Joint Broadband Technology Opportunities Program Request for Information
Joint Broadband Technology Opportunities Program Request for Information
Date:
March 12, 2009
Docket Number:
090309298-9299-01
American Recovery and Reinvestment
Act of 2009 Broadband Initiatives


Bill Weber, Russell Merbeth, James Prenetta, Jr., Kelsi Reeves, and Don Shepheard
Attached below
Intel Corporation
Attachment below
Brian Fontes
Comments attached.
Sally Greenberg
(Late Submission)
April 13, 2009
The Honorable Anna Gomez
Deputy Assistant Secretary
Herbert C. Hoover Building (HCHB)
U.S. Department of Commerce / NTIA
1401 Constitution Avenue, N.W.
Washington, D.C. 20230
Dear Secretary Gomez:
Founded in 1899, the National Consumers League (NCL) is the nation's oldest consumer organization. Our mission of protecting and promoting social and economic justice for consumers and workers in the United States and abroad is more relevant than ever in this time of economic turmoil and job uncertainty. To this end, we join with our colleagues like the Communications Workers of America (CWA) in applauding the 2009 American Recovery and Reinvestment Act (ARRA), which includes more than $7 billion for broadband deployment.
For tens of millions of American consumers, broadband is no longer a luxury but a necessity. Unfortunately, minority, senior and low-income communities have been disproportionately affected by the widening digital divide. For these vulnerable populations, broadband provides an essential link to community resources, health care programs, and educational opportunities. Action to address the digital divide is especially needed today. Millions of Americans have lost their jobs due to the economic crisis. For them, access to broadband is essential in the search for a new job and financial security.
With this in mind, NCL strongly encourages the National Telecommunications and Information Administration (NTIA) to quickly, efficiently, and transparently disperse the funding from the stimulus to state and local leaders to begin to implement the broadband goals of ARRA. It is also imperative to get the mapping process underway quickly
so communities can accurately identify unserved and underserved areas and direct resources.
Widely available, affordable access to broadband for America's consumers is needed now more than ever. President Obama and Congressional leaders rightly recognized the important role that broadband plays in driving America's economic recovery and empowering its citizens. We urge you to respond to this challenge by putting the broadband stimulus funds to work as soon as possible.
Thank you for providing NCL with this opportunity and we look forward to working with you in the coming months as this program progresses.
Sincerely,
Sally Greenberg
Executive Director
National Consumers League
"Donny Smith" <dsmith@jagcom.net>
Dear Sir or Madam:
Jaguar Communications comments on the ARRA program, specifically answering the questions posed under the portions on BTOP, NTIA, and RUS are attached to this email, of April the 13th, 2009. We will also post these comments on your website.
Respectfully,
/s/ Donny Smith, CEO
Jaguar Communications, Inc.
Wirefree Partners III, LLC
Wirefree Partners is reposting its April 13th Comments to the request for information under its corporate name, rather than the name of its president. See attached Comments.
Patrick W. Pearlman
See Attached.
Alastair Matheson
Please find attached comments from the National Association of County and City Health Officials (NACCHO) on the NTIA Broadband Technology Opportunities Program.
"BTOP BTOP" <BTOP@ntia.doc.gov>
0405 - McGuire-Rivera Signed Letter to Rep. Biggert
05-19-2009(13)_BB.pdf
Bonnie Lorang
See comments attached.
J. Kevin McGeary
Please see attachment for comments on the Broadband Technology Opportuntities Program from Kimball Consulting
Steven Glapa <SGlapa@zhone.com>
Please find attached our submission regarding recent discourse on
supply-side considerations in the ARRA broadband programs.
Respectfully,
Steven Glapa
VP of Product Management and Marketing
"Curtis Blessing" <Curtis.Blessing@mayor.ci.detroit.mi.us>
There was some difficulty in transmitting the attached statement of City of Detroit Mayor Cockrel under cover of my 4/13/09 email so I am resubmitting the statement. Curtis Blessing
>>> Curtis Blessing 4/13/2009 5:12 PM >>>
Dear Sirs/Mses.: Attached please find the comments of City of Detroit Mayor Kenneth V. Cockrel. Jr. wishes to submit regarding the Broadband Technology Opportunities Program.
Sincerely,
Curtis B. Blessing
Senior Advisor to Mayor Cockrel
curtis.blessing@detroitmi.gov
This message has been scanned for malware by SurfControl plc. www.surfcontrol.com
"Doane F. Kiechel" <DKiechel@fh-law.com>
To Whom It May Concern-
Attached please find comments of Stratophone, LLC in response to the
Joint Request for Information and Notice of Public Meetings, 74 Fed.
Reg. 10716 (Mar. 12, 2009), Docket No. 090309298-9299-01,
Regards,
Doane F. Kiechel
Fleischman and Harding LLP
1255 23rd Street, NW
Eighth Floor
Washington, DC 20037
(202) 939-7907
Counsel for Stratophone, LLC
"NTIAHelpDesk NTIAHelpDesk" <NTIAHelpDesk@ntia.doc.gov>
>>> "Goldman, Jason"
On behalf of the U.S. Chamber of Commerce, William L. Kovacs submitted
comments on 4/13/2009. However, there seems to be a technical error
with the posting of our comments. Clicking on the link to our
comments
results in a "Page Not Found" error. Please fix or advise me on how to
correct this problem.
Thanks,
Jason
===
Jason D. Goldman
Counsel
Environment, Technology & Regulatory Affairs
U.S. Chamber of Commerce
1615 H Street, NW
Washington, DC 20062
Tel: 202-463-5949
Fax: 202-887-3445
E-mail: jgoldman@uschamber.com
Embarq
See attachment
James P. Steyer
To Whom It May Concern:
The Broadband Technology Opportunities Program (BTOP) will be a significant step toward closing the digital divide in education and economics, and bringing valuable resources and opportunities to all our children, in every community. But it can’t be just wiring and hardware. Broadband investment – through BTOP and the Rural Utilities Service – won’t bring the rewards we need unless it includes comprehensive digital media literacy programs for America’s kids and schools. That is why Congress listed among the purposes of the BTOP the importance of providing education, awareness, training and support to schools, libraries and other community organizations.
As we work to bring the economic and educational benefits of broadband to every home, school and neighborhood in the United States, we must also ensure that parents and educators are prepared to help children learn how to navigate the digital media world, including how to find age-appropriate and educational media, and how best to avoid dangers online. If we invest wisely in the digital media literacy and education that need to accompany broadband, we will create new jobs, encourage demand for broadband service, and prepare our children for the high tech jobs of the future.
To facilitate this investment, we propose two alternative strategies for funding education, awareness, and training within the broadband programs:
1. Give priority funding to broadband grant applications that dedicate at least 5-10 percent of the funds to partnering with a qualified non-profit organization to provide digital media literacy programs in schools and community programs in the area served.
2. Reserve a portion of the available funds for grants to non-profit organizations to partner with elementary schools, secondary schools, and other educational entities and community organizations to provide digital media literacy programs, including professional development and in-service training for educators, technology support and staff development, and curriculum development and dissemination.
Innovative digital media literacy tools are already being used in many independent schools, and in some public school districts with appropriate staff support. They are the key to a successful 21st century classroom and to improving student achievement. Common Sense Media and other organizations have developed digital media literacy curriculum materials. To serve the public interest, and make the most of our investment in broadband, we must bring these resources – and the necessary support – to schools and community programs all over the United States, especially in rural and urban underserved areas.
We appreciate your consideration of these comments and invite you and your staff to contact us with any questions.
Sincerely yours,
James P. Steyer
Founder and CEO
DEAN TSILIKAS <dtsilikas@cityofchicago.org>
The City of Chicago is filing the attached comments with the National
Telecommunications and Information Administration (“NTIAâ€Â) of the U.S.
Department of Commerce and the Rural Utilities Service (“RUSâ€Â) of the
U.S. Department of Agriculture in response to the joint request for
information on the American Recovery and Reinvestment Act of 2009
Broadband Initiatives.
Docket No. 090309298-9299-01
If you require further clarification on the City of Chicago's comments,
please contact me, as I will be serving as the initial point of
contact.
We thank you for this opportunity to provide our input, and look
forward to the overall success of this important initiative.
Dean C. Tsilikas
Associate Director
City of Chicago
Washington, D.C. Office
202.783.0911 (W)
312.848.8778 (M)
dtsilikas@cityofchicago.org
------------------------------------------------------------------------------
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and any copy of any e-mail and printout thereof.
Spruce Knob Seneca Rocks Telephone, Inc.
Comments of Spruce Knob Seneca Rocks Telephone, Inc. submitted as a Word attachment by Phyllis A. Whitten, Attorney-at-Law.
The Telecommunications Industry Association
Attached please find a letter from the Telecommunications Industry Association requesting that the National Telecommunications and Information Administration, as it establishes a timeline for administering the Broadband Telecommunications Opportunity Program (BTOP), expedite BTOP grant awards and attribute pre-existing infrastructure investments necessary to BTOP projects as in-kind contributions to the BTOP 20 percent non-federal match requirement.
Leticia Van de Putte, R. Ph.
see attachment
Danna MacKenzie, Director of Information Systems
Thank you for the opportunity to provide input.
Please see attached document.
Steven A. Zecola
Please see the attached late-filed comment and my asssociated comment to the FCC.
National Rural Electric Cooperative Association
Comments of National Rural Electric Cooperative Association
Public Utilities Commission of Ohio
The attached Letter from the PUCO is signed by all PUCO Commissioners. It references and endorses aspects of the separate letter filed today by NARUC.
"Gent Cav @ G4" <gent@G4.net>
Dear Sir or Madame,
On behalf of G4 COMMUNICATIONS, CORP., attached are G4's comments for submission in NTIA/RUS Docket
No. 090309298-9299-01. Please contact me if you have any questions concerning this filing.
Sincerely yours,
--
Gent Cav
G4 Communications / Otel Telekom
(603) 703-0410 direct voice (email reaches me faster and preferred)
(603) 703-0670 direct fax
(603) 625-0555 company voice
(603) 647-7576 company fax
Cynthia Pols
See attachment for the comments (and a summary of those comments) of the Triangle J Council of Governments (TJCOG) Cable Broadband Consortium.
Diane Schou
Attached is a letter to President Obama regarding wireless problems, composed by well informed people. Signatures are being gathered nationwide.
John St. Julien
Please see comment attached as: "NTIA comments Lafayette JASTJ.rtf"
Markham C. Erickson
The Open Internet Coalition, including the undersigned entities, strongly support the provisions of the Broadband Technology Opportunities Program (“BTOPâ€Â), which is included as part of the American Recovery and Reinvestment Act (“the Stimulus Actâ€Â) signed into law by President Obama on February 17, 2009.
Among other things, the Stimulus Act states that the purpose of the BTOP is to (1) provide improved access to broadband service to consumers residing in unserved and underserved areas and (2) stimulate the demand for broadband, economic growth, and job creation.
We enthusiastically support these goals. It is widely recognized that the Internet fuels innovation, education, and jobs. Consequently, we support the notion that the BTOP is a key ingredient in developing a comprehensive broadband plan that provides ubiquitous, affordable high speed Internet connections to all Americans.
The Stimulus Act requires the Assistant Secretary of the National Telecommunications and Information Administration (“NTIAâ€Â), in cooperation with the Federal Communications Commission, to “publish the non-discrimination and network interconnection obligations that shall be contractual conditions of grants awarded.†These conditions “include at a minimum adherence to the principles contained in the Commission’s broadband policy statement.â€Â
We would like to emphasize our enthusiastic support for this common-sense notion that grant recipients must adhere to general openness principles. The open character of the Internet marketplace is what has fed the engine of economic and job growth in the information, communications, and technology sector for over a decade.
In publishing the nondiscrimination obligations, we urge the Assistant Secretary to include these contractual conditions, in addition to requiring adherence to the FCC’s Broadband Policy Statementâ€â€
Grant recipients, offering service to the public, A) must not operate their networks in such a way that privileges, degrades, prioritizes, or discriminates against any lawful Internet content application or service transmitted over the grant recipient’s network; and B) must offer bandwidth for Internet access upon reasonable request, on rates, terms, and conditions that are just, reasonable, and nondiscriminatory. Nondiscrimination shall not be construed to prohibit a grant recipient from engaging in reasonable network management consistent with the principle of nondiscrimination.
In publishing the network interconnection requirements, we urge the Assistant Secretary to require that grant recipients establish sufficient interconnection to provide consumers with robust access to the Internet.
Moreover, the nondiscrimination and interconnection obligations should apply in a technologically and platform neutral manner, to all grant recipients, regardless of whether the recipient provides wireless services, wireline services, or satellite services.
In addition, the NTIA should give priority to those qualified applicants with plans to deploy high speed fiber or wireless infrastructure, especially in those areas where access to such infrastructure is non-existent or inadequate. Using federal dollars to create a one-time investment in permanent fiber infrastructure is in most cases the most efficient use of federal dollars, which will benefit the public and a wide array of entities that rely on the Internet for commerce, health care, education, and other communications.
If you or your staff have any questions, please contact Markham Erickson at merickson@holcherickson.com or at (202) 624-1462.
Sincerely,
Markham C. Erickson
Executive Director
Adaptive Marketing LLC
Aegon Direct Marketing Services
Amazon.com
American Association of Law Libraries
American Library Association
Anglebeds.com
Ask.com
Association of Research Libraries
Bloglines
Chemistry.com
Circumedia LLC
Citysearch
CollegeHumor
Computer & Communications Industry Association
Cornerstone Brands, Inc.
Data Foundry
The Digital Media Association (DiMA)
Domania
Downstream
Dreamsleep.com
Dresses.com
EarthLink, Inc.
eBay
EDUCAUSE
Electronic Retailing Association
Entertainment Publications
Evite
Free Press
GetSmart
Gifts.com
GoGawGaw
Google
Hawthorne Direct
HomeLoanCenter.com
HSN
IAC
Iceland Health Inc.
iNest
Internet2
Interval International
iWon
Livemercial
Match.com
Media Access Project
Media Partners Worldwide
Mercury Media
Merrick Group
NationalBlinds.com
NetCoalition
New America Foundation
New Edge Networks, Inc.
North Texas Technology Council
PayPal
Product Partners
Pronto.com
Public Knowledge
RealEstate.com
ReserveAmerica
Savvier
ServiceMagic
Shoebuy.com
Shopping.com
Skype
Sling Media
Sony Electronics, Inc.
StubHub
Success in the City
TechNet
Ticketmaster
TiVo
Tonystickets.com
Tranquilitymattress.com
US PIRG
Vanguard
Washington Bureau for ISP Advocacy
Windward Instruments
YouTube
Ronald A. Brown
See Attached
Ramiro S. Salazar
Comment attached
Marc Hiller
See attached
Michael Cramer
This program would do the public a great service if it would provide grant monies to rural small business wireless broadband providers such as Business Machines Plus.
We are a startup trying to provide wireless to areas not serviced by any high speed service except satelite. We currently service about a 5 mile radius and have request for areas we can not quite quite reach due to terrain. The major tower companies make it cost prohibitive for us to rent space and purchasing our own towers and installing them is expensive.
We feel if we could erect a few more towers, we could serve the area quite well, but can not justify the expense due to our return on investment (ROI). I am sure the major players would say the same, but they seem to concentrate on the areas that will produce the best ROI (high concentration of potential subscribers).
You might consider making RURAL your primary consideration in making a grant,rather than who might be able to write the best grant proposal. Look at the demographics and availability of high speed as your primary consideration. If you do, then put us on the list for an application.
Thank you,
Michael Cramer
President
Business Machines Plus, Inc. and Little Falls Wireless
Evelyn Savarin
I mailed a previous submittal. I am concerned it could not be read properly in the format this box revises a letter. Therefore I am submitting the whole 'Comment Letter' again as an attachment with the additional attachments referenced in the Comment letter. Thank you for your patience and consideration of error.
Thank you
The People of the State of California and Governor Arnold Schwarzenegger
Attached are comments submitted on behalf of the People of California and Governor Arnold Schwarzenegger.
Richard Grobschmidt
Comments on the NTIA BTOP Program.
Frank Knott
Since 1992, ViTAL Economy, Inc. has been facilitating regional economies, throughout North America, on the development of regional frameworks to address the “digital divideâ€Â. Over these years we have learned that reversing the “digital divide†is as much about changing behavior and mindset of public, private, community leaders and the average citizen as it is about building broadband infrastructure to increase access to broadband services. We have learned that “if you build it they often may not comeâ€Â. Please accept the attached white paper as the ViTAL Economy submittal.
"Verlyn Veldhouse" <vveldhouse@1csi.com>
Are you searching for community coverage in rural areas or would you
prefer a county wide approach?
thanks
Verlyn Veldhouse,
Vice President
Your Total Communications Solution Provider
14910 Grover Street
Suite 300
Direct 402-938-5115
Office 402-597-3333
Fax 402-597-3577
Alternate 800-824-1636
Verlyn@1csi.com
Regulatory Commission of Alaska
Comments attached.
"NTIAHelpDesk NTIAHelpDesk" <NTIAHelpDesk@ntia.doc.gov>
NTIA Help Desk
Department of Commerce
National Telecommunications and Information Administration
Office of Spectrum Management
Herbert C. Hoover Building (HCHB)
U.S. Department of Commerce / NTIA, Room 4625
1401 Constitution Avenue, N.W.
Washington, D.C. 20230
Office: 202-482-4631
>>> "Becker, Rick"
Resubmission in PDF format. --Rick W. Becker
Office of the CIO and NITC
State of Nebraska
402-471-7984
rick.becker@nebraska.govFrom: Becker, Rick
Sent: Monday, April 13, 2009 2:09 PM
To: 'BTOP@ntia.doc.gov'
Subject: Comments - Docket No. 090309298*9299*01
Comments attached in PDF and Word formats. --Rick W. Becker
Office of the CIO and NITC
State of Nebraska
402-471-7984
rick.becker@nebraska.gov
"Burke, Christine" <christine.burke@frontiercorp.com>
Attached document was submitted via website, but it wasn't clear if the attachment went through successfully. Therefore, I am e:mailing a duplicate copy.
Kenneth F. Mason
Frontier Communications
Docket No. 090309298-9299-01
Christine Burke
National Manager, Funding Programs
Frontier, A Citizens Communications Company
585-777-6719
Gent Cav
See attached.
Patrick Moore
See Attachments
"Shirley Freriks" <sfreriks@mcn.org>
Thank you for inviting public comment.on how these Broadband Technology
Opportunities Program funds should be administered for broadband
deployment. I represent an active citizens group in Northwest California
called Mendocino Coast Broadband Alliance. We have been working to get
broadband for two years. We have done mapping of our communities,
surveys and public education. We have been trying to get providers to do
the deployment. The California Advanced Services Fund (CASF) program has
guidelines which have failed to materialize connection for our areas.
We are intimate with CASF and see the flaws in the process from the end
user point of view. We understand that you are looking at CASF as a
prototype so you should know its flaws and why the money is not able to
be awarded as expected. We want to offer our point of view on these
limitations to success and suggestions on how it must be changed if we
are to get connected. We do not stand a chance unless changes are
made.Other rural areas are also being left out because of flawed
guidelines. We offer many facets of their program flaws so you can avoid
the same mistakes.
Our comments speak to many aspects of your program questions and most
relevant to this question - What are the most effective ways to offer
broadband funds to ensure that they'll assist rural residents that lack
access? The three page attached report is simply written and the points
are clear (hopefully). There are quite a few points to be considered
from the grassroots, end user point of view so please do read them and
take them to heart. Much time is devoted to the companies at the top so
we hope you will give adequate attention to how this is going to be able
to really serve the mandate and connect ALL American households.
Thank you for reading our suggestions. We need broadband connection in
this isolated but highly active and educated area.
Peace be with you,
Shirley Freriks
Mendocino Coast Broadband Alliance
Andrew W Buffmire
See Attached Comments
Joshua Barrett <Josh@bdcgaming.com>
Could CDFI's evaluate locate, evaluate, and monitor projects?
They serve a demographic and sometimes geographic area.
Gabriela Lemus
April 13, 2009
The Honorable Anna Gomez
Deputy Assistant Secretary
Herbert C. Hoover Building (HCHB)
U.S. Department of Commerce / NTIA
1401 Constitution Avenue, N.W.
Washington, D.C. 20230
Dear Secretary Gomez:
For over 30 years, the Labor Council for Latin American Advancement (LCLAA) has provided a voice for Latino working families. As the main representative of approximately 1.7 million Latino trade unionists, we strongly believe in the social and economic empowerment of our communities and work tirelessly as an advocate for the rights of our Latino workers.
In a time of economic turmoil and job uncertainty, we must ensure that Congress continues to support legislation and programs that promote job creation and investment and not burdensome regulations. To this end, the LCLAA applauds the 2009 American Recovery and Reinvestment Act, which includes more than $7 billion for broadband deployment.
As our methods of communications become more sophisticated, access to broadband is no longer a luxury but a necessity. Minority and low-income communities have been disproportionately affected by the widening digital divide and need access to educational opportunities as well as life-saving health care programs. Broadband enables our Hispanic families to bridge this digital gap and can facilitate their social and economic advancement during this time of need.
As a leader in the Hispanic community, LCLAA strongly encourages the National Telecommunications and Information Administration (NTIA) to quickly, efficiently, and transparently disperse the funding from the stimulus to the state and local leaders to get these activities off and running. It is also imperative to get the mapping process underway quickly so communities can accurately identify underserved and unserved areas and direct resources.
To this end, the NHLA recommends the following four principles:
1) Get Broadband to All Parts of the Country – Mapping current availability of broadband is critical to ensuring that money is used efficiently and effectively. Identifying areas of need throughout all fifty states through the mapping process will provide information on broadband availability by community and allow for efficient dispersal of funds.
2) Reliance on state and local expertise – State and local leaders have a thorough understanding of what their communities need. By awarding grants to these leaders, there will be a greater likelihood that state and local government along with community-based organizations can identify qualified providers with sustainable business plans to ensure that broadband systems can reach those areas in greatest need first through the creation of public-private partnerships.
3) Transparency and Accountability – Eliminating potential waste and inefficiencies are essential to maximizing the benefits of the stimulus money. As state and local leaders help guide deployment, there must be a built-in mechanism for providing transparency to ensure funds are used appropriately.
4) Prioritize Communities of Need – Funding must focus first and foremost on deployment to those communities where no broadband connections exist. State and local organizations along with qualified providers can help focus attention on such unserved and underserved areas first, followed by the other communities that also need additional broadband access.
Delivery of next-generation broadband services will spur innovation, investment and create good paying jobs, while also helping provide solutions to some of the country’s biggest challenges like health care, education and energy efficiency. Technology and broadband is a gateway to social, political, and economic empowerment for all working families across our nation.
Sincerely,
Gabriela D. Lemus
Executive Director
"Libertad y Exito" <libertadexito@gmail.com>
Administre su propio Negocio
www.libertadyexito.com - info@libertadyexito.com
Escriba en Asunto REMOVER a: exitolibertady@yahoo.com
NBCSL President Calvin Smyre, NCBM Executive Director Vanessa Williams, NOBCO Executive Director Lin
see attached