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

"Tatum Martin" <tatum1@glenmartin.com>

(Late Submission)
Do we go to the local agency to ask for the Grants for the NTIA and
USDA?

Or is there a specific offices?


Tatum Martin

VP Operations

GlenMartin Inc

Phone: 660-882-2734 ext: 218

A Woman-Owned Business Enterprise



www.glenmartin.com







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Burt Solomons

(Late Submission)
The American Recovery and Reinvestment Act provides for federal grants for broadband. The state of Texas lags behind the national average for the adoption of broadband services as well as other large states. There are many factors that contribute to this, but for purposes of the stimulus plan, the key factors that will lead to sustainable adoption are availability, affordability and competition. To address these factors, the state of Texas needs to maximize stimulus funds available for construction of broadband networks in unserved and underserved areas of Texas. Unserved and underserved areas include rural areas in which broadband service is unavailable, as well as economically impoverished areas in which competitive and affordable broadband service is not available.

The state of Texas would use stimulus money to fund projects that seek to deploy broadband service to the most people, in the shortest amount of time at the lowest cost. These goals are technology-neutral, as both wire line and wireless technologies have strengths and weaknesses depending on the area in which services are being deployed.

The demand for such service in Texas is at an all time high. As an increasing number of Texans subscribe to online services, broadband becomes a larger player in the telecommunications market. The number of broadband subscribers in Texas has increased 133 percent from 2005 to 2007 demonstrating a high rate of adoption and demand for broadband service as its price continues to drop to a level that more Texans can afford.

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Solomons Letter re Broadband Stimulus April 8 2009.pdf 22.99 KB

Charles E. Wines

(Late Submission)
Please review our submittal to both the NTIA and the RUS regarding comments for the BTOP.

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BDC_NTIA_DocketNo090309298_9299_01.pdf 395.97 KB
BDC_RUS_DocketNo090309298_9299_01.pdf 395.97 KB

"Alexander J. Bryson" <abryson@harriswiltshire.com>

(Late Submission)
To Whom It May Concern:



The comments from General Communication Inc. on the National
Telecommunications and Information Administration and Rural Utilities
Service queries regarding the American Recovery and Reinvestment Act of
2009 Broadband Initiatives are attached in Microsoft Word form. Please
contact me, Alex Bryson, via phone at 202-730-1319 or e-mail at
abryson@harriswiltshire.com if there are any problems regarding this
filing.



Thank you very much for your time.



Alex Bryson

Legal Assistant

Harris, Wiltshire & Grannis LLP

1200 Eighteenth Street NW

Washington DC, 20036

(202) 730-1319

www.harriswiltshire.com






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GCI NTIA and RUS comments 4.13.09.doc 112 KB

lwagoner@ruraltel.com

(Late Submission)

Attached are comments (in Word format) from Rural Telephone Service Co.,
Inc. pertaining to the American Recovery and Reinvestment Act of 2009
Broadband Initiatives, Docket No. 090309298-9299-01.


(See attached file: Rural Telephone Comments Recovery Act April 13
2009.doc)


Lisa Wagoner
Executive Assistant
Rural Telephone / P.O. Box 158 / Lenora, KS 67645
785.567.4281 / 877.567.7872
**************************************************************


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Rural Telephone Comments Recovery Act April 13 2009.doc 66 KB

Public Knowledge

(Late Submission)
Submitting a report on Connected Nation and the privatization of public data.

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09-03-20reformatfinal.pdf 3.78 MB
09-03-20reformatfinal.pdf 3.78 MB

Carol C. McDonough

(Late Submission)
Comments are attached

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broadband grant.doc 29.5 KB

A. Philip Randolph Institute, Cuban American National Council, Hispanic Association of Colleges and

(Late Submission)
Please see the attached document.

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APRI et al letter to NTIA.pdf 35.71 KB

"Randolph May" <rmay@freestatefoundation.org>

(Late Submission)
Please include the attached comments in the public file.



If you have any questions, please contact me.



Thank you.



Randolph J. May

President

The Free State Foundation



P. O. Box 60680

Potomac, MD 20859

Tel. 301-299-3182

Fax. 301-299-5007

Cell 202-285-9926

E-Mail rmay@freestatefoundation.org

Web www.freestatefoundation.org

Blog http://freestatefoundation.blogspot.com







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NTIA Broadband Program Comments- Free State Foundation.pdf 60.5 KB
NTIA Broadband Program Comments- Free State Foundation.pdf 60.5 KB

"Wells, Terry L" <twells@decommunications.com>

(Late Submission)
Where on the web is the specifications and forms associated with The
American Recovery and Reinvestment Act?



Terry L Wells
OSP Network Planner - Strategic Network Planning
D&E Communications, Inc.
124 East Main Street
P.O. Box 458
Ephrata, Pa 17522
www.decommunications.com
717-738-8202 office
717-859-2552 fax
twells@decommunications.com




**DISCLAIMER
This e-mail message and any files transmitted with it are intended for the use of the individual or entity to which they are addressed and may contain information that is privileged, proprietary and confidential. If you are not the intended recipient, you may not use, copy or disclose to anyone the message or any information contained in the message. If you have received this communication in error, please notify the sender and delete this e-mail message. The contents do not represent the opinion of D&E except to the extent that it relates to their official business.



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Victoria Proffer/St. Louis Broadband

(Late Submission)
We were recently were asked to add more fixed wireless coverage in our proposal which is not reflected in our revised our comment.

We also agree and support the Wireless Internet Service Providers NTIA comments and questions. St. Louis Broadband is a member of WISPA.org

Victoria Proffer
CEO
St. Louis Broadband, LLC

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ACF165.pdf 230.07 KB

Universal Service for America Coalition

(Late Submission)
See Attachment.

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ACF7BF7.pdf 79.96 KB

"Landry, Andrew" <ALandry@preti.com>

(Late Submission)

Enclosed for filing in the above-captioned matter, please find the
Comments of Premium Choice Broadband.
If you have any questions regarding this information, please feel free
to contact me at (207) 791-3191 or alandry@preti.com.



Andrew Landry, Esq.
Preti Flaherty Beliveau & Pachios
45 Memorial Circle, PO Box 1058
Augusta, ME 04332-1058

Tel. 207.623.5300
Fax 207.623.2914
<>

--------------------------------------------------------------------------------
In accordance with Internal Revenue Service Circular 230, we hereby advise you that if this E-mail or any attachment hereto contains any tax advice, such tax advice was not intended or written to be used, and it cannot be used, by any taxpayer for the purpose of avoiding penalties that may be imposed on the taxpayer by the Internal Revenue Service.


This E-Mail may contain information that is privileged, confidential and / or exempt from discovery or disclosure under applicable law. Unintended transmission shall not constitute waiver of the attorney-client or any other privilege. If you are not the intended recipient of this communication, and have received it in error, please do not distribute it and notify me immediately by E-mail at ALandry@preti.com or via telephone at 207-791-3000 and delete the original message. Unless expressly stated in this e-mail, nothing in this message or any attachment should be construed as a digital or electronic signature or as a legal opinion.



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Premium Choice Broadband - Comments to NTIA and RUS.DOC 130.5 KB
Premium Comments Broadband - Cover Letter to NTIA.DOC 304 KB

Bill Johnson

(Late Submission)
April 13, 2009

Re: Comments on the American Recovery and Reinvestment Act Broadband Initiatives of the National Telecommunications and Information Administration and Rural Utilities Service Docket No. 090309298–9299–01

To Whom It May Concern:
The Oklahoma State Regents for Higher Education (OSRHE) believes that building mobile wireless broadband networks should be a primary consideration in state’s efforts to provision broadband in un- and underserved areas. The OSRHE recognizes that public-private partnerships are critical to the rollout and sustainability of the nation’s broadband efforts through the cost-sharing of infrastructure and expertise – ultimately providing a framework of collaboration that serves business and consumers as well as government and education entities that include, but are not limited to, K-20, healthcare, transportation, public safety, tribes and scientific research. This public-private partnership would definitely provide the best “bang for the stimulus buck”. Further, this has been the model for OSRHE’s Statewide Network “OneNet” for 16 years which has proven that State Government, Education and for-profit telecommunication companies can partner to reduce costs for both and provide tremendous value to consumer, business, government and education.
Today’s mobile technologies are also capable of speeds supporting the vast majority of uses critical to economic and social participation in cyberspace. Unlike wired networks, mobile wireless broadband networks have the ability to deliver a double benefit – broadband and mobility with a single, targeted investment.
Wireless technology is also the most cost-efficient means of providing affordable “last” and “middle mile” broadband both to sparsely populated rural areas and urban centers. Wireless broadband networks can be built quickly and due to their low cost, they are sustainable and more affordable than wired networks. Wireless broadband networks are also critical to attracting investment, spurring innovation, and increasing productivity.
OSRHE recommends that the “Agencies” implement the following strategies as part of their broadband initiatives.
• The Agencies should consider relevant broadband product markets when defining “un-served,” “underserved,” and “rural economic development.”
• Mobile wireless and fixed broadband services comprise separate product markets. Broadband services are comprised of different product markets that offer consumers different capabilities, irrespective of the broadband speed provided or the technology used. The ability of wireless networks to offer mobility places wireless broadband in an entirely separate product market.
• NTIA should define areas in which mobile wireless broadband service capable of delivering at least 3 mbps downlink and 768 kbps uplink speeds is unavailable as “un-served.”
• For the same reason, RUS should define areas in which mobile wireless broadband service is unavailable as lacking sufficient high speed broadband service to facilitate rural economic development.
• The Agencies should not require symmetrical threshold speeds for mobile wireless broadband networks.
• The Agencies should reject requests to limit initial rounds of funding to “un-served” areas only and instead consider both “un-served” and “underserved” areas concurrently.
• Projects that receive funding should represent a public–private partnership which will benefit consumers, rural business as well as hospitals, libraries, public safety and all levels of education and government including tribal government .
• The Agencies’ application selection criteria should consider whether multiple purposes or product markets would be served by an application.
• Applications which serve many markets and constituencies should be move to the top of the selection lists.
• The Agencies should give consideration to an applicant who has a history of providing enabling telecommunications with demonstrated commitment to rural and underserved areas.
State Role
• The Agencies should give substantial consideration to the views of the states.
• The “State” role should include identifying and insuring services are built to local communities, tribes, K-20 education, public safety, transportation, healthcare, smart grids and other government institutions.
• The Agencies should give positive consideration to states who operate their own private data networks and who have demonstrated history of reducing costs through public-private partnerships with for-profit telecommunications companies which ultimately lower costs to both by sharing most infrastructure costs.
• The Agencies should reject proposals, even from “States” which will not serve all levels of government. For example, a request for funds to build a “K-12” network which will not benefit libraries or higher educations should not be funded as it would requires duplicative efforts on the part of those other agencies.
OSRHE commends the Agencies’ adoption of an open and inclusive process for soliciting public comment on how to best implement the broadband funding provisions in Section 6001 of the American Recovery and Reinvestment Act of 2009 (“ARRA”). With ARRA funding, OSRHE will be able to accelerate broadband deployment to unserved and underserved areas, create and sustain jobs, and enhance public institutions’ capabilities with regard to the Internet. Accordingly, OSRHE has a direct and immediate interest in the Agencies’ funding criteria and application procedures, and offers these comments in an attempt to assist the Agencies in their efforts to implement the ARRA.
Conclusion
The Agencies should give substantial consideration to the views of the States.
The Agencies should give substantial consideration to the views of the states when determining whether a particular area is “unserved” or “underserved” as well as during the application selection process. Congress recognized that States have resources and a familiarity with local economic, demographic, and market conditions that could contribute to the success of the broadband grant program. This important role permits the states to share their considerable expertise.
OSRHE stands ready and willing to work with NTIA, RUS, the FCC and other industry groups to bring the ARRA application process to a successful conclusion.
Respectfully submitted, Oklahoma State Regents for Higher Education

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Docket_No_090309298–9299–01_Broadband_comments_OSRHE.pdf 129.81 KB

Governor Phil Bredesen

(Late Submission)
Please see attached letter.

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Letter to Anna Gomez 4-13-09.pdf 465.29 KB

John Stephens

(Late Submission)
attachment

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Letter_of_Support_Template[1] Connect TN.doc 32 KB

Gregg Vanderheiden

(Late Submission)
See the attached document.

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Trace Comment-NTIA-BTOP.pdf 453.67 KB

Carlson Wireless Technologies, Inc.

(Late Submission)
See attached Comments of Carlson Wireless Technologies, Inc.

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00013547.pdf 19.72 KB

Kentucky Municipal Utilities Association

(Late Submission)
Comments of the Kentucky Municipal Utilities Association

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KMUA NTIA RUS.pdf 1.1 MB
Comments in 07-38.pdf 510.62 KB
Reply Comments.pdf 4.58 MB

"support@CORTESE.US" <support@CORTESE.US>

(Late Submission)




    


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Jonathan V. Harlan

(Late Submission)
See Attachment

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jonathan lawson <jonathan@reclaimthemedia.org>

(Late Submission)
Dear friends,

I am writing to express Reclaim the Media's support for the attached
comment, submitted by several public interest advocacy organizations in
docket no. 090309298-9299-01, pertaining to the American Recovery and
Reinvestment Act of 2009 Broadband Initiatives.

The attached comment was submitted in advance of yesterday's deadline; I
have simply added our group's name to the list of cosigners.

many thanks

Jonathan Lawson


Jonathan Lawson
Executive Director

Reclaim the Media
Community organizing for social change through media justice
www.reclaimthemedia.org |
email list



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MDC NTIA RUS BB comments.pdf 63.05 KB

eXtension Foundation

(Late Submission)
Please find attached comments pertaining to the American Recovery and Reinvestment Act of 2009 Broadband Initiatives. These comments are provided from the eXtension Foundation, a national Internet-based educational network providing 24/7/365 access to objective, science-based information from land-grant universities and partners nationwide. It is an integral part of and complements the community-based Cooperative Extension System.

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NTIA-RUS Comments.doc 82 KB
NTIA-RUS Comments.pdf 133.74 KB

"Baker, Jim" <jbaker@seda-cog.org>

(Late Submission)
I've had no video since a few minutes into the broadcast. Still getting
the speech to text most of the time. Are you just overloaded?



Will there be a full transcript available afterwards?





James L. Baker, Chief

Information Technologies Group

SEDA - Council of Governments

201 Furnace Road

Lewisburg, PA 17837

voice: (570)524-4491 fax: (570)524-9190

www.seda-cog.org



"My job in the coming years will not be to attract companies... my job
will be to attract talent."
- Janet Miller, Nashville Area Chamber of Commerce






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Sara Dietrich, Director of Communications

(Late Submission)
See Attached Comments

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City Minneapolis.pdf 35.08 KB

"Anthony Lehv" <Anthony.Lehv@AmericanTower.com>

(Late Submission)
From: Anthony Lehv
Sent: Monday, April 13, 2009 9:51 PM
To: BTOP@ntia.doc.gov
Subject: NTIA/RUS Docket No. 090309298-9299-01



Dear sir or madam -



On behalf of American Tower Corporation, attached are its comments for
submission in NTIA/RUS Docket No. 090309298-9299-01.



Please contact me if you have any questions concerning this filing.



Respectfully submitted,



H. Anthony Lehv

Senior Vice President, Associate General Counsel & Chief Compliance
Officer

American Tower Corporation

116 Huntington Avenue

11th Floor

Boston, MA 02116



P: 617.375.7544

F: 617.375.7575

C: 202.423.4915

Anthony.Lehv@americantower.com



CONFIDENTIAL, PROPRIETARY and PRIVILEGED: The information contained in
this e-mail and any attachments constitutes proprietary and confidential
information of American Tower Corporation and its affiliates. This
communication contains information that is proprietary and may be
subject to the attorney-client, work product or other legal privilege or
otherwise legally exempt from disclosure even if received in error. The
communication is intended for the use of the addressee only. If you are
not the intended recipient, you are hereby notified that any
dissemination, distribution or copying of this communication is strictly
prohibited. If you have received this communication in error, please
immediately notify us by return e-mail and destroy any copies,
electronic, paper or otherwise, which you may have of this
communication. Thank you for your cooperation.






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American Tower - NTIA_RUS Comments.doc 103.5 KB

Nelson N. Angapak, Sr.

(Late Submission)
See Attachment for this

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AFN Comments on Docket No. 090309298-9299-01.pdf 242.95 KB

"John Tellis" <jtellis@qcdata.com>

(Late Submission)
To whom it may concern:

The attached file represents comments from QC Data, Inc.



Thank you,

John Tellis

Senior Account Executive

QC Data, Inc.

8000 East Maplewood Ave.

Suite 300

Greenwood Village, CO 80111

303-788-9121

303-547-6600 cell






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BTOP Comments to NTIA.pdf 2.1 MB

"Rob Franzo" <rob@wireless2020.net>

(Late Submission)
For each proposal, Service Level Agreement definitions should be included
that form the contract with the user and may be tiered by performance and
pricing with a basic SLA that is affordable for the market and supports
collaboration, interaction and multimedia applications, with the proposals
specifically outlining how the proposed implementation supports VoIP, video
streaming, and video interaction/collaboration.



These SLA should define the bandwidth in mbps for the uplink and downlink,
the latency and ability to support low-latency applications, and a measure
of Quality of Experience and a means for the subscriber to assess the QoE
and provide feedback to the provider.



All connections should be Internet Protocol compliant and support IPV6. As
part of the reporting mechanism, compliance to these SLA's and reporting of
the metrics for QoE should be included and assessed as part of the
fulfillment of the accepted proposal.





cid:image001.jpg@01C986E5.56034F20

Rob Franzo

Principal Consultant

+1.616.604.1229

rob@wireless2020.net

www.wireless2020.net






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"Hohman, Anne Kathryn" <aHohman@doitt.nyc.gov>

(Late Submission)
Please find attached comments of the City of New York regarding the
American Recovery and Reinvestment Act of 2009 Broadband Initiatives,
Docket No. 090309298-9299-01.







Kate Hohman

Project Manager

Department of Information Technology and Telecommunications

75 Park Place, 9th Floor

New York, NY 10007

Phone: (212) 513-6484

Fax: (212) 788-6528






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City of New York_NTIA RFI Comments_04.13.09.pdf 564.2 KB

"Bonnie Lorang" <blorang@mitstel.com>

(Late Submission)
Attached are the comments of Montana Independent Telecommunications Systems
(MITS) in the above noted docket, Request for Information on the ARRA 2009
Broadband Initiatives.



Please let me know if there are any questions at all. Thank you.







Bonnie Lorang

MITS - Montana Independent Telecom Systems

blorang@mitstel.com 406-594-9662 or 406-443-1940



MITS members, providing quality telecommunications service to rural
Montanans for over fifty years, include Nemont Telephone Cooperative, Inc.,
Project Telephone Co., Triangle Telephone Cooperative, Inc., Central Montana
Communications, Inc., Northern Telephone Cooperative, Inc., InterBel
Telephone Cooperative, Inc., and Mid-Rivers Communications.






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09 Apr 13 ARRA MITS Cmts FINAL.doc 51.5 KB

Scott Smyth

(Late Submission)
See attached

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NTIA RUS TRILLION COMMENTS ver 4 Final.doc 134 KB

"Derek E. Brooks" <dbrooks@inside-cable.net>

(Late Submission)
Dear NTIA Representative:



Kindly add myself and our company to the Broadband Initiative Correspondence
List. We are excited and anxious to get involved in continuing this
critical architecture process!



Please advise. Many thanks!



Best Regards,





Derek E. Brooks

President & Chief of Operations

INSIDE CABLE, INC.

85 Rangeway Road, Floor #1

Billerica, MA 01862

(781) 367-9881 - Direct

dbrooks@inside-cable.net

http://www.inside-cable.net





Full Service Telecom/Datacom Network Infrastructure SOLUTIONS



*Please Note New ICI Address, & Contact Information!






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Leslie Nulty <leslie.nulty@valleyfiber.net>

(Late Submission)
Please find attached our submission regarding implementation of the RUS
Broadband program under the ARRA.

Sincerely,

Loredo Sola, Chairman
East Central Vermont Community Fiber



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ECF RUS Comments 090413 final.pdf 210.22 KB

Marc Berejka <mberejka@microsoft.com>

(Late Submission)
Please let me know if you have any questions. Thank you!!

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msft ntia rus fcc comments 13apr09 FINAL.doc 82.5 KB

AlphaStar

(Late Submission)
AlphaStar International is seeking partnership with Rural WISPs. Telco's, Cable TV Systems , municipalities, schools , no-profit organizations , hospitals ,libraries , Native American , vendors and suppliers and other entities to apply to the broadband stimulus fund.
Since the year 2000 ,we have deployed an IP hybrid network ;terrestrial for users ( WiMax , WiFi ,mobile and fixed or wire-lines ) with satellite back-haul only. Immediate employment and deployment ( matter of weeks ) of broadband in the rural ,remote , mountainous and maritime locations with value added service such as VOIP ,VOD ,VPN etc . Also redundancy and disaster recovery.
AlphaStar is also seeking to hire employees, management teams and consultants in all phases. both in CT and the field nationwide.
Please read attachments and visit
: www.alphastar.com

Contact phone : 203 979 2700
or email :
contactus@alphastar.com

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ACF6DA3.mht 163.13 KB
FCC Broadband Comments (2).docx 19.89 KB
ACF6DA4.pdf 379.84 KB

Anthony Tull

(Late Submission)
Please see attached for comments and proposal. Our project plan is complete with financials and shovel ready upon approval.

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Project Plan.doc 6.6 MB
Project Plan.pdf 1.91 MB
NTIA comments.doc 67.5 KB
Project Plan.doc 6.6 MB
Project Plan.pdf 1.91 MB
NTIA comments.doc 67.5 KB

"John Hoffman" <jhoffman@zerodivide.org>

(Late Submission)
ZeroDivide is a 501(c)(3) public foundation that has invested more than
$45 million over the past 10 years in innovative programs that encourage
sustainable adoption of broadband services in unserved and underserved
communities. ZeroDivide provides financial support, capacity building
and technical assistance to nonprofit organizations that benefit
low-income, minority, immigrant, non-English speaking, LGBT, aged and
disability communities.



The following comments are in response to the American Recovery and
Reinvestment Act of 2009 Broadband Initiatives, Joint request for
information and notice of public meetings (Docket No.
090309298-9299-01):



NTIA should award grants to intermediaries with experience in
identifying, funding and supporting innovative technology programs that
increase sustainable adoption of broadband service in unserved and
underserved areas.



For-profit entities should be incentivized to partner with non-profit
entities that are also applying for BTOP funding.



Proposals which leverage other Recovery Act projects should be
encouraged, but such leverage should not be a requirement to receive
funding.



Applicants should be encouraged, but not required, to address more than
one purpose of the BTOP grant program.



States should not have an advisory role in the allocation of grant funds
if they themselves are applicants.



Funding should be diversified across multiple organizations within a
state and not sole-sourced to one entity within a state.



Organizations that can immediately provide 20% matching cash toward a
project should be given greater weighting than those organizations with
a contingency to raise matching funds from external sources.



The broadband mapping effort should include the mapping and tracking of
broadband adoption, in addition to broadband availability.



NTIA should consider the following factors in establishing selection
criteria for grant awards to stimulate the demand for broadband:



1. A proven track record (5 or more years) in stimulating demand for
broadband availability, adoption, and accessibility in unserved and
underserved communities.



2. Strong indigenous support within/by members of the targeted
communities in specific geographic areas, evidenced by needs/demand
assessment or survey data.



3. Proven cost-effective approaches, which leverage both public and
private sector resources.



4. All Computer Centers and NTIA-funded programs should be accessible
to individuals with disabilities.



5. Experience in creating a reasonable level of sustainable economic
impact/revenue generation (i.e. social enterprise), which will support
sustained broadband usage and ongoing adoption within economically
challenged communities.



6. Demonstration/proposal of replicable models of change which can be
propagated across multiple geographic/cultural/ethnic/socio-economic
vulnerable communities.



7. Potential for projects to scale. NTIA should direct funding
toward projects that can be scaled or replicated immediately as well as
toward targeted, innovative models that can be scaled in the future.



8. Development of relevant, culturally and linguistically competent
content for underserved consumers and broadband applications by
community-oriented entrepreneurs.



These recommendations are based upon our lessons learned over the past
decade and focus largely on the purposes of the Act to support broadband
adoption, demand, training, education and job creation in unserved and
underserved communities.



I have also attached ZeroDivide's full comments in Word format and
submitted these comments online via
http://www.ntia.doc.gov/broadbandgrants/form.cfm.



ZeroDivide looks forward to being an applicant for funding under the
BTOP program. Through our experience, we have learned that information
and communications technology is a powerful tool to increase economic
opportunities, create jobs, improve educational achievement, enhance
health and well-being, and increase civic engagement in communities.



Thank you,


John Hoffman
Director, Business Development
ZeroDivide
415.773.0388 x314
425 Bush Street, Suite 300
San Francisco, CA 94108
zerodivide.org




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ZD Comments to NTIA.doc 146.5 KB

Luisa Handem

(Late Submission)
National Telecommunications & Information Administration
and Rural Utilities Service
Joint Request for Information
Docket No. 090309298-9299-01

COMMENTS OF THE RURAL MOBILE BROADBAND ALLIANCE
(RuMBA) USA

Background

The Broadband Technology Opportunities Program (BTOP), created by the 2009 Recovery and Reinvestment ACT, presents an opportunity for the Federal Government to help support the creation of our nation’s first Next Generation Mobile Network (NGMN) (4G) Grid. The Grid is a cost-effective, IP-based mobile broadband 4th generation/backward-compatible network architecture that can rapidly be deployed in unserved, underserved areas and rural communities. RuMBA believes that (4G) Internet-based network technology is more economical and ’green’ than wired networks, and does not require expensive upgrades.

The build-out of a mobile broadband communications network will lead to immediate job retention and growth, and act as a long term economic stimulus, as envisioned in the 2009 Recovery Act. It should also provide essential communications and emergency alerting services in rural communities.

COMMENTS
RuMBA considers the following key minimum standards to be essential in determining the way forward in broadband deployment in rural areas:

1. Ubiquitous: Our telephones and modems must seamlessly work everywhere: in rural, suburban and urban areas, so as to cover the additional 2 million square miles of broadband coverage needed.

2. All areas of continental US must have availability of E-911, with location service, and an emergency cell broadcast system with weather and disaster alerting (SMS). Katrina-like outages are unacceptable.

3. Whether in the car, on the tractor, at home, in school or at work, and all areas in between, our nation relies on mobility; our networks must reflect our lifestyle needs.

4. Affordable: Rural Americans need competitive pricing for services and devices. Rural residents need the same access to services and devices as the rest of the country, at a fair price.

5. An investment must be made in next generation systems that can be operated at a profit and maintained by our local small town carriers. In expanding broadband connectivity, let’s look at the best, fastest, more dependable and affordable technologies, not yesterday’s.


PUBLIC SAFETY
With regards to point (2) above, Title VI states that grants should be issued to projects that “construct and deploy broadband facilities that improve public safety broadband communications services”. RuMBA considers it imperative that any mobile platform selected should support single-site, Phase II, E911 emergency cell broadcast, cell site priority calling and other critical public safety features. Providers should demonstrate their ability to provide and carry over their networks, emergency alert services (EAS) such as: severe weather watches and warnings, tornadoes, hurricanes, fires, earthquakes, Amber Alerts, and other natural and manmade emergency information relevant to people living in rural areas.

RuMBA believes that a healthy competition among providers will ensue only if Mobile broadband be given primary consideration for BTOP funding. Although fixed wireless broadband has been paramount to the expansion of high-speed Internet, the US experience, over the last twenty years, with personal communications services has proven that end users desire to take their communications services with them. Mobile service is now the primary means for voice communications, and broadband services will follow the same path:

- According to Informa Research, 75% of wireless users will subscribe to mobile broadband services by 2013
- Mobile broadband is growing three times faster than fixed broadband – according to studies done by Pyramid Research.

NTIA QUESTIONS:

Broadband:
The FCC defines “Basic Broadband” as 768 kbps to 1.5 Mbps, and several tiers of service (called generations) above 1.5 Mbps. Other entities have defined broadband as 100kbps and above, or 256 kbps and above. RuMBA recommends a separate definition of broadband for wireless networks, and that 4G-ready Infrastructure be deployed in all rural areas, unserved and underserved areas, allowing for the gradual implementation of the fastest radio speed available. The IP-based infrastructure chosen should allow for interoperability of radio access, whether 2G, 3G or 4G, on technologies ranging from GSM, CDMA, UMTA, LTE and WiMax. That wireless connectivity should meet the definition of Broadband.

Peak-Use Connection Speed: (True Connection Speed measured during peak usage times) Providers should guarantee a minimum peak-use connection speed.

Unserved Area: When less than 20 per cent coverage of a geographical area is present, the area is unserved.

Underserved Area: Where 80 per cent of the geographical area is covered, by broadband providers, with remaining 20 per cent without coverage, the area is underserved.

Broadband Penetration: Broadband penetration can be measured as the ratio of broadband subscribers to Internet subscribers/users.

Broadband Availability: Broadband availability is the portion of the population of an area that may subscribe to a broadband connection at prices comparable to those available in non-rural areas.

Selection Criteria for Grants
1. A primary consideration should be the applicant’s ability to provide broadband access to the greatest number of users possible, at the lowest possible cost, particularly, in rural, unserved and underserved areas.
2. The type of technology to be deployed. Although neutrality should be the rule, differences in technologies should be considered, when a particular technology can deliver a better broadband experience, to the greatest number of users, at the lowest possible cost, per customer and area covered.
3. The long-term sustainability of the deployed network should be a consideration. It should not require continuous government funding.
4. Solutions presented by providers with a proven track record of broadband deployment, should be prioritized.
5. Within mobile broadband technologies, there exists situations specific to rural areas, where legacy system architectures, which work well for schools and hospitals, have held back the delivery of services in many areas. Fortunately, there are wireless providers that offer cost-effective solutions that are non-municipal based, and that are available in wider areas, while offering more simple billing functions.
6. Speed is important, but as stated above, should take the back seat to deployment of robust mobile (4G) options that can be upgraded as new technologies emerge.
7. A competitive environment should prevail, allowing for lower prices to emerge as a result of competition.
8. Projects that are ‘shovel ready’ and deployable in the shortest possible time, need be given special attention

Selection Criteria for Grants Issued under the Special Allocation for “Innovative Programs to Encourage Sustainable Adoption of Broadband Services”
1. Solutions that can significantly reduce providers operating cost in rural markets should be given selection priority.
2. Customer take-up rates and operating profitability are measures that can be used to determine whether a program has succeeded.

NTIA should determine that it is in the public interest for private sector entities, including equipment and network vendors, to be eligible for grant awards.
1. Eligibility for funding should be open to all entities, including private sector providers and equipment makers, as long as the proposal meets the litmus test of public interest. Most network build-out work is performed by network and equipment vendors, thus, the need to include such entities in the application and selection process. A likely scenario will be service providers and equipment makers filing joint applications.

RUS Questions

BROADBAND SPEED CONSIDERATION, as long as the currently available minimum speed established by the FCC is available, the following should be prioritized:
1. The availability of services from multiple providers, in a competitive environment, is more conducive to end user satisfaction, as there will be a choice of services that best fit each person’s technical requirements and ability or desire to pay.
2. RUS should prioritize broadband projects that will benefit the most residents in rural and underserved areas.
3. End users should have a choice of Internet service providers
4. RUS should prioritize applicants that have the funds to commence and complete projects
5. RUS should evaluate, from existing grants’ recipients, effectiveness of the provider in expanding broadband coverage, and level of satisfaction of existing customers.


Conclusion
RuMBA USA recommends that the federal government select applicants for funding from a variety of perspectives, that:
- Providers are able to deploy broadband in the largest possible unserved and underserved geographical area, cost-effectively, and within the time frame established.
- Applicants have a proven track record of successfully deploying networks, beginning with an established customer-base, however small.
- That mobile broadband – 4th Generation IP-based - be evaluated as an optimal solution for rural areas, thereby enabling viable and sustainable businesses in remote areas where such economic activity was not previously possible.

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ACF7E37.doc 105 KB

"Kristy Szabo" <kristy.szabo@vantagepnt.com>

(Late Submission)
Please find attached Filling Comments on Section 6001 of the American
Recovery and Reinvestment Act of 2009. These comments are being filed
on behalf of Communications 1 Network Inc.

Kristy Szabo
On Behalf of Communications 1 Network Inc.
605-995-1786




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Communications 1 - NTIA-RUS Rules Comments 4 13 09.pdf 270.23 KB

"Michael Tracy-Ireland" <MIRELAND@MAIL.NYSED.GOV>

(Late Submission)



Michael Tracy-Ireland
Project Manager
NYSED Project Management Office
Rm. 301
89 Washington Avenue
Albany, NY 12234
518.474.6261
pmo@mail.nysed.gov
P Do you really need to print this e-mail?



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Michael Tracy-Ireland.vcf 745 bytes
Michael Tracy-Ireland.vcf 745 bytes

National Broadband Infrastructure Partnership

(Late Submission)
A critical issue has come up in our inquires to the FCC. As you are probably aware the FCC has set aside a range of radio spectrum for educational broadband service or (EBS) to be used by schools and the community for Broadband Wireless Access. This is the quickest and lowest cost method for a rural community to implement broadband services. In discussions with the FCC today case number 1162847 I was informed that the FCC has a freeze on new license applications for EBS and was provided with the attached document which in not on the FCC main page, but had to be searched for with the correct document code. The 2007 document attached in section 12 states that current filing freeze is in effect. If you go to apply for the license at the FCC web site you are un able to do so...

Section 12 of this document (see attached FCC document)

"In this connection, we note that the Commission implemented a filing freeze with respect to all applications for new BRS and EBS licenses, as well as for major modifications of those licenses, in order to permit the orderly and effective resolution of issues in the BRS/EBS proceeding"

This is a major blockade to schools and rural communities to roll out broadband services. The reasoning is not clear but should be revisited quickly or it will seriously impact the ability of NTIA grantees to implement services. Could you please pass this issue on to the stimulus committee and FCC. There is a Texas Federal Stimulus Meeting on the 14th where this well be read inot the record as well...

Regards,

Brent K. Earley

Chairman - National Broadband Infrastructure Partnership

214-912-6882
www.nbip.org
admin@nbip.org

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DA-07-435A1.doc 92.5 KB
DA-07-435A1.doc 92.5 KB

"Jeff Campbell (jeffrcam)" <jeffrcam@cisco.com>

(Late Submission)


________________________________

From: Jeff Campbell (jeffrcam)
Sent: Wednesday, April 15, 2009 3:55 PM
To: 'btop@nita.doc.gov'
Cc: 'Mark Seifert'
Subject: Notice of Ex Parte Discussion/Cisco Systems


On March 23, 2009, Jeffrey A. Campbell, Senior Director of Technology
and Trade Policy for Cisco Systems, Inc. spoke telephonically with Mark
Seifert, Senior Advisor to the Assistant Secretary, NTIA regarding the
applicability of the "Buy America" provisions of the American Recovery
and Reinvestment Act of 2009 to the Broadband Technology Opportunities
Program. Mr. Campbell indicated that Cisco did not believe that
broadband grants under BTOP constituted a "public work" which would
subject them to the "Buy America" requirement. Mr. Campbell also
indicated in the alternative that if the grants were determined to be
covered, then a public interest waiver of the "Buy America" requirements
should be granted for all electronics equipment used in broadband
networks.


Jeffrey A. Campbell
Senior Director, Technology and Trade Policy
Global Policy and Government Affairs

campbell@cisco.com
Phone :202-354-2920
Fax :202-354-2930


Cisco Systems, Inc.
1300 Pennsylvania Avenue, NW
Suite 250
Washington, DC 20004
United States
www.cisco.com









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Link Shadley

(Late Submission)
See attached

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ARRA Broadbrand Policy Rec 3-09.pdf 119.46 KB
ARRA Broadbrand Policy Rec 3-09.pdf 119.46 KB

"Jim Clarke" <Jim.Clarke@lacity.org>

(Late Submission)
Enclosed please find a comment letter from the Office of the Mayor, City of Los Angeles

-- Jim

Jim B. Clarke
Director of Federal Relations
Mayor Antonio R. Villaraigosa
City of Los Angeles
200 N. Spring Street, Room 303
Los Angeles, CA 90012
213-922-9743 / 213-978-0720 fax





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BTOP Regulations.pdf 115.06 KB

Karen Manuel

(Late Submission)
Communities Connect Network (CCN) is a statewide coalition of public, non-profit and private organizations working to ensure technology opportunities for all.

We represent 200+ organizations in the State of Washington providing technology access and learning opportunities. According to a recent study by the University of Washington, these organizations (CTs) receive more than one million visits per year.
We bring expertise in broadband deployment and adoption, a clearinghouse for research and training, and education about best practices and the needs of digital inclusion programs. Communities Connect Network was instrumental in creating the Washington State Community Technology Opportunity Grant Program and facilitating the awarding of grants for digital inclusion programs. We developed and manage a multi-sector state Digital Inclusion Council. We encourage the NTIA to consider formation of a national digital inclusion council and support these state councils.
We know from experience and research that you can offer valuable online content and applications like medical information or job applications, but if residents can’t afford a broadband connecton, don’t have a working computer, know where to find the content, or how to use the web effectively, then ARRA won’t attain it’s goal of reaching the most vulnerable populations and these residents, small businesses and non-profits will not become sustainable purchasers of broadband services. Our comments here focus on how to use the ARRA funds to link and support increased demand for and adoption of broadband. For instance, low-income residents and seniors will understand how to use broadband after receiving training and could benefit from low-cost computer distribution programs. The disabled need adapted equipment and training to take advantage of broadband. Technology training and web marketing assistance help enable disadvantaged business sustainability and new entrepreneurs...and greater demand for broadband.

Summary of our recommendtions:
1. NTIA and RUS should strengthen support for broadband adoption programs that increased demand, going beyond the minimum amounts set in the ARRA for public access and adoption programs. Broadband adoption programs increase user take-rates and support broadband sustainability. This is especially important for rural and low-income communities.
2. The $450 million allocated to public computing and the “innovative adoption programs” should be considered the minimum available for these purposes.
3. There should be different definitions and criteria for underserved in adoption programs vs deployment programs. Definitions and proposals focused on speed alone do not address the adoption needs of vulnerable populations in urban and rural settings for broadband application awareness, skills training, end-user hardware and software, and technical support. Community Technology Centers (CTC’s) should be eligible and receive funding, in addition to colleges and public libraries, for public access, training and adoption funds,
4. Local and regional programs that regrant to deliver services should be eligible and are an effective way to ensure use of best practices, enable greater reach to underserved populations and to deliver locally responsive community-based initiatives.
5. NTIA and RUS should support capacity building networks which promote best practices and strategic coordination. In Washington State, CCN provides training, program evaluation and other services which would otherwise be unavailable and unaffordable for small to mid-sized CT programs.
6. Affordability in broadband must also be addressed- for residents, non-profit community service providers, and small businesses.

Answers to the questions are detailed in the attached documents.

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CCNComments on NTIA-RUS questions ARRA2009Broadband Initiatives.docx 34.54 KB
What_is_Digital_Inclusion_4-09.doc 118 KB

"Markham Erickson" <merickson@holcherickson.com>

(Late Submission)


Markham C. Erickson

Holch & Erickson LLP

400 N. Capitol Street NW

Suite 585

Washington DC 20001



The phone at my office's reception desk: +1 202.624.1460

The phone on my desk: +1 202.624.1462

My mobile phone: +1 202.744.4318

Skype name: m.c.erickson

Y! Instant Messenger name:
markhamerickson@rocketmail.com

Email address:
merickson@holcherickson.com

Web address: www.holcherickson.com



This email communication and any attachments are intended only for the
individual or company to which it is addressed and may contain information
which is privileged, confidential, and prohibited from disclosure or
unauthorized use under applicable law. If you are not the intended
recipient of this email communication, you are hereby notified that any use,
dissemination, or copying of this email communication or the information
contained in this email is strictly prohibited by the sender. If you have
received this transmission in error, please return the material received to
the sender and delete all copies from your computer.






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Open Internet Coalition Comments April 13 2009.pdf 65.97 KB

"Bernadette McGuire-Rivera" <bmcguire-rivera@ntia.doc.gov>

(Late Submission)


>>> "Christopher White" 4/8/2009 11:21:49 AM
>>>
This is a resend.


This e-mail, including any attachments, is intended solely for the
personal and confidential use of the sender and recipient(s) named
above. If you have received this e-mail in error, please do not
review,
transmit, convert to hard copy, copy, use or disseminate this e-mail
or
any attachments to it. Please notify the sender by return e-mail and
delete this message and any attachments immediately.

This message may consist of or include advisory, consultative, and/or
deliberative material and/or attorney-client communications and/or
work
product. As such, this email and/or its attachments, or portions
thereof, may be privileged and confidential.



________________________________

From: Christopher White
Sent: Wednesday, April 08, 2009 11:18 AM
To: BTOP@ntia.doc.gov
Cc: Christopher White; mseifert@ntia.doc.gov;
bmcguire-river@ntia.doc.gov; ken.kuchno@usda.gov
Subject: New Jersey Division of Rate Counsel's comments on Request for
Information


Enclosed are comments for filing in Docket No.090309298-9299-01.


This e-mail, including any attachments, is intended solely for the
personal and confidential use of the sender and recipient(s) named
above. If you have received this e-mail in error, please do not
review,
transmit, convert to hard copy, copy, use or disseminate this e-mail
or
any attachments to it. Please notify the sender by return e-mail and
delete this message and any attachments immediately.

This message may consist of or include advisory, consultative, and/or
deliberative material and/or attorney-client communications and/or
work
product. As such, this email and/or its attachments, or portions
thereof, may be privileged and confidential.





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comments of New Jersey Division of Rate Counsel Docket No. 090309298-9299-01.PDF 192.09 KB

Diane Wells

(Late Submission)
See attachment.

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MNDOC comments to NTIAandRUS13apr09.pdf 134.99 KB

Charles Firestone

(Late Submission)
Please see the attached report of the 2008 Aspen Institute Communications Policy Conference. At a follow up meeting, participants noted three additional significant points:
1. Not all grants will succeed. It is important to understand from the beginning that with bold initiatives there will be some failures.
2. Evaluation should be built into the projects from the beginning. At the least, applicants could be asked what plans and measures they intend to take with respect to evaluating the project on an ongoing basis.
3. Funds should be spent on helping people gain access to these grants in areas and with populations that are not expert in grant writing.

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Aspen Institute ICT final published text.pdf 1.2 MB