Joint Broadband Technology Opportunities Program Request for Information
Joint Broadband Technology Opportunities Program Request for Information
Date:
March 12, 2009
Docket Number:
090309298-9299-01
American Recovery and Reinvestment
Act of 2009 Broadband Initiatives
Patrick Lanthier, Charles Brown & Larry Press
Attached as .pdf file
Eric Damman
Please see attached document- My effort to build awareness of the unique advantages smaller companies offer.
S. Derek Turner
Please find the attached written comment from Free Press, as filed April 13, 2009.
Morna Foy
Department of Commerce
National Telecommunications and Information Administration and the Department of Agriculture Rural Utilities Service
Washington, D.C. Joint request for information: American Recovery and Reinvestment Act of 2009 Broadband Initiatives )
)
) Docket No. 090309298-9299-01
The Wisconsin Technical College State Board is the governing body of the Wisconsin Technical College System (WTCS). The WTCS has 16 technical college districts throughout Wisconsin, which offer more than 300 programs awarding two-year associate degrees, one- and two-year technical diplomas and short-term technical diplomas. In addition, the System is a major provider of customized training and technical assistance to Wisconsin’s business and industry community and the primary provider of adult basic education services in the state. More than half of all adults in Wisconsin have accessed the technical colleges for education and training in the last decade. We appreciate this opportunity to comment on the broadband funding available in the American Recovery and Reinvestment Act of 2009 (ARRA). Following are comments regarding specific RUS/NTIA questions.
Effective ways to offer broadband funds to ensure that rural residents receive it
To ensure that un-served and under-served populations gain access to broadband services, proposals that include public/private partnerships should be given priority for infrastructure funding. Such projects should finance infrastructure to connect Community Anchor Institutions broadly defined to include Universities, Technical and Community colleges, Schools, Libraries, Museums, Health care facilities and other institutions that are able to aggregate regional entities, are geographically dispersed and are accessible to the public. The WTCS supports such a project filed in this same docket by WiscNet (Wisconsin’s Research, Education, and Public Service Network); Go-GIG!
If bandwidth can be expanded or brought to CANs (Community Area Networks) or Community Anchor Institutions, then local users only need to get local connections, which is much cheaper than the long distances between communities. Once we pay for the anchor sites – then the local ISP / providers can afford to connect public users on extra fiber that would be run when the Anchor Institutions are connected. Local users may still need to pay for the local connections, but the return on investment for the vendors should be less, so fees can be less to the users.
The $200 million for public computing centers should give priority to proposals that involve collaboration between libraries and community colleges and which leverage the existing broadband assets and capacity of both or multiple entities. To best leverage existing broadband capacity, and to ensure that the public can truly take advantage of new infrastructure or expanded capacity, services and staff associated with improving public access should be an eligible use of these funds, including training services, security, user support services, and equipment upgrades.
Eligible Grant Recipients
Community Area Networks (CANs) operated or managed by the public sector, not-for-profits, or by the private sector should be eligible entities. Priority should be given to CANs that serve areas with large low income populations or un- and under-served populations.
Establishing Selection Criteria for Grant Awards
In addition to the specific criteria referenced in the Recovery Act, priority or preference in the grant ranking process should be given to:
• Applications that seek to expand existing programs, infrastructure and services
• Applications that provide long-term benefits (e.g., fiber)
• Applications that show collaboration or partnerships, (e.g., CANs), and
• Applications that demonstrate a large regional or statewide impact.
Grant Mechanics
Give priority to applications that build on existing programs and services and that have a track record the applicant can document. Consider a more streamlined application process for grants requesting less than $50,000. Have reasonable limits on the length of the grant application form.
Grants for Expanding Public Computer Center Capacity
The nation’s technical and community colleges have significant investments in broadband capacity that could be leveraged with the nation’s public libraries physical capacity to maximize the number of public computing centers established through the ARRA funding. Key needs of such collaborative proposals include:
• Expanded bandwidth
• Security
• Ongoing user training and support
• Ongoing maintenance and equipment upgrades
To encourage leveraging of existing resources, the $200 million for public computing centers should give priority to proposals that involve collaboration between libraries and community colleges and which leverage the existing broadband assets and capacity of both or multiple entities. To best leverage existing broadband capacity, and to ensure that the public can truly take advantage of new infrastructure or expanded capacity, services and staff associated with improving public access should be an eligible use of these funds, including training services, security, user support services and equipment upgrades.
Innovative Programs to Encourage Sustainable Adoption of Broadband Services
The economic effect of expanding the nation’s broadband infrastructure will be reduced if the majority of end users of this structure (businesses, consumers) do not have the equipment, technical skills or knowledge to access the system. Educational and community service organizations with established programs for delivering this technical skill and knowledge and whose service area includes un-served or under-served populations, should be eligible to apply for grants for education, awareness, training, access, equipment, and support under Section 6001(b)(3) ).
Financial Contributions by Grant Applicants
Allow in-kind contributions to be considered as the “matchâ€Â. Specifically, for public computing center projects, in-kind match should be required to demonstrate existing broadband and public access assets.
"Micah Singer" <micah@voiplogic.com>
Here is a brief filing address mainly NTIA Question 7 on selecting grant
recipients for rural broadband projects.
Micah Singer
+1-310-279-4701 (direct)
+1-888-350-6664 (fax)
micah@voiplogic.com
VoIP Logic
VT DPS, MDTC, and MBI
Attached please find a copy of the joint comments of the Vermont Department of Public Service, the Massachusetts Broadband Institute, and the Massachusetts Department of Telecommunications and Cable.
Luisa Handem
Attached please see comments from the Rural Mobile Broadband Alliance (RuMBA) USA
Larry Press
Six suggestions for innovation in ownership and business models and technology
Larry Press, Professor, IS, California State University, Dominguez Hills
Charles Brown, The Emergency Communications Leadership and Innovation Center
Patrick Lanthier, The Emergency Communications Leadership and Innovation Center
This note is a summary of the attached paper, which is also available at:
http://www.uic.edu/htbin/cgiwrap/bin/ojs/index.php/fm/article/view/2374/2159.
The paper argues that the BTOP should:
1. Be pessimistic about our ability to create competition through legislation and regulation.
2. Support commodity IP connectivity, not differentiated services.
3. Study current municipal ownership and business models and policies in cities and local areas around the nation and world.
4. Encourage and evaluate innovation in ownership and business models in the local "middle mile" - to learn what works and what does not.
5. Encourage and evaluate projects that push ownership and control of portions of the access network out to home and building owners.
6. Encourage experimentation with last-link wireless, using existing standards like IEEE 802.11 and custom hardware and software.
Since divesture in 1984, we have hoped that legislation and independent regulation could bring about competition in telecommunication markets. However, the large broadband incumbents have benefited from public subsidy without living up to commitments to install fiber, and have used their power to defeat attempts to establish competition. They have also insisted on a service-oriented business model, selling telephone, television and other services rather than service-independent connectivity, leading to inefficient allocation of resources and allowing for cross-service subsidy.
Our access networks are aging, and will be stressed by increasing video traffic. Following the lead of some Asian and European nations, we are beginning to roll out next-generation access networks based on fiber and wireless technology. We will have fiber to all urban and many rural homes and buildings in the long run. The question is not whether we are going to deploy new access infrastructure; the question is "who will own it?"
The BTOP is not large enough to procure and deploy our next generation access networks, but we should use it to encourage and evaluate innovation in ownership and business models and technology.
For example, consider the monthly cost of fiber-based, residential Internet service in several cities:
* Stockholm, 100/100 Mbps: $11
* Seoul, 100/100 Mbps: $24
* Hong Kong, 100/100 Mbps: $35
* Tokyo, 100/100 Mbps: $61
* Amsterdam, 100/100 Mbps: $127
* Lafayette, Louisiana municipal network, 50/50 Mbps: $58
* Lafayette, Louisiana Cox Cable, 50/5 Mbps: $140
* US where available, Verizon FIOS, 50/20 Mbps: $145
Can we explain the large speed and cost differences?
The Cox Cable offering in Lafayette, Louisiana is the slowest and is only five dollars a month less than Verizon FIOS. The municipal network in the same city is faster and cheaper, but the Cox network reaches more neighborhoods, and Cox competes with temporary sale prices where there is overlap.
Stockholm is at the other extreme. They have a municipal network that reaches every block in the city. Unlike Lafayette, they do not offer consumer service over their fiber, but lease network access to anyone who would like to offer service. The Internet service providers, including incumbent telephone and cable companies, compete on an equal footing.
As a result, there are many competing service providers in Stockholm, and the city owns the expensive, long-life assets like fiber, rights of way, conduit, and tunnels, and the service providers own the electronic equipment that is relatively cheap and is upgraded frequently as technology improves.
This is only one, partial example. The BTOP should fund ongoing study of municipal projects. We have conducted studies to characterize the state of the Interent in many nations, using a framework developed by ourselves and colleagues. However, national context explains only a portion of the variation among cities. The city or local area, not the nation, is the relevant unit of analysis in this case, and a framework for characterizing the state of the Internet in a local area should be developed and used.
Going beyond the middle mile, we should encourage projects that push ownership and control of access networks out to home and building owners. In some cases, these may involve fiber to the structure. (Such a trial is underway now in Ottawa, Canada). Others may bring fiber to the curb or block and rely upon wireless technology in the last link. This may take many forms - point to multipoint links, local mesh networks, radios that adapt when interference is detected, etc. Whichever technologies are used, they should present standard interfaces, and the hardware should be packaged in self-install kits for mass distribution through chains like Home Depot or Radio Shack.
We will be living with the fiber and high-speed wireless infrastructure we build today for many decades. We will also be living with its owners. BTOP funds can be used to study what others have done and experiment with innovative ownership and business models and technology.
"Karmarkar, Radhika" <rkarmarkar@doitt.nyc.gov>
As I discussed with George, attached is a letter noting the meeting I
and others from my office had with NTIA about the BTOP program, as well
as the handout that was discussed during the meeting.
Radhika Karmarkar
Senior Counsel for Regulatory and Legislative Affairs
NYC Department of Information Technology and Telecommunications
75 Park Place, 9th Floor
New York, NY 10007
212-788-6565
"Debbie Goldman" <DEBBIE@cwa-union.org>
Mark -
Attached is the CWA Ex Parte on the Buy America provisions. You will find a CWA proposal to streamline implementation of these provisions. I am happy to discuss this further with you.
Debbie
Debbie Goldman
Telecommunications Policy Director and Research Economist
Communications Workers of America
501 Third St N.W.
Washington, D.C. 20001
202-434-1194 (phone)
202-434-1201 (fax)
dgoldman@cwa-union.org
"Steve Pastorkovich" <SFP@opastco.org>
Good afternoon;
I have attempted to submit the attached comments in .pdf format at
http://www.ntia.doc.gov/broadbandgrants/form.cfm per the March 12, 2009
Federal Register Notice. However, whenever I attempted to do so, a
message appeared saying that "comments were required," so I am uncertain
if the submission via the web page for was successful.
In any event, per the instructions in the Federal Register notice, I am
also submitting the comments, attached to this message. Please let me
know if you have any questions. Thank you,
Steve
Steve Pastorkovich
OPASTCO Business Development Director/
Senior Policy Analyst
202-659-5990 ext. 217
http://www.opastco.org
Great Plains Communications, Inc.
The attached comments were submitted earlier today in Word format via email pursuant to the Federal Register instructions. We are submitting them via Web Comment Word attachment as well to ensure inclusion in the record.
"Anderson, Carla" <carla@e-copernicus.com>
Kathy tried to send this twice and it would not go through. Trying from
my email address too.
Carla A. Anderson |SVP/COO | e-Copernicus | 317 Massachusetts Ave. NE:
Suite 200 | Washington, DC 20002 | Office: 202.292.4603 | Mobile:
202.498.6936 | Fax: 701.794.3356
From: Johnson, Kathy [mailto:Kathy.Johnson@governor.alabama.gov]
Sent: Monday, April 13, 2009 11:55 PM
To: BTOP@ntia.doc.gov
Cc: Anderson, Carla; Johnson, Kathy
Subject: Docket No. 090309298-9229-01 - ARRA Broadband Initiatives
Importance: High
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
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U.S. Chamber of Commerce
Please see the attached letter from R. Bruce Josten, Executive Vice President for Government Affairs at the U.S. Chamber of Commerce, urging the NTIA to adopt rules that would award Broadband Technology Opportunities Program grants funded by the American Recovery and Reinvestment Act of 2009 on an expedited basis to reputable applicants who demonstrate that they have ready-to-go projects that will bring broadband to unserved areas or spur broadband adoption.
Sincerely,
Jason Goldman
===
Jason D. Goldman
Counsel, Telecommunications & E-Commerce
Environment, Technology & Regulatory Affairs Division
U.S. Chamber of Commerce
1615 H Street, NW
Washington, DC 20062
Tel: 202-463-5949
Fax: 202-887-3445
E-mail: jgoldman@uschamber.com
Paul Budde on Behalf of Big Think Strategies
As noted following the Conclusion, this document reflects extensive review, analysis and the collective judgment of an international team of leaders in the communications industries whose experience spans technical, financial, economic and legal arenas. As such, it is not presented as representative of any one national government, carrier, academic institution, legal practice or consultancy, but rather as the collective and agreed upon view of many individuals who remain committed to the health of the world’s electronic communications infrastructure.
William Wells, Jr.
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
1109 E. 31st Street, Ste. G
Kansas City, MO 64108
816.234.8783
wwells@truebtv.com
www.trueh2o.com
Larry Goldberg, Jim Tobias
Comments re: access to broadband for people with disabilities attached. Submitted by NCAM & Inclusive Technologies
"Seth Cooper" <sethcooper@alec.org>
As per the instructions in the instructions provided in the Federal
Register notice, I hereby submit the attached set of comments on behalf
of the American Legislative Exchange Council. Both the attached pdf
document and the attached Word document are identical in content. (This
e-mail is not considered to be part of those comments.)
Best Regards,
Seth
____________
SETH COOPER
Director, Telecom & IT Task Force
American Legislative Exchange Council (ALEC)
Office: 202-742-8524
Cell: 202-302-3428
FAX: 202-466-3801
sethcooper@alec.org
Fiber-to-the-Home Council
Comment is attached as pdf
bob rasul <rasulb@hotmail.com>
_________________________________________________________________
Windows Liveâ„¢: Keep your life in sync.
http://windowslive.com/explore?ocid=TXT_TAGLM_WL_allup_1a_explore_042009
"Daniels, Emily J. H." <emily.daniels@pillsburylaw.com>
Attached, in both Word (.doc) and Adobe (.pdf) formats, are the comments
of SkyTerra Communications, Inc. in response to the joint NTIA and RUS
request for information.
<
Emily J. H. Daniels | Pillsbury Winthrop Shaw Pittman LLP
--------------------------------
Tel: 202.663.9378 | Fax: 202.663.8007
2300 N Street, NW | Washington, DC 20037-1122
Email: emily.daniels@pillsburylaw.com
www.pillsburylaw.com
-----------------------------------------------------------
The contents of this message, together with any attachments, are intended only for the use of the individual or entity to which they are addressed and may contain information that is legally privileged, confidential and exempt from disclosure. If you are not the intended recipient, you are hereby notified that any dissemination, distribution, or copying of this message, or any attachment, is strictly prohibited. If you have received this message in error, please notify the original sender or the Pillsbury Winthrop Shaw Pittman Help Desk at Tel: 800-477-0770 x4860 immediately by telephone or by return E-mail and delete this message, along with any attachments, from your computer. Thank you.
===========================================================
Siemens Enterprise Communications
See attached.
National Cable & Telecommunications Association
Please see attached.
John.Reynolds@iai.com
March 31, 2009
Via Electronic Mail
Bernadette McGuire-Rivera
Associate Administrator
Office of Telecommunications and Information Applications
Broadband Technology Opportunities Program
U.S. Department of Commerce, Room 4812
1401 Constitution Avenue, N.W.
Washington, DC 20230
Re: Docket No. 090309298-9299-0 1
Dear Ms. McGuire-Rivera:
Stratum Broadband submits the attached comments and attachment relative to
the American Recovery and Reinvestment Act of 2009 Broadband Initiatives.
We are pleased that the NTIA and RUS are moving forward with this most
important work. Broadband is the essential connection in many ways for the
nation and increasingly the global economy. It is essential to promoting
economic growth in all communities, both large and small.
If you require more detail or clarification, please do not hesitate to
contact us.
Respectfully submitted,
\s\
John Reynolds
Partner
Stratum Broadband
john.reynolds@stratumbroadband.com
(See attached file: Stratum Broadband ARRA RFI Response.doc)(See attached
file: Blueprint for Big Broadband.pdf)
Iowa Health System, Inc.
Please find attached the Comments of Iowa Health System, Inc. in response to the Joint Request for Information.
Patrick Sims
Please see the attachment.
Alaska Communications Systems
See attached
"Patrick Halley" <phalley@nena.org>
Attached are the comments of the National Emergency Number Association
(NENA) in response to the NTIA/RUS RFI concerning the Recovery Act
broadband initiatives. The comments were also submitted online.
Best regards,
Patrick Halley
Government Affairs Director
NENA
Don S. Samuelson
The criteria used by RUS in making evluations of stimulus support applications ought to be based on the twin stimulus objectives of: (1) the creation of jobs and businesses; and (2)the preparation of rural economies to compete successfully in serving global markets.
In addition, there should be explicit recognition that the costs to the government of "loan guarantees" are substantially less than "grants."
"Ridgway, John [IUB]" <John.Ridgway@iub.state.ia.us>
Will we receive any kind of confirmation that our comments were accepted?
John Ridgway
Manager - Telecom
Iowa Utilities Board
(515)281-4034
"Life is a long lesson in humility"
> -----Original Message-----
> From: Ridgway, John [IUB]
> Sent: Monday, April 13, 2009 2:07 PM
> To: 'btop@ntia.doc.gov'
> Subject: Responses to the Joint Request for Information
>
> > <
>
> John Ridgway
> Manager - Telecom
> Iowa Utilities Board
> (515)281-4034
> "Life is a long lesson in humility"
>
Jeffrey A. Campbell
Attached.
Marisabel "Maria" Shahnami
Attached is ACD Telecom's comments.
National Rural Telecommunications Cooperative and DigitalBridge Communications Corp.
See attached.
"BTOP BTOP" <BTOP@ntia.doc.gov>
0251 - Gomez Signed Letter to Gov. Kulongoski 05-19-2009(2)_BB.pdf
OPASTCO
Comments are attached in .pdf format.
EvenLink, LLC Partner Scott Musser
On behalf of EvenLink, LLC, we greatly appreciate the NTIA allowing the public to comment on this significant process. Please refer to the attached PDF for comments to the National Telecommunications and Information Administration and the United States Department of Agriculture Rural Utility Service on Rules for Broadband Grants and Loans(As authorized by the American Recovery and Reinvestment Act of 2009)
"NTIAHelpDesk NTIAHelpDesk" <NTIAHelpDesk@ntia.doc.gov>
>>> "Charles Walters"
>>>
I submitted comments yesterday on behalf of Walters & Associates, Inc.
at 7:01 p.m. However, I do not see my comments posted on the website.
Your assistance is greatly appreciated. I am attaching another copy of
my submission.
Charles E. Walters, ASA
Tom Chabin
Please see attachement
"Beenhouwer, Brian" <bbeenhouwer@fibertech.com>
Please add me to the list
Thanks,
Brian Beenhouwer | Product Manager
Fibertech Networks, LLC | 300 Meridian Centre|Rochester, NY 14618
Phone: 585-697-5129 Fax: 585-442-9709
www.fibertech.com
Joe Dolan
HITN Comments on NTIA RUS Broadband Stimulus Programs
XO Communications and Nextlink
Proposed rules for BTOP
National Rural Electric Cooperative Association
Errata to Comments submitted by National Rural Electric Cooperative Association on April 13, 2009
Beth McConnell <bmcconnell@media-democracy.net>
I filed these comments yesterday, but am hoping you will consider this
amended version instead. The substance is the same, but two additional
organizations have added their name to the filing.
Thank you,
Beth McConnell
On 4/13/09 5:07 PM, "Beth McConnell"
> 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
> bmcconnell@media-democracy.net
> Phone: 267-918-7207
> Fax: 509-756-0392
> www.media-democracy.net
>
--
Beth McConnell
Executive Director
Media & Democracy Coalition
2044 S. Darien St., Philadelphia PA 19148
1133 19th St., NW, 9th Floor, Washington DC, 20036
bmcconnell@media-democracy.net
Phone: 267-918-7207
Fax: 509-756-0392
www.media-democracy.net
"Jim Suchan" <jsmgr@lvcta.com>
Michael Ramage
attachment
Ad Hoc Telecom Manufacturer Coalition
See attached letter from ad hoc coalition of telecom manufacturing companies
Shelley Spencer, President
See Attached Comments
Senator Bill Ketron
see attached letter
EarthLink, Inc. and New Edge Networks, Inc.
Comments of EarthLink, Inc. and New Edge Networks, Inc.
Rob Raffety
See attached files.