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Responding to the Evaluation Criteria for
Television Digital Conversion Projects

RETURN TO RESPONDING TO THE EVALUATION CRITERIA

This section is intended to help you respond to the evaluation criteria contained in §2301.17 of the PTFP Final Rules. These six criteria will be used to judge the merits of your application.

  • You will find information on where in the application you should place your response to each of the evaluation criteria.

  • You will find recommendations on the kind of information that is responsive to the evaluation criteria for Broadcast Other projects.

  • Your principal responses to the criteria will go in the Program Narrative.

  • Two of the criteria are qualifying criteria: (1) Applicant Qualifications and (2) Financial Qualifications. We will consider for further review only those applications meeting the minimum qualifications for both of these criteria.

  • Your Program Narrative should begin with an introduction that serves as an Executive Summary of your project and that (1) indicates that you think your application belongs in the Broadcast Other category and (2) also indicates which of the subpriorities (see the Notice, Section VII (D)), you think your application belongs in. You should explain why you think your designations are correct.

  • You should then go on and address the evaluation criteria in separate sections of the narrative, as suggested below. We recommend that you address the criteria in the order that follows and that you label each section with the name of the criterion under discussion to assist the review panel in evaluating your application.

  • The narrative is limited to five pages for the first five evaluation criteria, but you may make as much use as you wish of the Optional Exhibits to provide a detailed explanation of any subject. You should state the main point in the narrative, with a cross-reference to the relevant Optional Exhibit. There is no page limit on your response to the sixth criterion, "Involvement of Women and Minorities."

A Note on Deferred Applications: If you are reactivating an application that was deferred after the 2001 grant cycle, you must submit a complete application in the appropriate number of copies for your category. If some sections are to be resubmitted unchanged, you may use photocopies. You should also 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.

The six criteria:
I. Applicant Qualifications
II. Project Objectives
III. Urgency
IV. Technical Qualifications
V. Financial Qualifications
VI. Involvement of Women and Minorities

I. THE APPLICANT QUALIFICATIONS CRITERION

Program Narrative
  • You must indicate at the beginning of the Narrative if your organization is a government, Indian Tribe, or non-profit organization that has received a prior grant from PTFP.
  • You must describe your organization and the resources it has (or will have) available to complete the proposed project and for the operation of the facility. Your narrative should demonstrate that your organization has the experience and resources necessary to carry out the project and to maintain the facility in the future.
Exhibit CC
  • If your organization is a government agency/entity, Indian Tribe, or non-profit that has received a prior PTFP grant, no further documentation of eligibility is required at this time.
  • If you are a non-profit organization that has never received a PTFP grant, you must supply (1) Certified copies of your articles of incorporation, (2) By-laws, and (3) IRS 501(c)(3) letter.

II. THE PROJECT OBJECTIVES CRITERION

Program Narrative
  • Your discussion of this criterion should begin with a general description of your project.
  • A thorough technical description of the project should be placed in Exhibit C.
  • You should discuss objectives from a programatic perspective – the effect that the project will have on your station’s operations and/or on its ability to provide services to the public. How will your station’s program service be maintained or strengthened by this project? Will new or expanded services be available as a result of the project? Will new audiences be served?
  • You should describe any ancillary contributions to your program service that may result from the project – availability of cable, ITFS, or other delivery mechanisms that might be accessed with multi-channel capability.
  • Your application should discuss how the project has been planned or coordinated with any telecommunications services in the service area or with local, regional or state telecommunications agencies.
  • Under the Final Rules, as modified in the Notice, you are permitted to include as eligible costs equipment that was purchased on or after July 1, 1999. We will consider inclusion of equipment purchased prior to that date on a case-by-case basis – only when you provide clear and compelling justification in the application. You must discuss when the equipment was acquired and the reasons why you were compelled to purchase the equipment prior to July 1, 1999.
  • Partnerships. If there are opportunities to partner with other entities in completing your digital conversion, this is the place to discuss the partnership – its nature, its scope, and all other pertinent details.
  • This is the place to discuss the reasons for your choice of subpriority for your application under the Broadcast Other category.
  • Many conversion projects may be quite complex. Be sure your application describes your project clearly. (You might have someone not associated with the project read the application to be sure you have explained everything as you intended.)
  • You should discuss how your project will be implemented if funded by PTFP. For example, you might provide:
    • Your staffing plans regarding construction of the project and operation of the facility including how your current technical or operational staff will be available to install and operate the equipment.
    • A description of fund-raising activities to generate the match and to cover ineligible costs and long term operational costs. The information included in the narrative should provide general information about your plan with specific details presented in the attachment to Exhibit A.
  • If you seek more than a 40% Federal share of the project, this is the place to provide full justification for your request.
  • If you are requesting a Federal share of 25% or less, this is the place to discuss your request, explaining how your station is able to provide 75% (or more) of the eligible costs.
Exhibit E
  • PTFP discourages the submission of community support letters for DTV conversion projects. We assume that the need for such conversion is self-evident, given the FCC’s Order.
  • However, PTFP advises conversion applicants that they should submit letters that will confirm participation by third parties in certain types of DTV projects. One example would be a project that involves the participation in the project by more than one PTV station or by a partnership with a commercial entity. Another example would be a project calling for equipment to make multicasting possible; this might be supported by letters from those entities – presumably educational institutions – that would contribute to or benefit from the expanded video capability made possible by such equipment.
  • Please note that support letters of any kind that are submitted more than a week or two after the Closing Date may not be seen by the application reviewers because the applications will already be in their hands.

III. THE URGENCY CRITERION

Program Narrative
  • Since all PTV stations start with the same basic goal: to meet the FCC’s deadline for the start of digital transmission, you should concentrate on providing a compelling case that justifies funding the project during the current grant cycle rather than in a future grant round.
  • If your conversion project includes replacement of equipment on the Digital TV List in order to maintain your station’s existing service, you should make a compelling argument that replacement now is essential to providing continued service to the community. You should discuss whether yours is an "essential station" as the term is used in the PTFP Rules.1 In many cases, the simple statement that you are the only public TV station in the area will suffice. You should document your status with coverage maps (in Exhibit D) if there are stations that overlap your coverage area.
  • If applicable, you should document that you have:
    • a time-sensitive opportunity for partnering with other broadcasters, either commercial or noncommercial; and/or
    • a time-sensitive opportunities for local funding.
  • While general letters of support from the community are unnecessary for DTV conversion projects, it is very important for applicants to submit (in Exhibit E) letters or other pertinent documents confirming either or both of these opportunities when they exist. Please note that support letters of any kind that are submitted more than a week or two after the Closing Date may not be seen by the application reviewers because the applications will already be in their hands.
Exhibit C
  • If your project includes replacement of equipment on the DTV equipment list in order to maintain your station’s existing service, there are several ways to document urgency of the replacement, including:
    • copies of maintenance logs showing excessive downtime and/or high incidence of repair,
    • records showing excessive maintenance costs,
    • letters from manufacturers regarding the unavailability of spare parts,
    • reports from independent engineers evaluating the condition, serviceability, and expected life of the equipment,
    • demonstration that the equipment uses a clearly obsolete technical standard, and
    • in some instances, photographs are useful in documenting the condition of equipment.
  • Do not include documentation of regular, routine maintenance (e.g., aligning tape recorders, cleaning heads, etc.).
  • If the documentation does not photocopy legibly, you should attach typescripts to the copies.
  • Please note that age alone is not sufficient justification for urgency of replacement.

IV. THE TECHNICAL QUALIFICATIONS CRITERION

You should list your requested equipment on the equipment pages, Part III, page 4, of the Application Form. You should also provide an inventory of equipment similar to that requested in Exhibit B on page 7 of the Application Form. The inventory exhibit should display an inventory only of equipment that corresponds to the equipment requested or is closely associated with it.

If yours is a multi-year project, submit a separate equipment list for each year. Please enter the year for each page on the line on the right of each page so that reviewers can tell easily what is proposed for each year of the project.

All Broadcast Other applicants must take the equipment they are requesting from the DTV list. They will, therefore, meet the technical broadcast qualifications and probably use PTFP pricing. Things that may distinguish your application from others include:

  • Efficient use of existing facilities in conjunction with the requested equipment.
  • The thoroughness of your description of the integration of the new digital equipment with the equipment your station already owns.
  • Your over-all plan.
  • Any unique technical problems faced by your project – and their projected solution.

hand graphic noting statement  Information on any new sites required for the project should be included in item 21, page 2, of the application.

Exhibit C
  • You should explain in Exhibit C how the equipment requested in Part III, page 4, is necessary to achieve the objectives of the project. You should describe the technical configuration of the project and relate how the requested equipment fits with achieving the ability to meet the FCC’s deadline.
  • You should demonstrate that the proposed costs reflect the most efficient use of Federal funds in achieving project objectives. You should also demonstrate that the equipment requested meets current industry and FCC performance standards.
  • If yours is a multi-year application, the narrative in this exhibit should explain why the project is broken down in the way you propose. That is, you need to explain why a particular item of equipment is proposed for the first, second, or third year of the project.
  • Where alternative technologies are possible, you should provide an evaluation of alternative technologies and rationale for selecting the particular items included in the application.
  • You must provide your station’s complete digital conversion plan if different from the current project. If it is the same, you should include a statement saying so.
  • Finally, you must provide a five-year equipment plan which places your current application in the context of your station’s long-term objectives. This plan can be a page in length within Exhibit C.

V. THE FINANCIAL QUALIFICATIONS CRITERION

Program Narrative
  • You should describe your history and demonstrated ability to raise operating and capital funds.
Exhibit A
  • You should attach to Exhibit A a proposed annual operating budget for your facility.
  • Multi-year applications should attach a proposed operating budget for the first year of the project plus a discussion of long-term budget plans.
  • Multi-year applicants should complete the Exhibit A form (page 6 of the Application Form) to certify just the first year of the project. (Certifications will be required at the appropriate time for subsequent years of the project.)
  • All applicants should discuss the funds they currently have available as well as identify funds committed or pledged by others to the construction or operation of the station.
  • You should attach any available documentation of local financial support that has been committed, even if conditionally.
  • Note that you are accounting for the funds needed for the actual construction of the project and also to cover ineligible costs that must be met in order to complete the project.
Exhibit A and Program Narrative
  • Since we retain a 10-year interest in any equipment funded by the program, we are also interested in the long-term financial viability of your organization.
  • You should therefore present a business plan as to how you will raise funds necessary to complete the construction of your proposed facility and for its continued operation.
  • If you request more than a 40% Federal share, it is very important that you include full justification supporting your request in the narrative. Also, be sure to include appropriate documentation as an attachment to Exhibit A.

VI. THE INVOVEMENT OF WOMEN AND MINORITIES CRITERION

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 programing 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).

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