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

H. Samuel Orth

(Late Submission)
Please see attached cover letter (Ohio cover ltr) and response document (Ohio RFI response).

AttachmentSize
Ohio cover ltr.pdf 818.58 KB
Ohio RFI response.doc 125.5 KB

Ann Bishop

(Late Submission)
Please see attached comments from the Graduate School of Library & Information Science at the University of Illinois at Urbana-Champaign.

AttachmentSize
FCCBroadbandComment.pdf 205.89 KB

Mayor Mark Hipsher

(Late Submission)
To Whom It May Concern:

Please see the attached comments below in the file attachments. Thank you so much for your time and consideration.

Thank you,
Mayor Mark Hipsher
865-828-3513

AttachmentSize
Connected Tennessee Computers 4 Kids Comments.doc 25.5 KB

Andre J. Imparato

(Late Submission)
AAPD comment is attached in Word.

AttachmentSize
AAPD COmments to NTIA re Broadband 4-13-09 FINAL.doc 190 KB

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

(Late Submission)


>>> "Joshi, Meena" 3/16/2009 3:41 PM >>>
On behalf of USTelecom, the attached letter is mailed via the US
Postal
Service and is also being sent to you electronically as a courtesy.



Meena Joshi
Administrative Assistant

Law & Policy

USTelecom

607 14th Street, NW, Suite 400

Washington, D.C. 20005

mjoshi@ustelecom.org

P: (202)326-7273

F: (202)315-3351

www.ustelecom.org

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.






AttachmentSize
Letter to NTIA_RUS re Broadband Stimulus .pdf 115.55 KB
Letter to NTIA_RUS re Broadband Stimulus .pdf 115.55 KB

"Eric Jensen" <eljensen@comcast.net>

(Late Submission)
Barbara Brown:

Please replace the previous submission with this revised version of the National Tribal Telecommunications Association's recommendations for the broadband stimulus program.

I would like to submit the attached statement on behalf of the National Tribal Telecommunications Association, comprised of the only 8 Indian Tribes (from 563 tribes) that have created their own regulatory telecommunications companies. NTTA is deeply concerned that the Broadband stimulus monies will not reach the communities that need broadband (and voice dialtone) connectivity the most: Indian Tribes. Included in our submission are specific positive recommendations for solutions that will balance out the imperative of the Department of Commerce, the Federal Communications Commission and the Department of Agriculture to reach the widest population in rural areas with communities that will never benefit from market force or private investment.

If you have any questions, please do not hesitate to contact me.

With Best Regards,

Eric Jensen
Policy Counsel
National Tribal Telecommunications Association, and,
CEO
Four Horizons Development Company
First Tribal Liaison Officer for the Federal Communications Commission
519 Tennessee Ave
Alexandria, VA 22305
(703) 683-3742
pcs: (703) 868-8325


AttachmentSize
NTTA Broadband Stimulus funding comments.dot 46.5 KB
NTTA Broadband Stimulus funding comments.dot 46.5 KB

"S. Derek Turner" <dturner@freepress.net>

(Late Submission)
Please find the attached Comments of Free Press, as submitted April 13th, 2009.

[note: these were submitted via the Web interface earlier today, but do not appear to have been received]

S. Derek Turner
Research Director
Free Press
o: 202.265.1490 ext. 28 
c: 650.201.6069


reform media. transform democracy.





AttachmentSize
Free Press_NTIA Formal Comments.pdf 302.64 KB

Julius Hollis

(Late Submission)
Please see attached.


Comments of the Alliance for Digital Equality


In response to your request for comment published on March 10, 2009, the Alliance for Digital Equality wishes to offer its perspective on the disposition of broadband funds provided by the ARRA with special focus on the issue of broadband adoption.

The Alliance for Digital Equality (ADE), a non-profit organization registered in the state of Georgia, was established two years ago as an advocate for communities that have not yet realized the full benefit of the information age revolution. In fulfillment of that mission, we seek to educate consumers about the benefits of broadband. With the help of local Digital Empowerment Councils in major American cities, we also act as a bridge between minorities and other underserved Americans and public policymakers on issues related to information technology.

Broadband Internet access is a transforming technology that can open the door to economic opportunity and individual empowerment, especially for minority communities that have often been the last to benefit from societal progress. Like electricity and telephone service before it, broadband is fast becoming an essential utility. Those who cannot or do not embrace it will lose out on vast opportunity. For those who are already lagging behind economically and socially, lack of broadband will tend to bury them even more firmly at the bottom of American society.

Thus, ADE enthusiastically welcomes the commitment of the new administration and the Congress to spread broadband throughout America and to designate a substantial portion of the economic stimulus package to programs that support both the deployment and adoption of broadband.

ADE’s Perspective on the Current Broadband Landscape

As we survey the broadband landscape, we see a mixture of good and bad. The rapid deployment of wireline network infrastructure by the private sector means that more than 90 percent of Americans live in communities where service is available, often from multiple providers, and some 60 percent of American households are currently wired to broadband. Wireless networks also are connecting more Americans every day to broadband Internet service, and minorities have readily embraced the wireless option. Although the digital divide between white and non-white Americans persists, it has narrowed significantly in recent years thanks to continued deployment and, especially, to declining prices. Narrowing this divide so that all Americans enjoy broadband service is ADE’s highest priority. To that end, we have consistently warned policymakers to avoid policies that would tend to add to the cost of broadband services and jeopardize recent progress by reducing the ability of lower-income Americans to afford broadband. Indeed, in light of the current recession, policies that boost costs could well force some lower income Americans to give up recently-acquired broadband service.

Despite the upward trend in broadband adoption, nearly 43.7 million households in urban America are without broadband, according to the US Census Bureau. Substantial pockets of rural America also lack access to broadband service especially where lower population density and greater geographic distances between potential subscribers erode the economic case for deployment. The present economic downturn could have a long term adverse impact on universal adoption by a large number of Americans to sign up for broadband service even where it is available. When asked by the Pew Foundation why they are not using broadband, more than half of non-Internet users and dial-up users said they aren’t interested, are too busy, or simply don’t want to switch. More than 15 percent of other hold outs said it was a waste of time, too difficult, or they were too old. Many of the 9 percent of adults who rely on dial up for broadband access said price was an important obstacle. Indeed, Pew data shows that lower income Americans make up a disproportionate number of those who do not have broadband service.

In light of this data as well as our ongoing consultations with community leaders around the country, ADE has developed a policy agenda to accelerate the spread of broadband in both currently unserved and underserved communities. While many of these policy proposals are outside the specific scope of the Broadband Technology Opportunity Program to be established by the NTIA or grants and loans to be provided by RUS, we believe they offer important context as you develop program criteria and also give texture to ADE’s specific comments below. Therefore, we have attached our broad policy recommendations as an informational resource.

ADE’s Specific Recommendations

Wide deployment of broadband infrastructure means that more than 90 percent of Americans have the opportunity to subscribe to broadband, but only about 60 percent of American households have in fact exercised the broadband option. Data indicates that low awareness of broadband benefits is the root cause of this gap. To close that gap, ADE urges NTIA and RUS to place a high priority on fulfilling ARRA’s mandate to “provide broadband education, awareness, training, access, equipment and support” to programs that promote greater use of broadband. Such digital literacy programs will stimulate adoption by familiarizing participants with technology and raising awareness of the benefits of broadband service.

We also note the Congressional directive to support organizations and agencies that seek “to facilitate greater use of broadband service by low-income, unemployed, aged, and other vulnerable populations.”

These types of targeted programs will directly address the concerns of those who now report little or no interest in broadband. Programs that directly deliver economic, educational and health opportunities will also spur adoption. Therefore, ADE encourages NTIA and RUS to support programs to introduce Americans to information technology and the Internet, provide training in IT skills, hands on experience with Broadband, and education about online safety. We also encourage funding for telemedicine programs that use broadband to deliver health care services and remote monitoring and support for programs that remotely connect individuals to academic opportunities and job training. Such tangible demonstrations will stimulate adoption among those Americans who are not subscribing to broadband because they do not fully appreciate its ability to improve their lives.

Of course, digital literacy alone will not deliver broadband for those who cannot afford to buy a computer and/or subscribe to a broadband service. Demonstrating the value of broadband will persuade some Americans that broadband is important enough to be included in their budget; they will discover that they can “afford” it. But, others simply lack the means. To address affordability issues, targeted programs that provide broadband access through community broadband centers in public locations such as libraries, schools, other government buildings or non-profit organizations merit consideration. We also encourage support for programs that provide free or low-cost computers and Internet connections to lower income Americans. In addition, stimulus program funds might be directed to the Federal Lifeline/Linkup program to provide discounts on broadband service for low-income Americans.

Programs that reduce barriers to adoption will accelerate progress toward America’s national goal of universal broadband by addressing the largest portion of those who do not currently enjoy broadband at home. However, these programs will not help the smaller number of Americans who live in communities where the network infrastructure does not deliver broadband service.

Thus, NTIA and RUS also must direct significant funding for programs that promote new deployment in areas where broadband connections are not now available. We believe part of the answer is so-called demand aggregation programs through public-private partnerships and local economic development authorities. By concentrating a large number of potential subscribers, demand aggregation can successfully build an economic case that will persuade network providers to deploy the necessary infrastructure.

In other instances, direct lending to service providers and grants to stimulate deployment may be the only way to overcome the financial barriers that discourage private investment in currently unserved areas. Importantly, we believe such direct deployment funding should be limited to those areas where broadband service is not currently available. Additionally, direct deployment funding should be limited to one provider in a community to increase the likelihood that the service will be economically sustainable over the long term. In our view, the government should not provide support for two providers in the same area as such “overbuild” funding might jeopardize long-term sustainability by reducing the number of some subscribers available to support the new service. We believe that every American in the 21st century should have equal access to affordable and reliable broadband, which will enhance the quality of life through the delivery of vital e-services in communities and particularly underserved and un-served neighborhoods across the United States.

Respectfully submitted,

Alliance for Digital Equality

Appendix I


ALLIANCE FOR DIGITAL EQUALITY
Policy Agenda to Put Broadband in Every Home

National Policy

Build on initiatives funded in the stimulus bill through a combination of adoption and deployment strategies as identified below

1. Promote broadband deployment and adoption by resisting, reducing or eliminating taxes and policies that raise the cost of broadband service and hurt consumers; embrace policies that support and encourage investment in IT and broadband infrastructure.

2. Expedite development of a national broadband map and supporting data collection to guide broadband expansion strategies in underserved communities.

3. Provide digital opportunity grants and financial assistance to support local digital literacy and technology opportunity programs (TOPs), especially in minority and rural communities, and enable broadband adoption by those who cannot afford home broadband on their own.

4. Encourage broadband adoption by expanding the use of information technology and online services in sectors such as health care, education, and e-gov to raise the value of residential broadband.

5. Launch a public education campaign that raises awareness in minority, rural and underserved communities of the educational, economic, social and health care opportunities it provides.

6. Update the Universal Service Fund to provide direct support for build-out of broadband infrastructure in rural America and other unserved and underserved communities.


State and Local Policies

1. Initiate statewide broadband mapping and community IT-needs assessment programs to identify priority areas for broadband promotion and for training programs to build digital literacy and computer skills.

2. Develop public-private partnerships to address barriers to computer ownership and residential broadband adoption, and also to encourage local economic development strategies that stimulate broadband deployment by aggregating demand and developing “anchor” customers for advanced network services.

3. Provide subsidies, grants and computer recycling to provide low-cost computers and/or other broadband-capable devices including netbooks and smart phones to K-12 students from low-income households.

4. Incorporate computer literacy and digital skills training into school curriculum beginning in early elementary school. Establish grade-appropriate computer literacy testing as part of promotion requirements.

5. Establish community-based learning centers in underserved communities to develop computer literacy and proficiency in core office software programs and to demonstrate the value of broadband. Leverage this training to develop an IT-ready workforce that attracts job-creating businesses to minority communities.

6. Set up computer and Internet access sites in public venues such as libraries, schools, churches and government buildings in underserved communities to provide broadband for those who do not have service at home.

7. Promote broadband adoption by removing regulatory and other service barriers, including local video franchise licensing and excessive fees for rights-of-way access, that raise subscription costs to consumers.

AttachmentSize
ADE NTIA ARRA Comments 4 13 09 FINAL.doc 40 KB

W. Kenneth Ferree and Barbara Esbin

(Late Submission)
See attached file

AttachmentSize
041009-broadband-stimulus-filing.pdf 37.9 KB

"Donald Evans" <evans@fhhlaw.com>

(Late Submission)
Dear Sirs and Mesdames - Attached in Word format is the comment of
McCotter Hotel Operations, Inc. in the referenced ARRA Docket.



Donald J. Evans

Fletcher, Heald & Hildreth

1300 N. 17th St.

11th Floor

Arlington, VA 22209

703-812-0430 (phone)

703-812-0486 (fax)






AttachmentSize
McCotter NTIA Comments (00054723).DOC 30.5 KB

"KRUFKY Kevin" <Kevin.Krufky@alcatel-lucent.com>

(Late Submission)
Alcatel-Lucent's comments are attached. Please contact me if you have
any difficulty with the document.

Kevin Krufky
Legislative Counsel
Global Government & Public Affairs
Alcatel-Lucent
1100 New York Avenue, N.W.
Suite 640, West Tower
Washington, DC 20005
Direct: 202-312-5914
Mobile: 202-258-9535
Fax: 202-842-2817
Kevin.Krufky@Alcatel-Lucent.com


Note: This message, and any attachments, is intended only for the
recipient(s) identified above. The information contained in this
message may be privileged, confidential or proprietary, and its use or
disclosure by other than intended recipient(s) is prohibited and may be
unlawful. If you have received this message in error, please delete it,
and do not distribute or retain a copy of it.





AttachmentSize
Comments of Alcatel-Lucent.NTIA-RUS.doc 176.5 KB

Eric Swanson

(Late Submission)
Please find attached, a letter from the Director of the Michigan Department of Information Technology and the Department's responses to the Request for Information regarding the NTIA and RUS Broadband Development Programs. Thank You for the opportunity to respond.

AttachmentSize
Michigan_RFI Responses_4_13_2009.pdf 617.79 KB

"Berner, Cynthia" <CBerner@wichita.gov>

(Late Submission)
I would like to be added to the correspondence list for the BTOP.

I would also like to have connectivity requirements for Webcast
connectivity for future meetings. I was unable to get any audio/video
from today's session and found that the streaming text worked only
sporadically so ended up relying heavily on refreshing the transcript.

Thanks.

Cynthia Berner Harris, Director of Libraries
Wichita Public Library
223 S Main, Wichita KS 67202
316-261-8520 (v) 316-219-6320 (f)
cberner@wichita.gov

<>
Please consider the environment before printing.






AttachmentSize
ole0.bmp 4.1 KB
ole0.bmp 4.1 KB

William Wells, Jr.

(Late Submission)
Broadband Technology Opportunities Program
United States Department of Commerce
Room 4812
1401 Constitution Avenue, N.W.
Washington, D.C. 20230

TO WHOM IT MAY CONCERN:

We are pleased to respond to NTIA, U.S. Department of Commerce; Rural Utilities Service, U.S. Department of Agriculture's joint request for information relative to the American Recovery and Reinvestment Act of 2009.

Attached please find an MS Word document which contains responses to the preliminary questions. We are excited about these opportunities, and appreciate the opportunity to provide input at this stage of the process.

We look forward to submitting several innovative, direct and partnership proposal submissions for future NTIA consideration.

Respectfully Submitted,

William Wells, Jr.
True Broadband Networks, LLC.
Managing Partner
1105 E. 31st Street, Ste. G
Kansas City, MO 64108
816.234.8783
wwells@truebtv.com
www.trueh2o.com

AttachmentSize
Public Comment-WW.docx 215.26 KB

Lisa Feldner

(Late Submission)
Please see comments attached.

AttachmentSize
State_of_ND_NTIA_response.pdf 115.45 KB

"James McConnaughey" <jmcconnaughey@ntia.doc.gov>

(Late Submission)
Attached is an ex parte for a meeting held on March 12 with Apex
(meeting description plus Apex attachments).



AttachmentSize
apex mapping meeting_1.doc 23.5 KB
Mapping Presentation to NTIA 12MAR09 (Rev 1.0).pdf 5.1 MB
Charlotte -Tract & Blocks.xlsx 27.14 KB
Charlotte County - Tracts.xlsx 11.16 KB

"Class, Edgar" <EClass@wileyrein.com>

(Late Submission)
Attached please find the comments of Nevesem, Inc. in Docket No.
090309298-9299-01.



Edgar Class
Wiley Rein LLP
1776 K Street NW
Washington, DC 20006
t: 202.719.7504
f: 202.719.7049
eclass@wileyrein.com


NOTICE: This message (including any attachments) from Wiley Rein LLP may constitute an attorney-client communication and may contain information that is PRIVILEGED and CONFIDENTIAL and/or ATTORNEY WORK PRODUCT. If you are not an intended recipient, you are hereby notified that any dissemination of this message is strictly prohibited. If you have received this message in error, please do not read, copy or forward this message. Please permanently delete all copies and any attachments and notify the sender immediately by sending an e-mail to Information@wileyrein.com.



AttachmentSize
Comments of Nevesem Inc.pdf 208.83 KB

Traverse Technologies, Inc.; Miles R. Fidelman, Director of Government Programs

(Late Submission)
Please see attached file.

AttachmentSize
TraverseTechnologies.doc 36 KB
TraverseTechnologies.doc 36 KB

"Johns, Cheryl M." <Cheryl.Johns@sba.gov>

(Late Submission)




Cheryl M. Johns

Assistant Chief Counsel, Telecommunications

Office of Advocacy

U.S. Small Business Administration

409 Third Street, S.W.

Washington, DC 20416

Phone (202) 205-6949

Fax (202) 205-6928

Email: cheryl.johns@sba.gov

---

In order to receive:

Advocacy's News Releases via email; Advocacy's monthly newsletter "The
Small Business Advocate" via email; Advocacy's Small Business Research
and Statistics via email; Advocacy's Regulatory Communications via
email; Visit http://web.sba.gov/list/ to
join the lists. To easily comment on important proposed regulations
visit http://www.sba.gov/advo/laws/law_regalerts.html







AttachmentSize
Advocacy-SBA Comments on NTIA RUS Recovery Act Programs 04-09.doc 84 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 Atkins Telephone Company.

Kristy Szabo
On Behalf of Atkins Telephone Company
605-995-1786




AttachmentSize
Atkins Telephone - NTIA-RUS 4 13 09.pdf 749.08 KB

Adam T. Drobot

(Late Submission)
See Attached File


In the Matter of:

Joint National Telecommunications and Information Administration- Rural Utilities Service Request for Information )
)
)
)
)
)
)
)

Docket No. 090309298-9299-01




COMMENTS OF
TELCORDIA TECHNOLOGIES


Telcordia Technologies (Telcordia) hereby submits comments to the National Telecommunications and Information Administration (NTIA) and the U.S. Department of Agriculture (USDA) in the above-captioned proceeding. Telcordia is a global leader in the development of fixed, mobile, and broadband communications software and services. Our products and services enable communications service providers, enterprises, suppliers, and government entities to successfully deploy innovative and advanced services across the full spectrum of communications and information networking. Since our beginnings as part of Bell Labs, Telcordia has been acknowledged for the breadth and depth of our technology and expertise and for our unique contributions as leaders and coordinators across the industry. Telcordia engineers and consultants have supported private and public entities world-wide in deploying high-performing and reliable communications infrastructure. Telcordia also has extensive experience managing major programs and building and operating real-time information and transaction systems. Telcordia has been at the forefront of innovation in ADSL (Asymmetric Digital Subscriber Line), ATM/SONET (Asynchronous Transfer Mode / Synchronous Optical Network), AIN (Advanced Intelligent Network), optical networking/WDM (Wave Division Multiplexing), wireless (3/4G, cellular, mobility), and security. Telcordia experts hold leadership positions in the industry’s most respected standards bodies and forums including ATIS (Alliance for Telecommunications Industry Solutions), ITU (International Telecommunication Union), TIA (Telecommunications Industry Association), TMF (TeleManagement Forum), IEEE (Institute of Electrical and Electronics Engineers), and OMA (Open Mobile Alliance Broadcasting).
Telcordia shares the goals announced in the American Recovery and Reinvestment Act of 2009 (ARRA) to ensure the speedy deployment of cutting-edge technologies, and to nurture a vibrant and growing high-technology sector based in the United States. We realize the risks inherent in administering an expansive grant program on a tight timetable as well as the necessity of ensuring that lasting benefits are realized with deployments that are scalable, secure, and robust and do not quickly become obsolete. At the same time, we believe that proactive steps can be taken to ensure that the BTOP and RUS programs deliver their promised benefits to the American people in a timely, efficient, and cost-effective manner. We offer our comments and technical expertise as NTIA and USDA develop rules and procedures to implement the Broadband Telecommunications Opportunity Program (BTOP) and Rural Utilities Service (RUS) grants as statutorily established in the ARRA.




DISCUSSION
I. Risk Mitigation and Security
The acquisition, installation, configuration, and systems integration of billions of dollars of new telecommunications equipment and software poses both exciting challenges and significant risks. Ensuring that the monies are spent promptly and wisely and that true and measurable benefits are returned requires a well-defined program with clear rules for participation and oversight processes which are proactive, light-weight, and transparent. A successful program will generate both a far greater number of qualified proposals than current funds can support, and also a wide range of very diverse proposals. Adequate personnel are required with the necessary expertise, experience, and program management skills as well as efficient procedures and systems for the rapid review, prioritization, and oversight of projects. A well-designed program will reduce risks via: the adequacy of the grant application process in soliciting critical information for evaluation and selection; the timeliness of the selection process in yielding transparent and uncontested priorities; and the effectiveness of monitoring procedures in guiding the rollouts and overseeing tax payer funds.
Creating trust in the expanding broadband infrastructure by ensuring security, privacy, and assurance is another critical element of risk reduction. The benefits of broadband access and services can only be achieved if citizens, businesses, and organizations trust the network, services, and applications. Broadband deployments must safeguard users’ privacy; insure the security of information, applications, and transactions; protect against denial-of-service and other attacks; and provide access controls so that sensitive digital information is available only for necessary and authorized use. Our expanding national broadband network will only be as strong as its weakest link, so it is critical that security, privacy, and assurance requirements be rapidly developed, uniformly adopted, tested, and certified to ensure trust in the infrastructure.
Telcordia recommends that the NTIA and RUS address the following factors in the applications, review, selection, and monitoring of the BTOP and RUS grant programs. Attention to these factors will help ensure effective deployments that fully deliver promised benefits:
• End-to-end planning for efficient operation, maintenance, upgrades and capacity enhancements across the lifecycle of the infrastructure;
• Ease of use so that network infrastructure will enable institutions and citizens in setting up services, accessing applications and connecting devices simply and easily;
• Cost-effective operations support systems to maintain network infrastructure proactively to ensure service quality and avoid stranded capital;
• Flexibility and evolvability so that the infrastructure can expand and scale to meet new and growing needs and to support emerging technologies, particularly in edge devices and applications;
• Robust and fault-tolerant network management systems and governance policies to enable rapid identification of faults and restoration of services; and
• End-to-end security and privacy methods and practices to reduce vulnerabilities, defend against intrusions, and ensure the security of transactions and the privacy of information.

II. Broadband Mapping
Much of the debate on broadband infrastructure capability, policy, and goals in the U.S. suffers from a lack of consistent and objective data and the Broadband Mapping program will go a long way towards redressing this critical need. We urge the NTIA and RUS to also include appropriate measurement and analysis components in their grant programs which will provide a foundation for a consistent, nation-wide broadband mapping program capable of informing both public policy makers and consumers. Without such metrics and analytics, it will be harder to efficiently determine compliance, assess progress towards societal goals, and quickly determine the appropriate course corrections that are virtually certain in such a large and complex undertaking. The question of providing meaningful broadband access extends beyond the ‘last mile’ connectivity issue to include appropriate interconnection between a broadband access provider and the wider telecommunications infrastructure including network interconnection, backhaul infrastructure, metropolitan and regional network capability, and core network bandwidth, and it is important that these issues be included in the mapping effort.
To support nation-wide objectives, data collected across the states must be consistent and comparable. A coherent, nationwide, dynamic picture of broadband availability, adoption, usage, and affordability is vital. By far the most cost effective way to do this is to establish standard data collection requirements, systems and procedures once that all states can adopt. Without appropriate coordination and consistency at the national level, 50 individual efforts are likely to lead not only to a fragmented and incomplete view of broadband in the U.S., but also to significantly greater total costs as individual states design separate approaches and methodologies.
In particular, Telcordia recommends the following for the broadband mapping effort.
• Include on-line data reporting requirements for all service providers and government entities that are not only practical and cost effective, but also adequate in terms of comprehensiveness and level of detail. The effort provides a unique and valuable opportunity to streamline, reduce, and coordinate reporting requirements on service providers of all types.
• Data collection should count not only the ‘pipes,’ but also the traffic levels and service types that flow through them. Reliable and accurate, data will map the availability, usage, quality, and costs of broadband, across all broadband technologies (wired, wireless, satellite, broadband over power line) and both upstream and downstream.
• The metrics and analysis system should include capability for processing the raw metrics information to create synthesized performance indices. These indices will enable consumers, business owners, service providers, and policy-makers to easily assess the status of available broadband infrastructure and its performance and make relevant comparisons.
• A publically-accessible information repository would make information available for consumers and businesses to create value-added linkages (mash-ups) with appropriate security and privacy safeguards for citizens and organizations. It is abundantly clear that very rapid change is a defining feature of broadband applications, devices, and technologies and we urge the NTIA and RUS to use automated and dynamic systems that provide up-to-date statistics and information. The data repository will enable modeling, forecasting, and analysis of the data to support identification of success factors and lead to improved decision making and advances in broadband deployments over time.
• The broadband map and metrics collection should be based upon an agreed-upon set of terminology, identifiers, and standard descriptions for broadband telecommunications equipment and services. This common set of terms and information will not only support uniform collection of data for the broadband map, but will also serve as an important resource for streamlining operations and integration across the broadband deployments.

III. Best Practices Clearing House
To make the most of the available resources for broadband deployment under the ARRA, the NTIA and RUS should ensure that current deployments are able to fully leverage the lessons learned from the past. There is ample opportunity to significantly shorten the learning curve and improve the successes of such deployments via the identification and dissemination of best practices. This in turn will deliver substantial savings in time and money and enable the aggressive time schedule for the stimulus plan to be met with sound deployments that deliver benefits to organizations, companies, and citizens. A Best Practices Clearing House can quickly offer vendor-agnostic and technology-neutral guidelines across the range of deployment issues from permitting and siting to network technology and evolution, and from management, operations, and maintenance to network and service evolution. By following the examples of best-of-breed systems, NTIA and RUS can shorten or eliminate learning curves and meet aggressive time scales with vetted, low-risk deployments.
In particular, the Best Practices Clearing House will:
• Identify successful deployments with varying geography, demographics, and technology selections;
• Characterize and analyze success strategies for permitting, siting, and construction; regulatory and governance framework; and financial and operational models;
• Develop succinct and useful guidelines, case studies, and templates to expedite sound broadband deployments and achieve the speedy action demanded by the ARRA; and
• Disseminate best practices as a dynamic industry resource to advance the state-of-the-art in U.S broadband deployment.


CONCLUSION

For the foregoing reasons, Telcordia urges NTIA to adopt our recommendations on Risk Mitigation and Security, Broadband Mapping, and a Best Practices Clearing House.

Respectfully submitted,
TELCORDIA

By: ________________

Adam T. Drobot
President, Advanced Technology Solutions
Chief Technology Officer
TELECORDIA
One Telcordia Drive
Piscataway, New Jersey
(732) 699-2100

April 13, 2009

AttachmentSize
Telcordia NTIA Comments Filed.doc 55.5 KB

Leticia Van de Putte, R. Ph.

(Late Submission)
see attachment

AttachmentSize
NTIALtr.pdf 116.61 KB

info@internet-coalition.org

(Late Submission)
To whom it may concern:

Please find attached our specific comments regarding specific questions raised in the Request for Information (RFI) Docket No. 090309298-9299-01 American Recovery and Reinvestment Act of 2009 Broadband Initiatives:
Thank you for the opportunity to provide input on this important grant program.




AttachmentSize
RFI.doc 45 KB
Proposal Eval Criteria for RFI.xls 32 KB

Richard Senese, Ph.D.

(Late Submission)
Please see attached letter commenting on criteria for broadband stimulus efforts to increase use of broadband

AttachmentSize
Letter to NTIC.doc 54.5 KB

Sree Tangella

(Late Submission)
Flow Mobile Comments on NTIA RUS Broadband Programs

AttachmentSize
Flow Mobile Comments on NTIA RUS Broadband Programs.PDF 1.43 MB

"Todd Lantor" <TLantor@fcclaw.com>

(Late Submission)
To Whom It May Concern:

Attached is a copy of the comments filed earlier this evening by Rural
Cellular Association (RCA) in Docket No. 090309298-9299-01. The same
filing was also submitted electronically via NTIA's webpage (
http://www.ntia.doc.gov/broadbandgrants/form.cfm).

Please do not hesitate to contact me if you have any questions regarding
the information provided.

Sincerely,

Todd B. Lantor
Lukas, Nace Gutierrez & Sachs, LLP
1650 Tysons Blvd.
Suite 1500
McLean, Virginia 22102
Phone: (703) 584-8671
Fax: (703) 584-8694

Counsel to Rural Cellular Association

If you have received this message in error, please contact me because it
may contain information that is confidential or protected by the
attorney-client privilege.



AttachmentSize
RCA BTOP Comments - 041309 - MASTER FILE.pdf 275.51 KB

American Cable Association

(Late Submission)
Attached please find the comments of the American Cable Association relating to the American Recovery and Reinvestment Act of 2009's Broadband Initiatives (Docket No. 090309298-9299-01). Please feel free to contact the undersigned should you have any questions.

Regards,

Jeremy M. Kissel
Cinnamon Mueller
2156 Wisconsin Ave, NW
Washington, DC 20007
202.609.7793 (direct)
202.747.5870 (fax)
jkissel@cm-chi.com

AttachmentSize
ACA NTIA_ RUS Comments 041309 FINAL.pdf 85.43 KB

"Joshi, Meena" <mjoshi@ustelecom.org>

(Late Submission)
On behalf of USTelecom, please accept the attached letter for filing





Meena Joshi

Law & Policy

USTelecom

607 14th Street, NW, Suite 400

Washington, D.C. 20005

mjoshi@ustelecom.org

P: (202)326-7273

F: (202)315-3351

www.ustelecom.org

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.




AttachmentSize
Letter to NTIA_RUS re Broadband Stimulus .pdf 115.55 KB
Letter to NTIA_RUS re Broadband Stimulus .pdf 115.55 KB

AT&T Inc.

(Late Submission)
Please find attached the comments of AT&T Inc.

AttachmentSize
AT&T_Comments_to_NTIA-RUS_re_BTOP_(4-13-09).pdf 103.21 KB

Steven Glapa <SGlapa@zhone.com>

(Late Submission)
Dear Sir or Ma'am:

I write in response to your Joint Request for Information and Notice of Public Meetings (Docket No. 090309298-9299-01). Please see the attached Microsoft Word 2003 document for our comments on Question 4 in the NTIA section of your RFI, pertaining to Establishing Selection Criteria for Grant Awards.

Please do not hesitate to contact us if you have any questions or technical difficulties with the attached.

Best regards,

Steven Glapa
VP of Product Management and Marketing
Zhone Technologies, Inc.
+1.510.777.7045 desktop
+1.408.921.1537 mobile
sglapa@zhone.com
www.zhone.com



AttachmentSize
Zhone to NTIA & RUS 2009.04.02 .doc 226 KB

Louis Klepner

(Late Submission)
(If improperly formatted, please see attachment)

NTIA BTOP Public Comments - Docket Number 090309298-9299-01

Hello NTIA and RUS Administrators,

I hope you’ve been enjoying reading the nearly 1000 comments as much as I, and in the interest of time, I’ll try to keep my comments concise -

Please consider the following:

1. Giving priority to optical deployments - the speed at which of optical fiber can be lit is unlikely to be matched, or exceeded, by any other type of connection, wireless, copper or otherwise, in the next decade and can be scaled to nearly infinite speeds.

2. Giving priority to those who expand the reach, scope and capacity of non-commercial middle-mile networks, in particular those of -
a. Research and Educational Networks (RENs) - Support the expansion of RENs by enabling the direction participation of community-based organizations in the local, state and national RENs.
b. Institution Fiber Nets (iNet) - iNets should be encouraged to provide middle-mile backhaul to local community initiatives. Those that have usage agreements prohibiting these types of arrangements should be forced to revise these arrangements prior to receiving BTOP funding.

3. Giving priority to projects that address a community’s needs much like that of college campuses – enabling symmetrical near-wirespeed connectivity between all participants.

In conclusion, it is my hope that the BTOP program will be considered a venture investment in non-profit community-centric initiatives, which as public charities, will reinvest 100% of their assets into the growth and stability of the.

Since there are few if any significant non-profit telecommunications providers providing community-wide services, it is my hope that NTIA and RUS administrators will be supportive of new non-profit entrants who are actively scaling up to meet this challenge.

Many thanks for your time and attention, great job on the program so far and I look forward to speaking with some of you soon –

Best,
- Lou

Louis S. Klepner
Founder, NYC Community Fiber Project
lou@communityfiberproject.net
212-796-0853

AttachmentSize
NTIA Comments – Community Fiber Project.pdf 59.1 KB

Home Town Cable TV, LLC

(Late Submission)
Separate comments for RUS and NTIA are attached.

AttachmentSize
HTC RUS comments.pdf 20.03 KB
HTC NTIA comments.pdf 29.03 KB

"Phyllis Whitten" <pawhitten@earthlink.net>

(Late Submission)
Transmitted as attachments below in both Word and PDF formats are the consolidated Comments of Spruce Knob Seneca Rocks Telephone, Inc. in both the NTIA/RUS Docket No. 090309298-9299-01 and the FCC's GN Docket No. 09-40. These Comments have been electronically filed via the NTIA's BTOP webpage and the FCC's ECFS system.

Please contact me if any questions arise.

Respectfully submitted,


Phyllis A. Whitten, Attorney-at-Law
Counsel to Spruce Knob Seneca Rocks Telephone, Inc.
1629 K Street, N.W., Suite 300
Washington, D.C. 20006
pawhitten@earthlink.net
(202) 550-0722


AttachmentSize
SKSRTBroadband Initiatives Comments.pdf 22.86 KB
SKSRT Broadband Initiatives Comments.doc 33.5 KB

"Jane Morlok" <jmorlok@westianet.com>

(Late Submission)
Reviewers:

Thank you for the opportunity to comment on the Broadband Opportunity
Program. Please see our attached comments.

Respectfully submitted.

Jane Morlok, CFO
Breda Telephone Corp.
112 East Main, P.O. Box 190
Breda, Iowa 51436
712.673.8101







AttachmentSize
win_sig_logo.jpg 7.19 KB
Broadband Oppor. Program 4-13-09.pdf 839.57 KB

XO Communincations and Nextlink Wireless, Inc.

(Late Submission)
Comment is over 10,000 characters. Submitting as attachment

AttachmentSize
XO Comments (NTIA) Docket No. 090309298-9299-01.pdf 3.04 MB

Ann Howe <ankitsa@comcast.net>

(Late Submission)
Stratsoft is a broadband mapping specialized consultancy located in
Massachusetts. Many mapping endeavors fall gravely short of the needs to
equate telecommunications delivery to populations, businesses needs and
public safety. Inadequate maps risk expensive errors in proposals,
bidding management, and ultimately successful delivery. Inadequate here
means too little directly pertinent data and inadequate back end charts
and graphs for one key stroke evaluation output. An attached document
provides detail. Seeing the maps that work can show this. We are happy
to meet with any and all to educate in the hopes of going on to work
with this project. Michael Tattersall, CEO, Stratsoft LLC Direct line
978-371-2299



AttachmentSize
Public Comment re Broadband Mapping Failure Avoidance Stratsoftllc.doc 33 KB
Public Comment re Broadband Mapping Failure Avoidance Stratsoftllc.doc 33 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 Van Horne Cooperative Telephone Company.

Kristy Szabo
On Behalf of Van Horne Cooperative Telephone Company
605-995-1786




AttachmentSize
VanHorne - NTIA-RUS Rules Comments 4 13 09.pdf 207.19 KB

Douglas Hawk

(Late Submission)
Please review my attached comments on BTOP funding and rules. Thank You!!

AttachmentSize
MTCO NTIA Letter.pdf 111.44 KB

Jennie B. Chandra

(Late Submission)
Please see attached comments.

AttachmentSize
WIN NTIA RUS Comments 090413.pdf 219.53 KB

"Johnson, Kathy" <Kathy.Johnson@governor.alabama.gov>

(Late Submission)
The State of Alabama submits the attached comments pursuant to the American Recovery and Reinvestment Act of 2009 broadband grant and loan programs, Docket No. 090309298-9229-01.



The ConnectingALABAMA team believes the advancement of (a) broadband deployment on the supply-side and (b) broadband-based applications on the demand-side are vital enablers to the economic opportunity and quality of life for all Americans. As such, we stand in strong support of the Broadband Technology Opportunity Program (BTOP) advanced by the American Recovery and Reinvestment Act (ARRA).



Thank you in advance for considering the State of Alabama's comments.



Kathy Johnson, Director
Alabama Broadband Initiative & ConnectingALABAMA
Office of Governor Bob Riley
Alabama State Capitol
600 Dexter Avenue, EB-09
Montgomery, AL 36130
P: 334.353.8760
F: 334.353.1190
E: kathy.johnson@governor.alabama.gov
W: www.connectingalabama.gov




AttachmentSize
State of Alabama NTIA RUS Comments 4-13-09.pdf 217.81 KB

"Thomas Wilson" <twilso@state.wy.us>

(Late Submission)
Please find attached a letter from Governor Dave Freudenthal of the State of Wyoming regarding the broadband stimulus inquiry.

Please let me know if you have any questions or concerns.
Tom Wilson
twilso@state.wy.us
(307) 777-5701




AttachmentSize
LockeVilsackGomezDortch ARRA Broadband.pdf 196.23 KB
LockeVilsackGomezDortch ARRA Broadband.doc 49 KB

Intrado Inc. and Intrado Communications Inc.

(Late Submission)
Attached please find the Comments of Intrado Inc. and Intrado Communications Inc.

AttachmentSize
INTRADO NTIA COMMENTS.pdf 37.34 KB

"Newson, Elizabeth" <enewson@neca.org>

(Late Submission)
Comments of the National Exchange Carrier Association, Inc. on BTOP


Privilege and Confidentiality Notice
The information in this message is intended for the named recipients only. It may contain information that is privileged, confidential or otherwise protected from disclosure. If you are not the intended recipient, you are hereby notified that any disclosure, copying, distribution, or the taking of any action in reliance on the contents of this message is strictly prohibited. If you have received this e-mail in error, do not print it or disseminate it or its contents. In such event, please notify the sender by return e-mail and delete the e-mail file immediately thereafter. Thank you.




AttachmentSize
041309nitaruscomments.pdf 44.25 KB

The Telecommunications Industry Association

(Late Submission)
The Telecommunications Industry Association respectfully submits this letter urging NTIA to attribute pre-existing infrastructure investments necessary to BTOP projects to the statutorily-required 20 percent non-Federal match as in-kind contributions. This letter was filed electronically yesterday at 5pm, but has not yet posted.

AttachmentSize
NTIA 20 Match FINAL.pdf 32.6 KB

Donny Smith, CEO

(Late Submission)
Please find attached the comments from Jaguar Communications, Inc.

AttachmentSize
2009 Joint BTOP NTIA RUS comments by Jaguar.pdf 273.44 KB

Marc Berejka

(Late Submission)
We are resubmitting our comments. The first version posted on the Web is garbled. Thanks.

AttachmentSize
msft ntia rus fcc comments 13apr09 FINAL.pdf 365.61 KB

"Johnson, Kathy" <Kathy.Johnson@governor.alabama.gov>

(Late Submission)
The State of Alabama submits the attached comments pursuant to the American Recovery and Reinvestment Act of 2009 broadband grant and loan programs, Docket No. 090309298-9229-01.



The ConnectingALABAMA team believes the advancement of (a) broadband deployment on the supply-side and (b) broadband-based applications on the demand-side are vital enablers to the economic opportunity and quality of life for all Americans. As such, we stand in strong support of the Broadband Technology Opportunity Program (BTOP) advanced by the American Recovery and Reinvestment Act (ARRA).



Thank you in advance for considering the State of Alabama's comments.



Kathy Johnson, Director
Alabama Broadband Initiative & ConnectingALABAMA
Office of Governor Bob Riley
Alabama State Capitol
600 Dexter Avenue, EB-09
Montgomery, AL 36130
P: 334.353.8760
F: 334.353.1190
E: kathy.johnson@governor.alabama.gov
W: www.connectingalabama.gov




AttachmentSize
State of Alabama NTIA RUS Comments 4-13-09.pdf 217.84 KB

FiberTower Corporation

(Late Submission)
Attached are FiberTower Corporation's comments. Please contact Russell Fox, counsel to FiberTower Corporation, at 202-434-7300 with any questions concerning this filing.

AttachmentSize
ACF7BD0.pdf 43.54 KB

asda

(Late Submission)
asdasdasd