Joint Broadband Technology Opportunities Program Request for Information

March 12, 2009
Docket Number: 

American Recovery and Reinvestment
Act of 2009 Broadband Initiatives

Yanira Cruz

(Late Submission)

20090409121659.pdf 87.56 KB

John A. Marinho

(Late Submission)
Please see attachment

062609 Alcatel-Lucent Letter.pdf 29.23 KB

Schools, Health and Libraries Broadband Coalition

(Late Submission)
The attached documents describe the goals of the new Schools, Health and Libraries Broadband Coalition.

SHLB Letter to DOC-DOA June 16, 2009.doc 57 KB
SHLB Mission Statement 6-16-09 Final.doc 46 KB

Tiffany Ann Norwood

(Late Submission)
Next Generation Broadband Inc
Submitted to the Federal Communications Commission
March 31, 2009

Recommendations Regarding the Application of Broadband Stimulus Funds

Next Generation Broadband, founded in 2001, is a broadband networking and software company that specializes in advanced application technology that enables automation and enhanced services for broadband networks. Located in the District of Columbia, Next Generation Broadband has developed and deployed, both domestically and internationally, systems that allow for advanced functionality such as fully automated customer installations, customer device management and session managed services.

NGB thanks the FCC for the opportunity to submit comments in relation to the proposed Broadband Stimulus funding, which we believe will provide insight and an alternative perspective to the Commission in determining the appropriate use of the funds allocated by Congress to achieve its aims in promoting the use and availability of broadband service to the highest level in the United States.

Comment on Application of Broadband Stimulus Funds
NGB’s interest in providing comments to the FCC is to suggest ways in which advanced technologies, like our own, can be used to enhance and leverage the investment that the government, and in particular the Department of Commerce’s National Telecommunications and Information Administration (NTIA) and the Department of Agriculture’s Rural Utilities Service (RUS) FCC and the Department of Agriculture to extend the use and availability of broadband services across the country. In this respect, Next Generation Broadband would like to comment on how advanced software based technology can support:
• Making access to broadband services more accessible to underserved and unserved markets through automation of systems supporting the broadband networks
• Reducing installation and operating costs through automation to make broadband generally more affordable
• Making systems at service providers more flexible to allow a greater variety of services that can address underserved markets
• Offering Pay-As-You-Go broadband to allow customers to buy broadband on an as needed basis
• Leveraging innovation and efficiency of productized software solutions to quickly impact these market segments
• Insuring US global leadership in advanced applications for broadband networks, which can then be exported, resulting in an increased and extended return on the government funds invested

Reducing Installation Costs Allows Operators to Offer Service to More Consumers
Beyond the investment in the core infrastructure, for both wireline or wireless networks, a key barrier to subscriber take-up is the cost of installation and activation of service. This cost on average is $100-150 per subscriber depending on a variety of factors. By automating all or part of the installation process through advanced software applications, this number can be reduced by at least 50%. Reducing this fixed cost, allows operators to:
• Offer services without an annual commitment
• Have more flexibility in pricing of services
• Loosen credit requirements for new customers
• Potentially lower cost of service

Flexible Systems in an Operator’s Data Center allows Economical Support of Underserved Markets
At the present, it is very difficult for operators to handle different groups of users in a unique manner, weather its low-income families that need subsidized service or government sponsored entities. Currently all subscribers have to be managed in the same manner, due to the inflexibility of the operator’s backe-end systems. Next Generation Broadband has developed software that resides in the operators’ central data center that can identify and direct different types of users to different product or service options in a cost effective automated manner. The possible benefits include:
• Special services and pricing for different groups of users
• Government sponsored subscriber segments that are provided free or subsidized service
• Virtual secondary networks for government or educational entities that can leverage the primary network of the service provider

Pay As You Go Broadband Makes Broadband more Affordable to a Larger Base of Subscribers
For most underserved markets, the service cost is a key impediment, new pricing options such as Pay as You Go” can be implemented that do not require a high monthly fee for broadband usage. Pay As You Go broadband also removes issues around credit checks. This service class is a model already used in the cellular telephone space with some success, and NGB has already had discussions with a number of large broadband service providers in North America and in Europe on our session management system that allows a cost effective means of automating the control and pricing of pay as you go services. Benefits include:
• Reduce need for credit checks
• Eliminating requirement for high fixed monthly payment by subscriber
• Cost effective solution for occasional users
• New service option for subscribers on a fixed income

Product Based Software Solutions Allow Immediate Impact and Access for the Underserved Markets
In making broadband services more accessible to underserved markets there are multiple options such as hardware based solutions or custom built applications. These options are very expensive and can take years to implement. Product based software solutions, from small innovative companies like Next Generation Broadband, are existing technology that can be deployed quickly and can have immediate impact on underserved markets. This technology is applicable to cable, DSL and wireless based networks. Productized software solutions allow:
• System deployments in months instead of years
• Impact on underserved markets in months instead of years
• Proven technology that has been previous deployed, supporting a national footprint both in the US and internationally
• Lower operational and technology risks for operators and service providers

Investing in Technology Developed by Small Businesses can be Leveraged and Exported Globally
The US has an opportunity to be a global market leader in developing advanced applications and software systems that expand functionality of broadband networks. Investment in these systems can be leveraged in international markets and have a multiplier effect beyond addressing underserved markets in the US. Government support of the capital expense of these technologies can help insure the leadership of US companies in this space. This type of innovation, historically originates from small businesses such as Next Generation Broadband, resulting in:
• New jobs created in the US to support the development and deployment of these applications
• US based intellectual property that can be sold and exported to overseas markets
• Global recognition of US as market leader in broadband technology
• Creation of cottage industries to support extensions of core technology

About Next Generation Broadband
Next Generation Broadband has installed systems both domestically and internationally to large broadband service providers, enabling automation and advanced functionality on broadband networks. Some of our systems include: auto installation for broadband data and VoIP, session managed solutions for pay as you go and free user trials, as well as, systems to identify and manage different types of broadband devices such as PCs, cable modems, gaming devices and home networking equipment. Currently NGB is developing new products for wireless and video networks.

NGB’s core team has worked at many key broadband service providers like, AT&T, Verizon, USWest, Time Warner, Telstra, Road Runner, and others. Our executive team has experience across international markets in Asia, Europe, South America as well as North America. Market experience includes Japan, Korea, Singapore, Hong Kong/China, Singapore, Australia, New Zealand in Asia and Oceania, and in Europe, the Netherlands, France, United Kingd

NGB Submission to the FCC 900331 final.pdf 26.61 KB

Allied Fiber, LLC

(Late Submission)
See attached file.

Allied Fiber NTIA Comments.pdf 73.71 KB
T-Mobile Responses.pdf 58.88 KB

Bertney Langley

(Late Submission)
Please see attched pdf

ACF7AF0.pdf 185.25 KB

"Eric Graham" <>

(Late Submission)
Attached, please find the Comments of Cellular South to the Joint
Request for Information on the Broadband Technology Opportunities
Program. The Comments are being submitted in both PDF and Word formats.
If you have any trouble with the attachments, please let me know.

Eric B. Graham | Vice President of Government Relations | Cellular
South, Inc.

1018 Highland Colony Parkway | Suite 300 | Ridgeland, MS 39157

Office 601.974.7601 | Fax 601.974.7199 |

Cellular South -- BTOP Comments.pdf 22.2 KB
Cellular South -- BTOP Comments.docx 23.23 KB

Utopian Wireless Corporation

(Late Submission)
Comments of Utopian Wireless Corporation attached.

Utopian Comment to NTIA Request Dckt No. 090309298-9299-01.pdf 433.38 KB

"Stephens, Cindy (DELEG)" <>

(Late Submission)
Attached are the comments filed by the Michigan Public Service
Commission to the NTIA/RUS joint request for information filed on behalf
of Robin Ancona, Director of the Telecommunications Division. I have
attached a signed PDF version as well as a Word version per the

Cindy Stephens

Telecommunications Division

(517) 241-6063

Comments to NTIA 4-13-09.pdf 96.64 KB
Comments to NTIA 4-13-09.doc 119.5 KB

"Schill, Robert" <>

(Late Submission)
Please accept these comments on behalf of the Hispanic Information and
Telecommunications Network

Should you have any questions please contact:

Contact: Joe Dolan

Office: 646-731-3635


Hispanic Information and Telecommunications Network

Building #292, Suite #211

63 Flushing Avenue, Unit 281

Brooklyn, NY 11205-1078

Rob Schill

Director of Federal Affairs, e-Copernicus

(Executive Director, VTIC)

317 Massachusetts Ave., NE, Suite 200

Washington, D.C. 20002

Direct: 202-292-4604

HITN Comments on NTIA RUS Broadband Stimulus Programs.PDF 868.8 KB

"Kristy Szabo" <>

(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 Sancom, Inc.

Kristy Szabo
On Behalf of Sancom, Inc.

NTIA-RUS Sancom Rules Comments 4 13 09.pdf 362.4 KB

Grant Seiffert

(Late Submission)
TIA letter to U.S. Department of Commerce and U.S. Department of Agriculture on the ARRA "Buy American" provision.

Letter to DOC and USDA on Buy American.pdf 41.65 KB

Association of Public Television Stations

(Late Submission)
Please accept the attached comments.

NTIA Comments 4 13 09.pdf 42.02 KB

Diana Bob for National Congress of American Indians

(Late Submission)
Please see attached.

Broadband Comments NCAI.doc 166 KB
PHX-08-070c FINAL.pdf 227.33 KB
TUL-05-041.pdf 227.11 KB
DEN-07-037.pdf 127.34 KB

Stephouse Networks

(Late Submission)
Attached please find the comments of Stephouse Networks. Please note that this filing is being made at 8:42 pm PDT on April 13, 2009.

Stephouse NTIA-RUS 4-13-09.PDF 711.2 KB

Traverse Technologies, Inc.

(Late Submission)
please see attached file

ACF619F.doc 36 KB
ACF619F.doc 36 KB

Kara Tollett Oakley <>

(Late Submission)

Dear Sir or Madam:

Attached please find the comments of Granite Broadband, LLC signed and
submitted by its President, Franklin Cumberbatch.

If it is possible to acknowledge receipt by email response it would be
greatly appreciated.


Kara Tollett Oakley

NTIA/RUS Comments 040909.doc 100.5 KB

"Schill, Robert" <>

(Late Submission)
Please accept the attached comments from the Advanced Emergency
Communications Coalition on the ARRA NTIA RUS broadband programs.

Should you have any question please feel free to reach:

Richard Taylor

c/o e-Copernicus

317 Massachusetts Ave, NE

Washington, DC 20002


Rob Schill

Director of Federal Affairs, e-Copernicus

(Executive Director, VTIC)

317 Massachusetts Ave., NE, Suite 200

Washington, D.C. 20002

Direct: 202-292-4604

AECC Comments on ARRA NTIA RUS Broadband Programs.PDF 1.11 MB

Mimi Pickering

(Late Submission)
comments attached

ACF7ADB.doc 42 KB

"Mafnas, Joe - Washington, DC" <>

(Late Submission)
Good Morning:

Will the RUS List of Materials be used? We utilize the RUS Buy American
provision in our program to identify domestic and non-domestic equipment
and I have attached a copy of this list. We are currently experiencing a
"tsunami" of new applications to get on the List and I suspect that
these vendors are anticipating that our List may be used to ensure that
any Buy American concerns are addressed. I am asking for a "heads-up"
because I want to prepare myself and our Branch; as I understand it
temporary positions are in play to handle the stimulus but not for
support our listing efforts. The RUS List of Materials would be the most
efficient mechanism to ensure any Buy American concerns are meet because
we have an extensive list of broadband vendors that are already trained
to understand our Buy American provision and any additional requirements
can be efficiently dispatched and screened for compliance (with
additional help). If not, I would like to know so I can tell these
vendors that our List of Materials will not be used, thank you and Happy


Advance Services Div., Technical Support Branch
USDA Rural Development - Utilities Programs

Phone: 202-720-0675, Fax: 202-720-1051

image001.jpg 8.59 KB

Towerstream Corp.

(Late Submission)
Referenced Comments are attached in .pdf format.

Towerstream Broadband Comments.pdf 31.93 KB


(Late Submission)

"Wayne A. Nichols" <>

(Late Submission)

In reference to the telecommunications portion of the Presidents Stimulus
package, I wholeheartedly support a strong, credible application of the
Bill's "Buy American" provision to the broadband program. Lets insure, as
the bill was originally intended, that American jobs are created and
sustained in order to "stimulate" OUR economy. Therefore, I urge you to
award any monies to American companies whose engineering and manufacturing
operations lie here in the USA. Thank you for your consideration. I will be
very interested in your response.

Wayne A. Nichols

504 Doherty Avenue, SE

New Prague, MN 56071

952.223.4653 Home - 651.325.1183 Cell

image001.gif 64 bytes

Jerry Baxley

(Late Submission)
From: Jerry Baxley

RE: Comments regarding grants for broadband.

Executive Statement of Facts.
The United States finds itself at many crossroads at this time in its history.
Certainly the restoration of the economy has to be foremost on the mind of everyone. However, the cross that will light our way to the future is the growth of "affordable, high capacity bandwidth" or broadband across this country.

The time has come to stop thinking of speeds like DSL or ADSL. It is time to be looking at speeds in the 10Mbps and up range, as we are challenged in this stimulus package to implement many practices that will be very bandwidth intensive.

It is time to rethink what we currently call a "network". The network these funds should help fund are "smart networks" that do allow delivery of not only electronic medical records but clearinghouse and medical back office management. This "smart network" should allow for the secure storage of not only electronic medical records, but banking and business records of its subscribers.

It is time the business subscriber got 10Mdps symmetrical bandwidth for less than $500 per month. And at the same time was able to pay a reasonable "per gigabyte" rate for storage.

It is time the residents of any state were able to get not only a minimum of 5Mbps symmetrical affordable, high speed bandwidth for less than $50 per month; but they should also be able to get 250+ HD TV channels for less than $60 a month.

Most important of all, any family anywhere, regardless of economic position should be able to have for themselves or their children, computer access without putting them in a further economic hardship.

This is not outside the realm of the current technological world. It is just out of the realm of incumbent mindsets.

I am attaching a very, very brief synopsis that supports the mindset that "It is cheaper to build a new smart network than it is to fix an old dumb network"


Jerry Baxley
Montgomery, Alabama 36104

~$OP-The United States.doc 162 bytes

Karen R Jackson

(Late Submission)
Comments attached

Commonwealth of VA - NTIA-RUS response.doc 89.5 KB

Sen. Reginald Tate

(Late Submission)
I am in support of this program.

C4K Letter.pdf 59.44 KB

"Joshi, Meena" <>

(Late Submission)
Attached herewith is USTelecom's Comments in the above-referenced
docket. Please accept the attached filing for your records.

Thank you.

Meena Joshi

Law & Policy


607 14th Street, NW, Suite 400

Washington, D.C. 20005

P: (202)326-7273

F: (202)315-3351

NOTE: This message, and any attachments, is intended only for the
above--identified recipient(s). The information contained herein may be
privileged, confidential or proprietary, and its use or disclosure by
other than the intended recipient(s) is prohibited and may be unlawful.
If you have received this electronic communication in error, kindly
delete it without re-publication or printing and notify me immediately.

20090413_USTelecom Comments re NTIA Broadband Stimulus.pdf 84.99 KB

"Haga, Robert" <>

(Late Submission)
The attached were submitted yesterday, and I received a confirmation of
their receipt, but they are inaccessible from NTIA comment website. I
converted them to PDF format for ease of transmission.

Robert Haga

Chief of Staff to Commissioner Chong


505 Van Ness Avenue

San Francisco, CA 94102

(415) 703-3700


California Comments Appendix E 041309 BPrac Matrix.pdf 160.13 KB
California Comments Appendix D 041309 CBTF Mapping Methodology.pdf 901.26 KB
California Comments Appendix C 041309 CETF Proposal Evaluation Template.pdf 49.35 KB
California Comments Appendix B 041309 FinalResT17143CASF2.pdf 314.79 KB
California Comments Appendix A 041309 CETF Public Awareness Messages.pdf 84.88 KB
California_Response_to_NTIA_on_BB_Stimulus_Grants_4-13-09.pdf 1.53 MB

Karyne Jones

(Late Submission)
The National Caucus and Center on Black Aged (NCBA) is submitting comments to the NTIA because we believe that the manner in which the $4.7 billion of funds in the stimulus package allocated for broadband deployment is distributed is critically important for the low-income and minority consumers we represent. Through this Congressionally-approved grant program the NTIA can vastly improve the lives of millions of seniors by expanding access to advanced telecommunications technologies and services.

NCBA NTIA Commentary.doc 37.5 KB

Beth McConnell <>

(Late Submission)
Attached are comments of a coalition of non profit and public interest
organizations. I can be the point of contact for this filing, and my info
is below.

Thank you,

Beth McConnell
Executive Director
Media & Democracy Coalition
2044 S. Darien St., Philadelphia PA 19148
1133 19th St., NW, 9th Floor, Washington DC, 20036
Phone: 267-918-7207
Fax: 509-756-0392

MDC NTIA RUS BB stim comments FINAL.pdf 282.05 KB

Kathy Gates

(Late Submission)
Please see the attachment. These comments are submitted on behalf of the CIOs at the four research universities in Mississippi.

NTIA BTOP and Broadband for Mississippi.pdf 248.56 KB

Sharmain Matlock-Turner

(Late Submission)
April 13, 2009

Broadband Technology Opportunities Program
U.S. Department of Commerce
Room 4812
1401 Constitution Avenue, NW
Washington, D.C. 20230

SUBJECT: Docket No. 090309298-9299-01 Request for Information

To Whom It May Concern:

On behalf of the Greater Philadelphia Urban Affairs Coalition (GPUAC), I am submitting comments on the development of the Broadband Technology Opportunities Program (BTOP). GPUAC is pleased that the Recovery Act appropriated $4.7 billion in funding to the National Telecommunications and Information Administration (NTIA). This funding will be used to develop and expand broadband services to unserved and underserved areas and improve access to broadband by public safety agencies.

Now celebrating our 40th year of service, GPUAC is committed to improving the lives of working families in the Philadelphia region. GPUAC’s mission is to unite government, business, neighborhoods, and individual initiative to improve the quality of life in the region, build wealth in urban communities, and solve emerging issues. As a fiscal sponsor, we represent a coalition of more than 90 grassroots organizations, with over 500 employees serving tens of thousands of residents throughout Philadelphia, Southeast Pennsylvania, New Jersey and Delaware. As an organization that drives change, GPUAC offers programs that build wealth in our communities and improve the life chances of youth and young adults.

Our primary concern with the allocation of all of the funding provided through the Recovery Act is that it will not be invested equally in all communities. We are especially concerned about urban neighborhoods that have been disenfranchised and faced with unemployment rates already in the double digits. The following comments regarding the development of the BTOP is in response to this concern.

1. Question 4.c. Establishing Selection Criteria for Grant Awards: The Recovery Act establishes several considerations for awarding grants under the BTOP. In addition to these considerations, NTIA may consider other priorities in selecting competitive grants.
How should the BTOP prioritize proposals that serve underserved or unserved areas?

GPUAC Response: In prioritizing proposals that serve underserved or unserved areas, the BTOP should prioritize neighborhoods, especially in urban areas, where a majority of residents are not accessing Broadband services in their homes. Looking at who currently is subscribing to broadband services demonstrates that access to broadband contributes to the digital divide.

Studies have shown a substantial discrepancy in household income and access to broadband. From 60 to 85 percent of homes with incomes earning over $100,000 have broadband connections compared to 10 to 25% of homes with incomes below $25,000 (Horrigan, J.B, 2008 & Kohlenberger , 2007). In addition to the socioeconomic digital divide, there is a racial divide. While two-thirds of whites (67%) have internet access, less than half of African Americans (40%) and slightly over one-third of Latinos (38%) are able to go online from their homes.

2. Question 5. A. Grant Mechanics: The Recovery Act requires all agencies to distribute funds efficiently and fund projects that would not receive investment otherwise.
What mechanisms for distributing for distributing stimulus funds should be used by NTIA and USDA in addition to traditional grant and loan programs?

GPUAC Response: Given our concern that Recovery Act funds be invested in disenfranchised communities, GPUAC believes that nontraditional mechanisms for distributing funds should be used by NTIA and USDA. It is not likely that the Recovery Act dollars will be invested equally in all communities, if our traditional, bureaucratic pipelines for distributing government funds are used. The individuals left out will be those who need these funds the most.

We believe that NTIA and USDA, as well as all government agencies with authority over Recovery Act funds, should work with nonprofit, intermediary organizations that have the expertise and capacity to infuse funds into struggling neighborhoods. Strong intermediaries, such as GPUAC, have the flexibility to expeditiously distribute funds, the necessary connections to leaders in each neighborhood, and a proven track record of awarding, monitoring and evaluating government contracts. We can ensure that these funds are allocated to distressed neighborhoods.

3. Question 6.b. Grants for Expanding Public Computer Center Capacity. The Recovery Act directs that no less than $200,000,00 of the BTOP shall be awarded to grants that expand public computer center capacity, including at community colleges and public libraries.
What additional institutions other than community colleges and public libraries should be considered as eligible recipients under this program?

GPUAC Response: First and foremost, GPUAC strongly supports the increased funding to expand public computer center capacity. As discussed above, we are concerned about the widening digital divide between income groups and race. Internet users who depend on “third places” for access – places other than home or work – are disproportionately likely to live in households earning less than $30,000. In addition, one-fourth of African-Americans and Latinos access the internet from a “third place.”

In determining other places, we urge NTIA to consider nonprofit organizations that work with families from low-income and disenfranchised communities, including churches and other faith-based organizations. Many nonprofit organizations located in these neighborhoods have the public space and infrastructure to provide these computers to their neighbors. In addition, the community members are likely to be receiving support from these organizations or the organizations have the ability to reach-out to low-income families that currently have no access to computers.

In conclusion, thank you for the opportunity to provide comments on the BTOP. GPUAC strongly believes that this program will have an impact on increasing access to broadband connections and narrowing the digital divide.


Sharmain Matlock-Turner
President & CEO

GPUAC Broadband Technology Opportunities Program Comments.doc 90.5 KB

John Wahba

(Late Submission)
Please include us in your email list. Our email is:
Also , 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

Contact phone : 203 979 2700
or email :

ACF6C60.mht 163.13 KB
ACF6C61.doc 37.5 KB
ACF6C62.pdf 379.84 KB

"Salons, Deborah J." <>

(Late Submission)
Attached hereto are the comments of the Broadband Diversity Supporters.
Please confirm receipt.

Deborah J. Salons, Esq.
Drinker Biddle & Reath LLP
1500 K Street, NW
Washington, D.C. 20005-1209
(202) 354-1340 (direct)
(202) 842-8465 (fax)

Disclaimer Required by IRS Rules of Practice:
Any discussion of tax matters contained herein is not intended or written to be
used, and cannot be used, for the purpose of avoiding any penalties that may be
imposed under Federal tax laws.
This message contains information which may be confidential and privileged.
Unless you are the intended addressee (or authorized to receive for the intended
addressee), you may not use, copy or disclose to anyone the message or any
information contained in the message. If you have received the message in error,
please advise the sender at Drinker Biddle & Reath LLP by reply e-mail and
delete the message.
Thank you very much.

BDSCommments.pdf 4.08 MB

Broadpoint, Inc.

(Late Submission)
Broadpoint, Inc.'s comments are attached. Please contact Russell Fox, Counsel for Broadpoint, Inc., at 202-434-7300 with any questions concerning this filing.

NTIA Comments 4.13.2009.pdf 49.73 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 entrpreneurs...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 addressed in the attachments provided.

CCNComments on NTIA-RUS questions ARRA2009Broadband Initiatives.pdf 178.5 KB
What_is_Digital_Inclusion_4-09.pdf 29.71 KB

ViaSat, Inc.

(Late Submission)
Please see attached pdf document.

ViaSat Comments to NTIA RUS.pdf 114.5 KB

The Rural Carriers

(Late Submission)
The following comments are submitted on behalf of the 58 rural incumbent local exchange carriers (Rural ILECs) and the centralized equal access providers (CEA Providers) listed therein.

Rural Carriers NTIA - RUS Comments.pdf 901.77 KB

"Gordon Caverly" <>

(Late Submission)
What role and support can the telecommunications design and engineering
firms in this country position themselves for in support of this
evolutionary process?

Gordon Caverly, RCDD, CWNA

Regional Vice-President

Mid-State Consultants

810-621-5656 (work)

810-845-6999 (cell)

Gordy Formal June 05 cropped

image001.jpg 2.07 KB
image001.jpg 2.07 KB


(Late Submission)

Summary includes:

Executive Summary | Preamble & Abstract | FCC Broadband Definitions | Document Summary
Municipal Wireless History | 3.65GHz WiMAX | 3.65GHz WiMAX - Municipal Operations
ARRA - Broadband Benefits | Digital Access, Inclusion & Literacy | Public/Private Partnerships | Private Sector Investment | Job Creation | Summary of BTOP Public Meetings | Document Conclusion | Addendum A - Response to National EBS Association Comments Regarding Use of the 2.5GHz EBS Band to Achieve BTOP Initiatives

(Original -

BTOP RFI Sectional Links - Table of Contents.doc
(Original -


"Response to National EBS Association Comments Regarding Use of 2.5GHz EBS-Based Wireless Broadband Facilities to Achieve BTOP Initiatives"

"The 2.5GHz Educational Broadband Service - Rural Telecommunication and Energy Cooperatives vs. Urban and Suburban Markets"

"The Backwards Lease"

Direct Links to Addendum A
Word -


UPDATED BTOP RFI Sectional Links - Table of Contents.doc (attached)

Graphics include:
Current Sprint, Clearwire and FCC 2.5ghz EBS Lease Business Model.gif

Proposed NTIA, RUS 2.5ghz EBS Lease/Operating Business Model.gif

Reference: NEBSA Comments (

Brad Bowman

ACF76D0.doc 65.5 KB
ACF76D1.pdf 180.53 KB
ACF76D2.doc 261 KB
Current Sprint Clearwire and FCC 2.5ghz EBS Lease Business Model.gif 31.28 KB
Proposed NTIA RUS 2.5ghz EBS Lease Business Model.gif 67.53 KB

Dean R. Brenner

(Late Submission)
Please see attached comments.

Comments to NTIA & RUS on Stimulus Final.pdf 126.28 KB

Teresa A. Gilchrist

(Late Submission)
Please ensure that funding opportunities will filter down to grassroot organizations. We are a non-profit 501c3 organization that trains the underemployed and unemployed population of the Washington, DC area in the skill of data installation. This trade directly relates to the type of jobs the Broadband grant should generate.

Once again please ensure small grassroot organizations can participate. Please ensure ex-offenders can participate. Employers are restricted from hiring qualified ex-offenders because of insurance refusal to grant employers liability insurance if they hire ex-offenders. The skill to perform cable lines is not complicated. We can give many employment and many people access to the internet.

Attached is our company brochure and a brief abstract about Building Inside Out. Thank You...Teresa Gilchrist

BuildingInsideOutBrochure[1].doc 224.5 KB
BIOGeneralFinal[1].doc 33 KB

"Dave Duncan" <>

(Late Submission)

Attached are the comments of the Iowa Telecommunication Association in
Docket No. 090309298-9299-01 for filing.

Dave Duncan, CAE


Iowa Telecommunications Association

2987 100th Street

Urbandale, IA 50322


image001.gif 92 bytes
ITA Comments 4-13-09 final.pdf 55.17 KB

"Fred Campbell" <>

(Late Submission)
Attached is an electronic copy in Word format of comments filed by the
Wireless Communications Association International, Inc., which were also
submitted today in pdf format via the NTIA website. Please let me know
if you have any questions.

Best regards,


Fred Campbell, President & CEO
Wireless Communications Association International
1333 H Street, Suite 700 West
Washington, DC 20005
t: 202-452-7823
m: 703-470-4145

WCAI Comments to NTIA-RUS on ARRA 04.09.09 FINAL.doc 97 KB

David M. Brown

(Late Submission)
Comment Attached.

WildBlue_HNS_Intelsat_NRTC Comments to NTIA_RUS RFI.pdf 47.37 KB

Vincent T Jordan <>

(Late Submission)
Please accept the attached comments for your consideration.

Best regards,

Vince Jordan | President/CEO
p: 720.204.2934 | skype: vtjordan |
1880 Industrial Circle Ste. C | Longmont, CO 80501
Live to Ride - Ride to Live
It's the Journey, not the destination...Journey well

CONFIDENTIALITY NOTE: Information in this e-mail and its attachments is
confidential and/or proprietary. If you are not the intended recipient, be
aware that any use, dissemination or printing is prohibited. If you
received this e-mail in error, please notify the sender and delete this copy
and reply from your system. Thank you!

image.jpg 2.81 KB
RidgeviewTel - NTIA Comments.doc 33 KB

Catherine Melchert, President

(Late Submission)
Please refer to the attached letter.

Catherine Melchert, Village of Bartlett.pdf 75.54 KB

"Bill Triplett" <>

(Late Submission)
Many thanks for your work on this project. Please let me know if we can be
of help.

Bill Triplett, Sr. Advisor to the Federal Co-Chairman

Office of the Federal Co-Chairman -- Delta Regional Authority // //


DRA -- Comments -- NTIA-RUS -- Final.doc 115 KB