Joint Broadband Technology Opportunities Program Request for Information

March 12, 2009
Docket Number: 

American Recovery and Reinvestment
Act of 2009 Broadband Initiatives

"Chuck Parker" <>

(Late Submission)
To Whom It May Concern:

Please find attached comments from the Continua Alliance directed to
criteria considerations for the BTOP grants.

We appreciate the opportunity to file on behalf of our 180 members.


Chuck Parker

Executive Director

Continua Health Alliance

For further questions:

direct 781 724-8872

office 503 619-0867

Continua Broadband Comments 4-13-09.DOC 209.5 KB

U.S. Chamber of Commerce

(Late Submission)
Please see the attached letter from R. Bruce Josten, Executive Vice President for Government Affairs at the U.S. Chamber of Commerce, urging the Rural Utilities Service to adopt rules that would award Rural Development Broadband Program grants and loans 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.

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

U.S. Chamber Urges Expedited Process for RUS Broadband Stimulus Funding.pdf 27.3 KB

(Late Submission)
Dear Dr. McGuire-Rivera,

Please find attached Ernst & Young's responses to RFI 090309298-9299-01,
American Recovery and Reinvestment Act of 2009 Broadband Initiatives. The
attached file is in Microsoft Word 2003 format.

We hope that this response will prove useful to you in navigating the
challenging path forward in implementation of the Act's mandate. Please
do not hesitate to contact us with any questions, concerns, or requests
for clarification as to any of the content of the attached.

Best regards,
Gaeron McClure

Gaeron R. McClure | Partner | Transaction Advisory Services

Ernst & Young LLP
200 Plaza Drive, Secaucus, NJ 07094, United States of America
Office: +1 201 872 1460 | Cell: +1 214 587 9701 |
Fax: +1 866 430 9675

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Response to RFI 090309298-9299-01 4-13-09.doc 293.5 KB

Dick Grayson

(Late Submission)
Please See Attachment

Kidcomputerletter.doc 1.62 MB

"Tim Sloan" <>

(Late Submission)
Attached is a summary of a meeting between OPAD stafff and Connected
Nation, held on March 4, 2009. Please post the summary on the NTIA

connected nation meeting notification.doc 24.5 KB

Mike Shelton <>

(Late Submission)
Dear NTIA and RUS administrators,

As part of the Telecommunications industry here in the U.S., let me ask that we carefully consider the use of the stimulus dollars being considered for our struggling industry. While the inflow of dollars will be greatly appreciated, and will obviously help generate more orders and therefore jobs here in the U.S., it would be mindful to make sure that the flow of funds does NOT flow right back out and over to foreign companies/interests.

Zhone Technologies, Inc. is one of the very few companies that still relies on our own technologies and workforce to produce a leading edge product. And we have been extremely successful at that. So let's make sure that those that have worked so hard receive their due rewards and are not left on the sidelines as the dollars slip out of our hands and into someone's that is not so deserving.

Thanks for your time.

Michael E. Shelton

Corporate Facilities Manager

Zhone Technologies, Inc.

Michael E. Shelton

Zhone Technologies, Inc.

Corporate Facilities Manager

Head of Security

(O) 510.777.7368

(F) 510.777.7488

image001.jpg 3.07 KB
image002.jpg 3.77 KB

Rey Ramsey

(Late Submission)
Please accept this updated version of our comments in place of the previous comments we submitted to RUS. Please remove the prior version, which included tracked changes.

Ken Eisner
Managing Director, OE Ventures
One Economy Corporation
202.256.2897 m

1Economy_RUS_cover.pdf 69.51 KB
ACF7B8D.pdf 98 KB

"Stephanie Mohl" <>

(Late Submission)
Please find attached comments on behalf of the American Heart
Association and its American Stroke Association in response to your
request for written comments about the broadband initiatives in the
American Recovery and Reinvestment Act.


Stephanie Mohl
Government Relations Manager
American Heart Association/American Stroke Association
Office of Legislative and Regulatory Affairs
1150 Connecticut Ave., NW
Suite 300
Washington, DC 20036
202-785-7950 (fax)

Go Red For Women.
Join the movement to wipe out heart disease. Visit:

Stroke Telemedicine Comments Commerce-RUS v3.doc 328 KB

Kevin Manovich

(Late Submission)
Attached is NWT Enterprises, Inc. comment on the BTOP RFI

NTIA-RUS RFI.pdf 95.14 KB
NTIA-RUS RFI Word Doc.doc 187 KB

John Chuang

(Late Submission)
Please accept the comments of Cinergy MetroNet, Inc.

CMN_NTIA_RUS Cmts.pdf 91.15 KB

Mayor David Pennington

(Late Submission)
Please see the attached document.

Mayor David Pennington, Coffee Co TN.pdf 87.23 KB

"Gray, Todd" <>

(Late Submission)
Please find attached the Comments of the National EBS Association
(NESBA) in Docket No. 090309298-9299-01.

Respectfully submitted,

Todd D. Gray
Counsel for NESBA

Todd D. Gray
Attorney at Law

1200 New Hampshire Avenue, NW Suite 800
Washington, DC 20036-6802
T 202-776-2571

F 202-776-4571

This message from the law firm of Dow Lohnes PLLC may contain
confidential or privileged information. If you received this
transmission in error, please call us immediately at (202)776-2000 or
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dowlohnes.gif 2.34 KB
NEBSA Comments in NTIA BTOP Proceeding.doc 59.5 KB

Pat Ford-Roegner

(Late Submission)
Please see attached file for comment.

letter to NTIA 0409.doc 522 KB

Paul Van Hoesen

(Late Submission)
Attached is a proposal and comment on the NTIA TOP Sustainable Broadband Adoption Grant Program. This is the result of two years of field research in driving broadband adoption and economic and community development through the utilization of the Internet in rural west Tennessee. We have attached the program synopsis and comments as a file.


Paul Van Hoesen
Director, cTechnology, Inc.

cTechnology Sustainable Broadband Adoption Program & Comment.pdf 479.97 KB

Mark Savage

(Late Submission)
Attached are the comments and a proposed business model between a State Trust Land Management orginization and private industry to identify and build out significant broadband infastructure across Washington State.

Washington DNR Comments.doc 44 KB

Commonwealth of Pennsylvania

(Late Submission)
Please find attached written response from Commonwealth of Pennsylvania, Governor's Office of Administration, related to joint RFI issuance from NTIA/RUS re [Docket No. 090309298-9299-01].


ACF7B20.pdf 1.11 MB
NTIA_RUS_RFI_FINAL_for_submission.doc 147 KB

"Nicholas Miller" <>

(Late Submission)
The statute says for RUS:

"No area of a project funded" may receive funding from TOPS

How will that allow coordinated projects?

Nicholas P. Miller
Miller & Van Eaton, P.L.L.C.
Suite 1000
1155 Connecticut Avenue. N.W.
Washington, D.C. 20036-4320
phone (202)785-0600
fax (202)785-1234

This message is intended only for the use of the individual or entity to
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telephone: (202) 785 0600.

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Blank Bkgrd.gif 145 bytes

Mark Luker

(Late Submission)

EDU NTIA RUS Comments4.13.2009.pdf 379.7 KB

Parul Desai <>

(Late Submission)
Please find attached Comments on behalf of Media Access Project.



Parul P. Desai
Vice President
Media Access Project
1625 K Street, NW
Suite 1000
Washington, DC 20006
p. 202-454-5683
f. 202-466-7656

Stimulus comments.pdf 33.73 KB

"James McConnaughey" <>

(Late Submission)
The attached describes an April 14, 2009, meeting with NTIA staff and
David Townsend & Mark Kennet.

Market Frontier Meeting.doc 22 KB

Motorola, Inc.

(Late Submission)
See attachment.


City of Palo Alto, California

(Late Submission)
Comments of the City of Palo Alto, CA are attached

Palo Alto NTIA Comments.pdf 1.52 MB

Jane Peebles

(Late Submission)
I live in a seculded spot in a rural, mountainous area & I have no affordable options for broadband access. I could probably get broadband via satellite, but the cost would be around $90 per month, which is more than I can afford, especially in the current economic times. It is getting to the point that it's almost impossible to manage without high-speed internet access, but that's my situation. The really sad thing is that if I had high-speed access, I could do more tele-commuting, which would save on travel costs & also vehicle emissions. I am an Information Systems Manager for a school system in western NC. How crazy is that, to be a computer professional who has no broadband access at home? Please help me to get access. Please see attachment.

Broadband Plea.doc 28.5 KB

Global Crossing

(Late Submission)
April 8, 2009

Ms. Bernadette McGuire-Rivera
Associate Administrator
Office of Telecommunications
and Information Applications
National Telecommunications
and Information Administration
U.S. Department of Commerce
1401 Constitution Ave., N.W.
Washington, D.C. 20230

Mr. David P. Grahn
Associate General Counsel
U.S. Department of Agriculture
Rural Development
Room 2017
Mail Stop 1423
1400 Independence Avenue SW
Washington, DC 20250-3201

(Docket No. 090309298-9299-01)

Dear Ms. McGuire-Rivera and Mr. Grahn:

Global Crossing submits this letter to urge the National Telecommunications and Information Administration (“NTIA”) and the U.S. Department of Agriculture (“USDA”) to establish a process that matches parties interested in deploying middle-mile broadband facilities with parties interested in deploying last-mile broadband facilities so as to avoid purely speculative (and potentially wasteful) investments in broadband facilities and optimize the effectiveness of the Broadband Technology Opportunities Program (“BTOP”) administered by the NTIA and the rural broadband grants and loan program administered by the USDA.

In laying out the goals of the BTOP program, Mark G. Seifert, Senior Advisor to the Assistant Secretary of NTIA, stated:

“First, we want to create jobs.”

“Second, we want to begin to close the broadband gap in America. We, therefore, want to extend high-capacity pipes closer to users in rural, remote, and underserved communities. As Congress has instructed, other entities will be able to connect to those pipes, which will spur competition and get service to people and businesses.

The high-capacity pipes referred to by Mr. Seifert are commonly known as “middle-mile” facilities that connect rural carriers to the Internet. Typically, these middle-mile facilities are the sole connection available to the Internet and can span literally hundreds of miles. Not surprisingly, the cost of these facilities is exorbitant and inhibits the growth of broadband speed and capacity in the last mile. It is fair to say that until there is a likelihood that middle-mile links will be available, it is difficult or impossible to deploy last-mile facilities in unserved and underserved areas. This is especially true for those areas where middle-mile facilities comprise the majority of costs associated with broadband deployment.

Global Crossing is a Tier 1 Internet backbone operator with substantial investment in telecommunications networks here in the United States and around the world. As the only Tier 1 Internet backbone operator with end to end IPv6 implementations as well as an ability to run legacy IPv4 dual stack we are also well poised to provide enhanced security and functionality to all middle/last mile facilities and the end users served by them. By providing training, education and experience on the more advanced IPv6 platform we can also contribute directly to Administration goals of training the workforce on technologies of the future. We are eager to make investments in middle-mile facilities in support of last-mile broadband efforts. Indeed, Global Crossing is currently working with existing rural carriers to identify potential middle-mile routes that would be eligible to receive funds under the BTOP and rural broadband grant and loan programs. However, our efforts appear limited to providing improved access to broadband in underserved areas of the United States rather than providing broadband access to unserved areas.

In order to provide access to broadband service to consumers residing in unserved areas of the United States, Global Crossing would have to deploy middle-mile facilities on a purely speculative basis. This is because it is unknown at this time if any entity is willing to invest in last-mile broadband facilities in unserved areas. The conundrum – or “chicken and egg” problem – is that entities based in the unserved areas aren’t willing to deploy last mile broadband facilities because they do not know if anyone will make available reasonably priced middle-mile facilities. The problem for Global Crossing and companies like us is that identifying potential partners in unserved areas is by definition a logical impossibility because the areas are unserved. (In underserved areas there are broadband providers already serving consumers to some extent and thus easily identifiable.) But in unserved areas there are no existing broadband providers and it is impossible to know who is willing to make such synergistic or mutually dependent investments

Hopefully the application process will reveal entities willing to make such investments, but the viability of those applications would be greatly enhanced if they were matched with applications regarding middle-mile investments. For this reason, Global Crossing urges the NTIA and USDA to establish a process whereby last-mile providers and middle-mile providers can be paired up in support of a more complete effort to provide broadband service to unserved areas. This would greatly enhance the effectiveness of the BTOP and rural broadband programs and avoid having broadband stimulus monies going to purely speculative ventures that may not advance the goals of the BTOP program or the rural broadband grants and loans programs.

As the NTIA and USDA make available the list of applicants to the BTOP and rural broadband programs, Global Crossing recommends that the lists be categorized geographically and functionally. This will allow applicants, or prospective applicants, to more easily identify potential synergistic applications. Parties should then be able to request that their application be considered in conjunction with each other. In effect, NTIA and USDA would be creating an information exchange and facilitating the sort of deal-making that is so difficult to achieve at this point due to a lack of information about potential applicants and a lack of transparency into the business plans of potential applicants. NTIA and USDA would of course have to weigh the synergistic opportunities as part of their evaluation of the applications and even allow for a period during which applicants could revise their applications to acknowledge the synergistic opportunities with other applicants, something Mr. Seifert contemplated in his testimony.

Global Crossing believes that proceeding in this fashion will result in a more comprehensive, and less speculative, deployment initiative, reduce waste, and deliver more broadband capabilities to a greater number of consumers. For these reasons, Global Crossing urges the NTIA and USDA to consider this recommendation.


Paul Kouroupas
Vice President, Regulatory Affairs

Broadband Letter.pdf 1.38 MB

MSS & ATC Coalition

(Late Submission)
Attached, in both Word (.doc) and Adobe (.pdf) formats, are the comments of the MSS & ATC Coalition in response to the joint NTIA and RUS request for information.

MSS-ATC Coalition NTIA-RUS Comments.pdf 37.6 KB
MSS-ATC Coalition NTIA-RUS Comments.doc 79 KB

Edward Anderson

(Late Submission)
Attached are the comments submitted by Ed Anderson Director, Network Services - Nevada System of Higher Education (NSHE) on behalf of NSHE, The Nevada Dept. of Transportation (NDOT), and teh Nevada Department of Information Technology (DoIT)

Economic Stimulus Formal Input.docx 85.33 KB
Economic Stimulus Formal Input.docx 85.33 KB

Dusan Janjic

(Late Submission)
We are submiting our coments in the form of two attachments.

comments.pdf 57.33 KB
080326_bb_policy_japanapectel.ppt 3.09 MB

"David L. Dyer" <>

(Late Submission)
Please add me to your correspondence list.


David L. Dyer

City Administrator

City of Galva

210 Front Street

Galva, IL 61434

Phone: (309) 932-2555

Fax: (309) 932-3306



Notebook.jpg 2.88 KB
Notebook.jpg 2.88 KB

"NTIAHelpDesk NTIAHelpDesk" <>

(Late Submission)

>>> Cynthia Pols 4/13/2009 4:22:06 PM >>>
I submitted comments on behalf of the Triangle J (NC) Cable Broadband
Consortium on the BTOP program a few minutes ago. However, they have
appeared on the NTIA website. Is there something wrong with the
website? I
have attached a copy of the comments on question to make sure that they
included in the docket for this proceeding.

Thanks for your attention to this matter.

Cynthia M. Pols

TJCOG summary & comments-2009.04.13.pdf 413.65 KB

Wilma Rahn <>

(Late Submission)
Please accept the attached comments from Commissioner Paul Bergman, Lake County, Minnesota

Wilma Rahn, Administrative Clerk of the Board
Lake County Board of Commissioners
601 Third Avenue
Two Harbors, MN 55616
(218) 834-8320 Fax: 218-834-8360

This e-mail message is intended only for the addressee(s) and contains information that may be confidential and/or legally protected. If you are not the intended recipient, please notify the sender by reply e-mail and immediately delete this e-mail. Use, disclosure or reproduction of this e-mail by anyone other than the intended recipient(s) is strictly prohibited. No representation is made that this e-mail or any attachments are free of viruses. Virus scanning is recommended and is the responsibility of the recipient.

broadbandltr.040809.docx 263.53 KB

Alyssa Clemsen

(Late Submission)
Broadband Stimulus Comments. Please see Attachment.

NTIA and RUS Comments -Final Submitted 4-10-09.pdf 27.1 KB

"Jami Kubacki" <>

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

Thank you.

Jami Kubacki ~ Operations Assistant ~ Agri-Valley Communications, Inc.
~ ~ 989-453-4420 (office) ~ 989-550-0810 (cell)

image002.jpg 1.92 KB
image002.jpg 1.92 KB

Frank Odasz <>

(Late Submission)

To: Barbara Brown, NTIA/BTOP at (202) 482-4374 or

Mary Campanola, USDA/RUS at (202) 720-8822 or

Re: Public Input on NTIA/BTOP and USDA/RUS grant guidelines and
Emailed April 13th, 2009 to and

Online at
Formatted Word doc:

From: Frank Odasz, Lone Eagle Consulting
2200 Rebich Lane, Dillon, Montana 59725
PH: 406 683 6260, Cell: 406 925 2519

Barbara and Mary,

With great respect and all seriousness Lone Eagle Consulting submits the
attached document regarding recommendations for NTIA/BTOP and USDA/RUS
grant guidelines and accountability. The Executive Summary is below.

Red, White and Blue,

Frank Odasz
Lone Eagle Consulting
PH 406 683 6270

America’s Historic Challenge to Fund Mass Innovation
without the risks of political backlash due to lack of documented

Executive Summary:

The U.S. Government needs to enact an effective ongoing process immediately
for identifying the best broadband training innovations for national
replication and distribution. Consider creating an Office of Broadband Best
Practices for Sustainable Families focused on identification and
dissemination of best practices as they emerge – with rapid turn-around
using social media and video-storytelling of successful replicable strategies.

Presuming “any” training program can turn broadband access into jobs in the
short term is an example of the naiveté of the U.S. government having not
paid close enough attention to the impacts, or lack thereof, of ten years
of lessons learned from broadband deployment. Best practices are not at all
obvious to anyone. Ideal curriculums for community technology centers,
(CTCs) and/or citizen engagement methodologies for local community networks
to produce socio-economic capacity are still in their infancy. What gets
measured - gets done.

America’s ideal opportunity related to the Obama administration’s new
openness is to design these grants programs with incentives to create an
intelligent “self-learning community” where grantees are tasked with
effective visible collaborative sharing of innovations as they emerge.
Grantees should to be required to publically maintain web postings of their
measurable outcomes, replicable training strategies, essential content,
sharable curriculum, and success stories using new media. Peer evaluations
via social media have proven to be very effective. Consider that perhaps
the only way to manage assessments for the volume of projected projects is
through peer evaluations and social media as has been demonstrated on
Youtube and many other such sites.

NTIA/USDA can provide funding incentives as well as social recognition for
effective online peer mentoring, community service engagement levels, and
cross-project sharing of essential online resources. NTIA/USDA programs
must become a smart celebration of American innovation, such that the whole
world benefits.

This can only happen by intent and design.

Frank Odasz
Lone Eagle Consulting
Ph/Fax: 406 683 6270
Cell: 406 925 2519

"In times of change, learners inherit the earth" - Eric Fromm

NTIA-USDA-Guidelines.doc 91.5 KB

The People of the State of California and Governor Arnold Schwarzenegger

(Late Submission)
Attached are comments submitted on behalf of the People of California and Governor Arnold Schwarzenegger.

California_Response_to_NTIA_on_BB_Stimulus_Grants_4-13-09.DOC 15.33 MB

"Laudeman, Greg" <>

(Late Submission)

Please accept the attached response, in HTML and MS Word formats, to the
NTIA and RUS joint RFI on broadband programs in the American
Reinvestment and Recovery Act of 2009 on behalf of the Rural
Telecommunications Congress.


-- Greg

Greg Laudeman

President, Rural Telecommunications Congress

Project Manager, Enterprise Innovation Institute
, Georgia Tech

5 S. Public Sq., Suite 104

Cartersville, GA 30120

Phone: 706-271-5521

Fax: 770-387-4001



RTC NTIA-RUS RFI response.doc 85 KB
RTC NTIA-RUS RFI response.mht 128.08 KB

Ali Shahnami

(Late Submission)
Please see attached comments on Mapping.

NTIA Stimulus Bill Questionaire - ACD Telecom 04 02 2009.pdf 104.33 KB

Dean Garfield

(Late Submission)
Letter Attached

ITI Submission to NTIA RUS on ARRA Broadband investment.pdf 159.34 KB

Bob Bush and Tad Polumbus

(Late Submission)
Please see attached

Innovative Grant Program Comments BB.CC.pdf 59.89 KB

Bill & Melinda Gates Foundation

(Late Submission)
Please find attached comments from the Bill & Melinda Gates Foundation in response to the Department of Commerce’s request for comments on NTIA’s Broadband Technology Opportunities Program. Should you have any questions or require additional information regarding the content of this submission, please do not hesitate to contact me. Thank you for the opportunity to comment.

Gates Foundation NTIA BTOP Comments.pdf 552.87 KB


(Late Submission)
See attachment.

NTIA-RUS RFI Comment FINAL 4-10-09.pdf 386.21 KB

Kodiak Kenai Cable Company, LLC

(Late Submission)
Comments have been submitted via the attached pdf. file.

KKCC NTIA Comments.pdf 1.58 MB

Paul L. Hill, Ph.D.

(Late Submission)
Please see attachments

NTIA.doc 281.5 KB
Unleashing Waves of Innovation 15.pdf 103.54 KB

RCN Corporation

(Late Submission)
See attached document that was submitted by email on April 13, 2009.

RCN NTIA-FCC Comments 041309.DOC 45 KB

Raul L. Katz

(Late Submission)
Dear Sir:

Over the past month we, at the Columbia Institute for Tele-Information at Columbia University, have been conducting research on the economic impact (particularly job creation) of the Broadband Technology Opportunities program. One of the outputs of this research is included in attachment.
As the paper indicates, while the estimates of jobs to be created as a result of investing $7.2 billion in broadband deployment are fairly robust, our calculated amounts are moderate (approximately 127,800 jobs over four years).
On the other hand, our research indicates that a bigger employment impact can be achieved as a result of the enablement effect of broadband on firm creation, innovation, new services and business growth. However, our research also indicates that there is a large degree uncertainty on the effectiveness of broadband deployment on the latter impact. In fact, it would appear that this effect could be greater if broadband deployment is combined with, for example, employment generation programs in the targeted geographies.
In this context, it would be necessary to introduce in the grant evaluation criteria an assessment of how will broadband deployment be combined with other economic development programs.
In addition, we believe the broadband program would provide the opportunity to launch further research on the actual economic effects of deploying broadband in underserved and unserved areas. The results of this research conducted while the program is being implemented would allow the creation of a set of tools aimed at further refining the process of grant allocation.
I would, therefore, suggest that, as part of the management of the program some funds are assigned for the implementation of an economic impact research effort.
Sincerely your,
Raul Katz
Adjunct Professor, Division of Finance and Economics (Columbia Business School)
Director, Business Strategy Research (Columbia Institute for Tele-Information)

Microsoft Word - Katz Working paper.pdf 229.38 KB
Microsoft Word - Katz Working paper.pdf 229.38 KB

Victoria Proffer

(Late Submission)
My name is Victoria Proffer, I am the CEO of St. Louis Broadband, LLC,

A bit about my background. I built the first dial-up network for our proposed fixed wireless coverage area, so I have been an ISP for sixteen years, I have been involved in fixed wireless for ten of those years and owned and operated St. Louis Broadband, a fixed wireless service provider in the metro St. Louis area for the last six years.

St. Louis Broadband provides services to business in the Westport area. We provide service to small business and are their technical partner, as well as large business where we back-up their wired services.

As a member of WISPA and a WISPA Legislative Committee I have worked answering the questions that NTIA has sent out. However, as a WISP I have been actively involved in developing a plan for my community.

St. Louis Broadband has been looking at a project that we have named ShowMe Broadband, We have been working on this project for the past two years. I have attached a coverage map of this area. There are several pockets, in the nine county area, of residential homes that range from 500 to 2500 population that are totally unserved. As well as there are the same pockets that are underserved with only one provider.

We talked to community leaders, colleges, hospitals, home owners association, as well as recently the state of Missouri regarding our project.

Because of envisioning this project two years ago in some locations we are currently “shovel ready” and ready to start construction today. However the State recently spoke of possible “rights of ways” for tower location in exchange for broadband services to State locations like prisons, court houses, etc. These areas still need to be examined for possible use.

One of St. Louis Broadband’s customers is the American Red Cross. We have been providing them service over the past five years, as well as technical support. One thing that we have been discussing during this time frame is our geological area and how dangerous it can be.

I feel that our project is one of the most important in the state of Missouri, if not in the nation. Our location is in the southeast portion of Missouri. This location has some interesting and challenging features due to the Precambrian geology. This area also hosts the New Madrid fault zone.

In some of the counties that we are proposing our fixed wireless solution, they are just now starting to install 911 services, I know of one county that there is no 911 service at all. Also another factor that makes this situation more vulnerable is because most of these counties, due to their rich ore where a part of a chain of mines, there are mazes of honeycombs that whole communities sit on.

“THE HIGHEST EARTHQUAKE RISK in the UNITED STATES outside the West Coast is along the New Madrid Fault. Damaging tremors are not as frequent as in California, but when they occur, the destruction covers over more than 20 times the area because of underlying geology.

A DAMAGING EARTHQUAKE in this AREA, 6.0 or greater, occur about every 80 years (the last one in 1895). The results would cause serious damage to schools and masonry buildings from Memphis to St Louis.”

As one can see from the above statement we are way past our deadline for this quake. Doubled in with the fact of communities sitting on top of this honeycomb of mines, it is a disaster waiting to happen. Add in the fact that these communities have little or no communications, it makes this another Katrina or worse in our midst.

St. Louis Broadband has designed a network with a triple fiber redundancy from different National Access Points, in the event that we could lose fiber connectivity, as well as we have added redundant satellite feeds. The tower network itself has a “self healing” distribution ring. We are limiting the use of guyed towers and opting for self-supporting towers for “earthquake prevention”.

Because of these towers being in great locations for wind in the fall/winter and solar in the spring/summer, rather than installing diesel powered generators for backup we have added solar and wind devices. We have also added a 4.9 GHz network for First Responders. We want all counties in our network to have access to this, we feel that this is very important.

We also feel it is important to include telemedicine programs, as well as distance learning. This network will be fully capable of supporting both.

What do we need from NTIA to provide this?
• Make emergency infrastructure a priority. While we understand the importance of bringing broadband to rural areas we feel that the loss of potential life is priority. These applications above all should receive first consideration.
• Keep it simple. While we recognize that certain information needs to be provided to disburse ARRA monies, don’t make the project unattainable because of complicated studies or too much government involvement.
• Let the States be involved. We realize that distributing the funds directly to the States is not what Congress intended. We also understand that this would add another layer of government that is not necessary. However we also realize that State involvement is crucial to understand the resources and support services that can be utilized. We feel that the States should support the applicable grants and be kept fully aware of the process, as well as the construction phases of each network.
• Flexibility. When designing a network of this magnitude, sometimes one runs into trouble. While it is easy to calculate the nuts and the bolts, building in the two year time frame may require slight changes of plans, such as easement issues, vendor issues, labor issues, etc. Let the States be involved in monthly project meetings where these changes could be discussed and approved. Let the States be the NTIA local authority.
• Complete Funding. When projects offer multiple goals of the ARRA Grant directives, allow complete funding of projects rather than the 20% commitment. My personal feeling is that we are going to see the “Pioneers of Broadband” involved in this project. These are the guys and gals that developed the fixed broadband solution. These are not the AT&T nor Verizon companies. These “Pioneers” have put up their homes to build their networks, risked everything to make this technology available for the masses. These companies compete daily with the ILECs who receive federal funding. These are the same ILECS that have “cherry picked” their networks and have put this country into the current situation it is in, with limited broadband access. We believe that companies that have received past federal funding should be exempt from this grant. These funds should also be available to draw upon immediately once a grant has been awarded. It is the guys that are operating the companies with less than $1 million in annual revenue that are going to build the American Broadband Backbone. These are the more “bang for the buck” guys, because they have had to be, nothing has been handed to them or easy for them, and I do speak from experience. These guys are true Americans that work hard for a living to bring the technology of fixed wireless to America.
• Give small and economically challenged businesses a break. We are a woman owned business, as well as Viet Nam veteran run and owned. To establish a SBA 8(a) certification it not only takes a great deal of time, but of money as well. Either use the self-certification set by the SBA for WOSB or streamline the SBA 8(a) certification process. These businesses should receive at least a 5% priority.

I hope the views of our company has helped and I hope to see the NTIA do what is right for America in this crucial time. Let our grandchildren know in the years to come that you made the right decision today.

Victoria Proffer
CEO – St. Louis Broadband

9 county network.jpeg 125.71 KB

"Marc-Anthony Signorino" <>

(Late Submission)
Dear Sirs & Madams:

Please accept these comments of the National Association of
Manufacturers regarding the NTIA Broadband Technologies Opportunity
Program. If you have any questions, please do not hesitate to contact
me at the phone numbers and email address below.



Marc-Anthony Signorino
Director, Technology Policy
Direct: (202) 637-3072
Cell: (202) 494-1290

National Association of Manufacturers
1331 Pennsylvania Avenue, NW Suite 600
Washington, DC 20004-1790

Check out our blog at

NAM Comments on NTIA BTOP FINAL April 13 09.DOC 110.5 KB

"Jess Posey" <>

(Late Submission)
TelePulse Technologies is proud to respond to this RFI and hopefully add
value to the efforts to get needed services in a financially efficient and
future-proof capable manner to rural, un-served and underserved communities.
We believe we can best add value by commenting on areas 4 (Establishing
Selection Criteria for Grant Awards); 5 (Grant Mechanics); 7 (Grants for
Innovative Programs to Encourage Sustainable Adoption of Broadband Service)

Jess Posey
CEO & President
TelePulse Technologies Corporation
Tel: 1-856-264-3961

TelePulse Tech NTIA BTOP RFI_2.doc 149.5 KB

"Hurley, Michael" <>

(Late Submission)

On behalf of Fibertech Networks, please accept the attach comments and
maps regarding the American Recovery and Reinvestment Act of 2009 -
Broadband Initiatives.

The purpose of these comments are to help educate and inform the
National Telecommunications and Information Administration, the U.S.
Department of Commerce, the Federal Communications Commission and the
Department of Agriculture, about Fibertech Networks, the fiber optic
network resources it has constructed, operates and has available for
lease, as well as our ability to efficiently extend fiber to where it is
needed as the agencies embark on their goal of deploying high-speed
Internet service in rural and underserved areas. It is our hope that
the funding will be utilized to leverage existing open-access fiber
networks such as ours and to help fund network deployment where no such
commercial infrastructure exists.

Fibertech is also offering its assistance in adding its network maps to
the NTIA's goal of establishing a comprehensive nationwide inventory map
of existing broadband service capability and availability in the U.S.,
and would be available to provide its maps in a desired electronic

We ask that you review our maps and include them into your discovery
process. We hope for an open process and the ability to compete for
funded projects where our open-access fiber network model may be of
assistance to the program. We also welcome the opportunity to answer
any additional questions and look forward to the opportunity to work
with the FCC, NTIA and the USDA and help us all realize the true benefit
of high-speed broadband that these rural and underserved areas need in
order to survive, prosper and compete.

We have mailed 5 bound copies of the attached information as well. We
look forward to supporting your initiatives where appropriate.

Thank you,

Michael C. Hurley

VP - Sales & Marketing

Fibertech Networks, LLC

300 Meridian Centre

Rochester, NY 14618


US Commerce-Broadband Technologies comments 3 12 09.doc 150 KB
Fibertech thumbnail network maps.ppt 6.06 MB
US Commerce-Broadband Technologies comments 3 12 09.doc 150 KB
Fibertech thumbnail network maps.ppt 6.06 MB

Pend Oreille County Public Utility Direct #1

(Late Submission)
Attached please find the comments of Pend Oreille County Public Utility District #1

Pend Oreille NTIA-RUS 4-13-09.PDF 693.51 KB