NTIA RUS Joint Request for Information

Date: 
November 16, 2009
Docket Number: 
0907141137-91375-05

Broadband Initiatives Program and Broadband Technology Opportunities Program

Tom Bullock

(Late Submission)
To whom it may concern:

Please see the attached file created with MS-Word 2003 containing comments in response to the Joint Request for Information (RFI) issued November 9, 2009 by RUS and NTIA regarding funding round 2 of the Broadband Initiatives Program and the Broadband Technology Opportunities Program.

The attached comments recommend only the clarification of eligibility requirements and associated terminology; they do not address any of the policy issues identified in the RFI.

Thank you,

Tom Bullock
Consortia Consulting
Phone: 402.441.4315
www.consortiaconsulting.com



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BIP-BTOP BullockComments 13Nov2009.doc 74 KB

Laura Mayhook <laura@mayhooklaw.com>

(Late Submission)
Attached please find the RFI comments of California Broadband Cooperative.

Best regards,

Laura Mayhook
MAYHOOK LAW, PLLC
www.mayhooklaw.com
T: 360.263.4340
F: 360.263.4343
M: 360.713.7633
laura@mayhooklaw.com



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CBC NTIA-RUS RFI comments 11-30-09 FINAL.pdf 1.18 MB

Gregg Vanderheiden <GV@trace.wisc.edu>

(Late Submission)




AttachmentSize
Trace Center Comments.doc 62.5 KB
ATT00001..htm 3.59 KB

Jen Leasure <jen@thequilt.net>

(Late Submission)
Please find the attached response from The Quilt and StateNets with respect to the second round of funding for BTOP and BIP.

I am available to answer any questions regarding these comments.

Thank you,

Jen Leasure
President and CEO
The Quilt
206-782-1091
jen@thequilt.net
www.thequilt.net


The Quilt
Collaborate | Influence | Inform



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Regional and State Network Round 2 Comments_F_ 20091130.pdf 102.03 KB

"Huffstickler, Karla" <KHuffstickler@wbklaw.com>

(Late Submission)
Attached please find Comments of the Wireless Communications Association International on the Joint Request for Information of the National Telecommunications and Information Administration and the Rural Utilities Service.

Karla Huffstickler
Legal Assistant
Wilkinson Barker Knauer, LLP
2300 N Street, NW
Suite 700
Washington, DC 20037-1128
202.783.4141 (phone)
202.783.5851 (fax)



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AttachmentSize
WCAI comments on RFI 11 30 09 FINAL.pdf 92.03 KB

Jeffrey Mayhook <jeffrey@mayhooklaw.com>

(Late Submission)
Regarding NTIA Docket Number 0907141137-91375-05, please find the City of Shafter’s attached response to the NTIA/RUS RFI.

Best regards,

Jeffrey Mayhook
MAYHOOK LAW, PLLC
34808 NE 14th Avenue
La Center, WA 98629
(360) 263-4340 office
(360) 263-4343 fax
(360) 609-3769 mobile
jeffrey@mayhooklaw.com
www.mayhooklaw.com

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AttachmentSize
Shafter NTIA-RUS RFI comments 11-30-09 FINAL.PDF 1.15 MB

Christopher Mitchell <christopher@newrules.org>

(Late Submission)
Attached.

Joint request for information:
Broadband Initiatives Program
and Broadband Technology
Opportunities Program

Comments of the Institute for Local Self-Reliance


Christopher Mitchell
Director, Telecommunications as Commons Initiative Institute for Local Self-Reliance http://www.newrules.org/information/
http://www.muninetworks.org
612-379-3815 x209


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ILSR-Round2-btop-bip-comments.doc 48 KB

Howard Lowe

(Late Submission)
Comments submitted by CBN Connect Inc. Plattsburgh NY November 30, 2009

I. The Application and Review Process

A. Streamlining the Applications

4. Relationship between BIP and BTOP
If an application does not meet the requirements of BIP, they should not be required to submit their application to BIP even if they are 75% rural.

B. Transparency and Confidentiality

Yes, there should be greater transparency of applications.
• All applications should be listed on the database, even if they were submitted late and accepted late.
• All application executive summaries should be posted without exception.
• All application support letters should be posted.
• There is a lot of other information that is confidential and may be proprietary and should not be published.

C. Outreach and Support

This was well done.

D. NTIA Expert Review Process

A higher standard should be used in selecting “experts”, and unpaid experts are preferable to
Federal or contractor staff with less expertise.

State review: It appears that State’s decided what criteria to use in evaluating and ranking applications. NTIA should provide criteria that is consistent across all states and aligned with NTIA’s standards and priorities.

Overlap with existing providers: this should be considered, however not all overlap is bad, given the desire to increase choice and competition. Middle mile projects encourage existing providers to bring more services into their coverage area and to enable them to reach a wider geography. That is different than approving a project that is to target a specific small area that another provider already provides service in as a last mile application.

II. Policy Issues Addressed in NOFA

1. Middle Mile Comprehensive Community Projects

For round 2 at least RUS should concentrate on middle mile open access projects because they already have a program in place for low interest loans for last mile solutions and since these last mile solutions will be enabled by having a strong middle mile open access backbone in place, the two would work well together.

We support an emphasis on Middle Mile solutions to ensure that fundamental infrastructure is in place to enable last mile solutions.

RUS and NTIA should favor comprehensive community projects, and should look for viable (strong business plan, proper regulatory credentials, shovel ready, etc.) public private partnerships where the applicant can demonstrate consensus among all participants on the need for the project and show credible evidence of economic impact. Service to vulnerable populations should be a criterion to encourage applicants to reach people who otherwise may not attain broadband access.

Overlap with existing providers: this should be considered, however not all overlap is bad, given the desire to increase choice and competition. Middle mile projects encourage existing providers to bring more services into their coverage area and to enable them to reach a wider geography. That is different than approving a project that is to target a specific small area that another provider already provides service in as a last mile application.

2. Economic development impact should be a criterion, and applicants should demonstrate a long term (five year) projection of the impact from their project, with appropriate documentation on job growth and retention from end users, economic development agencies, local government, etc. This is after all, the goal of the stimulus program.

3. Targeted Populations

We do not support a dedicating a specific amount of money for targeted populations. Generally, projects in these areas are able to show the need for broadband and should be reviewed with all other applications. The criteria should not be the number of people covered as this does not make sense when reviewing both urban and rural applications alongside one another. In this case, no rural applications would ever get funded. The scoring should be such that rural applications that can demonstrate economic impact for their area should be given points and the criteria of the 10,000 households passed should be removed. That criterion is what hurt rural applications as well as Native American applications.

Other Changes
B. Program Definitions:

The definitions were confusing. Remote area qualification is very troublesome, and made no sense in our 100% rural region, where we were not qualified as remote because of a city larger than 20,000 that is within 50 miles, but is in another state on the other side of a major lake. Also, it was impossible to avoid some incumbent providers’ public notice responses because census blocks they serve were touched by the mapping application even though they provide minimal service there.

C. Public Notice of Areas Served

The public notice process needs rethinking and redesign. In our case, comments were filed by Time Warner and Charter who stated that they provide internet access in our area. We are a Middle Mile application and neither Time Warner nor Charter offer wholesale broadband to other service providers in an open access fashion as a middle mile network. Our application and network are not in competition with them because they do not offer these services and they should not have been allowed to submit comments. This is also the case for Keene Valley Video and Willsboro Cable. This process should be changed. Open access is the wave of the future, and the benefits to the end user will come from networks that carry all qualified providers, even if that means building where existing providers currently offer services.

F. Reasonableness

The PE certification demonstrates the reasonableness of the pricing used in the application and this validation should remain.

Otherwise, this criterion is very subjective and should be modified. It is going to be expensive to get this infrastructure in place in rural areas in relation to the number of people that will be positively impacted by the investment. This was the same for the rural electrification funding that was done in the 1930s. this criterion should not be a disadvantage for rural applicants vs urban applicants, there are two different standards needed.


Howard Lowe
President, CBN Connect Inc.
Julie West
Executive Director, CBN Connect Inc.
194 U.S. Oval
Plattsburgh, NY 12901
518.564.2214


AttachmentSize
CBN Connect comments submitted to RUS, NTIA 11.30.09.docx 74.14 KB
CBN Connect comments submitted to RUS, NTIA 11.30.09 (1).docx 74.14 KB
CBN Connect comments submitted to RUS, NTIA 11.30.09 (2).docx 74.14 KB
BIP EXECUTIVE SUMMARY(8.26).doc 41 KB
CBN Connect comments submitted to RUS, NTIA 11.30.09 (3).docx 74.14 KB

"Andros, Peter" <PAndros@PattonBoggs.com>

(Late Submission)
Attached for filing in the above referenced docket please find the comments of Educational Services Network, Corp. I can be contacted at this email or the phone number listed below if any additional information is required. Thank you.

Peter Andros
Sr. Paralegal
Patton Boggs LLP
202-457-6472


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AttachmentSize
Revised RFI Comments2.doc 121.5 KB

"DelNero, Matthew" <mdelnero@cov.com>

(Late Submission)
Attached please find the comments of the Public Broadcasting Service in response to the NTIA and RUS joint request for information (Nov. 16, 2009). The comments are attached in both .pdf and .doc format. Thank you.


Matthew S. DelNero
Covington & Burling LLP
1201 Pennsylvania Ave., NW
Washington, DC 20004-2401
202.662.5543 (office)
202.778.5543 (fax)
mdelnero@cov.com
This message is intended only for the addressee shown above. It may contain information that is privileged, confidential or otherwise protected from disclosure. Any review, dissemination or use of this transmission or its contents by persons other than the addressee is strictly prohibited. If you have received this transmission in error, please reply immediately and delete the transmission.





AttachmentSize
PBS - Joint RFI Comments to NTIA and RUS - SCRUBBED on 11-30-09 16_30.DOC 71 KB
PBS Comments to Joint RFI - Nov 30 2009.pdf 27.72 KB

"Winstead, Don" <Don.Winstead@LASPBS.STATE.FL.US>

(Late Submission)


Please find attached comments for the National Telecommunication and Information Administration (NTIA) and Rural Utilities Service (RUS) Joint Request for Information. These comments are submitted in accordance with the instructions found in the Federal Register posting of November 16, 2009. These comments are submitted on behalf of the State of Florida. Thank you.

Don Winstead
Special Advisor
to Governor Charlie Crist
Telephone: 850-487-7914 (Assistant, Joan Morgan)
Direct Line: 850-488-5228
Cell: 850-528-6099
Email: Don.Winstead@myflorida.com









AttachmentSize
FL OER Response to Joint RFI 11-24-2009.pdf 191.28 KB

Laura Mayhook <laura@mayhooklaw.com>

(Late Submission)
Attached please find the comments of Rural Broadband Now!

Best regards,

Laura Mayhook
MAYHOOK LAW, PLLC
www.mayhooklaw.com
T: 360.263.4340
F: 360.263.4343
M: 360.713.7633
laura@mayhooklaw.com



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RBN NTIA-RUS RFI comments 11-30-09 FINAL.pdf 1.15 MB

"Ruth, Latonya Y." <Latonya.Ruth@bingham.com>

(Late Submission)
The attached document is being submitted on behalf of RCN Telecom Services, Inc. Please forward all questions or comments directly to Thomas K. Steel (tom.steel@rcn.net or 617-670-2906). Thank you.

Latonya Ruth




________________________________
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RCN.doc 718.5 KB

"Evslin, Tom" <Tom.Evslin@state.vt.us>

(Late Submission)


Tom Evslin
Chief Techology Officer
State of Vermont


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Round2comments.pdf 369.81 KB

Stephen Coran <scoran@rinicoran.com>

(Late Submission)
Attached for filing are the Comments of the Wireless Internet Service Providers Association in connection with the above-referenced Joint Request for Information concerning the second NTIA/RUS funding round. Please contact me if there are any questions. Thank you.

Stephen E. Coran
Rini Coran, PC
1140 19th Street, NW, Suite 600
Washington, D.C. 20036
202.463.4310 - voice
202.669.3288 - cell
202.296.2014 - fax
scoran@rinicoran.com - e-mail
www.rinicoran.com
www.telecommunicationslaw.com

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AttachmentSize
DOC113009-007.pdf 4.44 MB

Matthew Ames <mames@millervaneaton.com>

(Late Submission)
Attached for filing are the Comments of Loudoun County, Virginia, OpenBand Multimedia, LLC, and Roadstar Internet, Inc., in response to the Joint Request for Information of NTIA and RUS, published in the Federal Register on Nov. 16, 2009.

Please contact me with any questions.

Matthew C. Ames
mames@millervaneaton.com
Miller & Van Eaton
Suite 1000
1155 Connecticut Avenue, N.W.
Washington, D.C. 20036-4320
phone (202)785-0600
fax (202)785-1234
www.millervaneaton.com
This message is intended only for the use of the individual or entity to which it is addressed, and may contain information that is privileged, confidential and exempt from disclosure under applicable law.
If you have received this communication in error, please delete it and destroy any copies, do not distribute it, and notify us immediately by email: mames@millervaneaton.com or via telephone: (202) 785 0600.


AttachmentSize
00151114.pdf 156.21 KB

Joe Valandra <jmv1956@gmail.com>

(Late Submission)

Please accept the attached as comments to the ARRA relating to Tribal applications and evaluation.

Joe Valandra

P Please consider the environment before printing this e-mail




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Joint RFI Comment Letter -11302009-.pdf 233.95 KB

Dr. D.E. Haley

(Late Submission)
Please read the attached email concerning my dismay over proposed changes for the second round of proposals for broadband access funds created by stimulus money and offered by the National Telecommunications and Information Administration. I was delighted to discover that the NTIA has invited comments such as the one attached. Do let me know if you need more information.


--
Darryl E. Haley, Ph.D.
Associate Professor of English
- Technical Writing Program Director
- Director of Computer Assisted Writing
Department of English
East Tennessee State University
Campus Box 70683
Johnson City, TN 37614
(ofc) 423.439.5991
(fax) 423.439.7193


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NTIA Letter 091117.doc 44 KB

"Peter J. Pratt - PrattNetworks LLC" <pjpratt@prattnetworks.com>

(Late Submission)

Comments of PrattNetworks LLC, a telecommunications consultancy, are attached.

Our comments are relative to the use of the List of Materials program of the Rural Utilities Service (RUS).


- Peter J. Pratt, Principal

- PrattNetworks LLC





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image001.gif 906 bytes
Comments of PrattNetworks LLC.doc 124.5 KB

Kate Marie <kate.marie@ucdmc.ucdavis.edu>

(Late Submission)

Thank you for the opportunity to comment on issues relating to the implementation of the Broadband Initiatives Program and the Broadband Technology Opportunities Program. The attached comments are submitted on behalf of Dr. Thomas Nesbitt, Associate Vice-Chancellor for Strategic Technology & Alliances, UC Davis Health System School of Medicine, and Associated Director for the California Telehealth Network.

Please do not hesitate to contact me if you have any questions or need additional information. Best regards.



Kate Marie, MPA
Research & Grant Manager
Center for Health & Technology
UC Davis Medical System
2300 Stockton Blvd., Suite 3900
Sacramento, CA 95817
916-734-8858 (office)
916-949-8139 (cell)
916-734-3580 (fax)
kate.marie@ucdmc.ucdavis.edu


AttachmentSize
NTIA comments final 2009.11.30.pdf 2.21 MB

Steve Pastorkovich <SFP@opastco.org>

(Late Submission)
Attached please find comments of the Organization for the Promotion and Advancement of Small Telecommunications Companies (OPASTCO) in response to the Request for Information in Docket Number 0907141137-91375-05.
Per the instructions in the Federal Register, the comments are in Word format (read-only).

Please feel free to contact me if you have any questions.

Thank you for your attention,

Steve Pastorkovich
OPASTCO Business Development Director/
Senior Policy Analyst
202-659-5990 ext. 217
http://www.opastco.org


AttachmentSize
OPASTCO.doc 100 KB

Michael Griffin

(Late Submission)


"leera@gtlaw.com" <leera@gtlaw.com>

(Late Submission)
To Whom it May Concern:

Please find attached, in PDF format, comments from TracFone Wireless, Inc. in response to the Request for Information in Docket Number 0907141137-91375-05.

Also attached in Word (2003) format is a copy of the comments, without the attachments since they were in PDF format and unable to be converted.

Should you have any questions please contact Mitchell F. Brecher, counsel to TracFone Wireless, Inc.

Thank you.

Raymond Lee
Administrative Assistant
Greenberg Traurig LLP | 2101 L Street N.W. | Washington, D.C. 20037
Tel 202.533.2346 | Fax 202.331.3101
leera@gtlaw.com | www.gtlaw.com

Mitchell Brecher
Shareholder
Greenberg Traurig LLP | 2101 L Street N.W. | Washington, D.C. 20037
Tel 202.331.3152 | Fax 202.261.0152 | Cell 301-509-8998
BRECHERM@gtlaw.com | www.gtlaw.com


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AttachmentSize
TracFone - Comments to NTIA and RUS sent 11-30-09.pdf 811.48 KB
NTIA_RUS Comments.DOC 59 KB

"Grozier, Richard" <Richard.Grozier@qwest.com>

(Late Submission)


________________________________________
This communication is the property of Qwest and may contain confidential or
privileged information. Unauthorized use of this communication is strictly
prohibited and may be unlawful. If you have received this communication
in error, please immediately notify the sender by reply e-mail and destroy
all copies of the communication and any attachments.


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091130 Qwest Comments NTIA-RUS.pdf 2.71 MB

"Camicia, Joe@CIO" <Joe.Camicia@state.ca.gov>

(Late Submission)


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California Comments.docx 63.99 KB

"Keyes, David" <David.Keyes@seattle.gov>

(Late Submission)
Please find attached the comments from the Communities Connect Network on the Request for Information on the Broadband Stimulus Program, Docket 0907141137-91375-05. I am submitting these comments on behalf of Betty Buckley, the Executive Director of the Communities Connect Network, who was unavailable to submit these electronically due to travel.

Betty may be reached directly at 509-690-0530.

- David Keyes
206-291-4817


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CCN Comments on RFI.pdf 73.57 KB

"Landry, Andrew" <ALandry@preti.com>

(Late Submission)

Enclosed for filing in the above-captioned matter, please find the Comments of FairPoint Communications, Inc. in response to the Joint Request for Information issued by the National Telecommunications and Information Administration and the Rural Utilities Service on November 16, 2009.
Thank you for your attention in this matter.
Andrew Landry, Esq.
Preti Flaherty Beliveau & Pachios
45 Memorial Circle, PO Box 1058
Augusta, ME 04332-1058
Tel. 207.623.5300
Fax 207.623.2914
<>

________________________________________
In accordance with Internal Revenue Service Circular 230, we hereby advise you that if this E-mail or any attachment hereto contains any tax advice, such tax advice was not intended or written to be used, and it cannot be used, by any taxpayer for the purpose of avoiding penalties that may be imposed on the taxpayer by the Internal Revenue Service.

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AttachmentSize
FairPoint Cover Letter 113009.pdf 26.37 KB
FairPoint Written Comments re RFI 113009.DOC 109 KB

"Nighan, Michael" <mnighan@afsnetworks.com>

(Late Submission)
Dear Sir/Madam:

Attached please find a copy American Fiber Systems, Inc.’s comments filed in response to the Joint Request for Information issued by the Rural Utilities Service and the National Telecommunications and Information Administration (Docket No. 0907141137-91375-05).

Michael J. Nighan
Sr. Director - Regulatory Affairs and Contract Management
American Fiber Systems, Inc.
585.785.5837
??Please consider the environment before printing this e-mail


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AFS_Rusin_NTIA_RUS_Filing_113009.pdf 295.63 KB

"Forkner, Adam (EOHED)" <Adam.Forkner@state.ma.us>

(Late Submission)
Dear Sir / Madam:

On behalf of Secretary Gregory Bialecki, attached please find comments, along with a cover letter, from the Massachusetts Executive Office of Housing and Economic Development. These comments are in response to the joint RFI issued by the RUS and the NTIA and published in the Federal Register on November 16, 2009.

Thank you for this opportunity.


Sincerely yours,

Adam Forkner



Adam H. Forkner
Policy Advisor
Executive Office of Housing and Economic Development
One Ashburton Place, Room 2101
Boston, MA 02108
617.788.3624 (ph)
617.788.3605 (fax)
617.721.3479 (cell)
adam.forkner@state.ma.us


AttachmentSize
Cover letter for joint RFI comments from Massachusetts EOHED.pdf 172.83 KB
RUS - NTIA Joint RFI Comments from Massachusetts EOHED.pdf 173.89 KB

"Anderson, Carla" <carla@e-copernicus.com>

(Late Submission)
Dear Assistant Administrator Villano and Deputy Associate Administrator Wilhelm,

I am resubmitting/transmitting the joint comments filed by Martin L. Stern at 12:59 p.m. today on behalf of Hughes Network Systems, LLC, WildBlue Communications, Inc., EchoStar Satellite Services L.L.C., and ViaSat Inc. (‘ViaSat”)(collectively, the "Broadband Satellite Commenter’s") as there appears to be an issue with his email submission.

Mr. Stern submitted both Word and Adobe formats in an effort to ensure that one of the file formats would be acceptable to the system. When we checked the website to verify that the documents were received, the documents do not appear as submitted. We would like to confirm that our documents were received and are viewable.

I also included Mr. Stern’s original send for your reference.

Thank you for your time on this matter.

For your reference, this is the message we see when we open the website:

BIP/BTOP Request for Information, Docket No. 0907141137-91375-05 | "Stern, Marty" | 12:59:00 PM
BIP/BTOP Request for Information, Docket No. 0907141137-91375-05
Monday, November 30, 2009, 12:59:00 PM | "Stern, Marty"
Attached please find the joint comments of Hughes Network Systems, LLC, WildBlue Communications, Inc., EchoStar Satellite Services L.L.C., and ViaSat Inc. (‘ViaSat”)(collectively, the "Broadband Satellite Commenters") in response to the Joint Request for Information (“RFI”) released by the Rural Utilities Service (“RUS”) and the National Telecommunications and Information Administration (”NTIA”) in the captioned docket. For convenience, we are attaching a pdf and a locked Word version of these comments. Please direct any questions regarding these Joint Comments to the undersigned, or to one of the representatives of the Broadband Satellite Commenters, cc'd above.

Respectfully submitted,

Martin L. Stern
K&L Gates LLP
1601 K Street, NW
Washington, DC 20006
Direct Dial: 202-661-3700
Mobile: 202-236-0865
Fax: 202-778-9100
marty.stern@klgates.com
Counsel for Hughes Network Systems, LLC


This electronic message contains information from the law firm of K&L Gates LLP. The contents may be privileged and confidential and are intended for the use of the intended addressee(s) only. If you are not an intended addressee, note that any disclosure, copying, distribution, or use of the contents of this message is prohibited. If you have received this e-mail in error, please contact me at marty.stern@klgates.com.

Carla A. Anderson |SVP/COO | e-Copernicus | 317 Massachusetts Ave. NE: Suite 200 | Washington, DC 20002 | Office: 202.292.4603 | Mobile: 202.498.6936 | Fax: 701.794.3356

From: Stern, Marty [mailto:marty.stern@klgates.com]
Sent: Monday, November 30, 2009 12:59 PM
To: broadbandrfi@ntia.doc.gov
Cc: Dean Manson; Bob Koppel; Dean.Olmstead@echostar.com; Tom.Moore@viasat.com
Subject: BIP/BTOP Request for Information, Docket No. 0907141137-91375-05
Importance: Low

Attached please find the joint comments of Hughes Network Systems, LLC, WildBlue Communications, Inc., EchoStar Satellite Services L.L.C., and ViaSat Inc. (‘ViaSat”)(collectively, the "Broadband Satellite Commenters") in response to the Joint Request for Information (“RFI”) released by the Rural Utilities Service (“RUS”) and the National Telecommunications and Information Administration (”NTIA”) in the captioned docket. For convenience, we are attaching a pdf and a locked Word version of these comments. Please direct any questions regarding these Joint Comments to the undersigned, or to one of the representatives of the Broadband Satellite Commenters, cc'd above.

Respectfully submitted,

Martin L. Stern
K&L Gates LLP
1601 K Street, NW
Washington, DC 20006
Direct Dial: 202-661-3700
Mobile: 202-236-0865
Fax: 202-778-9100
marty.stern@klgates.com
Counsel for Hughes Network Systems, LLC


Joe Franell

(Late Submission)
This is sent in response to your RFI dated November 16th. For your convenience, a copy of these comments is attached in *.pdf form.


Broadband Initiatives Program
Rural Utilities Service
U.S. Department of Agriculture
1400 Independence Avenue, SW
Stop 1599
Washington, D.C. 20250


November 19, 2009


As a telecommunications professional, I have been looking forward with anticipation to the broadband stimulus program. I know that you are aware of much of the hard data that directly relates robust internet access to a healthy economy. Additionally, enhanced healthcare and educational opportunities through fast and easy access to broadband technologies clearly translate into a higher quality of life. That is what I want for Eastern Oregon and our country as a whole.
Unfortunately, my great anticipation turned to equally great disappointment as I dug into the rules that were released on Monday, July 6, 2009, in the form of a Notice of Funds Availability (NOFA). I realized that as so often is the case, the “devil is in the details”. In the case of the original NOFA, there are a number of points that I believe precluded many worthy projects from even being submitted during the “first round”.
First, any company that has a project that is “rural” must apply with RUS. This put companies like Eastern Oregon Telecom (EOT) at a disadvantage because the RUS program is comprised of low interest loans or a loan/grant combo as opposed to the 80%/20% grant/match available through BTOP. Since EOT has never received RUS funding before, other companies would receive priority consideration ahead of us. It is true that the NOFA states that programs not funded through RUS may be considered by BTOP; however, there is no guarantee and since those programs would get to the BTOP review team later than pure BTOP submissions, it is difficult to believe that they would be able to receive equal consideration. I recommend that any rural project should have the opportunity to compete for 80/20 grants.
I was also disappointed in the requirement to have complete design plans that are stamped by an engineer. Given the short suspense, this requirement made it very difficult for a company with our resources to have a hope of submitting. It took the NTIA and RUS almost five months to define the original rules and then to expect a complete business plan with stamped design work to be submitted as part of an application in just over 30 days was not reasonable especially if a company was planning to build fiber to the premise. I recommend that stamped plans not be a requirement until 120 days after approval of the project.
The fact that projects are required to be census block centric also provides challenges that I am certain were not foreseen while writing the NOFA. Below is a map showing the census blocks for the Hermiston area. If we use block 9513 as an example, you can see that there are only two small population centers; Stanfield and Echo. The remainder of the census block is made up of large farms and the Cold Springs Reservoir. The requirement to serve an entire census block makes it very difficult to develop a sustainable business plan for a truly robust broadband deployment. And yet, both of those communities have K-12 educational systems and other targeted anchor tenants. This area, within just a few miles of two Interstate highways; in the heart of some of the best agricultural land in Oregon, desperately needs better connectivity. Those two small towns could be healthier, better educated, and enjoying stronger economies if only they had real access to the internet. I don’t know how that is possible under the rules that were presented. The housing density or opportunity per mile in the rest of the census block is so sparse as to make any business case, even with stimulus money, difficult at best and in reality, probably impossible. I recommend that projects based on population centers, not census blocks, be considered in the next round.



The definition of “underserved” in the original NOFA excluded many worth projects in that it had the effect precluding any residential infrastructure programs in an area where a minimal level of broadband, even first generation DSL, is generally available. In many cases, just because DSL is advertised, doesn’t mean that is available to a significant portion of the population. Recommendation: Amend the definition of “underserved” to clarify that only one, rather than two, of the definitional options be met.
I also have difficulty understanding the government retaining interest in projects for the “life of the facilities”. While I understand that since taxpayer dollars are being invested in a project, this is similar to USF investments in telephony infrastructure. That program has worked marvelously without the government retaining ownership of all of the rural phone companies across America. My board of directors would not be comfortable spending the time and resources needed to build broadband infrastructure and then expend the resources to manage it if we could not ever effectively leverage it with another lender for future expansion of the business. It seem intuitively counter-productive in the long term to the goal of expanding access by effectively dead-ending a project with government ownership. I recommend removing this language and perhaps implementing similar controls as are now used under the USF.
Finally, there should be some mechanism to allow “coalition” projects to be considered. Prior to the first NOFA, there was a group of Oregon based telecommunications companies that had proposed to leverage each other’s core competencies to provide a state-wide solution for bringing broadband to rural Oregon. The solution we presented to the Governor’s office would have provided broadband to more than 180 un-served and underserved communities including 450,000 additional Oregonians. This would have included fiber to the anchor tenants in each of those communities including 358 K-12 and higher education facilities, 248 medical facilities and providers, and 82 libraries. Since we would have partnered together, the cost reductions in accomplishing this would have been significant allowing completion of all of the above for under $130 million. Unfortunately, the NOFA did not allow for this type of project.
I appreciate your support and the good work that you do on behalf of our country and am certainly willing to assist in any way needed to make this next round of funding more effective and efficient.

Respectfully,

Joseph Franell
General Manager & C.E.O.
Eastern Oregon Telecom
1475 N. First Street
Hermiston, OR 97838

Desk - (541) 289-7010
Main - (541) 289-7000
Fax - (541) 564-4342

jfranell@eotnet.com

www. eotnet.com


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EOT Response to RFI.pdf 2.07 MB

Dave Spencer <dspencer@noanet.net>

(Late Submission)
To whom it may concern:
Please consider our attached response to the BTOP RFI. Thanks,

Dave Spencer, COO NoaNet
208.343.6477


AttachmentSize
BTOP RFI Response 113009.pdf 58.83 KB

"Tricia K. Olson" <tolson@kansascommerce.com>

(Late Submission)
To Whom it May Concern:

Attached you will find the Kansas Department of Commerce’s response to the recently posted NTIA and Rural Utility Service (RUS) joint Request for Information.

Sincerely,
Tricia K. Olson
Personal Secretary to Acting Secretary Thornton
Kansas Department of Commerce
1000 SW Jackson, Suite 100
Topeka, KS 66612-1354
(785) 296-2741
(785) 296-3665 (fax)
www.kansascommerce.com



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electronicbroadbandlet11-30-09.doc 211.5 KB

"Rummel, Jeffrey" <Rummel.Jeffrey@ARENTFOX.COM>

(Late Submission)
Attached are the Comments of The University of Arkansas for Medical Sciences in Docket No. 0907141137–91375–05 (RIN: 0660-ZA28; RIN: 0572-ZA01).

Jeffrey E. Rummel
Partner

Arent Fox LLP | Attorneys at Law
1050 Connecticut Avenue, NW
Washington, DC 20036-5339
202.715.8479 DIRECT | 202.857.6395 FAX
rummel.jeffrey@arentfox.com | www.arentfox.com

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Document.pdf 780.35 KB

Matthew Ames <mames@millervaneaton.com>

(Late Submission)
Attached is a Word version of the comments filed earlier today (time-stamped 3:31 pm) on behalf of Loudoun County, Virginia, OpenBand Multimedia and Roadstar Internet. The prior attempt included the comments as a pdf attachment, but the attachment appears not to have been accepted.

Matthew C. Ames
mames@millervaneaton.com
Miller & Van Eaton
Suite 1000
1155 Connecticut Avenue, N.W.
Washington, D.C. 20036-4320
phone (202)785-0600
fax (202)785-1234
www.millervaneaton.com
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AttachmentSize
00151129.DOC 95 KB

"Bhatt, Hardik" <hardik.bhatt@cityofchicago.org>

(Late Submission)
Hello,
Attached please find City of Chicago's comments and response to the RFI for second round of BTOP funding.

Thank you.

Hardik Bhatt
Chief Information Officer
Innovation & Technology
50 W Washington St #2700,
Chicago IL 60602
(312) 742 0667
This e-mail, and any attachments thereto, is intended only for use by the addressee(s) named herein and may contain legally privileged and/or confidential information. If you are not the intended recipient of this e-mail (or the person responsible for delivering this document to the intended recipient), you are hereby notified that any dissemination, distribution, printing or copying of this e-mail, and any attachment thereto, is strictly prohibited. If you have received this e-mail in error, please respond to the individual sending the message, and permanently delete the original and any copy of any e-mail and printout thereof.


AttachmentSize
Chicago BTOP Comments Round 2 Final Draft.pdf 99.17 KB

"Edge, Joe D." <Joe.Edge@dbr.com>

(Late Submission)
Sirs:
Please see attached the Comments of Open Range Communications, Inc. on the Request for Information issued by NTIA and RUS on November 16, 2009. Copies are provided in both Word and pdf formats. If you have any questions please contact me at the address below.

Joe D. Edge, Esquire
Drinker Biddle & Reath LLP
1500 K Street, N.W., Suite 1100
Washington, DC 20009
Phone: 202-842-8800
Direct: 202-842-8809
Fax: 202-842-8465
Email: joe.edge@dbr.com



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AttachmentSize
digital_.pdf 598.94 KB
Comments Stimulus Application Process 11-19-jrl doc (2400709_2) (2).DOC (2403683_2).DOC 86.5 KB

Rebecca Schwartz <RSchwartz@tiaonline.org>

(Late Submission)
Please find attached the filing of the Telecommunications Industry Association in response to NTIA and RUS Request for Information regarding Docket No. 0907141137-91375-05

Thank you.

Rebecca Schwartz, Esq.
Director, Regulatory and Government Affairs
Telecommunications Industry Association (TIA)
10 G Street NE Suite 550
Washington, DC 20002
(202) 346-3248 (office)
(703) 395-7511 (cell)

TIA Members can now find our Listserv emails on our website at http://www.tiaonline.org/gov_affairs/committees_divisions/listserv.cfm




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NTIA-RUS Second RFI Comments_FINAL.pdf 120.5 KB

"Lopatkiewicz.Stefan@dorsey.com" <Lopatkiewicz.Stefan@dorsey.com>

(Late Submission)
Ladies and Gentlemen: Please accept the comments of the above referenced entity in response to the RUS/NTIA joint second RFI <> .
Regards, Stefan
Stefan M. Lopatkiewicz
Of Counsel
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
D O R S E Y & W H I T N E Y LLP
1801 K Street, Suite 750
Washington, DC 20006

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Thank you.


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RFI(2)_Comments.pdf 630.67 KB

"Bocher, Robert DPI" <Robert.Bocher@dpi.wi.gov>

(Late Submission)
FYI:

Please find attached our comments regarding round 2 of the BTOP/BIP ARRA broadband grant program. If you have any questions, please contact me.

-Bob
________________________________
Bob Bocher, Technology Consultant
Wisconsin Dept. of Public Instruction
Division for Libraries, Technology and Community Learning
Madison, WI 53707-7841 - 608-266-2127 - robert.bocher@dpi.wi.gov



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Wisconsin DPI BIP BTOP Comments.pdf 280.29 KB

"Jensen, Cheryl" <cjensen@ci.tacoma.wa.us>

(Late Submission)
Attached please find a letter from Mayor Bill Baarsma of the City of Tacoma, Washington.

AttachmentSize
20091130155033778.pdf 161.47 KB

"Perez, Tony" <Tony.Perez@seattle.gov>

(Late Submission)
Please accept these comments on behalf of the City of Seattle. You can contact Tony Perez at tony.perez@seattle.gov or at 206.386.0070 if you have any questions.

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Seattle_RFI_comments.doc 60 KB

Benjamin Sanborn <bensanborn@me.com>

(Late Submission)
Attached please find the comments of the Telephone Association of Maine in response to the BTOP/BIP Request for Information.

-Ben Sanborn




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TAM RFI Comments.pdf 70.82 KB
ATT00001..txt 794 bytes

"Kenefick, Paul (Paul)" <Paul.Kenefick@alcatel-lucent.com>

(Late Submission)
Please see the attached. Thank you.

Paul Kenefick
Vice President, Public Affairs
Americas Region
Alcatel-Lucent
1100 New York Avenue, NW
Suite 640
Washington, DC 20005
202-312-5901 (Office)
202-412-4356 (Mobile)




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ALU Comments to Round 2 RFI.doc 93.5 KB

"Brenner, Daniel L." <dlbrenner@hhlaw.com>

(Late Submission)
On behalf of the National Cable & Telecommunications Association and the United States Telecom Association, attached is their joint filing in the captioned dockets in response to the Joint Request for Information.


DANIEL BRENNER, PARTNER
HOGAN & HARTSON LLP
Columbia Square, 555 Thirteenth Street, NW, Washington, DC 20004
direct +1.202.637.5532 | tel +1.202.637.5600 | fax +1.202.637.5910
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NCTA_USTelecom NTIA-RUS filing Nov.30, 2009 (2).DOC 81 KB

"Herrera, Mitsuko" <Mitsuko.Herrera@montgomerycountymd.gov>

(Late Submission)


Mitsuko R. Herrera | Cable Communications Administrator | Montgomery County MD
mitsuko.herrera@montgomerycountymd.gov | 240-773-2288 main | 240-777-2928 direct


mjohnson@natoa.org


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Montgomery County NTIA-RUS Comments 11-30-09.doc 131 KB

Ann Mony <AMony@NCTA.com>

(Late Submission)
Good afternoon:

Please find attached NCTA’s Comments in response to the Joint Request for Information.

Thank you,

Ann Mony
Administrative Assistant, Legal Department
National Cable & Telecommunications Association
25 Massachusetts Avenue, NW - Suite 100
Washington DC, 20001
Phone: 202-222-2458
Fax: 202-222-2446




AttachmentSize
NCTA RFI Comments.pdf 101.97 KB

"Brian B.K. Min" <bmin@nubron.com>

(Late Submission)

NUBRON INC.
3160 De La Cruz Blvd.
Suite 207
Santa Clara, CA 95054
http://www.nubron.com
408-855-0009

30 November 2009

To: Jonathan S. Adelstein,
Administrator, Rural Utilities Service
U.S. Department of Agriculture
1400 Independence Avenue, SW
Stop 1599
Washington, DC 20250

and

Lawrence E. Strickling,
Assistant Secretary for Communications and Information
U.S. Department of Commerce,
HCHB Room 4887
1401 Constitution Avenue, NW
Washington, DC 20230.

Subject: Response to

DEPARTMENT OF AGRICULTURE
Rural Utilities Service
RIN: 0572–ZA01

DEPARTMENT OF COMMERCE
National Telecommunications and Information Administration
Docket No.: 0907141137-91375-05
RIN: 0660_ZA28

Broadband Initiative Program and Broadband Technology Opportunities Program

e-mail to broadbandrfi@ntia.doc.gov


Dear Sirs:

NUBRON INC. consults for satellite communications and manufacturing and, in response to the above RFI, would like to offer the following comments.

(1) For example, should any steps be undertaken to adjust applications for satellite systems that provide nationwide service, but are primarily intended to provide access in remote areas and other places not served by landline or wireless systems?
[II. Policy Issues Addressed in the NOFA A. Funding Priorities and Objectives. 4. Other Changes.]

NUBRON INC. Comments:

Absolutely. In recent years, a number of satellite broadband systems have been constructed primarily to serve unserved and underserved areas including those in rural areas. The footprints of satellite systems typically cover a large area and, although the initial investment is relatively high, the economy of the scale more than compensates the high initial expense offering the most economical bandwidth to many of those areas. The very fact that in many unserved and underserved areas the only available broadband service today is the satellite service speaks for itself for the economical efficiency of the satellite systems.

Unfortunately the satellite systems have been specifically excluded in the first round of this funding. To exclude the satellite systems and subsidize other less economical systems will actually harm the long term economical efficiencies against the statutory Purposes of the Recovery Act: to provide investments needed to increase economic efficiency by spurring technological advances in science and health; to invest in transportation, environmental protection, and other infrastructure that will provide long-term economic benefits.

Satellite systems are an infrastructure consisting of space assets and ground assets. Only the space assets should typically be replaced every 15 years.


(2) Should they be modified to include a specific factor relating to the affordability of broadband service or the socioeconomic makeup of a given defined service area, and, if so, how should such factors be measured? Should the agencies adopt more objective and readily verifiable measures, and if so, what would they be? How should satellite-based proposals be evaluated against these criteria? [II. Policy Issues Addressed in the NOFA B. Program Definitions]

NUBRON INC. Comments:

Again, absolutely and absolutely. Broadband technologies are still evolving. All proposals must be required to include a metric for affordability. This will help RUS and NTIA to determine which of currently available technologies will survive in the long run consistent with at least two of the statutory Purposes of the Recovery Act: to provide investments needed to increase economic efficiency by spurring technological advances in science and health; to invest in transportation, environmental protection, and other infrastructure that will provide long-term economic benefits.

Affordability (i.e., the economy of a given technical solution) can be easily measured by such metric as $/megabit/user/month when this is estimated without taking the subsidized or grant portion into account.

(3) Mobile platforms such as passenger airplanes and trains must be considered to be unserved or underserved areas.

Broadband to mobile platforms marries the transportation infrastructure to all objectives of broadband technology opportunities program with enormous economic impact. They are consistent with all of the statutory Purposes of the Recovery Act: to assist those most impacted by the recession; to provide investments needed to increase economic efficiency by spurring technological advances in science and health; to invest in transportation, environmental protection, and other infrastructure that will provide long-term economic benefits; and to stabilize state and local government budgets.

In particular, airline passengers must have access to Internet. According to Bureau of Transportation Statistics, in 2008 the United States’ population in transit amassed 811.4 billion passenger miles per year or approx. 270 million passenger hours per year in air without access to Internet. The reason for this is, although some technical means currently exist, the business model with the long term viability of those technologies has never been proven.

Private investment is not enough for this. It is now history that only a few years ago the Boeing Company built a satellite based system with a large investment but failed to materialize it as a viable business. Today, both terrestrial based and satellite based systems vie for some segments of airplane routes, domestic and international. BTOP funding for this purpose will be well spent for a lasting and great economic impact.

To accommodate a program benefiting the population in transit, BTOP must redefine “the geographical areas” to include mobile platforms that serve all population in transit, not only for those inside the geographical U.S. territory but also for those outside the geographical U.S. territory since the U.S. mobile platforms are still the U.S. territory serving the U.S. population whether inside or outside the geographical U.S. territory.

Very Truly Yours,





Brian B.K. Min, Ph. D
General Manager
(408) 855-0009 (W)
(650) 799-1572 (M)


AttachmentSize
BTOP_RFI_Response_NUBRON_INC.doc 44 KB
BTOP_RFI_Response_NUBRON_INC_Signed.pdf 42.95 KB

Jennie Rios <jennie.r@ccgconsult.com>

(Late Submission)
Broadband RFI

Provided in Microsoft Word 2003




Jennie M. Rios
National Account Executive
Communications Consulting Group, Inc.
Corporate Offices
330 Clematis Street, Suite 211
West Palm Beach, FL 33401
Office: (561) 228-8495
Toll Free: (866) 901-0337
Cellular: (561) 420-5481
Fax: (561) 835-9312
www.ccgconsult.com











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USDA broadband RFI from CCG.doc 221.5 KB