Yearly Archives: 2022

Courts Uphold 6 GHz WiFi Order

The right to use spectrum is turning into one of the most valuable pieces of real estate in the country. Cellular carriers have been paying huge sums in FCC auctions to get the rights to use spectrum. Perhaps the biggest sign of the value of spectrum is that there is seemingly a lawsuit every time the FCC makes a spectrum decision by those who want to see the spectrum used in other ways.

The United States Court of Appeals for the District of Columbia recently upheld the FCC’s April 2020 order that assigned 1,200 MHz of the 6 GHz spectrum band for public use. That order was challenged by a coalition of Apple and cellular carriers like AT&T. The challengers wanted some of the 6 GHz spectrum to be auctioned to those willing to pay the most for it – presumably the cellular carriers. Not surprisingly, the intervenors supporting the FCC decision were the big cable companies who take the most advantage of WiFi.

The original FCC order clearly supports the idea that the public needs better WiFi. The 6 GHz spectrum band will revolutionize the way we use WiFi in homes and businesses. WiFi performance is already slated to improve due to the new WiFi 6 technology. But adding the 6 GHz spectrum will drive performance to yet another level by adding seven 160 MHz channels to the WiFi environment.

The legal challenge followed the lines of other recent spectrum challenges that question the FCC’s technical assumptions used in making the order. Since this new spectrum band is open to everybody, including the cellular carriers – the challengers argued, among other technical points, that there will be too much interference to make the spectrum useful for cellular data.

The Court came down clearly on the side of the FCC. The court said that the courts owe ‘significant deference’ to the FCC and its technical staff in deciding complicated technical issues. Intervenors had raised the same interference issues at the FCC during the deliberation of the issue – and the courts were not having any rehashing of issues that the FCC had already considered.

The court did remand one minor issue related to interference back to the FCC raised by the National Association of Broadcasters about interference in the 2.4 GHz WiFi band. The FCC will revisit that issue.

The court decision finally frees up the 6 GHz spectrum for WiFi use. Vendors have assumed this would be ordered and have been building the capability to use the spectrum into devices over the last few years.

I think we’re going to look back at the FCC’s decision to expand WiFi and the Court’s backing of that order as the most important spectrum decision of our time. The current WiFi spectrum is overtaxed and growing busier by the day. This new spectrum will revitalize the WiFi distribution of bandwidth around the home and the office that we’ve all been wanting.

Industry vendors haven’t been sitting still and have already started to develop the next generation of WiFi that will create another big leap in performance.

The Fixation with Broadband Speeds

Leichtman Research Group recently conducted a nationwide poll of 2,000 households asking about broadband usage. LRG has been tracking broadband for many years and reports that overall broadband subscriptions are at 87% of all households in 2021, up from 83% in 2016, and 69% in 2006. There are a few results of the survey that I think warrant additional examination.

According to the LRG survey, 63% of broadband subscribers rate the speed of their Internet connection as 8 to10 on a 10-point scale with 10 being excellent. In a similar question, 69% of respondents who subscribe to speeds of at least 100 Mbps are satisfied with their broadband service.

The big news here isn’t that many homes are satisfied with broadband speeds – it’s that one-third of all households don’t think their broadband speeds are great. The news is that over 30% of homes with speeds over 100 Mbps are not satisfied with their broadband.

My consulting firm conducts surveys at the community level, and I often see similar results. LRG only released the high-level summary responses to the survey, so we don’t know all of the questions they asked. But if LRG only asked about broadband speeds, they asked the wrong question. This was borne out by the response to a different survey question where 45% of the respondents in the LRG poll don’t even know their subscribed broadband speed.

What I’ve found through surveys is that people don’t really care about broadband speeds – they care if their broadband connection works. Most people haven’t the slightest idea at any given time how much broadband speed is being delivered to their home. I sometimes hear dismay when people finally take a speed test and find out that they are only receiving a portion of what they are paying for – but even these people might not be unhappy with broadband if it works.

Here are the things I hear from the public when we ask the same kinds of questions that LRG asked:

  • One of the most common complaints I hear about big cable company broadband is outages. The issue in most markets is not big hours-long outages but frequent small outages of a few minutes in duration. These small drive people mad because it invariably disrupts whatever they were doing with the broadband.
  • Right behind unhappiness with outages is unhappiness with slowdowns. The complaint I hear is that broadband works most of the time but then gets maddingly slow at times. It’s almost as disruptive as an outage when broadband slows to a crawl.
  • The other big recurring complaint I hear is when broadband won’t perform an expected function. People become quickly unhappy with their broadband connection when they can’t do something like maintain a Zoom call or if they get kicked off a school or office connection. Somebody might have no trouble streaming Netflix movies but find that they can’t stream the more demanding live sports broadcasts.

This survey reminded me of something that has become clear to me over the last year – policymakers are fixated on broadband speeds but people care about broadband performance. These are not the same thing. I’ve never talked to anybody outside the industry who cares one iota about the definition of broadband – they only care if everybody in the household can use the Internet at the same time.

From a policy perspective, it seems like we’ve decided that there are no urban broadband problems because everybody can buy Internet faster than 100 Mbps download. Even if we set aside the issue that many homes can’t afford broadband, this survey points out that a lot of urban households find their broadband connection to be inadequate.

Our policies are all due to the fixation with broadband speeds. Concentrating on speeds as the only way to measure broadband means that policymakers can yield to cable company lobbying that says we have no urban broadband issues.

I am absolutely thrilled that we are finally going to use some money to bring faster broadband to rural areas that have little or no broadband. But policymakers need to understand that this will not eliminate broadband problems elsewhere. A huge number of people in urban areas are still not happy with their broadband connection – and that’s a problem that’s not going to go away by throwing grant money at rural markets. If anything, building rural fiber is going to remind urban residents that they have something of lesser quality.

Final Treasury Rules for ARPA

The U.S. Department of the Treasury released the final rules applicable to using ARPA funding. This was the giant pile of $350 billion that was paid out to local governments, counties, and states to address issues related to the pandemic. These rules take effect on April 1, 2022. As usual, this is not a simple document and is 437 pages long.

There has been a lot of confusion in cities and counties about how they can use these funds. This final rule should answer any open questions about broadband because the final rules are clear about how these funds can be used. Following are the most important provisions of the final rules that relate to building broadband infrastructure.

Broadband Speed Tests. The Interim Treasury rules had included requirements that broadband could only be constructed to areas that were considered as unserved or underserved using the typical definitions of 25/3 Mbps or less to be unserved. The final rules eliminate any consideration of existing broadband speeds. The final rules allow broadband to be constructed to reach households and businesses with an identified need for additional broadband infrastructure investment.

There still must be a justification that the project addresses a problem highlighted by the pandemic. But rather than relying on speed as the justification, localities can consider broadband reliability, affordability, or access to a connection that meets or exceed symmetrical 100 Mbps. Localities can document this need using any available data, including local speed tests, federal or state data, interviews with residents and businesses in the affected areas, and just about any other way that proves there is an existing broadband need.

This is an important clarification because it means local governments don’t have to spend the energy interpreting and fighting incumbent ISPs and the FCC maps.

Matching Funds. As is usual, the rules are written by lawyers and are never crystal clear. Following is the specific language in the order specific to using ARPA as matching for other grants:

Given the final rule’s revised requirements on eligible areas for investment, the final rule also modifies the interim final rule’s requirements around duplication of resources. Since recipients must ensure that the objective of the broadband projects is to serve locations with an identified need for additional broadband investment, the final rule provides that, to the extent recipients are considering deploying broadband to locations where there are existing enforceable federal or state funding commitments for reliable service at speeds of at least 100 Mbps download speed and 20 Mbps upload speed, recipients must ensure that SLFRF funds are designed to address an identified need for additional broadband investment that is not met by existing federal or state funding commitments. Recipients must also ensure that SLFRF funds will not be used for costs that will be reimbursed by the other federal or state funding streams.

I read this to mean that ARPA (SLFRF) can be used for matching, but with some important caveats. There is a two-part test for using ARPA along with another grants. ARPA must address a need not met by the existing federal or state grants, and second, it must not duplicate any payments for the same infrastructure.

The second test is the easy one to make and applies universally to all matching grants. For example, if one grant pays for 50% of an asset, the matching can be used to pay for the remainder – but the two grants together can’t pay more than 100% of the cost of the asset.

But the first test is going to require some legal gymnastics. The obvious justification for using ARPA is that the project won’t work without it. But there are easier ways to make this work that more easily meet the final rules. If ARPA is used for assets not included in the original state or federal grant, there is no duplication. That might mean using ARPA to build to additional households or using the original grant to build last-mile but ARPA to build drops. Folks are going to have to get creative to use ARPA money as matching – and this language lays out how to do so.

Low-Income. The final rules require ARPA-funded ISPs to participate in the Affordable Connectivity Program.

The Future of Data Storage

One of the consequences of our increased use of broadband is a big increase in the amount the data that we store outside our homes and businesses. The numbers are becoming staggering. There are currently about 3.7 billion people using the Internet, and together we generate 2.5 quintillion bytes of online data every day. The trends are that by 2025 we’ll be storing 160 zettabytes of data per year – a zettabyte is one trillion gigabytes.

I store a lot more data online than I used to. I now store things in the cloud all day long. When I edit a Word or Excel file, my changes are all stored in the cloud. I also back up every change on my computer every day. I write and store these blogs on a WordPress server. Copies of my blogs are automatically posted and stored on Twitter and LinkedIn. My company’s accounting records are stored online. When my car pulls into a driveway, it uploads diagnostics into the cloud. Pictures I take on my cellphone are automatically saved. I have no idea what else is being shared and saved by apps and software that I routinely use. As recently as a few years ago, I had very little interaction with the cloud, but I now seemingly live and work in the cloud.

It may be hard to believe, but in the foreseeable future, we’ll be facing a data storage crisis. We can’t afford the resources to be able to store data in the same way we do today. Data centers now use nearly 20% of the electricity used by technology. A single data center uses more electricity than a small town. We’re consuming electric generation resources and spinning off huge amounts of carbon dioxide to be able to save the 45 pictures taken at the birthday party you attended last night.

One of the obvious solutions to the data storage challenge is to throw away data. But who gets to decide what gets kept? The alternative is to find better methods of data storage that don’t require as much energy or take as much space. There are several areas of research into better storage – none is yet ready for prime time, but the ideas are intriguing.

5D Optical Storage.

Researchers at the University of Southampton are exploring data storage using lasers to etch into cubes of silicon glass. The technique is being called 5F, because in addition to using the normal three axes as storage parameters they are also using the size of a recorded record and the orientation. Think of this as a 3D version of the way we used to store data on compact disks. This technology would be used for long-term storage since something that is etched into the glass is permanent. Storing data in glass requires no power, and the glass cubes are nearly indestructible. One small cube could store hundreds of terabytes of data.

Cold Storage.

Researchers at the University of Manchester are taking a different approach and looking at the benefits of storing data at super-cold temperatures. They have developed man-made molecules that can store several hundred times more data than in the equivalent space on current hard drives. The key is to store the molecules at low temperatures. This is the same research group that discovered graphene and that works with unique molecular structures. Scientists have known that storage at lower temperatures can work, and the big breakthrough is having this technology work at 80 Kelvin using liquid nitrogen (which is significantly warmer than past work near to absolute zero using liquid helium). Since our atmosphere is mostly nitrogen the frozen gas is inexpensive to produce. Scientists are hoping that the molecules will be able to store data for a long time, even if losing power.

DNA Storage. Scientists have been intrigued for over a decade about using DNA as a storage medium. DNA could be an idea storage media because it’s made from our base-pair amino acids, and the convoluted coiled structure provides a lot of storage capacity in a condensed space. A team at Harvard was able to store the code for a video on a strand of bacterial DNA. Since then, the commercial company Catalog has been working to perfect the technology. The company believes it is close to a breakthrough by using a synthetic version of a DNA molecule rather than living tissue. Data could be written to the molecule as it’s being assembled. Like with etched glass, this is permanent storage and highly promising. In the past summer, the company announced it was able to record the full 16 Gigabytes of Wikipedia into a tiny vial of the material.

We need these technologies and others to work if we don’t want to drown in our own data.

Regulatory Capture

Regulatory capture is an economic principle that describes a situation where regulatory agencies are dominated by the industries they are supposed to be regulating. Economic theory predicts that regulators caught by regulatory capture act in ways that protect incumbent providers instead of the public interest. Unfortunately, the broadband industry is one of the best (or worst) examples of regulatory capture.

Economic theory says that it’s necessary to regulate any industry where a handful of large players control the market. Good regulation is not supposed to be antagonistic to large corporations but should strike a balance between what’s good for the industry and what’s good for the public. In a perfectly regulated industry, both the industry and the public should be miffed at regulators for not fully supporting their issues.

The concept of regulatory capture was proposed in the 1970s by George Stigler, a Nobel prize-winning economist. He described the characteristics of regulatory capture as follows. His list matches what’s happening in the broadband industry to a tee.

  • Regulated industries devote a large budget to influence regulators at the federal, state, and local levels. It’s typical that citizens don’t have the wherewithal to effectively lobby the public’s side of issues.
  • Regulators tend to come from the regulated industry, and they tend to take advantage of the revolving door to return to industry at the end of their stint as a regulator.
  • Regulation from the legislative process tends to become corrupt, such as when politicians vote for bills they don’t understand in return for contributions. Actual regulators can also be corrupt – but often regulators side with the industry over the public because they have an industry perspective.
  • In the extreme case of regulatory capture, the incumbents are deregulated from any onerous regulations while new market entrants have hoops to jump through.

There are many examples throughout history of economic cartels that successfully captured regulators. For example, the railroads in the 19th century ran roughshod over the economy and regulators. Unfortunately, the best current example of regulatory capture is the broadband industry, perhaps closely followed by big agriculture and big pharmaceuticals. There is no question that the power of the broadband industry is concentrated among only a few firms. Comcast, Charter, AT&T, and Verizon together serve 75% of all broadband customers in the country.

The FCC is a textbook example of a captured regulator. The FCC under Ajit Pai went so far as to deregulate broadband and to wash the FCC’s hands of broadband as much as possible by theoretically passing the little remaining regulation to the FTC. It’s hard to imagine an FCC more under the sway of the broadband industry than the last one.

But federal regulators are only the tip of the iceberg. The large ISPs have convinced most state regulators to deregulate (or never regulate) broadband. The ISPs spend an immense amount of money in state legislatures trying to get laws passed that favor the big ISPs or that disfavor any potential competitors. The surest sign of regulatory capture is that the big ISPs are also active at the local level and pressure City and County Councils to not consider local broadband projects. There is an immense lobbying effort currently underway to dissuade local politicians from using ARPA grant money for broadband.

We don’t have to look far to see how the industry has gotten its way with regulators. The U.S. has some of the most expensive broadband in the world. Tens of millions of homes have little or no broadband. The broadband industry has the worst overall customer service among all industries- and that’s saying something. The big ISPs abuse customers in other ways such as quietly monetizing customers’ private data.

There is no real fix for regulatory capture other than a loud public outcry that brings back strong regulations. That can start at the FCC, but even that isn’t going to put a dent in the influence of the ISPs at the state and local level.

WiFi 7

The WiFi 6 standard was just approved in 2020 and is starting to find its way into home and business WiFi networks. If you’ve purchased a new WiFi router recently, there is a decent chance that it can support WiFi 6. However, the benefits of the new WiFi aren’t going to benefit a home until you’ve upgraded devices like TVs, computers, and various IoT devices to use the new standard. It’s likely to take years for WiFi 6 to get fully integrated into most homes.

But that hasn’t stopped vendors from already working on the next generation of WiFi technology, naturally being called WiFi 7. WiFi 7 promises faster speeds and lower latency and will be aimed at maximizing video performance. Qualcomm says it expects full WiFi 7 to become available after 2024. WiFi 7 will be using the new WiFi specification 802.11be.

The speed capabilities have climbed with each subsequent generation of WiFi. WiFi 5, which most of you are running in your home today has a maximum speed capability of 3.5 Gbps. WiFi 6 stepped maximum speeds up to 9.6 Gbps. The early specifications for WiFi 7 call for maximum data speeds of 30 Gbps. While most of us will never tax the capabilities of WiFi 5, faster speeds are important because it means a WiFi signal can burst huge amounts of data in a short period of time.

WiFi 7 isn’t going to require additional WiFi spectrum – but more spectrum helps. The federal Court of Appeaks for Washington DC just recently confirmed the FCC’s allocation of 6 GHz spectrum for WiFi use. The NCTA, representing the big cable companies, recently filed a request with the FCC asking the agency to consider opening additional new bands of free public spectrum for WiFi using 7 GHz spectrum and lower 3 GHz spectrum. The trade group argues that WiFi has created the largest public benefit of any spectrum band that FCC has ever authorized. The trade association argues that the world is finally becoming awash in Internet of Things devices, with Charter alone connecting to half a billion IoT devices.

There are two big changes that will differentiate WiFi 7 from WiFi 6. First is a major upgrade to the WiFi upload link. WiFi 7 will incorporate uplink multiuser multiple-input multiple-output (UL MU-MIMO) technology. The new technology creates multiple paths between a router and a WiFi-connected device. Connecting multiple paths to a device will significantly increase the amount of data that can be transmitted in a short period of time. WiFi 6 allows for a theoretical eight simultaneous paths – WiFi 7 increases that to sixteen paths.

WiFi 7 will also bring another improvement labeled as coordinated multiuser MMO (CMU-MIMO). CMU-MIMO will let a home device connect to more than one WiFi router at the same time. Picture your computer connected to several channels from different home routers. This coordination should result in faster connections, lower latency, and the ability to deliver high bandwidth to every corner of a home that is equipped with multiple WiFi access points. This is the most complicated challenge in the WiFi 7 specification.

WiFi 7 promises other improvements as well. The 802.11be specification allows for combining spectrum paths. Today’s WiFi routers use one channel of spectrum for a single device, and the planned upgrade would allow devices to combine signal paths from different WiFi frequencies at the same time. Another slated improvement is an upgrade to allow the use of 4096-QAM. The QAM technology will allow the combination of more than one frequency modulation in the same data path.

The 801.11be specification is pushing the limits of physics in a few places and may never fully achieve everything being promised. But it represents another huge upgrade for WiFi. There are a few vendors that will be previewing early versions of WiFi 7 technology at CES 2022. Maybe most of us will at least have made the transition to WiFi 6 before this latest and greatest WiFi is available.

FCC – Please Do the Right Thing with RDOF

The $42.5 federal BEAD broadband grants that are being funded from the Infrastructure Investment and Jobs Act should be a gamechanger for rural broadband. There will be many hundreds of millions of grants given to each state to fund the construction of broadband networks. This is likely once-in-a-generation funding, so there will only be one chance to do this right.

There is one pending issue that could really gum up the BEAD grants – there are pending RDOF awards that should not be funded. These pending RDOF grants fall into three categories.

First are RDOF auction winners that have probably bitten off more than they can chew. An example of this might be LTD Broadband. I don’t have any inside knowledge of the company, but I’ve seen estimates that the company would need to raise something north of $7 billion dollars to go along with the $1 billion RDOF award. There are likely other similar companies in the auction. The FCC has had almost a year to determine the financial ability of grant winners to fund the rest of the projects they won. If these companies don’t have the needed funding, it’s time for the FCC to cut them loose. This shouldn’t be a hard determination.

The second category is unique. Starlink won nearly a billion dollars of RDOF funding. There are still a lot of unknowns about the company’s capabilities. I know some of the RDOF areas won by Starlink are heavily wooded, and from what I hear, that’s a big problem for the technology. There are also still questions about the ability of Starlink to serve every home in a grant area – which is what the RDOF requires. I have nothing against Starlink, and if I lived in a rural area, I would have been first in line for the beta test. But the company is still an unproven technology in terms of being able to serve everybody. The company is still a start-up with no guarantee of success or longevity. At the end of the day, Starlink doesn’t meet the basic requirement that federal funding should only go to companies that can guarantee to meet the requirements of the award.

Finally, are the RDOF auction winners that claim to be able to deliver gigabit wireless technology. Like Starlink, these are not field-proven technologies and likely will never deliver what is being promised. Over the last year, I haven’t talked to a single engineer who thinks it’s possible to deliver a wireless gigabit to every customer in rural Census blocks with gigabit wireless. I have no doubt that the new wireless technologies have the capability of being a lot faster than current fixed wireless technology. But these grants weren’t awarded to deliver a few hundred megabits per second. These grant winner should be tossed for overclaiming the technology, since doing so gave them an unfair advantage in the auction. If they had bid with the ability to deliver 200 Mbps the auction results would have been very different. These companies gamed the auction rules and that alone should have invalidated the awards. Unfortunately, the FCC might be ready to make these awards, having recently awarded funding to Resound Networks to provide gigabit wireless broadband.

It’s obvious that the FCC is already wrestling with all of these issues because it’s been eleven months since the RDOF winners filed their long-form information. But the FCC must know that the BEAD grants change everything. If it had known that BEAD grants were coming, the FCC probably would not have held the reverse auction. This new federal grant money changes the equation and brings a new paradigm that should make it easier for the FCC to make up its mind about questionable RDOF awards.

If the FCC gets this wrong, then the RDOF areas in question won’t be seeing the same broadband solutions that are coming everywhere else. The BEAD grants make it easy for the FCC to reject applicants that have not demonstrated the financial wherewithal to fund the promised RDOF solution. The BEAD grants should make it easy to reject Starlink – the company is still free to market broadband to all of rural America, and it already has a huge waiting list of people willing to buy service. The BEAD grants should make it easier for the FCC to admit it erred in letting bidders overclaim technology.

It’s not going to be easy for the FCC to publicly admit that it made some big mistakes in the RDOF auction. Most of these issues could have been avoided if the FCC had pre-screened applicants. Any technology that was not already proven to work in the real world should have been excluded from the auction. Applicants should have been given a dollar limit for participation in the auction based on their balance sheet. But the FCC has a chance to set this right by rejecting the questionable awards and letting the folks that live in these areas have a chance for a better and more permanent broadband solution through BEAD grants. FCC – please do the right thing.

Using ARPA Funding

I’m getting a lot of calls asking about ways that local ARPA (American Rescue Plan Act) funds can be used for broadband. Many of these questions are coming as the result of cities and counties being told they can’t use the funds to build broadband. In some cases, conservative local legal opinions are cautioning against using the money. We’ve heard of examples where big ISPs are telling communities they can’t use this money. In my state of North Carolina, the State Legislature has gone so far as to warn local governments that if they build infrastructure with ARPA that they won’t be eligible for state grant funding.

The reality is that the Department of Treasury has written the rules in such a way that communities have a huge amount of control over how they can use the ARPA funds. The only big overriding rule is that the funding must address some problem created by the pandemic – that’s an incredibly easy hurdle to cross with anything related to broadband. I’m not going to repeat the basic grant rules which are discussed in this earlier blog – but the blog is a good reminder that Treasury worked hard to make the funding easy to use.

I’m starting to hear some interesting stories from cities that want to use the money for broadband. Following are a few of the ideas that I know are being considered:

  • I know cities that are considering using ARPA money to bring broadband to public housing and to low-cost neighborhoods. These cities want to provide free or low-cost broadband to citizens who have not been able to afford broadband. This goes far past using the $30 discount from the Affordable Connectivity Program – $30 off cable company broadband connection is still out of reach for many homes.
  • There are cities using the money to create a wireless system to reach all students at home so that every student is guaranteed a connection for doing homework.
  • There are cities connecting to anchor institutions with fiber to reduce the ongoing cost of paying to connect city buildings.
  • I know cities that are looking to build fiber to business districts that have been devastated during the pandemic. Smaller communities aren’t going to fully recover from the pandemic until local merchants and local jobs are up and running again.
  • If you know of other ideas for using ARPA in cities, I’d love for you to describe them in the comments section of this blog.

Rural counties and small towns are mostly focused on bringing broadband to rural areas that have poor or no broadband. Rural communities are mostly partnering with local ISPs to bring better broadband.

  • I know several counties that are using ARPA money as matching funds for state and local grants. Communities are recognizing that the most powerful use for this money is to use it to attract larger grant funding from elsewhere. Many states are encouraging this. I saw a presentation recently from the Virginia grant office that encourages localities to layer local, state, and federal grants together to bring broadband to high-cost places.
  • I know a few communities that are taking the idea of collaboration to the next level past state and federal grants and are also attracting funding from schools and libraries, rural health care facilities, electric cooperatives to create the funding plan to bring broadband to every stakeholder.
  • I know of counties that plan to use the funding to directly build broadband to places they fear nobody else will serve.
  • I’ve also heard of a few cases of counties that are using the money to build middle-mile fiber with a partnership in place for an ISP to bring the funding to build the last-mile networks.

In all of the above cases, the ARPA money can be used for the engineering and feasibility study work needed to quantify the costs of a project.

My bottom-line advice is to ignore those who are telling you that this funding can’t be used for broadband. I think Treasury made it abundantly clear that communities get to call the shots about how they want to use the funding. Once this funding hits your coffers, it’s your money – as long as you follow a few simple guidelines.