Frequently Asked Questions #2

The Innovation Fund’s second NOFO aims to advance open radio unit (RU) commercialization and innovation.

The RU is the largest, most costly part of the carrier network and provides a key opportunity for carriers to make the switch to open radio access networks (RAN) as they consider network upgrades, available spectrum, and market expansion. Open RUs have the potential to drive energy efficiencies, new innovations, and cost savings that can then be passed on to consumers.

For open RUs to achieve widespread adoption they must not only be cost-competitive at scale, but also meet or surpass the technical performance of traditional RUs. Through this NOFO, NTIA intends to fund projects that tackle both priorities. Specific Research Focus Area 1 (SRFA 1) will incentivize open RU suppliers and MNOs to collaborate on the development of market-ready open RUs, while Specific Research Focus Area 2 (SRFA 2) will drive open RU innovation that results in advanced performance and technical features for later 5G standards and future generation technologies.

We know stakeholder input is critical to the successful implementation of the Innovation Fund. The Innovation Fund continues to incorporate feedback from NTIA’s previous listening session and request for comment, as well as ongoing market analysis.

We expect the launch of the advisory committee later this year and look forward to sharing more soon.  Once established, our advisory committee will augment existing stakeholder processes.

We recognize that for the Innovation Fund to be successful, global promotion and commercial adoption are necessary. For this reason, we are giving SRFA 1 applicants the flexibility to use funding for certain overseas activities, including operator lab and field testing.

We are requiring that development of radio unit products under SRFA 1 take place in the U.S. to encourage capacity building here at home. By requiring work to be done in the U.S., we are enabling U.S.-based companies, including small and medium enterprises, to enter the market and compete while also allowing global RU suppliers to participate and leverage U.S. resources and infrastructure.

With respect to SRFA 2, like NOFO 1, we are requiring that R&D work take place in the U.S., to support our innovation economy and President Biden’s Investing in America agenda.

We do not expect the U.S. place of performance requirements to unnecessarily restrict applicants.

No, MNO partners under SRFA 1 are only required to submit a Letter of Partnership Intent. The Letter of Partnership Intent is sufficient to demonstrate the MNO’s partnership with the RU supplier during the application process, but NTIA will request a more formal demonstration of the partnership post-award.

Any other participating consultants, subrecipients, or subcontractors, whether under SRFA 1 or 2, must submit a Letter of Commitment as described in Section 4.1.1. (n).

SRFA 1 applicants and their MNO partners are subject to the requirements described in Section 2.1 of the NOFO. The applicant must partner with at least one entity that meets the definition of Mobile Network Operator (MNO) provided in Appendix A of the NOFO. There is no restriction on the maximum number of MNO partners one applicant may have.

For each MNO partner, the applicant must submit a Letter of Partnership Intent as described in Section 2.4.4 of the NOFO.

Per Section 2.2.1, MNO partner(s) can be based in the U.S. or abroad. However, either the applicant, an MNO partner, or both must hold Ultimate Beneficial Ownership (UBO) in the U.S., its territories, and its possessions. UBO will be validated by the SAM Registration or SF-328 of each party. If neither the applicant nor any MNO partners meet the UBO requirement, the application will be disqualified.

Per the NOFO 2 Appendix A – Glossary of Terms, “Mobile Network Operator (MNO) – The term “Mobile Network Operator”, or “MNO”, means an entity that operates a 5G NR network (this includes 4G network operators with 5G NR upgrade plans), offering network services to the public, and owns the RAN infrastructure used by the network using radio spectrum for which it holds a license or lease providing for exclusive use by the operator. The term “5G New Radio (NR)” means specifications developed by the 3rd Generation Partnership Project (3GPP) for 5G technology. For the purposes of this NOFO, this is 3GPP Release 16 and later 5G NR specifications.”

Please use these definitions when considering if your entity qualifies as an MNO.

MNO partners under SRFA 1 are only required to submit a Letter of Partnership Intent and do not require that the partnership indicate the funding ratio for RU and network components. The letter, however, should indicate the resources invested by both parties and, if applicable, the proportion of federal funding that would be utilized by the MNO.

See NOFO Section 2.4.4. – MNO Letter(s) of Partnership Intent – for guidance on what additional information the letter should include.

Eligible entities include for-profit companies, non-profit companies, institutions of higher education, industry groups, and partnerships consisting of two or more such entities (see NOFO sections 2.2.1. and 3.2.1.). The applicant is the entity, i.e., the organization, submitting the application package on grants.gov using a unique SAM registration.

SRFA 1 applicants and their MNO partners are subject to the requirements described in Section 2.1 of the NOFO. The applicant must partner with at least one entity that meets the definition of Mobile Network Operator (MNO) provided in Appendix A of the NOFO. There is no restriction on the maximum number of MNO partners one applicant may have.

For the purposes of the Innovation Fund, the term Mobile Network Operator, or MNO, means an “entity that operates a 5G NR network (this includes 4G network operators with 5G NR upgrade plans), offering network services to the public, and owns the RAN infrastructure used by the network using radio spectrum for which it holds a license or lease providing for exclusive use by the operator.” Please use this definition when considering if your entity qualifies.

SRFA 1 applicants must partner with at least one MNO, as that term is defined in Appendix A of the NOFO. A Wireless Internet Service Provider must meet the requirements set forth in that definition to qualify as an MNO for the purposes of this NOFO.

While the MNO partnership is a requirement, SRFA 1 applicants may also partner with other eligible entities described in Section 2.2.1 of the NOFO. If a Wireless Internet Service Provider meets these criteria and all applicable NOFO requirements, the applicant may partner with the Wireless Internet Service Provider.

SRFA 2 applicants may partner with a Wireless Internet Service Provider if the service provider meets the eligibility criteria in Section 3.2.1 of the NOFO and all applicable NOFO requirements.

SRFA 2 applicants may be based in the U.S. or abroad and are not required to hold UBO in the U.S. However, all activities must be performed in the U.S., its territories, and possessions. Costs for work performed outside of the U.S. are not allowable.

We know stakeholder input is critical to the success of the Innovation Fund and are actively working to stand up the Innovation Fund Advisory Committee. We expect to launch the advisory committee later this year and look forward to sharing more soon.

Once established, our advisory committee will augment existing stakeholder processes.

We encourage stakeholders to frequently visit the Innovation Fund section for the latest information and details related to program updates and announcements.

Open RU chip development is eligible for funding under SRFA 2 if the activity addresses one or more of the radio innovation topic areas described in Section 3.3.1, such as radio component advancement. It is the applicant’s responsibility to thoroughly evaluate and justify the relevance, feasibility, and viability of their project in relation to the topic areas specified in Section 3.3.1. The applicant must ensure their proposal aligns with the scope and objectives outlined, while demonstrating the project’s potential for success and sustainability.

If open RU chip development is the sole purpose of the proposed project, it is not eligible for funding under SRFA 1. SRFA 1 applicants are required to deliver a complete open RU product. However, open RU chip development may be eligible for funding under SRFA 1 if the RU supplier has partnered with an entity to develop open RU chips for the complete radio.

Yes, Priority Access Licenses (PALs) will count as “exclusive use” spectrum for the purposes of qualifying as an MNO for this funding opportunity. Network operators using only CBRS General Authorized Access (GAA) do not qualify since those network operators requesting access to CBRS under GAA are not guaranteed access to the spectrum. All other criteria to qualify as an MNO will still be required.

As per NOFO, the term “Mobile Network Operator”, or “MNO”, means an entity that operates a 5G NR network (this includes 4G network operators with 5G NR upgrade plans), offering network services to the public, and owns the RAN infrastructure used by the network using radio spectrum for which it holds a license or lease providing for exclusive use by the operator.

Yes, applicants can use the T&E laboratories funded during NOFO 1 as a part of their projects. The applicant must negotiate with the T&E labs directly. It is important for both parties to understand cost share requirements, as funding claimed as a contribution in any other Federal award or funding received by any other Federal award generally cannot be counted as cost share. Budget and spending for all NOFO funded projects are tracked, monitored, and recorded separately to ensure fiscal accountability and compliance.

For example:

• A NOFO 2 applicant cannot report the funding received by a T&E lab to support testing under Innovation Fund NOFO 1 as cost share on the NOFO 2 application; and
• A NOFO 1 T&E lab cannot report any funding received by a NOFO 2 awardee as a cost share for its NOFO 1 award.

Again, this does not prevent any entity from making the most of existing federal investments. More information on cost share criteria can be found in 2 CFR 200.306(b).

SRFA 2 does not require building an entire radio. Component level projects are sufficient, but the project should consider how it would integrate into the broader system (e.g. into a complete radio or the broader RAN) while meeting the appropriate technology and manufacturing levels. As the NOFO mentions, “[s]uccessful projects under this focus area will be able to interoperate with commercial-grade products and will be sufficiently scaled for applications beyond research and development.”

It is the applicant’s responsibility to thoroughly evaluate and justify the relevance, feasibility, and viability of their project in relation to the topic areas specified in Section 3.3.1. The applicant must make sure their proposal aligns with the scope and objectives outlined, while demonstrating the project’s potential for success and sustainability.

Yes, an SRFA 1 proposal can design multiple radios in the technical scope. However, while the market impact (as described in the Commercial Transition Plan) is an important factor in evaluation, applicants should be cognizant that applications will also be evaluated on the quality of the proposal and ability of the applicant to scale operations to support proposed radio products during production.

The applicant is the entity, i.e., the organization submitting the application package on grants.gov using a unique SAM registration. The applicant is not the principal investigator (PI).

As noted in the Executive Summary, each applicant may submit a maximum of one SRFA 1 application and three SRFA 2 applications. Eligible entities include for-profit companies, non-profit companies, institutions of higher education, industry groups, and partnerships consisting of two or more such entities (see NOFO sections 2.2.1. and 3.2.1. for additional eligibility requirements).

The applicant is not the PI. The applicant is the entity, i.e., the organization submitting the application package on grants.gov using a unique SAM registration.

NIST and NTIA only require the eligible entity applying for Innovation Fund NOFO 2 project funding to be registered with SAM.gov and have a UEI. For SRFA 1 applications, the MNO partner(s) need to provide a SAM UEI or provide a completed SF-328. Note, however, that any entity that receives Federal funding will need a UEI before receiving those funds.

There is no limit to the number of applications where an entity can participate as a subgrantee, contractor, or any other type of allowable partnership, if the other requirements are met (i.e. national security, place of performance, etc.).

NTIA does not require that the Letter of Partnership Intent legally commit the MNO partner(s) to purchasing and/or deploying open RUs developed under the NOFO. However, NTIA expects the Letter of Partnership Intent to demonstrate the MNO partner(s) intent to purchase and/or deploy the open RUs following completion of the grant. At a minimum, the MNO must actively provide the RU supplier with detailed requirements, agree on technical specifications for the radio, and validate if the RU developed meets the MNO's needs. (See Sections 2.3.3 and 2.4 of the NOFO). For additional Letter of Partnership Requirements, please reference Section 2.4.4 of the NOFO.

Similarly, NTIA does not require that the Commercial Transition Plan include an agreement that legally commits the MNO partner(s) to integrating the open RUs into their network(s). However, applicants may choose to include such an agreement, legally binding or otherwise, to strengthen their Commercial Transition Plan. A more formal demonstration of the partnership will be requested post-award. Additional guidance on this requirement will be forthcoming.