Responding to the Evaluation Criteria for

Broadcast Activation & Extension Projects

This section is intended to help you respond to the six criteria that will be used to evaluate your application. (They are found in §2301.17 of the PTFP Final Rules.)

■    Two of the criteria are qualifying criteria: Applicant Qualifications and Financial Qualifications. We consider for further review only applications that meet the minimum qualifications for both of these criteria.

■    Your Narrative should begin with an introduction that serves as an Executive Summary of your project. It should be a brief, straightforward statement of what you propose to accomplish and indicates which priority you think your application belongs in—1A, 1B, 3, or 4A—and why. Supporting arguments and justifications belong in the sections that follow.

■    You should then address the six evaluation criteria in separate sections of the Narrative. We recommend that you address them in the order that follows and that you label each section with the name of the criterion being discussed to help the reviewers who evaluate your application.

■    The Narrative is limited to a total of five pages for the Executive Summary and the first five criteria, but you may make as much use as you wish of Optional Exhibits to provide a detailed explanation of any subject. You should state the main point(s) in the Narrative, with a cross-reference to the Optional Exhibit in which you provide additional information.

■    There is no page limit on your response to the sixth criterion, “Involvement of Women and Minorities.”

      Low-Power FM: PTFP awards grants for the activation of LPFM stations under Priorities 1A and 4A. Applicants for construction grants for LPFM stations use the standard PTFP Application Form and follow the guidelines and instructions provided for all Construction Grant applicants.

      Previous Planning Grant: If your construction application was preceded by a PTFP-supported Planning Grant for the proposed facility, you must include a complete copy of the Final Report in one of the Optional Exhibits of your application.

      Deferred Applications: If you are reactivating an application that did not receive a grant award in the 2004 grant cycle, you must submit a complete application. You should examine very critically what was submitted before to see if it can be strengthened.

To assist all who read your application, its narrative sections—Part V, the Program Narrative, and the technical narrative for Exhibit C in response to the evaluation criterion “Technical Qualifications”—should be printed on one side of plain white paper with margins of at least one inch on all sides and in 12-point Times New Roman typeface or equivalent in actual size. This paragraph is in 12-point Times New Roman.

 

Program Narrative

■    You must indicate at the beginning of the Narrative if your organization is a government entity, an Indian Tribe, or a non-profit organization that has received a prior grant from PTFP.

      ▫  If your organization has received a prior PTFP grant, no further documentation of eligibility is required at this time.

      ▫  If yours is a non-profit organization that has never received a PTFP grant, you must supply certified copies of your (1) articles of incorporation, (2) by-laws, and (3) IRS 501(c)(3) letter in Exhibit BB.

■    Your Narrative should include . . .

      ▫  your organization’s staffing levels and capabilities available to construct the proposed station and operate and maintain it in the future;

      ▫  your plans for programing the proposed station; and

      ▫  your organization’s prior experience in providing public broadcasting service.

■    You should also . . .

      ▫  discuss any affiliations you have with other broadcast, media, or educational organizations;

      ▫  include documentation of community organizations committed to your project;

      ▫  describe any consultants you have identified to assist in the project; and

      ▫  if you are a newly organized non-profit organization, discuss the background of the members of your Board of Directors, including their media or business experience.

■    Is your organization experienced in broadcasting? If not, what source of the appropriate expertise will it have available to assist it in the operation of the new station?

■    How will your organization oversee the operation of a new broadcast station? Will the station have an advisory board or committee? If so, how will its members be chosen? Will there be any participation by the general public?

       In sum, your Program Narrative should demonstrate that your organization has the experience and resources necessary to complete construction of the proposed station and to maintain and operate it in the future.

Program Narrative

■    Your discussion of this criterion should indicate the Priority you believe is appropriate for the project and begin with a description of your project.

■    A complete technical description of the project should be placed in Exhibit C.

■    You should discuss the mission/purpose of the new station. Who will benefit from its operation?

■    What other means of communication were considered before your organization decided on constructing a station? What are the pros and cons for each type in your situation? Why did you choose a station?

■    You should make a compelling case as to how the proposed station will meet unserved needs of the community, including a discussion of any community needs assessment you conducted or have available and then explain how the proposed station will help meet those needs..

■    You should describe the number and types of organizations that have agreed to participate and cooperate with your organization in serving the community. Their involvement should be documented with letters of support, participation, and cooperation in Exhibit F.

■    You should discuss how the project has been coordinated with any telecommunications services in the coverage area or with local, regional, or state telecommunications agencies. If there hasn’t been any coordination, you should explain why.

■    What evidence do you have that the population of the expected coverage area is interested in the proposed station?

■    As stated in the Federal Funding Opportunity, NTIA will normally fund projects to upgrade translators to repeaters and Priority 1B transmitter or antenna replacements at a 50% Federal share. If your application seeks a higher Federal percentage, you must provide justification for the request.

■    You should also discuss how the project will be implemented if funded by PTFP. For example, you might discuss:

      ▫  Your staffing plans for the construction and continuing operation of the station. Identify staff, consultants, or contractors where possible.

      ▫  Exactly how you will go about raising the money for the local match and ineligible project costs as well as long-term operational costs. Describe the general plan in the Narrative and provide details in the attachment to Exhibit A.

         In addition to the general requirements mentioned in this section, you should provide the specific information requested for the following types of projects:

■    If you request a Priority 1A, 1B, or 4A station activation, you should address whether you seek funds to equip the station with digital broadcast capability.

      ▫  As noted in the Federal Funding Opportunity announcement—see Section I, B, 2a—we anticipate funding digital-upgradable transmitters as the usual equipment for new radio stations.

      ▫  Radio grant recipients may—at their own expense—add in-band-on-channel (IBOC) exciters and power output modules as needed.

      ▫  Radio applicants requesting a full IBOC digital transmitter in an activation application must include the station’s full digital plan, including utilization of Program Associated Data or the Supplemental Audio Channel when authorized by the FCC.

      ▫  Radio digital technical exhibits must address the type of analog/digital signal combining proposed.

■    If you request Priority 1A or 1B, you must demonstrate that the proposed coverage area is currently unserved by a public radio station for a radio project or a public television station for a television project.

      ▫  We consider an area served if it receives a public broadcast service from a grade B television signal or a 60 dBu FM radio signal. If you propose an FM station that will serve an area covered by an AM daytime-only public radio station, we will evaluate the amount of service provided via the AM station in determining the priority of the proposed FM station.

      ▫  In some instances, the simple statement in the Narrative that “the nearest public (radio or television) station is (call letters), which is (approximate distance) miles away,” will suffice.

      ▫  In situations where an existing public broadcast station is nearby but does not cover the proposed signal area, it is often useful for the applicant to discuss the differences in coverage in the Narrative and include coverage maps in Exhibit E as discussed below.

■    If you request Priority 1A, 3, or 4A, your project must contain local origination equipment. Your Narrative should, therefore, describe this equipment and how the station’s staff will utilize it to address the needs of the local community.

■    If you request Priority 1C, your application should discuss how the satellite downlink facilities will improve the programing to serve the needs of your local community. You should document that you will provide the first national programing in your service area.

      ▫  In some instances, the simple statement in the Narrative that “the nearest public (radio or television) station with national satellite downlink capability is (call letters), which is (approximate distance) miles away,” will suffice.

      ▫  If your coverage area overlaps another public station of the same type (radio or television), you should provide coverage maps in Exhibit E documenting whether or not any of your service area is already served by an existing public station that carries national programing. You will find further suggestions on the use of Exhibit E in the next section.

■    A Priority 3 project requests funds to bring the first local origination capability to an area already receiving some public broadcasting service from non-local sources. You should, therefore, document that the existing service does not provide for local origination. You should discuss coverage issues in the Narrative and include coverage maps in Exhibit E.

■    If you are proposing a Priority 4A broadcast activation, you must demonstrate that you will address underserved needs in a way that significantly differentiates your proposed service from what is already available in the service area.

Exhibit E

■    A coverage map of the proposed station or facility should be placed in Exhibit E. You should also include in Exhibit E information regarding the population to be served. The number of persons benefitting should be entered on page 1 of the Application Form, question 11, New Broadcast facility, repeater, or translator.

■    You can often find information concerning the population to be served in an exhibit prepared for submission to the FCC as part of the application for a construction permit for the proposed station.

■    We consider an area served if it receives public broadcast service from a grade B television signal or a 60 dBu FM radio signal. If the proposed coverage area overlaps with the coverage area of another station of the same type, you should also provide a calculation of the non-duplicated coverage population in Exhibit E. You should enter the number of non-duplicated persons benefitting on page 1 of the Application Form, part 11, “First Service added by NEW proposed facility,” with the duplicated population entered on the line for “ADDED SERVICE to those covered by others” (as appropriate).

■    Priority 1B transmission power increase projects. Sometimes, replacement of a station’s transmitter results in an increase in coverage to a new, but relatively small, unserved audience. PTFP usually treats these applications with incidental coverage increases as Priority 2 applications if the equipment replacement meets the Priority 2 criteria. If you are requesting a Priority 1B consideration of such an application, you should provide documentation of a significant increase in the population covered. We will evaluate such requests on a case-by-case basis.

■    Priority 3 applicants should document that the existing public broadcasting service comes from a distant source (the proposed service area is beyond the grade B or 60 dBu contour of the program origination station.)

Exhibit F

It is extremely important that an application for a broadcast activation project in Priorities 1A, 1B, 1C, 3 or 4A provide full documentation of support from residents, community organizations, and local groups within the proposed service area. This documentation usually takes the form of letters of support that are placed in Exhibit F or in an Optional Exhibit.

       You may forward support letters at any time, even after the Closing Date, but please understand that such letters received by PTFP more than about 10 days after the Closing Date may not be seen by the application reviewers because the applications probably will be in their hands by then.

NOTE: If you obtain letters of support from members of Congress addressed to the Department of Commerce, NTIA, or PTFP, you should be sure the originals of those letters are mailed separately to the addressees. The originals should not be included in the application folders. You should place copies of the letters in Exhibit F for consideration by the reviewers.

Program Narrative

■    You should provide a compelling case that justifies funding the proposed project during the current grant cycle.

■    You might discuss any negative consequences that may result if your project is not carried out at this time.

■    Priority 1 applicants. Although activation of new broadcast stations in unserved areas is our highest priority for broadcast projects, you should not presume that all Priority 1A or 1B applications will be funded automatically. Both the project objectives criterion discussed in the preceding section and the urgency criterion must be documented in the application in order to support funding the application during the current grant cycle.

■    Priority 3 or 4A applicants. If you propose a Priority 3 or a 4A project, you should discuss the urgency requiring the activation of a new station to address needs in an area that significantly differentiates your proposed service from what is already available in the area.

Ways to document urgency. Documentation of urgency for broadcast activations can take many forms and may include . . .

      ▫  the number of people to receive the proposed broadcast service;

      ▫  the results of a needs assessment of the intended audience;

      ▫  documentation that the intended target audience is eager for service and is supportive of the application (this is sometimes documented in Exhibit F by letters, copies of petitions, resolutions from governmental bodies, etc.);

      ▫  documentation that relevant groups/educational institutions intend to actively work with the proposed station (place such documentation in Exhibit F also);

      ▫  fulfillment of a legislative initiative; or

      ▫  the presence of unique circumstances such as the availability of a local partner or of matching funds that may be withdrawn after the current grant cycle.

■    The equipment you wish to purchase with a grant must be listed on the equipment pages, Part III, page 4, of the Application Form.

■    In Exhibit B, page 7 of the Application Form, you must provide an inventory of the equipment you presently own that is similar to that requested. The exhibit should give an inventory only of equipment that corresponds to the equipment requested or is closely associated with it. If you have no equipment to list, you should include the form and check the “NA” box.

■    If you are requesting a radio grant for a full IBOC digital transmitter, you must address the type of analog/digital signal combining proposed.

■    In exceptional circumstances you may be permitted to include as eligible costs equipment that was purchased prior to the PTFP closing date. (See §2301.6(b)(2)). We will consider inclusion of equipment purchased prior to the closing date on a case-by-case basis.

      ▫  You must show when the equipment was acquired and what compelled you to purchase the equipment prior to the PTFP Closing Date.

■    Do you have sites for the studios, transmitter, and tower for the new station? Does your organization own them or will it buy or lease them? (Enter the information in Question 22, page 2, of the Application Form and discuss further in Exhibit C.)

If you do not have sites, explain what is being done to get them.

■    Describe the engineering resources that will be available for (a) the construction of the station and (b) the long-term maintenance of the equipment for its operation and continued useful life.

Exhibit C

■    You should explain in Exhibit C how the equipment requested in Part III is necessary to achieve the objectives of the project. You should describe the technical configuration of the project and explain how the requested equipment will fit with the proposed station operation (e.g., discuss the number of studios in relation to staff size, amount of locally produced programing, number of engineers and equipment maintenance).

■    You should demonstrate that the proposed costs reflect the most efficient use of Federal funds in achieving the objectives of your project. You should also demonstrate that the equipment requested meets current industry performance standards (and FCC standards, if appropriate).

■    If alternative technologies are possible, you should provide an evaluation of them and give a rationale for selecting the particular items requested in the application.

NOTE: Stations sometimes propose Priority 1B projects for the activation of translators to serve communities, or sections of communities, that are theoretically within the station’s coverage area, but are prevented from receiving a usable broadcast signal because of the terrain. These applications should include documentation of the absence of a signal in the proposed coverage area. The documentation could include . . .

      ■  signal strength reports from qualified engineers,

      ■  terrain profiles indicating obstructions to the station’s signal,

      ■  computer-generated maps that take terrain into account, and

      ■  letters from the public documenting the lack of a signal in the area.

We strongly advise you to conduct an engineering study, if at all possible. If you are unable to conduct formal signal strength measurement, we have accepted an informal, but thorough and well documented, coverage study of the affected area.

Exhibit D

■    You must provide a five-year equipment plan that places your current application in the context of your station’s long-term objectives.

■    The statute authorizing PTFP requires construction applicants to submit “a 5-year plan outlining the applicant’s projected facilities requirements and the projected costs of such facilities requirements.”

■    We do not specify a format for the plan.

■    You should make it as long as needed to provide an adequate response to the requirement. One or two pages are usually enough.

■    Note that application reviewers usually reduce the scores they give to individual applications if a 5-year plan is not included.

FCC Applications

■    We urge you to file your FCC application(s) as early as possible to permit the FCC’s processing to be completed, since PTFP will not fund a project that has not cleared the FCC review process.

Exhibit A

■    You must provide a certification of the local match and other funds in Exhibit A.

■    You should attach to Exhibit A a proposed annual operating budget for your station.

■    You should describe your organization’s history and demonstrated ability to raise operating and capital funds.

■    One of your greatest challenges will be obtaining the necessary local funds to pay for the station.

      ▫  PTFP cannot fund many costs involved in setting up a station, such as building construction and/or renovation and land improvements.

      ▫  You will need funds to pay for staff and operating costs while the station is being built.

      ▫  You should discuss the funds you currently have available as well as identify funds committed or pledged by others to the construction or operation of the station.

      ▫  The Federal government retains a 10-year interest in all equipment funded by PTFP, so we are interested in the long term financial viability of your project.

■    You should, therefore, present a business plan as to how you will raise funds necessary to complete the construction of your proposed station and pay for its continued operation.

      ▫  You should explain how you expect to raise the funds to pay all of the costs mentioned.

      ▫  You should provide documentation of local support that has been committed, with dollar-commitment estimates, even if the commitment is conditioned on completion of the project.

      ▫  If you expect to get financial support from state or local governments, you should include documentation showing that the support actually will be provided if the station is constructed.

      ▫  Include any other documentation you have to show that your financial expectations are realistic.

■    If you anticipate operating grants from the Corporation for Public Broadcasting, you should indicate which current CPB grants are expected and how and when the station will qualify for them.

All applicants must respond to this criterion or they will receive no score for this criterion. Points can be awarded for this criterion only when you provide a discussion of this topic as part of your Narrative. Failure to respond to this criterion places your application at a competitive disadvantage and can result in loss of an award because of a loss of possible points. This part of the Narrative does not have to be included within the 5-page limit for your discussions of the other criteria.

In accordance with §392(f) of the Act, the Agency will give special consideration to applications that foster ownership of, operation of, and participation in public telecommunications entities by minorities and women. NTIA has not established any minimum minority or women participation requirements for Special Consideration in PTFP evaluations in order to carry out the objectives of the statute. Rather, NTIA believes that the Congressional intent can be achieved in a fair and flexible manner by taking into account all factual circumstances that might lead to special consideration.

The PTFP Rules, in §2301.5, provide the following clarifications about special consideration:

• "Ownership and operation of" includes the holding of management and other positions in the entity, especially those concerned with programing decisions and day-to-day operation and management.
• "Participation" may be shown by the entity's involvement of women and minorities in public telecommunications through its programing strategies as meeting the needs and interests of those groups.
• "Minorities" include American Indians or Alaska natives; Asian or Pacific Islanders, Hispanics, and Blacks, not of Hispanic Origin.

Employment of minorities or women is not the only way in which NTIA may assess whether an application promotes significant diversity in the ownership of, operation of, and participation in, by minorities and women. NTIA is also interested in outreach efforts, audience development, and programming strategies. One stated purpose of this program is to respond to the educational, cultural and related programing needs of diverse groups.

Applicants should provide a narrative (with supporting documentation when necessary) that discusses the participation of women and minorities in the station’s ownership and management, especially those concerned with programing decisions and day-to-day operation and management. In preparing their exhibit, applicants should take care to clarify whether they are discussing women, minorities (minorities can be considered as a single group, but the predominant group should be identified as such), or a combination of women and minorities (where the predominant group/gender should be identified, and applicants should express whether they are discussing women or minorities in the case of an individual who is a female minority).