TRIBAL BROADBAND
CONNECTIVITY PROGRAM (TBCP)
SECOND NOTICE OF FUNDING
OPPORTUNITY
BROADBAND INFRASTRUCTURE
DEPLOYMENT PROJECT
APPLICATION GUIDANCE
This guidance document is for informational purposes only and is intended solely to assist
applicants in better understanding the NTIA Tribal Broadband Connectivity Program, and the
requirements set forth in the program’s Notice of Funding Opportunity (Second TBCP
NOFO). This guidance does not and is not intended to supersede, modify, or otherwise alter
applicable statutory or regulatory requirements, or the specific application requirements set
forth in the Second TBCP NOFO. In all cases, statutory and regulatory mandates, and the
requirements set forth in the Second TBCP NOFO, shall prevail over any inconsistencies
contained in the guidance below. The Second TBCP NOFO is available at: ntia-tbcp-round2-
nofo.pdf.
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Project Narrative Guidance ......................................................................................................... 3
Executive Summary ..................................................................................................................... 3
Eligible Entity Description .......................................................................................................... 3
Table of Funded Participants and Unfunded Collaborators ........................................................ 3
Resumes of Key Personnel ........................................................................................................ 4
Description of the Activities to be Funded by the Grant ...................................................................................................... 4
Project Purpose and Benefits ..................................................................................................................................................... 4
Level of Need .......................................................................................................................................................................... 4
Poverty Level........................................................................................................................................................................... 5
Job Creation and Labor Standards............................................................................................................................................ 6
Broadband Speed Tiers and Affordable Pricing .................................................................................................................... 6
Climate Resiliency ...................................................................................................................................................................... 7
Project Plan................................................................................................................................................................................... 7
Sustainability ................................................................................................................................................................................ 8
Description of the Physical Project Area, and its Surroundings.......................................................................................... 8
Additional Application Guidance ................................................................................................ 9
TBCP2 Project Information Form ............................................................................................................................................ 9
Maps of Proposed Service Areas .............................................................................................................................................. 9
Tribal Resolution of Consent..................................................................................................................................................... 9
Tribal Government Certification of Unserved Areas ..........................................................................................................10
Community Economic Development Strategy (optional) ..................................................................................................11
Request for Extension of Award Period (optional) .............................................................................................................11
Budget Narrative and Detailed Budget Justification ...........................................................................................................11
Indirect Cost Rate ......................................................................................................................................................................11
Pro Forma Financial Projections.............................................................................................................................................12
Physical Network Diagrams and System Designs ...............................................................................................................12
Certification Regarding Compliance with Cybersecurity and Supply Chain Management Requirements ...............12
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Project Narrative Guidance
The Project Narrative is a word-processed document of not more than 20 single- or 40 double-
spaced pages (including the Executive Summary) responsive to the program description,
statutory purposes, funding priorities, and the evaluation criteria set forth in the NOFO. The
project narrative must identify specific tasks, measurable milestones and performance outcomes
resulting for Native American/Alaska Native/Native Hawaiian communities from the proposed
project activities. A complete project narrative must include all of the components outlined
below.
Executive Summary (p. 23 of the NOFO)
An executive summary of the project not to exceed two (2) pages. Please note, if an applicant’s
proposal is selected for funding, NTIA may use all or a portion of the Executive Summary as
part of a press release issued by NTIA, or for other public information and outreach purposes.
Applicants are advised not to incorporate information pertaining to business trade secrets or
other confidential cultural, commercial, or financial information as part of the Executive
Summary. See also 15 C.F.R. § 4.9(c) concerning the designation of business information by the
applicant.
Eligible Entity Description (p. 23-24 of the NOFO)
Information to sufficiently demonstrate that they are in the category of eligible entities as defined
in section 905(a)(8) of the Consolidated Appropriations Act, 2021, as amended (Act).
1
Section
905(a)(8) of the Act specifies the following types of entities as eligible to receive TBCP grants:
(i) a Tribal Government;
(ii) a Tribal College or University;
(iii) the Department of Hawaiian Home Lands on behalf of the Native Hawaiian
Community, including Native Hawaiian Education Programs;
(iv) a Tribal organization; or
(v) an Alaska Native Corporation.
A description of the eligible entity and the qualifications and experience of key personnel
responsible for implementing the proposed project.
Table of Funded Participants and Unfunded Collaborators (p. 24 of the NOFO)
(Does not count toward page limit.) Provide a table that identifies all organizations that will
participate in and contribute to the proposed activities, note whether they will be funded or
unfunded and whether known or unknown at the time of the application submission. The table
should consist of an alphabetically ordered list, by organization, of all Funded Project
Participants and all Unfunded Informal Collaborators, and indicate which is which. The table
should include the organization’s name, address, administrative role, scope of work (funded
participants only) and proposed funding amount (funded participants only). Administrative roles
are applicant, subrecipient, or contractor for funded participants; or collaborator if they will not
1
Consolidated Appropriations Act, 2021, Division N, Title IX, Sections 905(a)(8), Pub. L. 116-260, 134 Stat. 1182
(Dec. 27, 2020), as amended by the Infrastructure Investment and Jobs Act, Division F, Title II, Section 60201, Pub.
L. 117-58, 135 Stat. 429 (Nov. 15, 2021).
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receive funding. Additionally, if the contractor has not been determined, under “Organization”,
recommend inserting “TBD”.
Organization
Scope of Work
(funded participants
only)
Funding Amount
(funded participants
only)
Resumes of Key Personnel (p. 24 of the NOFO)
(Does not count toward page limit but are limited to one-page each). One-page resumes of no
more than five key personnel from applicant (not subrecipients) may be included. Any
information beyond one page for each resume and any additional resumes submitted will not be
considered. Key personnel qualifications and experience may be demonstrated by reference to
successful implementation of previously-received Federal broadband grants (under programs
administered by NTIA, FCC, USDA, or otherwise).
Description of the Activities to be Funded by the Grant (p. 24 of the NOFO)
Describe the activities to be funded, the eligible uses of the funding, and the proposed objectives
and outcomes for Native American/Alaska Native/Native Hawaiian communities from the
project. Federally Recognized Tribes should include a description of the broadband infrastructure
activities that they would perform if they were only to receive the equitable distribution
allocation of up to $500,000. (If this is a dual application, ensure that the equitable distribution
allocation matches in both applications). Note that during this second round, NTIA will not fund
projects proposing to conduct planning activities or prepare feasibility or sustainability studies
unless they are part of a proposal to deploy broadband infrastructure or construct broadband
networks.
All proposed projects submitted should be comprehensive and completely autonomous, therefore
not reliant on future funding or a future adjacent project.
Project Purpose and Benefits
Level of Need (p. 24-25 of the NOFO)
Define the proposed service area and the total number of unserved Native American/Alaska
Native/Native Hawaiian households, businesses and community anchor institutions located
therein to be served by completion of the proposed project. In accordance with Section
905(c)(8) of the Act, applicants proposing to use grant funds for the construction of new
broadband infrastructure must prioritize projects that deploy broadband infrastructure to
Unserved Native American/Alaska Native/Native Hawaiian households. Describe the total
number of Native American/Alaska Native/Native Hawaiian households, businesses, and
community anchor institutions lacking access to the Internet and to qualifying broadband service
(i.e., those not currently receiving Internet service with speeds of 25/3 Mbps or greater with
latency considerations). This description should include a list of locations lacking such access,
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preferably based on the FCC’s Fabric from its National Broadband Map. Applicants may
include a polygon that captures the locations to be served. The applicant should also identify the
total number of Native American/Alaska Native/Native Hawaiian households, businesses and
community anchor institutions that it plans to connect to Qualifying Broadband Service and the
number that will be connected at speeds higher than Qualifying Broadband Service, specifying
the speed level. Sample provided below:
TOTAL Number of Tribal Households on Tribal Land?
300
Number of UNSERVED Tribal households on Tribal Land?
150
Number of UNSERVED Tribal households that this project will connect
to Qualifying Broadband Service (defined as 25 Mbps download/3 Mbps
upload with sufficient latency for real time interactive applications)?
Number receiving speeds higher than Qualifying Broadband Service,
specifying the speed level?
75
75 at 100 Mbps/20
Mbps
Number of UNSERVED Tribal Businesses that this project will connect
to Qualifying Broadband Service?
Number receiving speeds higher than Qualifying Broadband Service,
specifying the speed level?
10
5 at 100 Mbps/20 Mbps
Number of UNSERVED Tribal Community Anchor Institutions that this
project will connect to Qualifying Broadband Service?
Number receiving speeds higher than Qualifying Broadband Service,
specifying the speed level?
5
5 at 100 Mbps/20 Mbps
Describe plans to deploy Qualifying Broadband Service to Native American/Alaska
Native/Native Hawaiian households, businesses, and community anchor institutions in the
proposed project area that meets quality of service performance measures such that network
outages do not exceed, on average, 48 hours over any 365-day period.
In addition, the Applicant must:
• identify the distance to the nearest fiber node; and
• identify any libraries within the proposed build receiving E-Rate funding.
Poverty Level (p. 25 of the NOFO)
A description of the number of total Native American/Alaska Native/Native Hawaiian
households in the proposed service area at or below 150% of the poverty line (provide
percentage as it compares to all households on the Tribal land proposed service area) applicable
to the average family size represented on the particular Tribal land covered by the project in the
lower 48 states, Alaska and Hawaii (utilizing HHS Poverty Guidelines). Provide an explanation
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detailing how the percentage was calculated, data source, and factors included. Sample table
included:
Data
Source
Description
Calculation Method
Total Native
American/Alaska
Native/Native Hawaiian
households in the proposed
service area at or below 150%
of the poverty line
Tribal
census,
HHS
poverty
guidelines,
etc.
25 Tribal Households
at or below 150%
poverty line / 100
Total Tribal
Households
25%
Job Creation (p. 25 of the NOFO)
Provide an estimate of the total number of jobs, including a subset for Native American/Alaska
Native/Native Hawaiian jobs, and subset of those jobs that will comply with the Tribal
Employment Rights Ordinance of the Tribe (TERO). Describe a plan for workforce training and
development, including in broadband deployment-related occupations, as well as plans to
address any anticipated labor shortages in these fields.
Broadband Speed Tiers and Affordable Pricing (p. 25-26 of the NOFO)
Provide a description of the pricing for the broadband services that the applicant intends to offer
compared to existing broadband services in the proposed service area along with a demonstration
that the pricing is competitive and affordable in the target market. Describe plans to participate in
federal subsidy programs, such as the FCC’s Affordable Connectivity Program, to reduce costs
of broadband service for Native American/Alaska Native/Native Hawaiian households in the
proposed service area.
2
In order to meet this requirement, NTIA recommends including the variations in offerings that
will be provided, including speed tiers, pricing, and local pricing in the area to show
affordability. Provide the data source(s) used to calculate the average price in the area including
company name(s).
Sample table below:
Type
Proposed Speed
Offering
Proposed
Pricing
Average in the area
(include Company)
2
The Affordable Connectivity Program was established in IIJA as the successor to a previous program that has since
been discontinued. The FCC in 2022 the Affordable Connectivity Program Report and Order, which sets out details
regarding the ACP’s operation. See Affordable Connectivity Program, Report and Order and Further Notice of
Proposed Rulemaking, FCC 22-2 (rel. Jan. 21, 2022) available at https://docs.fcc.gov/public/attachments/FCC-22-
2A1.pdf. The Affordable Connectivity Program provides a $75 monthly subsidy for qualifying households living on
Tribal Lands.
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Residential
25/3
39.99
59.99 (Comcast)
50/10
49.99
69.99
100/20
59.99
79.99
Commercial
100/100
99.99
129.99
200/200
199.99
249.99
500/500
299.99
369.99
Labor Standards (p. 26 of the NOFO)
Provide a description of whether and, if so, how the project will incorporate strong labor
standards, consistent with Tribal law, including project labor agreements and community benefit
agreements that offer wages at or above the prevailing rate and include local hire provisions, and
a description of the applicant’s workforce plans and practices.
Climate Resiliency (p. 26 of the NOFO)
Provide an assessment of weather and climate hazards within the Tribal Land served by the
project and a description of how the applicant intends to avoid and/or mitigate the weather and
climate risks identified.
3
Project Plan (p. 26 of the NOFO)
Provide the overall project objectives and outcomes. The project plan should describe all major
project activities and timelines for implementation, including key deployment milestones.
Describe the overall project plan, including cost effectiveness (e.g., costs for single network and
economies of scale for consortium); service capacity; timeframes for construction; and
scalability.
Applicant should include a timeline, including but not limited to, major milestones, dates, and
evaluation criteria for each milestone. See example provided below.
3
In making this assessment, Eligible Entities should make use of available tools and resources from the National
Oceanic and Atmospheric Administration (NOAA) and other federal agencies. Such resources include the 2018
National Climate Assessment (https://nca2018.globalchange.gov); NOAA’s state climate summaries
(https://statesummaries.ncics.org/); NOAA’s disaster and risk mapping tool
(https://www.ncdc.noaa.gov/billions/mapping) and NOAA’s storms event database
(https://www.ncdc.noaa.gov/stormevents/). FEMA’s National Risk Index (https://hazards.fema.gov/nri/learn-more)
provides composite risk index for all regions across the United States, incorporating a range of natural hazards,
many of which are weather- and climate-related. FEMA’s flood risk maps (https://msc.fema.gov/portal/home)
provides information on current conditions for specific locations.
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Efforts to minimize lack of service (p. 26 of the NOFO)
Provide details and evidence of any proactivity, initiative, and or financial investment the
applicant may have made in an effort to move toward a resolution to minimize or eliminate any
gaps or lack of service.
Sustainability (p. 26 of the NOFO)
Describe a comprehensive and defined plan for long-term network sustainability that includes
projected revenue (pro-forma), operating expenses, working capital, and equipment replacement
funding, as well as work force development and capacity building. “Long-term” means
demonstrating the ability of the project to be sustained beyond the award period.
Description of the Physical Project Area, and its Surroundings (p. 26-27 of the NOFO)
For projects including construction and/or ground disturbing activities, a brief description of the
physical project area and its surroundings (e.g., disturbed or developed land vs. open space;
adjacent natural resources, such as rivers, wetlands, or forestlands; and any protected lands or
resources in or near the project area), including site photographs and aerial (e.g., Google Maps
images) photographs. This description should also describe how the applicant intends to comply
with the environmental and historic preservation and cultural requirements applicable to an
award received under the TBCP (including, but not limited to, the National Environmental
Policy Act and the National Historic Preservation Act) and, if applicable, a copy of any
environmental and historic preservation review documentation that has been prepared in
connection with obtaining permits or approvals from State, Tribal, local or other federal entities.
It is the applicant’s responsibility to obtain all necessary federal, State, Tribal, and local
governmental permits and approvals necessary for the proposed work to be conducted.
Applicants are expected to design their projects so that they minimize the potential for adverse
impacts on the environment. Environmental and historic preservation review documentation, if
provided, is not included in the 20-page limit of the project narrative.
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Additional Application Guidance
TBCP2 Project Information Form (p. 19 of the NOFO)
All applicants are required to complete all applicable fields in the TBCP2 Project Information
Form and submit it with their application package.
Maps of Proposed Service Areas (p. 27 of the NOFO)
To ensure conformity with NTIA’s National Broadband Availability Map (NBAM), applicants
must submit GIS shapefiles consistent with the project narrative, where applicable. This format
will allow application reviewers to efficiently identify critical components of the proposed
service area, proposed network, and households, business and community anchor institutions to
be served. This format will also facilitate the de-duplication analysis described in Section E.3.c.i
of the NOFO. The GIS shapefile must include the following data elements as applicable:
a) Proposed and existing fiber
b) Proposed and existing infrastructure (e.g., towers, power poles, buildings, or structures)
c) Distance/location of overhead construction
d) Distance/location of underground construction
e) Drop points (identify if overhead or underground)
f) Fiber counts
g) Innerduct size and count
h) Handholes and testing stations
i) Power supply and backup power
j) Backhaul connection
k) Tribal boundary
l) Tribal home locations (proposed connections)
m) Tribal business locations (proposed connections)
n) Community Anchor Institution locations (proposed connections)
o) Proposed service area
p) Last mile connections (proposed and existing)
q) Points of Presence
r) Proposed and/or existing network shelter
s) Census block
t) Network propagation maps
Tribal Resolution of Consent (p. 27 of the NOFO)
Applicants must provide Tribal Resolutions of Consent that reference the NOFO and are dated
after its release. The resolution must come from the entity specified in the Federally Recognized
Indian Tribe List Act of 1994.
Consortium Applications: Each Eligible Entity applying for Broadband Infrastructure
Deployment funds is required to submit a Resolution of Consent from each Tribal Government
and/or from the Tribal Council of the appropriate governing body upon whose Tribal Lands the
application will serve. Consortium applications submitted without resolutions from each Tribe
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named in the application will be considered incomplete. For additional information on the
Resolution requirement for consortia, see Section C.3.c of the NOFO.
Tribal Government Certification of Unserved Areas (p. 27-28 of the NOFO)
A Tribal Government may certify that locations within its own Tribal Lands are unserved. Any
other Eligible Entity may also submit such a certification of Unserved locations provided to them
by a Tribal Government. Any such Tribal Government certification that a location is Unserved
must certify that the areas where last mile service is proposed are not served by Qualifying
Broadband Service and provide a resolution on Tribal Letterhead, along with source data
supporting the certification, explaining how that determination of unserved was reached. The
Department of Hawaiian Home Lands may also certify whether Tribal Lands as described in
Subsection D of the NOFO are Unserved by Qualifying Broadband Service, along with source
data supporting the certification, explaining how the determination of unserved was reached. A
Tribal Government may not certify Tribal Lands covered under an Enforceable Buildout
Commitment, as defined in Section A.3.k of the NOFO, as Unserved. If the Tribe is aware of the
presence of facilities capable of delivering Qualifying Broadband Service, e.g., fiber facilities or
other broadband technology, deployed on their Tribal Lands, they must disclose this information
to NTIA. As part of the process described in Section E.3.c.ii, NTIA will conduct an analysis of
these certifications and disclosures.
As part of its Tribal Government Certification of Unserved Areas, the Tribe must consult the
FCC’s National Broadband Map. If that map indicates that Qualifying Broadband Service is
available at any location within the proposed service area(s), but the Tribe disagrees, then the
Tribe shall submit a formal challenge to the FCC using the challenge process for its National
Broadband Map or indicate that it is participating in the state’s submission for the FCC’s
challenge process, and provide documentation to NTIA of the challenge(s) submitted.
Required Disclosures for the Tribal Government Certification of Unserved Areas:
• Disclosure of all Enforceable Buildout Commitments.
• Disclosure of a terminated Enforceable Buildout Commitment. A Tribal Government
must disclose whether it has terminated an agreement qualifying as an Enforceable
Buildout Commitment in anticipation of receiving funding under the TBCP. Failure to
disclose may result in NTIA removing the application from consideration for TBCP
funding.
• Disclosure of the presence of facilities capable of delivering Qualifying Broadband
Service, including fiber facilities or other broadband technology, deployed on Tribal
Lands if the Tribe has knowledge of their locations.
• Disclosure of the Tribe’s participation in the FCC’s challenge process for its National
Broadband Map or its participation in the state’s submission for the FCC’s challenge
process for the FCC National Broadband Map. Provide documentation of the
challenge(s) submitted.
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Community Economic Development Strategy (optional) (p. 28 of the NOFO)
An eligible entity may submit a copy of its own Community Economic Development Strategy, or
a regional or State Community Economic Development Strategy, if applicable to its project
proposal. If this is not applicable (N/A) or you do not have one, please leave this header in
and identify that you do not have one or it is N/A.
Request for Extension of Award Period (optional) (p. 28 of the NOFO)
Any request for an extension of the award period must be made on Tribal letterhead and signed
by the Authorized Organization Representative. If this is not applicable (N/A) or you do not
have one, please leave this header in and identify that you do not have one or it is N/A.
Budget Narrative and Detailed Budget Justification (p. 29 of the NOFO)
Please see the SAMPLE_Budget Narrative and SAMPLE_Budget Justification for guidance
on satisfying these application requirements. For more information, see Section D.2.c.viii of the
NOFO.
Indirect Cost Rate (p. 29 of the NOFO)
Section 905(c)(6)(A) of the Act, as amended, prohibits an Eligible Entity from using more than 2
percent of grants funds received under the TBCP for administrative expenses. For this purpose,
the 2 percent limitation on administrative expenses includes the combined total of indirect costs
and direct administrative costs charged to an award.
If indirect costs are included in the proposed budget, the applicant must ensure that the budgeted
amounts for indirect costs, plus the budgeted amounts for direct administrative costs, do not
exceed two percent of the requested grant amount, regardless of any previously approved indirect
cost rate it may have negotiated with a cognizant federal agency. If indirect costs are included in
the proposed budget, the applicant must provide a copy of the approved negotiated agreement if
this rate was negotiated with a cognizant federal audit agency. If the rate was not established by
a cognizant federal audit agency, provide a statement to this effect. If the successful applicant
includes indirect costs in the budget and has not established an indirect cost rate with a cognizant
federal audit agency, the applicant will be required to obtain such a rate in accordance with
Section B.06 of the Department of Commerce Financial Assistance Standard Terms and
Conditions, dated November 12, 2020.
Alternatively, consistent with 2 C.F.R. § 200.414(f), applicants that do not have a current
negotiated indirect cost rate may elect to charge indirect costs to an award pursuant to a de
minimis rate of up to 2 percent of modified total direct costs (MTDC), in which case a negotiated
indirect cost rate agreement is not required. Applicants proposing an up to 2 percent de minimis
rate pursuant to 2 C.F.R. § 200.414(f) should note this election as part of the budget portion of
the application.
As described in 2 C.F.R. § 200.403, costs must be consistently charged as either indirect or direct
costs but may not be double charged or inconsistently charged as both. Applicants are reminded
Broadband Infrastructure Deployment Guidance –
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that the two percent limitation on administrative expenses includes the combined total of indirect
costs and direct administrative costs charged to an award. The applicant must clearly describe in
the budget narrative how it applied or calculated the 2 percent limitation of administrative and
indirect costs.
Pro Forma Financial Projections (p. 30 of the NOFO)
Using the Pro Forma Financial Projection Template form as a guide, provide pro forma financial
information and analyses for the proposed project(s), such as balance sheets, income statements,
and statement of cash flows.
Physical Network Diagrams and System Designs (p. 30 of the NOFO)
Physical network diagrams and system designs for broadband deployment and construction
projects in GIS shapefile format. The GIS shapefile shall include the following data elements
when and where applicable: identification of proposed fiber (aerial and/or underground); existing
fiber (aerial and/or underground); drop points; fiber counts; handholes; power supply and backup
power locations; backhaul connection; Tribal boundaries; Unserved Tribal homes; proposed
service area; and last mile connection. Supporting GIS shapefiles should be clearly labeled with
the name of the network component they represent, e.g., proposed fiber, handholes, etc. GIS
shapefiles must conform to the description of the proposed service area provided in the project
narrative. See Section D.2.c.ii.d of the NOFO.
Certification Regarding Compliance with Cybersecurity and Supply Chain Management
Requirements (p. 19 of the NOFO)
All applicants are required to submit an executed copy of the Certification Regarding
Compliance with Cybersecurity and Supply Chain Management Requirements contained in
Appendix A of the NOFO, and attached below. In the case of a consortium, each Eligible Entity
participating in the consortium must submit its own executed certification.
Note on Certifications Regarding Debarment and Suspension
By signing and submitting an application for funding pursuant to the Second TBCP NOFO, the
applicant is making all certifications regarding debarment and suspension listed in Section D.2.g
of the Second TBCP NOFO.
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Appendix A
Certification Regarding Compliance with Cybersecurity
and Supply Chain Management Requirements
[To be completed and submitted by each applicant as part of its application]
On behalf of [Organization Name], I, [print name] , hereby certify
that, in submitting this Tribal Broadband Connectivity Program (TBCP) application, my
organization is in compliance with the Cybersecurity and Supply Chain Management requirements
discussed in Section F.4 of the Tribal Broadband Connectivity Program Notice of Funding
Opportunity, Funding Opportunity Number NTIA-ICG-TBCPO-2023-2008098, published on July
27, 2023. I further certify that my organization is in compliance with each of the below
requirements and attest that:
My organization and any prospective or actual subgrantees of my organization fully recognize and
understand that it is the policy of the United States to strengthen the security and resilience of its
critical infrastructure against both physical and cybersecurity threats. Entities receiving federal
funds must therefore ensure that cybersecurity is integrated into the design, development,
operation, and maintenance of critical infrastructure communication technology and operational
technology;
In order to accomplish the cybersecurity objectives of the United States Government, my
organization and any prospective or actual subgrantees will complete the following actions within
twelve (12) months of the acceptance of any TBCP grant award to my organization:
1. Review the Cybersecurity and Infrastructure Security Agency (CISA) Cross-Sector
Cybersecurity Performance Goals (CPGs) (https://www.cisa.gov/sites/default/files/2023-
03/CISA_CPG_REPORT_v1.0.1_FINAL.pdf), which establish the baseline cybersecurity
practices and controls with known risk-reduction value that are actionable and broadly applicable
across all critical infrastructure sectors;
2. Perform an initial assessment of the cybersecurity practices of the TBCP award-funded project
(Project) using the CISA CPG Checklist Adapted for Grant Awards. This assessment will include
the cyber assets controlled as part of the execution of the Project and the cybersecurity practices
of my organization and any parent and/or partner organizations;
3. Develop and submit a Cybersecurity Risk Mitigation Plan (Plan) for my organization and any
prospective or actual subgrantees that includes:
a. The CISA CPG Checklist Adapted for Grant Awards with a current assessment
documented for cyber assets controlled as part of the Project, as well as an assessment of the
cybersecurity practices of my organization and any parent and/or partner organizations;
Broadband Infrastructure Deployment Guidance –
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b. A prioritized list of Project CPG gaps that need to be addressed for cyber assets
controlled as part of the execution of the Project, as well as any CPG gaps affecting my
organization and any parent and/or partner organizations;
c. Documentation of Project cybersecurity risk mitigation efforts to be undertaken as part
of the execution of the TBCP award, with a target implementation date identified for each
mitigation effort, including mitigation efforts to address identified Project CPG gaps, as well as
mitigation efforts to address identified CPG gaps of my organization and any parent and/or partner
organization;
My organization and any prospective or actual subgrantees of my organization fully recognize and
understand that any failure to submit and obtain the approval of a Plan by the National
Telecommunications and Information Administration (NTIA) within twelve (12) months of
acceptance of a TBCP award to my organization will result in corrective action, potentially
including, but not limited to, the imposition of a performance improvement plan, additional risk
monitoring measures, and/or possible limitations on certain uses of TBCP award funds;
With respect to Supply Chain Risk Management (SCRM), my organization has an SCRM plan
(SCRM Plan or Plans) in place that is either: operational, if either my organization or any
prospective or actual subgrantees is or are already providing any form or type of
telecommunications services; or ready to be operationalized, if my organization and/or any
prospective or actual subgrantees is or are not yet providing any form or type of
telecommunications services;
The SCRM Plan is based upon the key practices discussed in the National Institute of Standards
and Technology (NIST) publication NISTIR 8276, Key Production In Cyber Supply Chain Risk
Management: Observations from Industry and related SCRM guidance from NIST, including
NIST 800-161, Cybersecurity Supply Chain Risk Management Practices for Systems and
Organizations, and specifies the supply chain risk management controls being implemented;
The SCRM Plan will be reevaluated and updated by my organization on a periodic basis and as
events warrant;
The SCRM Plan or Plans of any prospective or actual subgrantees will be submitted to my
organization prior to the allocation of grant funds. If a prospective or actual subgrantee makes any
substantive changes to its SCRM Plan, a new version will be submitted to my organization within
30 calendar days. My organization will provide its SCRM Plan and the SCRM Plan or Plans of
any prospective or actual subgrantees to NTIA upon request; and
My organization will ensure that, to the extent that my organization and/or any prospective or
actual subgrantee relies or rely in whole or in part on network facilities owned or operated by one
or more third parties (e.g., through the purchase of wholesale carriage on such facilities), my
organization will obtain the above attestations from these third parties with respect to both
cybersecurity and SCRM practices.
Broadband Infrastructure Deployment Guidance –
15
I understand and agree that, if I or my organization knowingly or negligently provides false or
inaccurate information in this certification, the organization shall:
1. Not be eligible to receive the Tribal Broadband Connectivity Program grant funding
associated with this certification and accompanying application for funding; and
2. Return any grant awarded under the Tribal Broadband Connectivity Program during the
time that this certification was not valid; and
3. Not be eligible to receive any subsequent grants under the Tribal Broadband
Connectivity Program; and
4. potentially be subject to criminal prosecution (including under 18 U.S.C. § 1001 and/or
1621), civil and administrative penalties, and other remedies, as may its officers,
executives, members, or employees, as applicable, as well as any other associated entities,
persons, or individuals, including I myself.
Signature of Authorized Organization Representative:
Title:
Date: