fiber-optic rings, 11 regeneration sites built to Category 3 hurricane standards, self-contained air conditioning and heating units, Uninterruptable Power Supplies (UPS) systems, generators, and complete environment and security monitoring. Now, connection to BVCOGNET is available not only to healthcare providers, but governments, nonprofits, and commercial businesses within its seven-county service area.

Small and Mid-Sized Communities Left Out of the Coronavirus Relief Fund

On March 27th, the president signed into law the third federal COVID-19 aid package: the Coronavirus Aid, Relief, and Economic Security (CARES) Act (H.R. 748). This legislation is the most substantial coronavirus relief package released so far, providing the country with $2.3 trillion of aid to counter the physical and economic effects of the COVID-19 pandemic. One snag in this massive piece of legislation is a rule which leaves small and mid-sized communities across the country without direct access to funding.

The CARES Act created a $150 billion Coronavirus Relief Fund to provide payments to states and local governments with populations over 500,000. Each state is guaranteed a payment of at least $1.25 billion from the fund, with money provided to local governments within their borders subtracted from the total that is allocated to them. The amount made available to each state will vary based on their population, and states are not obligated to disperse these funds to localities that are not eligible under the 500,000 population minimum. The Treasury Department has provided a full breakdown of each state’s allocation.

The legislation’s language concerning the 500,000 population threshold has led to a lack of consensus on which counties, cities, localities, and “other unit[s] of general government” are eligible to receive these funds and the Treasury Department has only recently provided further clarification. Both the National Association of Counties (NACo) and the National League of Cities (NLC) have submitted separate letters to Treasury Secretary Steven Mnuchin asking for more direct funding to local governments and clarification regarding the 500,000 rule.

Recent Clarification from the Treasury Regarding the 500,000 Rule.

Eligibility of Local Governments

According to the Treasury Department, a unit of local government eligible for receipt of direct payment includes a county, municipality, town, township, village, parish, borough, or other unit of general government below the State level with a population that exceeds 500,000. A local government must have a population in excess of 500,000 to provide a certification for payment. There is no further explicit clarification of what is and is not an “other unit of general government.”

Overlapping Jurisdictions

Some local governments, such as cities, may be entirely within the boundaries of a larger local government such as a county. The larger local government may include, for purposes of determining whether it meets the 500,000 threshold for eligibility, the population of the smaller, constituent local government.

  • If the smaller, constituent local government does not provide a certification for payment, the entire population of the larger local government (including the population of the smaller local government) will be used for purposes of calculating its payment amount.
  • If the smaller, constituent local government provides a certification for payment, the population of the smaller local government will be subtracted from the population of the larger local government for purposes of calculating its payment amount.

Listed Eligible Governments

The Treasury Department has distributed a list of 171 counties and cities/towns that have a population of more than 500,000 people according to Census data. According to the Treasury, consolidated cities and counties and city-counties may be listed twice. For example, Los Angeles County and Los Angeles city are both listed. The Treasury has not specified what happens in the event that a city and county both qualify under the 500,000 rule.  Some are concerned with double counting and its effect on the disbursement of payments. Governments eligible for payments must provide payment information and supporting documentation through the electronic form on the Treasury’s CARES Act assistance webpage. To ensure that payments are made within the 30 day period specified by the CARES Act, governments must submit completed payment materials not later than 11:59 p.m. EDT on April 17, 2020.

The Next Round of Funding Support

In response to small and medium local governments missing out on this massive funding opportunity, a group of House Democrats including U.S. House Assistant Speaker Ben Ray Luján (D-NM), Joe Neguse (D-CO), Andy Levin (D-MI), and Tom Malinowski (D-NJ) have introduced the Coronavirus Community Relief Act to provide $250 billion in stabilization funds for localities with 500,000 people or less amidst the COVID-19 pandemic. The congressmen pointed to the many towns, cities, and counties being left out of direct funding from the CARES Act, highlighting that some of these communities were in areas that had been hit hardest by COVID-19.

In addition to the bill they are proposing, Congressmembers Luján, Neguse, Levin, and Malinowski wrote a letter to Speaker Pelosi requesting that the 500,000 population cap be removed and additional funds be authorized for cities and towns in the next stimulus package from Congress. 

NARC has also weighed in on this issue, requesting that the federal government provide more funding to local governments and allow regional councils and metropolitan planning organizations with a collective population of greater than 500,000 to apply for direct funding on behalf of their member local governments. In a letter to Secretary Mnuchin, NARC expressed that many regional planning organizations are well positioned to work with the federal government to provide accountability for the expenditure of funds and to establish an equitable distribution of funds to local governments within their regions.

As authorities across the country have ordered nonessential operations and businesses to temporarily close, unemployment is skyrocketing and government revenues are expected to drop sharply compared to projected levels. Unfortunately, the CARES Act lacks sufficient funding and flexibility for states and localities to compensate for these revenue reductions. In the next funding package, federal lawmakers should deliver “unencumbered aid” for state and local governments regardless of population to ensure they have the resources needed to address the long-term health and economic concerns of their residents.

NARC will continue to track this situation and provide members with any updates or clarification from the Treasury Department.

Additional Resources

Treasury Department: A complete breakdown of eligibility can be found here.

Treasury Department: A full list of eligible counties and cities can be found here.

NLC Action Campaign to Co-sponsor the Coronavirus Community Relief Act here.

NLC/USCM CARES Act Fact Sheet here.

NLC/USCM Infographic here.

GFOA Letter to Congressional Leadership Requesting Direct Funding to Local Governments of all sizes in the next funding Package here.