NTIA RUS Joint Request for Information
NTIA RUS Joint Request for Information
Date:
November 16, 2009
Docket Number:
0907141137-91375-05
Broadband Initiatives Program and Broadband Technology Opportunities Program
Greg Monroe <gjmonroe@merit.edu>
Attached is Merit Network's comment for NOFA Round 2.
--
Greg Monroe
Merit Network, Inc.
Grants, Development Writer
& Marketing Coordinator
gjmonroe@merit.edu
734.717.3810
Thomas Sachson <tsachson@gmail.com>
Please find enclosed our comment letter in response to the Joint Request For Information (RFI) from the National Telecommunications Information Administration (NTIAÂ) and Rural Utilities Service (RUSÂ) on the suggested improvements to the Second Round of Funding under the Broadband Technology Opportunities Program (BTOP).
Kind regards,
Thomas Sachson
Attachments:
-- BTOP RFI Sachson 11-29-2009
"Anderson, Carla" <carla@e-copernicus.com>
Dear Assistant Administrator Villano and Deputy Associate Administrator Wilhelm:
On behalf of Sree Tangella, CEO of New EA dba as Flow Mobile, please find Flow Mobile’s comments regarding Round II ARRA funding. These comments are in response to the Joint Request for Information (RFI) issued by RUS and NTIA ~ Docket No. 0907141137-91375-05.
We ease of use are attaching two formats of our RFI filing. Word and Adobe. The Adobe file contains Mr. Tangella’s signature.
Please feel free to contact me if you have any questions or issues with these documents. I can be reached at stangella@flowmobile.com. You may also contact Gregory Rohde or Carla Anderson at 202.292.4603 or glr@e-copernicus.com / carla@e-copernicus.com.
Thank you in advance for considering our comments. Mr. Tangella’s contact information is:
Sree Tangella
CEO
Flow Mobile
1915 N. Kaveney Drive
Bismarck, ND 58501
Office: 701.255.9500
Email: stangella@flowmobile.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
David Honig <dhonig@crosslink.net>
"Morris, Evan" <emorri05@harris.com>
Comments of Harris Corporation
Docket number 0907141137-91375-05
Joint RUS-NTIA Request for Information
If there are any problems with the document please contact Evan Morris by phone at (202) 729-3702 or by e-mail at evan.morris@harris.com.
<
"Julkowski, Amy" <Amy.Julkowski@ci.portland.or.us>
Hello-
I have been asked to forward to you for your consideration. Please let me know if you have any questions.
Thank you,
Amy
Amy M. Julkowski
Executive Assistant to Dan Bates,
Director of Government Relations
City of Portland mailcode 131/410
p 503-823-1036
f 503-823-3014
Brent Stoddard <Brent.Stoddard@mesaaz.gov>
Attached is the City of Mesa’s response to the Request for Information (RFI) on the second, and last round, of grants for the Recovery Act Broadband Technology Opportunities Program (BTOP).
Brent Stoddard
Government Relations
City of Mesa
Office 480-644-5796
Cell 602-769-6821
Brent.Stoddard@mesaaz.gov
Victoria Proffer <victoria@stlbroadband.com>
Please find attached our RFI for NOFA 2.
Sincerely,
Victoria Proffer - President/CEO
StLouisBroadband.com
ShowMeBroadband.com
Rural Missouri Wireless Project.
314.974.5600 * Fax 573.747.4756
Follow us on Twitter.com @stlbroadband
SBA Certified WOSB
[cid:image003.jpg@01CA71D0.D57B14F0]
Maud Naroll
Maud Naroll
Chief Planner
Budget & Planning Division
209 East Musser Street, Room 200
Carson City, Nevada 89701
v 775.684.0223
c 775.287.2723
mnaroll@budget.state.nv.us
Gayle Schultz <GSchultz@westu.org>
Administrator Strickling,
Please see the attached letter from the City of West University Place, Texas concerning the Broadband Technology Opportunities Program.
Thank you,
Gayle Schultz
Gayle Schultz
Executive Assistant
City of West University Place
West University Place TX 77005-2899
Phone: 713-662-5812
Fax: 713-662-5305
E-mail: gschultz@westu.org
John Windhausen <jwindhausen@telepoly.com>
This version corrects a few formatting flaws in the SHLB Coalition comments filed a few minutes ago.
Thank you,
John Windhausen
John Windhausen, Jr.
Telepoly Consulting
(202) 256-9616
Mark Pruner <mark@webcounsel.com>
Please find our comments on the 2nd Round NOFA RFI.
Thank you for this opportunity to comment,
Mark Pruner
__________________________________________
NATIVE AMERICAN BROADBAND ASSOCIATION
Mark Pruner 203-969-7900
President mark@webcounsel.com
__________________________________________
TSTCI Member Services <tstci@tstci.org>
Attached to this message are the comments of Texas Statewide Telephone Cooperative, Inc. (TSTCI) in response to the RUS and NTIA Joint Request for Information published in the November 16, 2009 issue of the Federal Register.
The comments are provided in Word format as specified in the filing instructions. A copy in pdf format is also attached for you convenience in posting online.
If you have any questions or require additional information, please contact Cammie Hughes at 512-343-2587 or email tstci@tstci.org
"Fishel, Alan" <Fishel.Alan@ARENTFOX.COM>
Attached is the Internet2 comments in word format as well for docket number 0907141137-91375-05
Alan G. Fishel
Partner
Arent Fox LLP | Attorneys at Law
1050 Connecticut Avenue, NW
Washington, DC 20036-5339
202.857.6450 DIRECT | 202.857.6395 FAX
fishel.alan@arentfox.com | www.arentfox.com
CONFIDENTIALITY NOTICE: This e-mail and any attachments are for the exclusive and confidential use of the intended recipient. If you received this in error, please do not read, distribute, or take action in reliance upon this message. Instead, please notify us immediately by return e-mail and promptly delete this message and its attachments from your computer system. We do not waive attorney-client or work product privilege by the transmission of this message.
________________________________________
IRS Circular 230 disclosure: To ensure compliance with requirements imposed by the IRS, we inform you that, unless expressly stated otherwise, any U.S. federal tax advice contained in this communication (including any attachments) is not intended or written to be used, and cannot be used, for the purpose of (i) avoiding penalties under the Internal Revenue Code or (ii) promoting, marketing or recommending to another party any transaction or matter addressed herein.
"Solomon Balraj (solomon_balraj@darkstrand.com)" <solomon_balraj@darkstrand.com>
Dear Sir or Madam,
Attached are Darkstrand Inc’s formal written comments to the above referenced RFI. Please acknowledge receipt of this submission. If you have any questions, please let me know. Thank you for attention to this matter.
Yours Truly,
Solomon F. Balraj, JD, PMP, CPF
Program Director
Direct - (312) 589-2029
Mobile - (312) 802-1445
Home - (309) 369-5548
E-Mail - Solomon_Balraj@darkstrand.com
This e-mail (including any attachments) may contain information that is private and confidential. If you received this e-mail in error, please delete it from your system without copying it and notify sender by reply e-mail.
Aaron Fischbach
Please find attached our response to the November 16 Request for Information pertaining to the broadband programs. It is an Adobe pdf file.
Thank you.
___________________________________________
Aaron Fischbach
Director of Policy Development and Applied Research
Rural Community Assistance Partnership, Inc.
1522 K Street NW, Suite 400
Washington, DC 20005
202-470-1571 or 800-321-7227
202-408-8165
afischbach@rcap.org
http://www.rcap.org
For a free subscription to the Safe Drinking Water Trust eBulletin,
visit http://www.watertrust.org.
Brian Backus
Amended version with the attachment (which was not included in the prior email).
From: Backus, Brian
Sent: Monday, November 30, 2009 2:15 PM
To: 'broadbandrfi@ntia.doc.gov'
Cc: 'Bamberger, James (OCLA)'; Marler, Dirk A.
Subject: Comments on RUS and NTIA Joint Request for Information - Amended Submission
Please substitute the attached for the Washington State law and justice organizations’ original submission.
Brian Backus
Administrative Office of the Courts
360-705-5320
brian.backus@courts.wa.gov
Ryan Nichols <rnichols@digitalimpactgroup.org>
To whom it may concern:
Attached please find Digital Impact Group’s response to the RUS/NTIA Joint Request for Information regarding the Broadband Initiatives Program and the Broadband Technology Opportunities Program. This document was created using Microsoft Office Word 2007 (SP2).
Please feel free to contact us via the information below with any questions.
Thanks!
Contact Information
Greg Goldman, CEO
(215) 990-5998
ggoldman@digitalimpactgroup.org
Ryan Nichols, Director of Communications
(267) 210-3185
rnichols@digitalimpactgroup.org
[cid:image001.jpg@01CA71D9.91DBBF20]
RYAN NICHOLS
Communications Officer
rnichols@digitalimpactgroup.org
121 South 13th Street, 4th Floor
Philadelphia, PA 19107
O
|
215.627.3560 x104
F
|
215.627.3515
C
|
267.210.3185
digitalimpactgroup.org
Stacey Brigham <Sbrigham@tcatel.com>
Dear Sir or Madam,
Attached please find TCA’s comments to the joint Request For Information released by NTIA and RUS seeking comment on the BIP and BTOP programs.
Sincerely,
Stacey Brigham
TCA
1975 Research Parkway, Suite 320
Colorado Springs, CO 80920
P: (719) 266-4334 F: (719) 266-4335
sbrigham@tcatel.com
Carrie McGuire <cmcguire@alawash.org>
Hello,
The American Library Association’s response to the joint Request for Information is attached to this message.
Thank you,
Carrie McGuire
Director, Program on Networks
American Library Association Office for Information Technology Policy
1615 New Hampshire Ave NW
Washington, DC 20009
202-628-8410
Alyssa Clemsen <alyssa.clemsen-roberts@ibec.net>
To Whom it May Concern,
I do not see our comments posted. Please advise.
Thank you,
Alyssa Clemsen Roberts
Government Affairs Coordinator
International Broadband Electric Communications, Inc.
(256) 456 - 1429 Office
(509) 339 - 5336 Mobile
alyssa.clemsen@ibec.net
From: Alyssa Clemsen [mailto:alyssa.clemsen-roberts@ibec.net]
Sent: Friday, November 20, 2009 9:49 PM
To: 'broadbandrfi@ntia.doc.gov'
Cc: 'Steve Turner'
Subject: RFI
Please see attached comments (Word 2003).
Thank you,
Alyssa Clemsen Roberts
Government Affairs Coordinator
International Broadband Electric Communications, Inc.
(256) 456 - 1429 Office
(509) 339 - 5336 Mobile
alyssa.clemsen@ibec.net
"Lay, Tim" <tim.lay@spiegelmcd.com>
<
Comments of the City of Palo Alto, California, in response to the Request for Information to be filed in Docket No. 090714113791375-05.
Any questions should be directed to the undersigned.
Respectfully submitted,
Tim Lay
Tillman L. Lay
Spiegel & McDiarmid LLP
1333 New Hampshire Ave., NW
Washington, DC 20036
202-879-4000
Direct: 202-879-4022
Fax: 202-393-2866
E-mail: tim.lay@spiegelmcd.com
Counsel for the City of Palo Alto, California
"Andros, Peter" <PAndros@PattonBoggs.com>
The filed comments were from DBC and NRTC, not Educational Services Network, Corp as originally stated in the filing email. Thank you.
________________________________________
From: Andros, Peter
Sent: Monday, November 30, 2009 5:00 PM
To: 'broadbandrfi@ntia.doc.gov'
Cc: Didden, Carly; Murphy, Rebecca
Subject: Dkt. No. 0907141137-91375-05
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
DISCLAIMER:
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Sybil Anne Strimbu <strimbu@lojlaw.com>
Attached please find the Comments of EarthLink, Inc. and New Edge Network, Inc. on the NTIA and RUS joint Request for Information (Docket Number 0907141137-91375-05).
SYBIL ANNE STRIMBU
Firm Administrator and Paralegal
LAMPERT, O’CONNOR & JOHNSTON, P.C.
1776 K Street NW, Suite 700 | Washington, DC 20006
202-887-6230 tel | 202-887-6231 fax
www.lojlaw.com
This message is intended only for the use of the addressee and may contain information that is PRIVILEGED and CONFIDENTIAL, and/or may contain ATTORNEY WORK PRODUCT. If you are not the intended recipient of this message, you are hereby notified that any dissemination of this communication is strictly prohibited. If you have received this communication in error, please erase all copies of the message and its attachments and notify us immediately. If you have found any unintended metadata in any document attached to or included in this message, please notify us immediately. Thank You.
Sue Platner <sue.platner@northridgegroup.com>
Please find attached comments of Rural Broadband Corporation in response to NTIA’s Broadband Initiatives Program and Broadband Technology Opportunities Program Docket No. 0907141137-91375-05, Request for Information.
Please call me , or Jeb Brown, CEO of Rural Broadband Corporation 301-518-5985, if there are any questions related to the attached comments.
Sincerely,
Susan M. Platner
President
The Northridge Group, Inc.
9700 W. Higgins Road, Suite 820
Rosemont, IL 60018
847 692 6722 office
847 612 1416 cell
"Hansel, Anthony" <ahansel@covad.com>
On behalf of Covad Communications Company, attached are comments for submission in NTIA/RUS Docket No. 0907141137-91375-05. Please contact me if you have any questions concerning this filing.
Anthony Hansel
Covad Communications
(202) 220-0410
Sakura Saunders <sakura.saunders@gmail.com>
Docket Number: 0907141137–91375–05
Comments attached in pdf and rtf formats.
--
Sakura Saunders
Regulatory Research Coordinator
Prometheus Radio Project
phone: 215-727-9620 ext. 517
cell: 415-287-3737
sakura@prometheusradio.org
Bonnie Lorang <blorang@mitstel.com>
Attached are the comments to the RFI issued by RUS and NTIA. Thank you.
Bonnie Lorang
MITS - Montana Independent Telecom Systems
blorang@mitstel.com
MITS members, providing quality telecommunications service to rural Montanans for over fifty years, include Nemont Telephone Cooperative, Inc., Project Telephone Co., Triangle Telephone Cooperative, Inc., Central Montana Communications, Inc., Northern Telephone Cooperative, Inc., InterBel Telephone Cooperative, Inc., and Mid-Rivers Communications.
Chris Borek <chrisb@azulstar.com>
Please feel free to contact me with any questions.
Christopher Borek
Vice President Corporate Development
[cid:image003.jpg@01CA71D7.BB769AA0]
1051 Jackson St.
Grand Haven, MI 49417
(M) 616.843.1040/(F) 616.842.1104/ (E) chrisb@azulstar.com
John Hoffman <jhoffman@zerodivide.org>
On behalf of ZeroDivide, please find attached recommendations to the U.S. Department of Commerce and the U.S Department of Agriculture in response to the Joint Request for Information on the Broadband Technology Opportunities Program and Broadband Initiatives Program published in the Federal Register, Vol. 74, No. 219 / Monday, November 16, 2009.
Thank you,
John Hoffman
Director, Business Development
ZeroDivide
415.773.0388 x314
425 Bush Street, Suite 300
San Francisco, CA 94108
zerodivide.org
Join ZD on Facebook
http://www.facebook.com/ZeroDivideorg
Follow ZD on Twitter
http://twitter.com/zerodivideorg
"Hohman, Anne Kathryn" <aHohman@doitt.nyc.gov>
Please find attached the comments of the City of New York in response to the Joint Request for Information on the Broadband Initiatives Program and Broadband Technology Opportunities Program, Docket Number: 0907141137-91375-05.
Best,
Kate Hohman
Project Manager
New York City Department of Information Technology and Telecommunications
75 Park Place, 9th Floor
New York, NY 10007
Phone: (212) 513-6484
Fax: (212) 788-6528
Jen Leasure <jen@thequilt.net>
----- Original Message -----
From: Jen Leasure
To: broadbandrfi@ntia.doc.gov
Sent: Monday, November 30, 2009 1:37 PM
Subject: Joint Comments from The Quilt and StateNets for Docket Number: 0907141137-91375-05
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
Geoff Feiss <gfeiss@telecomassn.org>
Attached are the Comments of the Montana Telecommunications Association (MTA) in response to the Joint Request for Information by RUS and NTIA in Docket No. 0907141137-91375-05.
Please feel free to call or reply if you have any questions.
Respectfully submitted,
Geoff Feiss
Montana Telecommunications Association
406.442.4316 (office)
406.594.0424 (mobile)
[cid:3342437683_3613054]
Serving Montana’s telecommunications industry for 55 years
NOTE: this communication may contain confidential and privileged material not intended for use or dissemination beyond the recipient.
"Rupy, Kevin" <krupy@ustelecom.org>
USTelecom submits the attached comments in the above referenced proceeding.
Should you have any questions, please contact the undersigned.
Kevin G. Rupy
Director, Policy Development
USTelecom
607 14th Street, NW
Suite 400
Washington, DC 20005
Phone: (202) 326-7276
krupy@ustelecom.org
Tom Carroccio <tom.carroccio@carrocciolaw.com>
Ladies and Gentlemen:
Attached please find the Comments of the Communications Finance Association, which are submitted in response to the RUS and NTIA "Joint Request for Information", which was published in the Federal Register on November 16, 2009.
Please advise if there is any problem with this transmission.
Tom Carroccio
A. Thomas Carroccio
1140 – 19th Street, N.W., Suite 600
Washington, D. C. 20036
202.296.8870 (Direct)
202.296.8877 (Fax)
Tom.Carroccio@CarroccioLaw.com
This electronic message and any files transmitted with it are solely for the use of the intended recipient, and may be confidential or privileged. Unless you are the intended recipient, you are prohibited from using, copying, disclosing or otherwise disseminating this message or any information or file contained in this message. If you are not the intended recipient of this message, please notify A. Thomas Carroccio by telephone (202.296.8870) or e-mail (Tom.Carroccio@CarroccioLaw.com), and delete this message and its contents from all your computers without retaining any copy. Thank you.
Mark W. Keeling
Sorry, here's a word document version of the comments filed yesterday in .pdf format. Hope this helps. Thanks!
<
CONFIDENTIALITY / PRIVILEGE NOTICE This transmission and any
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Laura McClanahan <lmcclanahan@wtownky.org>
Please find attached the Comments of the City of Williamstown, Kentucky, to go before the Rural Utilities Service, Department of Agriculture, and National Telecommunications and Information Administration, Department of Commerce.
Should you have any questions pertaining to the attached information, I ask that you please not hesitate to contact the City of Williamstown at 859-824-3633.
Thank you.
Laura McClanahan
City of Williamstown
400 North Main Street
P. O. Box 147
Williamstown, KY 41097
(859) 824-3633
(859) 824-6320 - fax
lmcclanahan@wtownky.org
20091125_094225;
"Miller, Margaret" <mmiller@dowlohnes.com>
Dear NTIA:
I am attaching (in PDF format) the Comments on the National EBS Association in response to the Joint RFI on BIP and BTOP implementation.
Respectfully Submitted,
Meg
Margaret L. Miller
Attorney at Law
1200 New Hampshire Avenue, NW Suite 800 Washington, DC 20036-6802
T 202-776-2914 M 202-415-3170 F 202-776-4914
E mmiller@dowlohnes.com
www.dowlohnes.com
____________________________________________________
This message from the law firm of Dow Lohnes PLLC may contain confidential or privileged information. If you received this transmission in error, please call us immediately at (202)776-2000 or contact us by E-mail at admin@dowlohnes.com. Disclosure or use of any part of this message by persons other than the intended recipient is prohibited.
Sara Wedeman
Please see my response, in the form of a word document, attached.
Sincerely,
Sara C Wedeman
Sara C. Wedeman, PhD
BECG-Behavioral Economics Consulting Group
t: 215.242.5415 m: 267.825.4044 skype:auroraz7
"Merchant, Monisha" <Monisha.Merchant@Level3.com>
Please see attached.
If you need further information, please contact me.
Regards,
Monisha Merchant
-----------------------------------------
Monisha M. Merchant
Director, Product Management
Intercity Wavelength Services
Level 3 Communications, LLC
o: (720) 888-6037
e: monisha.merchant@level3.com
Unless otherwise noted, the information in this e-mail is proprietary and confidential and only intended for the recipients addressed in this e-mail. This information should not be distributed to third parties without expressed written consent from Level 3. Quotes provided are only valid for 30 days.
Thomas M Disselhorst <tdisselhorst@uttc.edu>
Attached in Word 2003 format are the comments of United Tribes Technical College to the request for information published in the November 16, 2009 Federal Register by:
Broadband Initiatives Program, Rural Utilities
Service, U.S. Department of Agriculture,
1400 Independence Avenue, SW, Stop
1599, Washington, DC 20250, and
Broadband Technology Opportunities
Program, National Telecommunications
and Information Administration, U.S.
Department of Commerce, HCHB Room
4887, 1401 Constitution Avenue, NW
Washington, DC 20230.
A one page executive summary is attached as a separate document.
Thomas M. Disselhorst
Attorney for United Tribes Technical College
3315 University Drive
Bismarck, ND 58504
Tel. 701-255-3285 Ext. 1238
Wireless: 701-421-1646
CONFIDENTIALITY NOTICE: This message is intended only for the use of the individuals to which this e-mail is addressed, and may contain information that is privileged, confidential and exempt from disclosure under applicable laws. This message should not be released, transferred, revealed, transmitted, copied or otherwise distributed to anyone but the intended recipients unless authorized in a similar electronic message by the above individual. If you have received this e-mail in error, please notify the sender immediately and delete this e-mail from both your "mailbox" and your "trash." Thank you.
James Driessen
"Hightower, Lauren" <lhightower@connectednation.org>
If possible please use the attached version vs what was sent at 5pm today. I apologize for any confusion. Also, please let me know if you would prefer to have access to this document in a different format.
Thank you,
Lauren Hightower
Lauren A. Hightower
Manager, Policy & Research Communications
Connected Nation
(502) 706-1414
LHightower@connectednation.org
www.connectednation.org
________________________________________
From: Hightower, Lauren
Sent: Monday, November 30, 2009 5:02 PM
To: broadbandrfi@ntia.doc.gov
Subject: Comments of Connected Nation to RFI, Docket Number: 0907141137-91375-05, RIN: 0660-ZA28
To whom it may concern,
Please find attached comments from Connected Nation to RFI, Docket Number: 0907141137-91375-05, RIN: 0660-ZA28.
Sincerely,
Lauren Hightower
Lauren A. Hightower
Manager, Policy & Research Communications
Connected Nation
(502) 706-1414
LHightower@connectednation.org
www.connectednation.org
Susan Walters <susan.walters@cetfund.org>
[cid:image003.png@01CA71B8.7F5AAAD0]
To Whom It May Concern:
The attached doc is a word doc with a docx format.
Thanks you.
Susan E. Walters
Senior Vice President
California Emerging Technology Fund
susan.walters@cetfund.org
5 Third Street, Suite 520 l San Francisco, CA 94103 l www.cetfund.org
James Losey <losey@newamerica.net>
Please see the attached comments from the New America Foundation's Open Technology Foundation et al.
Please let us know if there is any issues in opening the file.
James Losey
202 596 3417
losey@newamerica.net
Stacey Brigham <Sbrigham@tcatel.com>
Before the
U.S. DEPARTMENT OF AGRIGULTURE
Rural Utilities Service
U.S. DEPARTMENT OF COMMERCE
National Telecommunications and Information Administration
Washington, D.C.
In the Matter of )
)
Broadband Initiatives Program and ) RIN: 0660ZA28
)
Broadband Technology Opportunities Program ) Docket Number: 0907141137-91375-05
Comments of TCA
I INTRODUCTION
TCA provides the following comments in response to NTIA and RUS’s joint Request for Information (RFI). NTIA and RUS seeks guidance on several issues related to the Broadband Initiatives Program (BIP) and the Broadband Technologies Opportunity Program (BTOP). TCA takes this opportunity to comment on several issues from the RFI, which if modified would improve the application process in the next window of funding.
TCA is a consulting firm that performs financial, regulatory, management, and marketing services for over one hundred and sixty small, rural local exchange carriers (LECs) and their affiliates throughout the United States. Several TCA clients submitted BIP and BTOP applications during round one and several others are considering applying in the next round. Accordingly, TCA files these comments on behalf of its clients.
II. RURAL APPLICANTS SHOULD NOT BE REQUIRED TO APPLY TO RUS
TCA does not agree that infrastructure applicants proposing to serve an area in which 75% or more of the area is defined as rural should be required to submit their application to RUS. While TCA appreciates NTIA and RUS’s desire to efficiently distribute federal funds, requiring a rural company to apply for a loan when it is not in a position to take on debt is a deterrent to many small companies applying for funds for their unserved areas. Additionally, this requirement places unnecessary burden on the applicant as well as the reviewers. Applicants are required to submit a separate set of financial documents for RUS and NTIA, regardless of
whether or not the BIP program will work for their business plan. Then, RUS must review the application to determine that it indeed will not qualify for a loan or loan/grant combination and then pass the application on to NTIA for their review. If it is understood from the beginning that the applicant, although serving a rural area, requires a grant to fund the project or that they are only interested in the BTOP program, they should be allowed to apply directly to NTIA.
III. DEFINITION OF REMOTE SHOULD BE ELIMINATED
TCA suggests the agencies eliminate the current definition of remote from 50 miles from the limits of a non-rural area. Instead, TCA proposes that RUS consider all unserved areas as eligible for up to 100% grant funding. Additionally, TCA suggests that the agencies consider population density in the scoring of the applications. TCA recommends the following scale to be used: 1 point for areas that have 25-21 households per square mile, 2 points for areas that have 20-16 households per square mile, 3 points for 15-11 households per square mile, 4 points for 10-6 households per square mile, 5 points for 5 or less households per square mile.
IV. COMPREHENSIVE COMMUNITY PROJECTS SHOULD NOT BE THE TOP PRIORITY
TCA agrees that funding middle mile projects is essential to bringing broadband to many unserved and underserved areas. The cost of middle mile transport can deter last mile providers from increasing speeds to their customers. However, TCA contends that the priority of the funding should remain expanding broadband to all customers in unserved and underserved areas. TCA is concerned that if funding is limited to connecting anchor institutions within communities, this American Recovery and Reinvestment Act goal may not be met. Finally, TCA suggests that if the agencies change the focus of funding, that they also implement rules that will ensure that the entire communities benefit from the middle mile projects, not just anchor institutions.
V. CURRENT SERVICE PROVIDER RESPONSE PROCESS SHOULD BE MODIFIED
TCA thanks NTIA and RUS for giving current service providers an opportunity to respond to applications with proposed funded service areas that overlap with their current service area. However, the response process in the first funding window was overly burdensome to current service providers. TCA suggests two changes to the process in the next window. First, the community lists in the mapping tool should be generated from the maps drawn by the applicant and included in the application database. This will assist current service providers with sorting through the applications to find those with proposed funded service areas that overlap their current service area. Currently, the community list is created by the applicant and, in several cases, it was incomplete or inaccurate.
Second, allow respondents to enter information once and overlay these maps over the applicants proposed funded service areas. When looking at maps drawn in the mapping tool, it appears that the viewer can see all proposed funded service areas within a region as well as areas that are approved for funding. This raises questions whether a “master†map or database exists where the information is being obtained. If this is the case, then it would be preferable for respondents to draw their entire service area(s) once and provide the availability of broadband within that area(s). This would provide the agencies a more accurate and comprehensive understanding of a current service provider’s area during their review.
VI. METHODS OF SUPPORT AND OUTREACH NEED IMPROVEMENT
TCA commends NTIA and RUS on their multiple methods of disseminating information to applicants and the public. TCA relied on the workshops, publishing the guidance manuals, FAQs and the helpdesk and found each provided varying degrees of assistance. However, all of these methods of support and outreach are in need of improvement for the next round of funding. Most importantly, there needs to be better communication between the agencies, because messages were sometimes contradictory. For example, on September 28, 2009, TCA posed a question to RUS, NTIA and the helpdesk and received three different and contradictory responses.
The workshops were helpful for applicants to receive preliminary information, but there were contradictions on how to interpret the Notice of Funds Availability between the sessions and between the workshops. Additionally, attendees were told at the Boston and Albuquerque workshops that only applications that advanced to step two of the application process would be posted on the Public Notice Filings site, resulting in confusion when all applications were posted.
The application guidance manual was also a useful tool. However, the manuals that were provided in round one were formatted based on the printable application and not the online application. Revising the manuals in the next round so that the questions are in the same order as the online form would be helpful. Also, it would be helpful for the agencies to announce any changes to the manual on the broadbandUSA.gov website so that applicants know that they are using the most recent version.
The FAQs portion of the broadbandUSA.gov site was very informative. Initially, the agencies stated that the FAQs would be posted at the beginning of the application window to incorporate questions received at the workshops, prior to the release of the application, and would be added onto from there. However, the list was not posted until two weeks into the application window when workshop attendees brought it to the agencies’ attention.
While the helpdesk fielded many calls and emails, it appears that it was quickly overloaded. In one instance, TCA waited 5 days to receive a response to a question regarding uploading a document into the application. Additionally, in the days leading up to both the application and response deadlines, TCA was unable to contact the helpdesk by phone, as the system had all calls hold for several minutes and then told the caller to leave a message. TCA asks the agencies to consider increasing the staff and the working hours for the Help Desk to better provide timely support.
VII. CONCLUSION
TCA thanks NTIA and RUS for the opportunity to comment on BIP and BTOP and for the agencies’ continued efforts to improve these programs. TCA contends that the recommendations we have proposed will improve both the application and response processes for the next round.
Respectfully submitted by,
Electronically submitted_____________
TCA
1975 Research Parkway, Suite 320
Colorado Springs, CO 80920
(719) 266-4334
November 30, 2009
"pcoady@coady.org" <pcoady@coady.org>
Dear NTIA & RUS:
Attached are our comments regarding suggestions for the second round of funding. We thank you for asking for our input before the next round.
Sincerely yours,
Patrick Coady
Executive Director
Eastern Shore of Virginia Broadband Authority
757 414-0304
U.S. Reps. Matsui, Eshoo, & Markey
Brian Backus
Re: Docket Number 0907141137-91375-05
Broadband Technology Opportunities Program
In response to the NTIA RFI published in the federal register at 74 Fed. Reg. 58940, please find attached the consolidated comments of a broad community of Washington State law and justice related organizations regarding changes and clarifications that we recommend be incorporated into the forthcoming Round 2 Notice of Funding Availability. These comments are designed to give full meaning to the letter and intent of the Recovery Act’s broadband investment authority, consistent with the President’s vision of broadband as an essential component of integrated systems that promote public safety (including the fair and proper administration of the law), enhance quality of life for all, empower communities (including low income and vulnerable communities) and create jobs. We look forward to your favorable consideration of our comments.
Brian Backus
Administrative Office of the Courts
360-705-5320
brian.backus@courts.wa.gov
"Woodworth, Scott" <SWoodworth@wileyrein.com>
The comments of AT&T, Inc. in Docket Number: 0907141137-91375-05 are attached hereto. Thanks.
Scott Woodrow Woodworth
Wiley Rein LLP
1776 K Street, NW
Washington, DC 20006
Tel (202) 719-7509
Fax (202) 719-7049
swoodworth@wileyrein.com
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