Joint Broadband Technology Opportunities Program Request for Information

March 12, 2009
Docket Number: 

American Recovery and Reinvestment
Act of 2009 Broadband Initiatives

CTIA-The Wireless Association

(Late Submission)
See attached file.

090413 FILED CTIA BTOP Comments.pdf 69.04 KB

Paul W. Schroeder, Vice President, Programs and Policy

(Late Submission)
April 13, 2009

Ms. Anna Gomez
Deputy Assistant Secretary
National Telecommunications and Information Administration
1401 Constitution Avenue, NW
Washington, DC 20230

Dear Deputy Assistant Secretary Gomez:

On behalf of the American Foundation for the Blind (AFB), I am pleased to comment on NTIA’s plans to distribute funds made available by the American Recovery and Reinvestment Act to create broadband networks in unserved and underserved areas. We urge the NTIA to employ the most efficient processes to deliver service to the areas of highest need with the help of state and local leaders.

For nearly ninety years, AFB has worked tirelessly to expand possibilities for individuals experiencing vision loss of all ages. In doing so, AFB has pioneered the development and implementation of accessible technology and sound public policy meeting the unique needs of people who are blind or visually impaired. Our leadership was instrumental in the enactment of section 255 of the Telecommunications Act of 1996, a landmark legislative promise that telecommunications technologies and services be accessible to and usable by people with disabilities. That promise can only be fulfilled adequately through the widespread availability, affordability and accessibility of broadband services and technologies.

Fair and affordable access to information of all kinds through broadband is essential to the safety, productivity, empowerment and independence of all Americans. Significantly improved and wisely implemented broadband deployment will enable people with disabilities, particularly those with vision loss, to gain access to life-saving health, employment and educational programs and services and enable them to be better informed to timely respond to emergencies and other hazardous circumstances.

To make this possibility a more realizable reality, broadband mapping will also play a large role by allowing our states to identify the areas that need broadband first. Accountability and efficiency go hand-in-hand, and the sooner the NTIA can disperse funds to the states, the sooner broadband will begin to more effectively play a part in changing the lives of all people with disabilities. Mapping stimulus funds should be done on a priority basis and achieved through close consultation with state and local governments to exercise the most relevant judgment for best stimulating their regional economies. Many of these local governments have experience working with public-private partnerships that will aid in network construction and management.

The NTIA must also include strong provisions of transparency and accountability throughout the entire process. Specifically, state proposals to the NTIA should provide in-depth information regarding how applicants will ensure their funds and deployment reach prioritized areas that do not have access to broadband. Additionally, while NTIA must not set up unnecessary regulatory hurtles that inhibit growth and investment and subsequently dissuade potential participants from deploying broadband, we believe strongly that stimulus funds should not be used to invest in services and technologies that are not accessible to and usable by people with disabilities. America's broadband infrastructure should be built in light of current policy expectations, not the least of which is the section 255 mandate for telecommunications accessibility. To that end, the NTIA should focus its attention on those potential broadband customers both with and without disabilities who are truly unserved, namely those living where no affordable and accessible broadband services currently exist. Until mapping is completed and more detailed plans are developed, the states should be relied upon to allow proper identification of unserved areas in the near term and make sure that qualified providers with sustainable business plans are meeting expectations. Once this clear priority has been met, attention should then be turned toward the task of targeting remaining funds to underserved areas where broadband is not as widely available, affordable and accessible as it could be.

Again, thank you for the opportunity to offer comment on this important and transformative initiative.


Paul W. Schroeder
Vice President, Programs and Policy
American Foundation for the Blind

Paul W. Schroeder, American Foundation for the Blind, NTIA comments.doc 335 KB

"Shannon Menard" <>

(Late Submission)
Good Afternoon,

Please accept the attached public comment submitted by the National
Association of Regional Councils (NARC) in response to docket
090309298-9299-01. Feel free to contact me with any questions or if the
document does not come through properly.

Thank you,

Shannon A. Menard

Policy Manager

National Association of Regional Councils

1666 Connecticut Avenue, NW - Suite 300

Washington, DC 20009

tel 202.986.1032 x217, fax 202.986.1038

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NARC Broadband Public Comment - Docket 090309298.pdf 1.99 MB

Carol E. Mershon

(Late Submission)
I am one of a growing number of individuals who has developed an environmental illness in recent decades called Electromagnetic Hypersensitivity. EHS is essentially a DEBILITATING allergy to ALL man-generated sources of electromagnetic and microwave radiation, and mine really took off when the number of cell phone towers and antennas began to increase exponentially in the 90's. Broadband internet is yet another source of radiation in an environment that is already PAST its saturation point. I am begging you to STOP this INSANE proliferation of ALL sources of man-generated electromagnetic and/or microwave radiation, and this would include broadband internet! The disappearing honeybees, dying bats, and dying amphibians are already sounding an alarm! The question is - will it be too late when we finally hear the alarm? Please review the Bioinitiative Report and other links below, as well as the attached Becker Excerpts x 3. We are playing with fire.

Bioinitiative Report:

Becker Interview:

Electro Hypersensitivity - Talking to Your Doctor:

German Doctors Unite on RF Health Effects:

Mobile Phone Emissions Increase Worm Fertility:

Becker Excerpts x 3.doc 34 KB
Becker Excerpts x 3.doc 34 KB

Donald Gilroy

(Late Submission)
My response is in the from of an attachment.
please vier the attachment

Health issues with low power Wireless Communications.doc 43.5 KB

Tolly Marcus <>

(Late Submission)

I would like to join the list...

Best Regards



Tolly Marcus
CEO World Wide
fx: 313.481.6014
Aim: ZingMAX
Yahoo: tollytech
Skype: ZingMAX1

image.jpg 1.04 KB
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"Tobey, Margaret (NBC Universal)" <>

(Late Submission)
Attached please find Comments on Joint Request for Information in Docket
No. 090309298-9299-01, submitted on behalf of the organizations listed
therein pursuant to the notice published in the Federal Register on
March 12, 2009. Please contact me if you have any questions regarding
these Comments.

Margaret L. Tobey
Vice President, Regulatory Affairs
NBC Universal, Inc.
1299 Pennsylvania Ave., NW
Washington, DC 20004
202-637-4262 (O)
202-262-8480 (M)
202-637-4538 (F)

Broadband Stimulus NTIA RUS Comments PDF Final.pdf 278.87 KB

"Cohen, Thomas" <>

(Late Submission)
Attached are comments from the Fiber-to-the-Home Council on the Rural
Utilities Service broadband stimulus program. We ask that these be made
part of the official record for Docket No. 090309298-9299-01. These are
filed in PDF format. Please let me know if you wish to have them filed
in another format, e.g. Word.

Thomas Cohen

Kelley Drye & Warren LLP

3050 K Street NW

Washington, DC 20007


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FTTH Comments.pdf 3.8 MB

Greg Goldman

(Late Submission)
It is great news that the broadband expansion component of the 2009 American Recovery and Reinvestment Act includes significant funding to facilitate access to broadband services by vulnerable populations. With more than half of the nation’s low-income households still lacking broadband, this is a crucial step toward ensuring that all Americans have full access to today’s educational, employment, civic and other life opportunities.

In order to make a real difference for families, however, this funding must be properly deployed. A comprehensive package of technology services is essential, and is best delivered through established community-based organizations to which economically disadvantaged populations are already connected. Broadband service is a powerful incentive for the achievement of these organizations’ benchmarks.

"Thanks to all the trainers that have opened the door to a wonderful digital life," wrote Sharon Duckett, a Philadelphia resident who received such a package. On Philadelphia Family TIES, an online support network for individuals with disabled family members, Duckett added, "Now I have the power to expand my knowledge with endless possibilities! I will advocate for my family and network with others."

Wireless Philadelphia has pioneered an approach to providing economically disadvantaged families and communities with the technology and support necessary for full civic participation and full access to employment, education, health and other life opportunities. Experience here over the past two years has taught several important lessons when it comes to enabling families to permanently cross the digital divide:

First, demand for broadband access among economically disadvantaged families is high, but so are the financial, technical and educational barriers to access. Therefore, families need a great deal of support to secure the full set of products and services required to realize the benefits of broadband at home. These products and services are best delivered as a comprehensive package.

The package must include a computer that is set up and ready to go and broadband service that is prescreened and does not require long-term contracts or complicated installation. Also required are introductory content and hands-on training that is literacy-level appropriate and targeted to the needs and interests of the families to be served, with plenty of local, live technical support.

Second, this package is most efficiently delivered through the network of schools and other trusted community-based organizations (CBOs) to which families are already connected, instead of the traditional retail channels. By offering the package as an incentive, these organizations are better able to attract and retain clients and achieve their program goals. A costly qualification process is also eliminated.

Third, digital inclusion program participants should be given the opportunity to earn the package via “sweat equity.”

The sweat equity approach eliminates the financial, technical and educational barriers to access, provides an incentive for families to complete training and/or education programs, and at the same time supports the attainment of program outcomes that are key to funding for ongoing service delivery.

This is the innovative model that is giving Sharon Duckett and other economically disadvantaged parents of disabled children broadband access and training so they can secure special education services and supports. It is the approach through which low-income pregnant moms have earned full broadband access packages by completing the prenatal regimen and pre-employment training. Vulnerable high-school seniors have earned access and training oriented to online college admission and financial aid by achieving certain grade averages.

And new micro-enterprises who have completed a rigorous business training regimen have established an online presence and begun to generate revenue on-line, closing an additional digital divide that exists for businesses in economically disadvantaged communities.

Furthermore, members of these groups continue to interact after completing programs via social networks – like Philadelphia Family TIES – that were created to facilitate online and in-person community building. These are just a few examples — this approach can be applied to almost any group and can help almost any organization.

An independent evaluation completed last September by the OMG Center for Collaborative Learning cited WP as a model for expansion and replication. The evaluation revealed positive impacts on family employment and education, with a high degree of trickle-up and –down learning among children and other adult learners in recipients’ households and communities. (The Executive Summary and full evaluation are attached to this filing.)

It is entirely right that the Broadband Technology Opportunities Program supports not only network expansion, but also broadband adoption by low-income families. The reality though, is that for families who lack access, no single element alone is enough to enable them to permanently cross the digital divide. To be effective, real digital inclusion programs must be comprehensive, conscious of the barriers, and community-based.

12-1 WP Rapid Assessment Report Final.pdf 169.35 KB
12_1 WP Rapid Assessment Executive Summary.pdf 28.08 KB

Bala Sankar

(Late Submission)
Book Title: Web On-The-Go. Subtitle: A Preview of The Way of Living in the Wireless Web World.

Web-On-The-Go_Preview.pdf 369.01 KB

Kelvin D. Smith

(Late Submission)
Thank you for allowing me to comment

ACF7CAA.doc 122.5 KB

Nickolaus E. Leggett

(Late Submission)
My comments are included in an attached four-page Microsoft Word document.
Nickolaus E. Leggett, Inventor and Analyst

ntiarural.doc 38 KB
ntiarural.doc 38 KB

"Karl Medina" <>

(Late Submission)

Karl- representing Zing Wireless WISP providing broadband in Detroit,

Will this bring different companies an opportunity or is it MAINLY looking
to provide broadband to people without regard to who will provide it, hence
large providers will be the only beneficiaries.?

Karl Medina
fx: 313.481.6014
Aim: karltech33
Yahoo: karlmedina33
Skype: karlmonet1

image001.jpg 1.04 KB
image001.jpg 1.04 KB

Perry LaForge

(Late Submission)
The CDMA Development Group (CDG) is submitting these comments in response to the Joint Request for Information released on March 10, 2009 by the U.S. Department of Commerce’s National Telecommunications Information Administration (NTIA) and the U.S. Department of Agricultures’ Rural Utility Service (RUS) concerning the Broadband Technology Opportunities Program (BTOP). See attached.

CDG Comments to NTIA 13APR2009.pdf 38.42 KB

Tennessee Broadband Task Force

(Late Submission)
Attached are the comments of the Tennessee Broadband Task Force.

TN BB Task Force Comments_Final.pdf 72.13 KB

"Doane F. Kiechel" <>

(Late Submission)
To Whom It May Concern-

Attached please find comments of WorldNet Telecommunications, Inc. in
response to the Joint Request for Information and Notice of Public
Meetings, 74 Fed. Reg. 10716 (Mar. 12, 2009), Docket No.


Doane F. Kiechel
Fleischman and Harding LLP
1255 23rd Street, NW
Eighth Floor
Washington, DC 20037
(202) 939-7907
Counsel for Stratophone, LLC

204208_1.DOC 31.5 KB

National Rural Electric Cooperative Association

(Late Submission)
Comments of National Rural Electric Cooperative Association

Scan090413180414.pdf 2.39 MB

Level 3 Communications

(Late Submission)
Resubmit of comments originally submitted on April 13

ACF7F85.pdf 1.01 MB

City of Mansass, Virginia

(Late Submission)
Comments of the City of Manassas, VA

Manassas NTIA.pdf 218.26 KB

Dr. Gary Goff

(Late Submission)
I am writing to convey the importance of the Connected Tennessee partnership and its Computers 4 Kids program.

Led by Governor Phil Bredesen, Connected Tennessee is a public-private partnership that brings together state and local government, community organizations, business leaders, libraries, schools, healthcare institutions and technology providers in an effort to work in every Tennessee county to ensure better broadband access and computer literacy. To accomplish this, Connected Tennessee uses collaborative broadband mapping, local research, grassroots technology planning in every county and computer connectivity programs.

Through Connected Tennessee’s Computers 4 KidsSM (C4K) program, computers are distributed to children in Tennessee who need them most. To date, the C4K program has distributed more than 1,300 computers to children, families and organizations in need across Tennessee, with plans to distribute at least 1,700 more over the coming years.

As you implement the Broadband Data Improvement Act, please make every effort to ensure that Connected Tennessee and its Computers 4 Kids program is eligible for funding through the American Recovery and Reinvestment Act. As we work together toward economic recovery, it is critical for the federal government to offer funding and support to existing public-private partnerships which have proven effective in bridging the digital divide.

Thank you for your consideration.

2009 Apr 13 Connected Tennessee.pdf 108.74 KB

Nebraska Rural Independent Companies

(Late Submission)
Attached are the comments of the Nebraska Rural Independent Companies in Docket No. 090309298-9299-01.

Nebraska RIC Comments 041309.pdf 170 KB

Ali Shahnami

(Late Submission)
Please see attached document

NTIA Stimulus Bill Questionaire - ACD Telecom 03 27 2009.pdf 171.13 KB

TJCOG Cable Broadband Consortium

(Late Submission)
Attached are the comments and a summary of the comments of the Triangle J COG Council of Governments Cable Broadband Consortium

ACF7C4A.pdf 413.65 KB

Communications Workers of America

(Late Submission)
file attached

Communications Workers of America Comments - NTIA-RUS.pdf 71.47 KB

"Andrei Chakine" <>

(Late Submission)
Dear Members of the Federal Communications Commission,

Please accept the attached testimony submitted on behalf of William E.
Martin, CCTHITA President. Please don't hesitate to call me with
questions or for additional information.

Thank you for the opportunity to testify on the Commission's role in the
broadband provisions of the American Recovery Act.


Andrei Chakine

Business and Economic Development Department Manager

Central Council of Tlingit and Haida Indian Tribes of Alaska

9097 Glacier Hwy

Juneau, Alaska 99801

(907) 463-7121 phone

(907) 463-7356 fax

CCTHITA Testimony on Rural Broadband.pdf 1.55 MB

"Karl, Andrew" <>

(Late Submission)

Dear Sir or Madam:

Sage Telecom, Inc. "Sage" files in the above-referenced
docket its Comments in the matter of American Recovery and Reinvestment
Act of 2009 (the "Recovery Act") Broadband Initiatives. Should you have
any questions regarding this filing, please do not hesitate to contact
the undersigned.

Respectfully submitted,

Robert W. McCausland

Vice President and Secretary

Sage Telecom, Inc.

805 Central Expressway South

Suite 100

Allen, TX 75013-2789

Tel: (214) 495-4878

CONFIDENTIALITY NOTICE: The information contained in this ELECTRONIC
MAIL transmission is CONFIDENTIAL. It may also qualify as privileged
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Comments of Sage Telecom Inc In Response To Joint Request For Information 041309.DOC 41.5 KB


(Late Submission)

"Campanola, Mary - Washington, DC" <>

(Late Submission)
We are hoping to release the Notice of Funds Availability by the end of
this month or early July.

Mary Campanola
Outreach Coordinator
USDA Rural Development
Rural Utilities Service
Telecommunications Program
202-720-8822 (voice)
202-720-0810 (fax)


From: Alfred Barr []
Sent: Tuesday, June 23, 2009 11:15 AM
To:;; Campanola, Mary -
Washington, DC
Subject: RE: NTIA & RUS RFP and app submission Date Status
Importance: High

Ms. Brown and Campanola;

During a teleconference today with DMS of Florida, there was mentioned a
release of dates for potential release of information.

In my review of the NTIA web site,
, I am not able to
find any updates after May 18, 2009.

Can you provide us with options to review updated information on actual
or prospective dates for release of information and or of projected
application submission or RFP releases.

Thank you

Alfred Barr
Managing General Partner
Global Wireless Communications

Formerly VCS Interactive, LLC
550 N. Reo Street, Suite 300
Tampa, FL 33609
813-767-2270 - Cell phone
Web Site -

Click Hyperlink for video demo

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image001.jpg 3.48 KB
image002.gif 5.16 KB

"Steve Hall" <>

(Late Submission)
Thank you.

ARRA broadband comments 4-09.doc 155.5 KB

"NTIAHelpDesk NTIAHelpDesk" <>

(Late Submission)

>>> "John Crigler" 3/26/2009 11:06:43 AM >>>
Dear Sir/Madam --

We filed comments yesterday afternoon on behalf of Native Public Media
using the BTOP On-Line Comment Form. We completed the form and
our comments in the File Attachment section. Our attachment was in
format. We received a confirmation of the filing, but the
did not include any reference to our attached file. We would like to
confirm that you received our filing along with the attachment and
our filing (including the attachment) is acceptable for filing
with your office. Additionally, we emailed a copy of Native Public
Media's Comments (in PDF format) to

For convenience, I have attached another copy of Native Public Media's

Thank you for your assistance. We look forward to your response.


John Crigler

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Comments of Native Public Media.PDF 204.53 KB

Dale Hancock

(Late Submission)
I have a passion to build and operate the most cost effective, highest quality telecommunication system possible. The following list will provide many advantages to accomplish my vision: 1. Experience of over 30 years including Fiber to the Home certified (no need for expensive consultants) 2. I love and enjoy this business 3. I became debt free in 2007 with an excellent credit score 4. I purchased my first and only cable system in Sept. 2007 in Snow Hill NC 28580 5. Ownership includes my wife and I (no investors requesting profits) 6. Memership with the National Cable Television Coperative (NCTC) for volume discounts on programming, materials, vehicles, etc. 7. Create locals jobs while saving on expensive contractors
I want to aquire funding to take this rural area to a Fiber to the Home (FTTH) system with Docsis 3.0 which will provide 180 meg up and 120 meg down while keeping the products very affordable.
Thank you for allowing me the opportunity to share my dream.
Dale Hancock
Media Cast
1121 S.E. 2nd Street
Snow Hill NC 28580
Cell: 606.307.3163
P.S. Please include my contact info on your list.

Resume 2009.doc 49.5 KB

"Kubik Rob-P26788" <>

(Late Submission)
Please find attached comments of the WiMAX Forum in response to the
Joint Request for Information and Notice of Public Meetings, 74 Fed.
Reg. 10716 (Mar. 12, 2009), Docket No. 090309298-9299-01

Rob Kubik
WiMAX Forum Regulatory Working Group Vice-Chair

WiMAX Forum - 2009-04-13.pdf 42.05 KB

"Mafnas, Joe - Washington, DC" <>

(Late Submission)
Good Morning:

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


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

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

image001.jpg 8.59 KB
listomat-03-31-2009.pdf 593.98 KB

Sara C. Wedeman, PhD

(Late Submission)
My comment concerns Broadband Mapping and is attached.

Comment1-BBmapping.pdf 908.55 KB

M. Ciesla

(Late Submission)
Expand Funding for Broadband Development Beyond “List of Materials”

Congress recently passed the American Recovery and Reinvestment Act of 2009, parts of which authorize the Rural Utility Service (RUS) and the National Telecommunications and Information Administration (NTIA) to distribute funds totaling over $7 billion to support development of broadband internet service.

In the past the RUS developed important programs to provide loans and grants to purchase certain types of broadband infrastructure – primarily equipment such as wires, cables, and wireless hubs. However, to most effectively and efficiently promote broadband internet use, it is critical to also fund products and technologies that will be directly used by end-users. Such products and technologies can significantly enhance growth of rural broadband internet access and potentially save the government billions of dollars. Innovative technologies and products that lower the cost of adoption by end users, that make it easier for them to physically use broadband devices, that offer increased flexibility of use, and that stimulate demand are essential for the successful expansion of effective, sustainable rural broadband.

In the past, the primary method RUS has used for distributing funds has been to have the recipient organizations apply the allocated money to the purchase and installation of items from a predetermined “List of Materials” broken down into 6 categories: (1) wire and cable, (2) housing, splice cases, etc., (3) miscellaneous splicing materials, (4) electrical protective devices, (5) access, central office, and transmission equipment, wireless networks, electronic network elements, and (6) general hardware.

This earlier approach, however, excludes a few critical categories technologies for enhancing rural broadband access devices. Specifically, (a) technologies that reduce the cost of accessing, and improve the usability of end-users devices that connect to broadband networks in rural areas; (b) technologies that increase the actual usability of end-users broadband connection devices in rural areas; and (c) technologies used by end-users that promote rapid adoption of broadband access by individuals and businesses. Some of these important technologies may be currently in development and as such might not fit well into a current ‘List of Materials.” However, those technologies and products may be able to reach the broad market in large volumes within one to three years. Therefore, a modification from past funding rounds would greatly enhance development of broadband and should be strongly considered.

Investment in technology used by end-users can dramatically reduce the cost of rural broadband access by potentially billions of dollars while increasing adoption rates among the population. Moreover, such investment directly provides more jobs and directly enhances America’s competitiveness in the world through home-grown technologies and significantly improved rural broadband.
We write this letter to urge the RUS (and NTIA) to expand their loan and grant program to include – as a as a separate category or categories in addition to its “List of Materials” – the funding of products and technologies for use by end-users that can enhance rural broadband access.

Public Comment to RUS and NTIA.doc 26.5 KB

Sally Hampton

(Late Submission)
Please work for the removal of universal wireless broadband and broadband over power lines from consideration, and instead promote broadband access using only communication cables and fiber optics.
Fiber optics is the best technology and best investment long term.
Wireless infrastructure is a poor investment looking to the future, can be ugly and has potential harmful health effects. Wireless should be a last resort and temporary technology to fill in.
For profit companies should provide, in return for use of our public rights of way, fiber to every curb. Or, the infrastructure should be treated the same way we treat other important infrastructure that we all depend on and deployed as a true PUBLIC utility and not for profit.
The telecomm industry already received 200 billion in rate hikes and tax breaks to provide us fiber but pocketed the money instead. Americans are tired of being raped by these large corporations and the lack of regulations that allow them to use public assets for private profit must stop.

SCANDALFINAL92006.pdf 1.65 MB
SCANDALFINAL92006.pdf 1.65 MB

"Kristy Szabo" <>

(Late Submission)
Please find attached Filling Comments on Section 6001 of the American
Recovery and Reinvestment Act of 2009. These comments are being filed
on behalf of Farmers Mutual Telephone Company.

Kristy Szabo
On Behalf of Farmers Mutual Telephone Company

NTIA-RUS Rules Comments 4 13 09.pdf 221.24 KB

Galen Updike

(Late Submission)
See Attachment

GITA Response to NTIA RFI April 13 2009 _2_.pdf 241.47 KB

Tina Pidgeon

(Late Submission)
The comments from General Communication Inc. on the National Telecommunications and Information Administration and Rural Utilities Service queries regarding the American Recovery and Reinvestment Act of 2009 Broadband Initiatives are attached.

GCI NTIA and RUS comments 4.13.09.pdf 69.37 KB

"Richard Sherwin" <>

(Late Submission)
To Whom It May Concern:

Please find our comments on the Broadband Technology Opportunity Program

Thank you.

Richard J. Sherwin

Chief Executive Officer

Spot On Networks, LLC

Phone: 203 523 5202

Fax: 203 773 1947

No Wires, No Worries, No Waiting

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NTIA Comments letter final.pdf 82.21 KB

Robert J. Irving, Jr.

(Late Submission)
Please see attached pdf

Cricket Comments to NTIA (2009.04.13).pdf 47.98 KB

Rosa Rosales

(Late Submission)
April 13, 2009

The Honorable Anna Gomez
Deputy Assistant Secretary
Herbert C. Hoover Building (HCHB)
U.S. Department of Commerce / NTIA
1401 Constitution Avenue, N.W.
Washington, D.C. 20230

Dear Secretary Gomez:

As the largest and oldest Hispanic organization in the United States, the League of United Latin American Citizens respectfully requests the National Telecommunications and Information Administration to quickly and efficiently distribute the more than $7 billion set aside for broadband deployment and mapping in the American Recovery and Reinvestment Act of 2009.

To facilitate the dispersal of funds to unserved and underserved areas, NTIA must stipulate several provisions for any state interested in broadband funding. As the government continues to inject money into the economy, NTIA must require some method of transparency and accountability for all interested parties. This will help eliminate potential waste and ensure funds are being used properly. However, when considering the provisions to attach to broadband stimulus funding, NTIA must be careful not to require overly burdensome regulatory criteria that suppresses growth and investment. The unfortunate by-product would be lower participation in broadband stimulus programs and less deployment to communities that need it most. The focus must continue to stay on broadband deployment to these communities instead of Internet regulatory policies that go well beyond the Federal Communications Commission’s (FCC) well-established principles and undercut the Congressional intent found in the stimulus bill.

Mapping is a key component to ensuring an effective process. This will enable proper identification of areas that do not have broadband access first and deploy to those neighborhoods that need it most. Working with knowledgeable community-based organizations (CBO) to facilitate the deployment process will be most effective as they can identify qualified providers with which to partner. These CBOs know their communities well and, together with private entities, can help provide broadband access to families left behind in this digital age.

One of the main goals at LULAC is to advance the economic condition of Hispanic Americans through public-private partnerships working in conjunction with community-based organizations. We believe strongly in providing access to educational opportunities to our constituents to promote job creation and economic empowerment. With this in mind, we fully support the money for broadband expansion in communities of need and hope that Hispanics and other minorities can gain access to the life-changing opportunities that broadband provides.

As our nation continues to evolve into an e-society based on digital access and literacy, we must ensure that underserved and unserved populations are not left behind. Access to new and existing technologies is necessary to compete in the local, national and global marketplace. It not only provides efficiencies of service but, with the broadband stimulus money, will also become more affordable to communities struggling to make ends meet.

Broadband deployment and mapping will allow effective identification of areas and families that need broadband the most and provide access to information technology in an efficient and affordable manner. With a stagnant economy, Hispanic Americans and other low-income communities need educational and social opportunities to stay afloat and compete in the marketplace. The quicker NTIA can disperse broadband funding to our state and local leaders, the quicker these disadvantaged communities can gain access to tools of economic opportunity.


Respectfully submitted,

Rosa Rosales
LULAC National President

NTIA.pdf 47.07 KB

"Scott Jordan" <>

(Late Submission)
Attached please find comments regarding non-discrimination obligations of
the Broadband Technologies Opportunities Program under NTIA Docket No.

-Scott Jordan


Professor Scott Jordan

Department of Computer Science

University of California, Irvine

3029 Bren Hall

Irvine, CA 92697


Phone: 949-824-2177


Jordan_BTOP_comments.pdf 56.98 KB

Howard Lowe

(Late Submission)
See attachment, same text also included here:

Comments to NTIA regarding Broadband TOP Stimulus Grant Program

In considering requests for federal broadband stimulus funds, NTIA should give priority to:
• Networks that will use an “open access” or “open services” business model, in which the infrastructure constructed with federal funds is open in a nondiscriminatory manner to all qualified digital telecommunications service providers, and which employs a wholesale rate structure with the goal of encouraging a competitive market that offers greater choice and affordability to end users, particularly vulnerable populations.
• Networks that use BTOP funds to build new open access infrastructure in underserved and unserved areas. Underserved should be defined as an area where:
 Potential end users have access to only one terrestrial service provider
 Potential end users live in an area to which service providers have not built
 Existing service providers do not have redundant service facilities that permit immediate restoration of service in the event of an outage
 Existing service providers cannot provide at least 10 megabits of symmetrical service to end users at an affordable rate
• Entities that will use BTOP funds to build high capacity fiber optic backbones that will be fundamental to the distribution of services to unserved and underserved areas
• Non-profit or municipal open access networks that demonstrate a viable business model for a public – private partnership which creates jobs in both public and private sector companies
• Networks that will interoperate and peer with adjacent public and private fiber networks to facilitate traffic flow throughout a multi-county or multi-state geography
• Networks that serve multiple counties and can be expanded into additional underserved and unserved regions
• Networks that bring fiber service to significant community institutions such as hospitals, libraries, emergency management offices, municipal buildings, correctional facilities, schools, colleges, etc
• Networks that will serve Native American communities and provide them with a role in network oversight
• Networks that demonstrate a plan to increase digital literacy and expand demand for broadband connectivity.

 The role of the states should be to certify projects that fit into a statewide plan for expanding broadband availability, and not to prioritize projects within the State.
 Matching funds: Allow in-kind expenses to qualify for grantee match; allow federal funds from outside of Treasury (e.g. FCC/USAC) to qualify for grantee match.

Submitted by Howard Lowe, President, and Julie West, Executive Director, April 13, 2009
CBN Connect Inc. is a nonprofit 501c3.

Comments to NTIA re Broadband Stimulus 4.09.doc 232 KB

Sharon Reishus, Chair

(Late Submission)
See attached letter and information responses.

Commissioners Letter.pdf 42.25 KB
Responses NTIA-RUS 031209 Notice.doc 73 KB

Gene DeJordy, Esq.

(Late Submission)
See Attached Comments

nat comments broadband ntia apr 09.doc 44.5 KB

Thomas Terry

(Late Submission)
ARRA funds need to begin investment at the site where the broadband is needed. The home or place of business does not benefit from a mid-mile investment without an organized linkage to last mile providers. Applications need to assure a completion of the connection to the actual service site. Please see attached files.

lastmileOAN 3.2.doc 238.5 KB
lastmileOAN 3.2.ppt 3.07 MB

Consortium for School Networking/International Society for Technology in Education/National Educatio

(Late Submission)
Before The
U.S. Department of Commerce
Washington, DC 202230

In the Matter of )
Rural Utilities Service and ) Docket No. 090309298-
) 9299-01
American Recovery and Reinvestment Act of 2009 )
Broadband Initiatives )
Joint Request for Information )


The Consortium for School Networking (CoSN), the International Society for Technology in Education (ISTE) and the National Education Association (NEA) are pleased to submit these comments in response to the above captioned Joint Request for Information. CoSN is the country's premier voice in education technology leadership, serving K-12 technology leaders who, through their strategic use of technology, improve teaching and learning. CoSN’s core audiences are the chief technology officers and technology leaders in school districts. ISTE is the premier membership association for educators and education leaders engaged in improving teaching and learning by advancing the effective use of technology in PK-12 and teacher education. Home of NETS and NECC, ISTE represents more than 85,000 education professionals worldwide. NEA is the nation’s largest professional employee organization, representing 3.2 million elementary and secondary teachers, college faculty, school administrators, education support professionals, retired educators, and students preparing to become teachers.
CoSN, ISTE and NEA believe that the Broadband Technology Opportunities Program (BTOP) is an excellent resource that will complement the E-Rate program’s efforts to deliver advanced telecommunications services to our nation’s public and private schools and public libraries. Our interest in addressing the questions raised by the National Telecommunications and Information Administration (NTIA) and the Rural Utilities Service’s (RUS) Joint Request for Information (Joint Request) regarding Section 6001 of the American Recovery and Investment Act of 2009 (the Recovery Act), reflects our members’ commitment to ensuring that all of America’s students and educators gain access to broadband services which, in turn, will deliver to them the knowledge and skills they need to compete in the global economy.
I. Guidance Regarding BTOP Funding
In the Joint Notice, NTIA requests guidance on several topics related to the funding of BTOP. Our comments address the following topics: eligibility requirements for entities seeking BTOP funds; the role of states in awarding grants to eligible entities; the role retail price should play in determining whether an area is underserved or unserved; broadband mapping requirements; and the expansion of computer center capacities.

A. Eligibility Requirements
Section 6001(e) of The Recovery Act defines entities eligible for participation in BTOP as “a State or political subdivision thereof, the District of Columbia, a territory or possession of the United States, and Indian tribe…or native Hawaiian organization.”
While ISTE, CoSN and NEA understand that the Recovery Act does not clearly state that Local Education Agencies (LEAs) and Education Service Agencies (ESAs) are eligible participants under BTOP, we submit that LEAs are eligible based on a common definition of the term “political subdivision” and the plain intent of Recovery Act’s framers.
Black’s Law Dictionary defines a school district as a “a political division of a state, created by the legislature and invested with local powers of self government, to build, maintain, fund, and support the public schools within its territory and to otherwise assist the state in its educational responsibilities.” This definition was recently relied upon by an Appellate Court of Ohio, which went on to further explain that “[a] school district is clearly an entity responsible for governmental activities for the purpose of ensuring a functioning school system.” Therefore, given that LEAs receive their authority from the State to provide education services to local communities and are governed by elected officials, they can and should be considered “political subdivisions.” We request that NTIA state affirmatively that LEAs are “political subdivisions” and therefore eligible to receive BTOP funds.
Aside from this definitional issue, the Recovery Act’s language authorizing the BTOP program evidences the clear intent of its authors that K-12 educational institutions receive direct benefits through BTOP. The language explicitly references education numerous times, most notably in the sections that chart the BTOP’s mission and the bases for making awards. Specifically, the Recovery Act identifies the program’s goals as, “To accelerate broadband deployment in unserved and underserved areas and to strategic institutions that are likely to create jobs or provide significant public benefits.” The Recovery Act expands on the “strategic institutions” language by indicating that one of the program’s central purposes is to “provide broadband education, awareness, training, access, equipment and support” to, among others, “schools, libraries, medical and healthcare providers, community colleges…[and] institutions of higher education....” (emphasis added). Additionally, the Recovery Act requires NTIA to make awards based on a number of factors, including whether the grant “will, if approved, enhance service for health care delivery, education, or children to the greatest population of users in the area.” (emphasis added). Based on this language of the Recovery Act, there should be no doubt that the intent of the statute was that LEAs should be eligible to receive funds under the BTOP.
B. Consideration of State Priorities in Awarding Grants
The Joint Request asks for guidance on whether projects must first receive a State’s permission to request BTOP funds from NTIA. CoSN, ISTE and NEA believe that school district submitted projects should not require permission from the State before applying for BTOP funds, as it will slow down the application process and consequently delay the stimulative affect of such projects. As such, requiring school districts to request permission from States before applying for BTOP funds will thwart Congress’s intent in the Act, “to establish and implement the grant program as expeditiously as possible.” (emphasis added).
Moreover, school districts may understand their broadband needs better than state authorities, and therefore will be able identify those needs better than the state. This is exemplified in the E-Rate program, which allows districts to assess their needs and apply directly for support. The BTOP program should operate under similar guidelines.
Although CoSN, ISTE and NEA do not support a requirement that school district projects receive state permission before applying for BTOP funds, we recognize the states’ interest in coordinating resources within their states. Accordingly, CoSN, ISTE and NEA recommend that NTIA require that school districts notify states of their submission of applications for BTOP grants. In this way, states would have the opportunity to help direct and guide projects so that funding would be coordinated across the state and aligned with state and federal directives and programs.
Finally, CoSN, ISTE and NEA must note that the BTOP grant program provides one of the few opportunities in the entirety of the Recovery Act for school districts to apply directly for federal funding. The vast majority of new programs funded through the Recovery Act are open only to states, such as the State Fiscal Stabilization Fund and the Race to the Top grants, leaving school districts without any direct access to much-needed federal funds to restore and revitalize their local education systems. Above and beyond the merits of the preceding arguments, we contend that fairness dictates that NTIA permit school districts to apply directly for BTOP grants.
C. The Role of Retail Price in Determining Whether An Area Is Unserved Or Underserved
In the Joint Request, NTIA requests that the public provide comments on how the terms “underserved” and “unserved” are defined, and whether retail price for broadband services should be a factor in those definitions. CoSN, ISTE and NEA believe that retail price is an important factor in determining whether an area is underserved or unserved; providing broadband at prices that are too high for area residents and schools to afford would have the same effect as not providing services to an area at all. One of the central rationales for the E-Rate program, and ultimately one of its greatest successes, was ensuring that schools and libraries in low-income and high cost areas gain access to Internet connectivity that was on par with the access enjoyed by residents of wealthier and lower cost areas. We believe that NTIA can and must base the BTOP program on this very same concern. Accordingly, we urge NTIA to incorporate the concept of affordability into its definitions of underserved or unserved.
D. Broadband Mapping
The NTIA seeks comments in the Joint Notice on what level of specificity a geographic broadband map should provide about broadband services in each area. CoSN, ISTE and NEA believe that in order to provide the most accurate information about the services in each school, a broadband map must include public schools and go deeper than merely mapping connections to the school door. We think it critical that, if possible, any mapping provide detailed information about broadband capacity to individual classrooms and students. We also recommend that the collection of this information be conducted in as non-burdensome a manner as possible, capitalizing on any pre-existing, recent surveys (including data collected from school and library applicants for the E-Rate program by the Universal Service Administrative Company) that can supply the relevant information.
To evaluate the level of broadband capacity in classrooms, CoSN, ISTE and NEA recommend that NTIA collect information on how many classrooms have at least one wired broadband-level connection as well as how many broadband level wireless access points exist at each school. Compiling this information will provide a “snapshot” of classroom broadband capability at each school and greatly augment the broadband data map produced by NTIA.
However, this information about classroom broadband capability needs to be further distilled to determine the effective broadband capability for each end user. Consequently, we urge NTIA to collect information on the broadband levels for each end user computing device, including speeds at peak and off-peak hours. NTIA should then use this information to create an accurate map about available broadband resources for each student at public schools across the country.
E. Institutions Eligible for BTOP Funds to Expand Computer Center Capacities Other Than Colleges and Public Libraries
NTIA also seeks comments in the Joint Request on what institutions, other than colleges and public libraries, should be eligible to receive BTOP funds to expand computer center capacities. In response to this inquiry, CoSN, ISTE and NEA recommend that NTIA expressly include public schools and school libraries as institutions eligible to receive grants for expanding computer center capacities.
Making schools and school libraries eligible recipients of the funds allotted for expansion of public computer center capacity would complement and enhance the work that the E-Rate is doing. Whereas E-Rate prohibits schools from acquiring computers and software with program resources, the Recovery Act authorizes BTOP to fund the purchase of hardware and software to promote broadband usage in unserved and underserved areas. This expansion of hardware and software in school computer rooms and school libraries through BTOP would be a tremendous benefit to, at a minimum, students and teachers at schools receiving E-Rate support.
Ultimately, we believe that the addition of computer capacity to schools and school libraries will also provide a tremendous benefit to the public. Currently, many schools and school libraries in rural and/or low-income areas serve as the focal points of community activities and are used for continuing education and other similar purposes. The expansion of public center computing capacity at schools and school libraries would only serve to bolster those roles and provide valuable services to residents unable to access technology elsewhere.
CoSN, ISTE and NEA recognize, though, that current E-Rate program rules make it difficult for schools and school libraries to allow the public to use E-rate supported telecommunications and Internet services during non-school hours. Under the current rules, schools must cost-allocate E-Rate services if such services are used for non-educational purposes. CoSN, ISTE and NEA are seeking to eliminate this cost-allocation burden, thereby making it easier for schools to allow the public to receive additional benefits from E-Rate supported services. While we recognize that such a rule change could take some time, we are confident of success. Once that change occurs, the full fruits of expanding public computer center capacity through BTOP investments will be fully realized.
II. Additional Concerns Regarding BTOP Funding
A. Financial Contributions by Grant Applicants
Although it was not specifically mentioned in the Joint Notice, CoSN, ISTE and NEA also provide the following comments on the 20% matching requirement required under BTOP:
Given the economic downturn and the likely budget challenges faced by public entities that BTOP was designed to serve, we believe that the 20% matching requirement should be able to come in the form of cash- and in-kind contributions. Allowing these types of contributions is not without precedent, as NTIA permitted grantees under BTOP’s predecessor, the Technology Opportunities Program (TOP), to use cash- and in-kind contributions for the program’s 20% matching requirement. Accordingly, allowing cash- and in-kind contributions will not only lessen the burden on already strapped public resources but also follow the precedent NTIA established previously under TOP.
B. Non-applicability of “Unserved” and “Underserved” to K12 Schools
CoSN, ISTE and NEA endorse comments filed by EDUCAUSE that the terms “unserved” and “underserved” are not intended to and do not apply to K12 schools, thereby allowing all K12 institutions to apply for funding regardless of whether their locations are unserved or underserved by broadband services. We agree that all K12 schools should have access to BTOP funds because, as EDUCAUSE submits, “they aggregate large groups of people and have a need for high-capacity broadband connections independent of the (availability of broadband for) surrounding households."
CoSN, ISTE and NEA appreciate the Department of Commerce’s work on these BTOP issues. We look forward to continuing to assist and advise the Department of Commerce in this important undertaking.
Submitted on Behalf of CoSN, ISTE and NEA:
Jon Bernstein
Bernstein Strategy Group
919 18th Street, NW
Suite 925
Washington, DC 20006
(202) 263-2572

BTOP Comments.doc 52.5 KB

Angela Flynn

(Late Submission)
Please see attachments

April 6, 2009

Electronic Submission via

Dear Broadband Technologies Opportunities Program,

Broadband is a crucial and enjoyable technology that everyone should have access to. I laud President Obama’s Broadband Initiative to bring broadband to underserved rural areas. This is quite clearly a massive undertaking and the technology used to implement this program will have long-term ramifications. It is imperative that the sustainability and the health impacts of this undertaking be thoroughly examined and considered in the choosing of the broadband technology. Sustainability and Health must be given the highest status as part of the Selection Criteria for the program.

For these reasons fiber optics is the most desirable technology to implement. Next generation fiber optics uses less energy and will therefore contribute less CO2 than other systems. In addition to the CO2 emissions from wireless communications the RF radiation, which amplifies in crystalline structures, may be a factor in the rapid melting of Artic and Antarctic ice and in warming of the ice crystals in our atmosphere.

Fiber optics is also the clear choice for our Homeland Security needs. Fiber optics are not easily hacked into and they cause no RF interference with other communication systems. In addition they are mostly impervious to harm from nuclear radiation and any potential solar electromagnetic interference.

But, the clear reason as to why fiber optics should be used is that it will limit the amount of RF radiation the general population is exposed to. I was injured three years ago from chronic exposure to cellular antennas. I have been researching this issue extensively and I have found there is much scientific evidence, which indicates that there are biological non-thermal effects from exposure to RF radiation. I have also networked with people from all over the world who have had their health impacted by chronic RF radiation exposure. Many of these people, including myself, have had to quit our jobs and move from our homes in our effort to minimize our RF radiation exposure. I can attest from anecdotal evidence from my networking that minimizing RF radiation exposure is the only way to lesson the sensitivity to RF radiation that occurs from chronic exposure. While there is a growing population of people who have realized the source of their deteriorating health is due to RF radiation exposure there are potentially millions of people who are being harmed without realizing the cause. Doctors worldwide are reporting increases in new diseases. These increases have grown along with our growth of wireless communication antennas. Many countries in Europe and elsewhere have taken measures to limit RF radiation exposure. Doctors and scientists have issued warnings, especially for pregnant women and children to limit exposure.

The U.S. must take steps to limit exposure to RF radiation. Our federal exposure standards are outdated and only take into account thermal effects. The exposure harm is not limited to humans. Animals, birds, plants and even our climate are impacted by the increase of RF radiation due to human wireless communications.

In addition to wireless systems, Broadband over power lines will increase RF radiation exposure unless steps are taken to limit the antenna effect of our current wire lines. The braiding of communication cables and the coupling of telephone wires limit the antenna effect and should be used for any power line broadband use.

With sincere hope,

Angela Flynn
5309 Iroquois Road
Bethesda, MD 20816

Please refer to these supporting documents:

1. European Parliament resolution of 2 April 2009 on health concerns associated with electromagnetic fields

2. Pathophysiology xxx (2009) xxx–xxx
Public health implications of wireless technologies
Cindy Sage a,!, David O. Carpenter b
a Sage Associates, 1396 Danielson Road, Santa Barbara, CA 93108, USA
b Institute for Health and the Environment, University at Albany, Rensselaer, NY, USA
Received 18 January 2008; accepted 30 January 2009

3. Petition to Halt Universal Wireless Broadband, A Public Health Hazard

4. Bees, Birds and Mankind
Destroying Nature by `Electrosmog´
Ulrich Warnke

Effects of Wireless Communication Technologies
A Brochure Series by the Competence Initiative for the Protection of Humanity, Environment and Democracy

5. Power Lines as Antennas From 100 kHz to 50 MHz
Author: Ed Hare, ARRL Laboratory Manager1
Date: July 7, 2003

ARRL, Ed Hare, Laboratory Manager, 225 Main St., Newington, CT 06111, Tel: 860-594-0318, Email:, Web:

6. Fielding a Current Idea: Expoloring the Public Health Impact of Electromagnetic Radiation. (available as a html version here -

7. BioInitiative: A Rationale for a Biologically-based Public Exposure Standard for Electromagnetic Fields (ELF and RF)


Report: available at

Expressions of Concern from Scientists in the last years

Broadbandcomments.doc 63 KB
EP.Press release on EMF resolsution. APR2.09.pdf 212.26 KB
Wireless Implications.pdf 289.39 KB
to_obama.pdf 319.44 KB
ki_beesbirdsandmankind_screen.pdf 1.52 MB
Power_lines_as_antennas.pdf 60.11 KB
genuisemf_emr.pdf 293.17 KB
bioinitiativesummary.doc 59.5 KB

Michael Armstrong

(Late Submission)
Comments are provided for each question in the attached documents. Our comments are in bold italic type.

Thank you.

Michael Armstrong

ACF79E5.doc 86 KB