Comment  

Docket No. 000208032-0032-01.'' 

Gregg Caudell
Commissioner District #3
Ferry County PUD
Republic, WA

 Questions for Public Comment
    1. Is it technologically feasible today to deliver local-into-local
broadcast service to rural regions, small markets, and other unserved
areas? This might include comments on satellite, enhancements to
terrestrial digital television, wireless cable, video streaming,
wireless packet data, and other technological means.

Yes, Ferry County PUD, Republic, WA. is working to assist our local
telco , local cable provider, digital modem wireless telecommunications
contractor and internet service provider to establish a rural
telecommunications system to bridge the digital divide that exists
between urban and rural communities and the growing reliance upon high
speed technologies to do business, medicine and education. 
 As our local cable association has a system and ready market
established, bringing internet service over this technology will be
somewhat convenient.  
Demand for local news and programming has always been an issue, it is
quite disconcerting that a rural culture such as ours, dependent upon
reliable weather and road reports, can get news from L.A. over satellite
better than the poor analogue signals from our local translators.

     2. What are the trade-offs between the technology options?

Cost! The high cost of deploying fiber optics which is the most
comprehensive technology to achieve all levels of service in one pipe is
both cost prohibitive for rural entities and large telecommunications
services such as U.S West and AT&T.  In this regard Washington State
Public Utilities are active in trying to gain telecommunications
authority to bring this technology to our rural constituents.  As
utilities we have a convenient and ready made system on which to deploy
the technology and experience with service and history of providing for
our rural needs.
     3. Under what circumstances is the use of one technology more
appropriate than another?
Fiber optics is the material that has enough bandwidth to accommodate
multi medias such as television, video, data transfer, internet and dial
tone, simultaneously.  It is the preferred technology to deploy but at a
very high cost of $60,000 a mile and up depending on topography.  Less
expensive and facile technologies such as satellite + wireless + cable
can be combined with fiber or high speed copper such as T-1 or T-3 lines
although slower are feasible designs.

     4. Should multiple technologies be used to accomplish the delivery
of local television service to rural regions, small markets, and other
unserved areas?
Yes, it is the most readily affordable and least regulated technologies. 
    5. What are the economic impediments, if any, to the use of any of
the technologies that might be used to facilitate local television
service to rural regions, small markets, and other unserved areas?
Financing.  Community Associations do not exist with the expertise or
financial credit to borrow or finance systems.  Government agencies such
as public utilities, port districts with that can float bonds or even
better, make revolving loans and grants available through rural economic
development programs are the best prospect for accomplishing such
endeavors, thereby infusing the private sector and working towards a
sustainable economy.


     6. What are the legal impediments, if any, to the use of any of the
technologies that might be used to facilitate local television service
to rural regions, small markets, and other unserved areas?

In Washington state, the Washington Utilities and Transportation
Commission implements federal statutes of the '96 telecommunications act
which mandates that 'Universal Service' be provided to rural
communities.  The current definition of 'Universal service' is for
emergency 911 and basic dial tone.  The Universal Service Fund is an
industry assessment of 8.6% of all phone usage which in effect the
subsidy of rural costs to be deferred by the large urban telephone
traffic.  As the deployment of high speed telecommunications
technologies have developed in high areas of population it goes to
follow that rural high speed telecommunications needs should be
provisioned in like manner.  
The definition of 'Universal Service' will have to include high speed
telecommunications service also.
It will also be necessary to allow entities such as utilities that
already operate in the public domain and have an established track
record of provisioning rural energy needs, to partner with private
telecommunications entities to deploy high speed systems.  
     7. What legal measures, if any, should be taken to foster the
delivery of local television service to rural regions, small markets,
and other unserved areas?
With regard to deploying fiber optics as a single technology to cover
the greatest benefit, government entities such as Bonneville Power
Administration which owns hundreds of miles of public corridor, private
and public power utilities and telecommunications companies must
collaborate with interconnection agreements that have yet to be
established.  The definition of 'Universal Service', the assessment
measures to achieve capital outlay and the regulatory measures to assure
a level playing field must be crafted.  As the laws now stand the public
and private domains are pitted against each other.
     8. What economic and technological policy measures, if any, should
 be taken to foster the delivery of local television service to rural
 regions, small markets, and other unserved areas?

Currently there are federal Five Star Enterprise Community Economic
Zones established throughout the U.S. that are addressing such issues at
a local community level.  Infused with federal monies for revolving loan
funds administrated by Community Trade and Economic Development Agencies
and local boards that prioritize bench marks to achieve their needs. 
Such things as water systems and medical clinics could include
television and communications needs.
One of the most successful programs was Al Gore's E-rate program that
brought the internet to schools throughout America.  With such support
using existing rural economic agencies and programs already in place,
efforts to deploy technology in rural America can be achieved.
 
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