NTIA RUS Joint Request for Information

November 16, 2009
Docket Number: 

Broadband Initiatives Program and Broadband Technology Opportunities Program

Greg Monroe <gjmonroe@merit.edu>

(Late Submission)
Attached is Merit Network's comment for NOFA Round 2.

Greg Monroe
Merit Network, Inc.
Grants, Development Writer
& Marketing Coordinator


20091130_RFI_RUS and NTIA_Process Comments_Merit Network.doc 72.5 KB

Thomas Sachson <tsachson@gmail.com>

(Late Submission)
Please find enclosed our comment letter in response to the Joint Request For Information (RFI) from the National Telecommunications Information Administration (NTIA) and Rural Utilities Service (RUS) on the suggested improvements to the Second Round of Funding under the Broadband Technology Opportunities Program (BTOP).

Kind regards,

Thomas Sachson

-- BTOP RFI Sachson 11-29-2009

BTOP RFI Sachson 11-29-2009.pdf 413.79 KB
ATT00001..txt 777 bytes

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

(Late Submission)
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
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

Flow Mobiles RFI Comments Round II FINAL to Submit 11-30-09.doc 1013.5 KB
Flow Mobiles RFI Comments Round II FINAL Submitted.pdf 112.03 KB

David Honig <dhonig@crosslink.net>

(Late Submission)

NTIA-RUS Round 2 Comments 113009.pdf 109.63 KB

"Morris, Evan" <emorri05@harris.com>

(Late Submission)
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.

RUS-NTIA Second RFI Comments of Harris Corporation.pdf 119.38 KB

"Julkowski, Amy" <Amy.Julkowski@ci.portland.or.us>

(Late Submission)

I have been asked to forward to you for your consideration. Please let me know if you have any questions.

Thank you,


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

BTOP.pdf 31.48 KB

Brent Stoddard <Brent.Stoddard@mesaaz.gov>

(Late Submission)
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

Victoria Proffer <victoria@stlbroadband.com>

(Late Submission)
Please find attached our RFI for NOFA 2.

Victoria Proffer - President/CEO
Rural Missouri Wireless Project.
314.974.5600 * Fax 573.747.4756
Follow us on Twitter.com @stlbroadband
SBA Certified WOSB

image003.jpg 2.38 KB
NOFA2_RFI.pdf 1.51 MB

Maud Naroll

(Late Submission)

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

Nevada Broadband RFI Nov 09.doc 55 KB

Gayle Schultz <GSchultz@westu.org>

(Late Submission)
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

NTIA Letter.PDF 51.1 KB

John Windhausen <jwindhausen@telepoly.com>

(Late Submission)
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

SHLB-NTIA Comments 11-30 Final2.pdf 111.7 KB

Mark Pruner <mark@webcounsel.com>

(Late Submission)

Please find our comments on the 2nd Round NOFA RFI.

Thank you for this opportunity to comment,

Mark Pruner


Mark Pruner 203-969-7900
President mark@webcounsel.com

2nd.NABAComments.mp.113009.doc 47.5 KB
NCAI.BBResol.PSP-09-026_final.102309.pdf 251.82 KB

TSTCI Member Services <tstci@tstci.org>

(Late Submission)
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.

TSTCI_BIP-BTOP_2009_1125.doc 144 KB
TSTCI_BIP-BTOP_2009_1125.pdf 166.89 KB

"Fishel, Alan" <Fishel.Alan@ARENTFOX.COM>

(Late Submission)
Attached is the Internet2 comments in word format as well for docket number 0907141137-91375-05

Alan G. Fishel

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.

Internet2 NTIA RUS RFI Nov 30 2009.doc.DOC 150 KB

"Solomon Balraj (solomon_balraj@darkstrand.com)" <solomon_balraj@darkstrand.com>

(Late Submission)
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.

Darkstrand Written Comments to NTIA & RUS RFI (30 Nov 09) - Final.doc 270 KB

Aaron Fischbach

(Late Submission)

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

For a free subscription to the Safe Drinking Water Trust eBulletin,
visit http://www.watertrust.org.

RCAP response to joint RFI - Nov 09.pdf 975.93 KB

Brian Backus

(Late Submission)
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

justicenet letter0001.pdf 6.23 MB
Comments on July 9 NOFA 11-23-09.pdf 6 MB

Ryan Nichols <rnichols@digitalimpactgroup.org>

(Late Submission)
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.


Contact Information
Greg Goldman, CEO
(215) 990-5998

Ryan Nichols, Director of Communications
(267) 210-3185


Communications Officer

121 South 13th Street, 4th Floor
Philadelphia, PA 19107


215.627.3560 x104








image001.jpg 13.01 KB
dig_response_bip_btop_rfi_113009.docx 62.03 KB

Stacey Brigham <Sbrigham@tcatel.com>

(Late Submission)
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.


Stacey Brigham
1975 Research Parkway, Suite 320
Colorado Springs, CO 80920
P: (719) 266-4334 F: (719) 266-4335

TCA Comments on the RFI for BIP and BTOP.pdf 17.46 KB

Carrie McGuire <cmcguire@alawash.org>

(Late Submission)

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

ALA-RFI-11-30.pdf 202.44 KB

Alyssa Clemsen <alyssa.clemsen-roberts@ibec.net>

(Late Submission)
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

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

NOFA Comments-ACR-Final.doc 29.5 KB

"Lay, Tim" <tim.lay@spiegelmcd.com>

(Late Submission)
<> Attached please find, in PDF format, the
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
Direct: 202-879-4022
Fax: 202-393-2866
E-mail: tim.lay@spiegelmcd.com

Counsel for the City of Palo Alto, California

PA 2nd Round.PDF 1.07 MB

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

(Late Submission)
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

This e-mail message contains confidential, privileged information intended solely for the addressee. Please do not read, copy, or disseminate it unless you are the addressee. If you have received it in error, please call us (collect) at (202) 457-6000 and ask to speak with the message sender. Also, we would appreciate your forwarding the message back to us and deleting it from your system. Thank you.

This e-mail and all other electronic (including voice) communications from the sender's firm are for informational purposes only. No such communication is intended by the sender to constitute either an electronic record or an electronic signature, or to constitute any agreement by the sender to conduct a transaction by electronic means. Any such intention or agreement is hereby expressly disclaimed unless otherwise specifically indicated. To learn more about our firm, please visit our website at http://www.pattonboggs.com.

Revised RFI Comments2.doc 124.5 KB

Sybil Anne Strimbu <strimbu@lojlaw.com>

(Late Submission)
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).

Firm Administrator and Paralegal

1776 K Street NW, Suite 700 | Washington, DC 20006
202-887-6230 tel | 202-887-6231 fax

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.

11-30-09 ELNK Comments re 2nd Jt RFI w Ex Parte (RUS 0907141137-91375-05) FINAL.pdf 48.11 KB

Sue Platner <sue.platner@northridgegroup.com>

(Late Submission)
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.


Susan M. Platner
The Northridge Group, Inc.
9700 W. Higgins Road, Suite 820
Rosemont, IL 60018
847 692 6722 office
847 612 1416 cell

NOFA Round 2 Comments of Rural Broadband Corporation (11-30-09).pdf 69.34 KB

"Hansel, Anthony" <ahansel@covad.com>

(Late Submission)
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

Covad Comments on Second RFI (NTIA_RUS).doc 42.5 KB

Sakura Saunders <sakura.saunders@gmail.com>

(Late Submission)
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

Broadband_RFI_PROMETHEUS.rtf 8.09 KB
Broadband_RFI_PROMETHEUS.pdf 93 KB

Bonnie Lorang <blorang@mitstel.com>

(Late Submission)
Attached are the comments to the RFI issued by RUS and NTIA. Thank you.

Bonnie Lorang
MITS - Montana Independent Telecom Systems
blorang@mitstel.com 406-594-9662 or 406-443-1940

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.

09 Nov 30 ARRA MITS Cmts FINAL.doc 48 KB

Chris Borek <chrisb@azulstar.com>

(Late Submission)
Please feel free to contact me with any questions.

Christopher Borek
Vice President Corporate Development
1051 Jackson St.
Grand Haven, MI 49417
(M) 616.843.1040/(F) 616.842.1104/ (E) chrisb@azulstar.com

image003.jpg 2.03 KB
RFI Response.pdf 148.7 KB

John Hoffman <jhoffman@zerodivide.org>

(Late Submission)
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

415.773.0388 x314
425 Bush Street, Suite 300
San Francisco, CA 94108

Join ZD on Facebook
Follow ZD on Twitter

ZD BTOP Comments Round 2.doc 44 KB

"Hohman, Anne Kathryn" <aHohman@doitt.nyc.gov>

(Late Submission)
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.


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

City of New York Comments NTIA_RUS RFI Round 2 FINAL.pdf 156.64 KB

Jen Leasure <jen@thequilt.net>

(Late Submission)

----- 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

The Quilt
Collaborate | Influence | Inform

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

Geoff Feiss <gfeiss@telecomassn.org>

(Late Submission)

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)


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.

image.jpg 1.84 KB
ARRA-NOFA Round 2 RFI-MTA comments-final 113009.pdf 140.57 KB

"Rupy, Kevin" <krupy@ustelecom.org>

(Late Submission)
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
607 14th Street, NW
Suite 400
Washington, DC 20005
Phone: (202) 326-7276

USTelecom-Comments-FINAL.pdf 144.75 KB

Tom Carroccio <tom.carroccio@carrocciolaw.com>

(Late Submission)
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)


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

(Late Submission)
Sorry, here's a word document version of the comments filed yesterday in .pdf format. Hope this helps. Thanks!


attachments are intended solely for the addressee. The information contained in this transmission is confidential in nature and protected from further use or disclosure under U.S. Pub. L. 106-102, 113 U.S.
Stat. 1338 (1999), and may be subject to attorney-client or other legal privilege. Your use or disclosure of this information for any purpose other than that intended by its transmittal is strictly prohibited, and may subject you to fines and/or penalties under federal and state law.
If you are not the intended recipient of this transmission, please DESTROY ALL COPIES RECEIVED and confirm destruction to the sender via return transmittal.

BTOP Public Comments.docx 60.53 KB

Laura McClanahan <lmcclanahan@wtownky.org>

(Late Submission)
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


20091125_094225.pdf 124.16 KB

"Miller, Margaret" <mmiller@dowlohnes.com>

(Late Submission)
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,

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

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.

NEBSA BTOP Round 2 Comments (Final) (4).pdf 118.73 KB

Sara Wedeman

(Late Submission)
Please see my response, in the form of a word document, attached.


Sara C Wedeman

Sara C. Wedeman, PhD
BECG-Behavioral Economics Consulting Group
t: 215.242.5415 m: 267.825.4044 skype:auroraz7

Thank you for requesting feedback.doc 285 KB

"Merchant, Monisha" <Monisha.Merchant@Level3.com>

(Late Submission)
Please see attached.

If you need further information, please contact me.


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.

BTOP BIP RFI Response - Level 3 Communications.pdf 23.23 KB
Exhibit 1.pdf 205.8 KB

Thomas M Disselhorst <tdisselhorst@uttc.edu>

(Late Submission)
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.

Broadband RFI comments Executive Summary.doc 23.5 KB
UTTC Comments 11-30-09 USDA-RUS-BIP Commerce-NTIA-BTOP Joint Request for Information.doc 43 KB

James Driessen

(Late Submission)

"Hightower, Lauren" <lhightower@connectednation.org>

(Late Submission)
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

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.


Lauren Hightower

Lauren A. Hightower
Manager, Policy & Research Communications
Connected Nation
(502) 706-1414

CN response to NTIA RUS RFI FINAL 11_2009.pdf 1.32 MB

Susan Walters <susan.walters@cetfund.org>

(Late Submission)

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

5 Third Street, Suite 520 l San Francisco, CA 94103 l www.cetfund.org l 415.744.2385 o l 415.694.1661 c l 415.744.2399 f

image003.png 10.77 KB
CETF Comments on NTIA_RUS Round 2 Rules.docx 93.97 KB

James Losey <losey@newamerica.net>

(Late Submission)
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

NewAmerica_NTIARUS_RFI_113009.pdf 455.64 KB

Stacey Brigham <Sbrigham@tcatel.com>

(Late Submission)
Before the
Rural Utilities Service
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

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.

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.

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.

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.

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.

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.

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_____________
1975 Research Parkway, Suite 320
Colorado Springs, CO 80920
(719) 266-4334

November 30, 2009

TCA Comments on the RFI for BIP and BTOP.pdf 17.46 KB
TCA Comments on the RFI for BIP and BTOP.docx 21.54 KB

"pcoady@coady.org" <pcoady@coady.org>

(Late Submission)
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

Response to RFI BTOP-BIP.doc 44 KB

U.S. Reps. Matsui, Eshoo, & Markey

(Late Submission)

Brian Backus

(Late Submission)
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

Comments on July 9 NOFA 11-23-09.pdf 6 MB
justicenet final0001.pdf 6.92 MB

"Woodworth, Scott" <SWoodworth@wileyrein.com>

(Late Submission)
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

NOTICE: This message (including any attachments) from Wiley Rein LLP may constitute an attorney-client communication and may contain information that is PRIVILEGED and CONFIDENTIAL and/or ATTORNEY WORK PRODUCT. If you are not an intended recipient, you are hereby notified that any dissemination of this message is strictly prohibited. If you have received this message in error, please do not read, copy or forward this message. Please permanently delete all copies and any attachments and notify the sender immediately by sending an e-mail to Information@wileyrein.com.

AT&T Inc.'s Comments in Docket Number 0907141137 91375 05.pdf 243.31 KB