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Joint Broadband Technology Opportunities Program Request for Information

Date: 
March 12, 2009
Docket Number: 
090309298-9299-01

American Recovery and Reinvestment
Act of 2009 Broadband Initiatives

Comments

(Late Submission)
Comments and a Presentation are filed in the form of atttachments.

(Late Submission)
Attached please find written comments of the Center for Democracy &
Technology on the Broadband Technology Opportunities Program. These
comments are in Word format.

If there is any problem with the transmission, please contact David
Sohn at 202-637-9800 x317.




(Late Submission)
attachment included

(Late Submission)
Please see the attached letter from Jagdeep Singh, CEO of Infinera Corporation, regarding the Buy American provisions of ARRA, and correcting some information on the record about the U.S. broadband manufacturing market.

Respectfully,

Joel Bernstein
On behalf of Infinera Corporation

(Late Submission)
To Whom it may concern,

Please find attached a word document containing comments for RUS Docket No. 090309298-9299-01 for American Recovery and Reinvestment Act of 2009 Broadband Initiatives

A 2 page summary is included in the document with 18 pages of follow-up documentation.

Please contact me if you have any questions or comments.

Regards,

Scott Bashore



Scott W. Bashore
Manager of Broadband Services

w 703.771.5578
e sbashore@loudoun.gov
m 571.233.8144
f 703.771.5037

41975 Loudoun Center Place
Leesburg, Virginia 20175-8901



(Late Submission)
The Regional Fiber Consortium would like to apply for funds but is most concerned about the match requirements. If a cash match is required the Regional Fiber Consortium and most other public agencies will not be able to apply because they have limited resources. the resources that they have been able to invest in broadband have been invested, so they should be allowed to include some of this investment if it is an integral part of the project.

(Late Submission)
We are VERY frustrated that we are getting only sporadic streaming. Will
you be making the complete transcript available immediately on the web
site? We have meetings scheduled to pass on this information at 1PM, and
we haven't been able to get anything long enough to be
coherent....Thanks!



C. Allen Shaffer


Direct Dial 614.227.4868
ashaffer@bricker.com

V-CARD

BIO

Bricker & Eckler LLP
100 South Third Street
Columbus, OH 43215-4291

Main 614.227.2300
Fax 614.227.2390
www.bricker.com



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(Late Submission)
On behalf of Covad Communications Company, attached are Covad's comments
for submission in NTIA/RUS Docket No. 090309298-9299-01. Please contact
me if you have any questions concerning this filing.



Respectfully submitted,



Anthony Hansel

Assistant General Counsel

Covad Communications Company

1750 K Street, NW

Suite 200

Washington, DC 20006

(202) 220-0410 (tel)

(202) 833-2026 (fax)

ahansel@covad.com




(Late Submission)
Attached please find Comments of TracFone Wireless, Inc. on NTIA's BTOP.
Please contact me if you have any questions regarding this submission.

Sincerely,

Debra McGuire Mercer

Debra McGuire Mercer
Of Counsel
Greenberg Traurig LLP | 2101 L Street N.W. | Washington, D.C. 20037
Tel 202.331.3194 | Fax 202.261.0194

mercerdm@gtlaw.com | www.gtlaw.com

Greenberg Traurig

Please consider the environment before printing this email



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(Late Submission)
Please see the attached file

(Late Submission)
Comment to the NTIA-RUS Request for Information is attached

(Late Submission)
Please see attached pdf for comments.

(Late Submission)
Congressional Letters to BTOP



(Late Submission)
See attachment.

(Late Submission)
Hello,

Attached are my comments, suggestions and request for clarification.

Thank you.

(Late Submission)
Comments of COMPTEL in Response to RFI

(Late Submission)



This message has been scanned for malware by SurfControl plc. www.surfcontrol.com



(Late Submission)
On behalf of Vonage Holdings Corp., attached are Vonage's comments on
the NTIA/RUS joint request for information on the American Recovery and
Reinvestment Act of 2009's Broadband Initiatives, NTIA/RUS Docket No.
090309298-9299-01. Please contact me if you have any questions.



Brendan Kasper
Senior Regulatory Counsel
| 23 Main Street | Holmdel, NJ 07733
t: 732.444.2216| c: 848.219.9567
e: brendan.kasper@vonage.com
w: www.vonage.com





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(Late Submission)
Attached are the comments of the Wisconsin Department of Commerce in regards to Docket No. 090309298-9299-01.

Respectfully,

Jessica L. Stoller
Wisconsin Dept of Commerce
Policy Initiatives Advisor
Jessica.Stoller@wisconsin.gov
Ph (608) 261-8469

Wisconsin Dept of Commerce
201 W. Washington Ave. 6th Floor
P.O. Box 7970
Madison, WI 53707-7970
Fax (608) 266-3447



(Late Submission)
Now the text streaming has also cut out with the following message:

Unable to connect to Text Broadcaster. You may be being blocked by your firewall. Please contact your network administrator or this event's host.

Since I was previously receiving the text stream, I am sure this is not a problem with my firewall.

Can you please be sure that Asst. Secretary receives the below comment and question?
----- Original Message -----
From: Driessen
To: btop@ntia.doc.gov
Sent: Tuesday, March 10, 2009 9:15 AM
Subject: Streaming of Kickoff was unavailable


I was able to get streaming text, but video and sound was unavailable. My flash Player and uStream.tv were working just fine on my computer. Perhaps, there were just limited connections available. My question is whether the panel will consider the municipal special purpose local Goverment Entity ("LGE") as a preferred model for grant oversight? Letting a community know that they "own" the network will help increase success.

As long as communities follow their own state law, where applicable (on providing cable tv or telecommunications, or refrain from anti competitive franchising where there is no state law on point) then the communities can become providers of telecommunications with public forum oversight of all the activities. But more importantly this provides a means to leverage momentum in both financing and penetration into rural areas.

James Driessen, JD/MBA BSME
305 N 1130 E
Lindon, UT 84042
wk 801.796.6924
mb 801.360.8044
fx 801.785.2744


(Late Submission)
The Town of Lamar is trying to receive funds to install and or initiate a telecommunications infrastructure project for the Town. We have been approached by several companies, residents and other businesses to install the system into our general area. The Town of Lamar is located only 3 miles from Interstate 20 and services a large rural area. Time Warner Cable currently surrounds our jurisdiction and has 3 nodes that can easily adapt to our local area needs. We are working with US Rep. John Spratt, S.C. Senator Gerald Malloy and S.C. House Rep. Robert Williams to obtain funds to establish higher level cable and broadband into our area. Economic Development projects have been turned away due to the current state of cable in our area. The residents are currently working on a survey of the area to establish how many of them will promote the services once they are available. A mapping survey of a five mile radius of the Town has established a 7,500 to 10,000 population base which directly shows the need. Please review the information we have obtained as attachment to our cause and needs. We look forward to comments from the NTIA and what your organization can do for our local area. The costs to install the project are well under 2 million dollars which should be cost effective once the population base has been serviced.

Thanks,

Victor Pizzurro, Director
Development & Planning

(Late Submission)
Please see the attached comments which FPL FiberNet, LLC respectfully submits regarding the administration of grants under the Broadband Technology Opportunities Program.

Sincerely,

David Eckmann
Director of Core Business Development, Legal & Regulatory Affairs
FPL FiberNet, LLC
david.eckmann@fpl.com
305-345-8053 (cell)



(Late Submission)
It is very important that data on broadband access be collected as part of the full Decennial Census, to be conducted in 2010. In the two attached documents, I explain and illustrate why this is so urgent.

(Late Submission)
see attachment

(Late Submission)
Attached are the comments of the Wisconsin Department of Commerce in regards to Docket No. 090309298-9299-01.

(Late Submission)
Enclosed are comments for filing in Docket No.090309298-9299-01.


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(Late Submission)
Please find comments on the Broadband Technology Opportunities Program on
behalf of Oakland County, Michigan attached.



Thank you for your consideration,



Tammi Shepherd

Project Manager



Implementation Services

Information Technology

Oakland County

1200 N Telegraph, Building 49 West

Pontiac, Michigan 48341

248.858.4922

shepherdt@oakgov.com






(Late Submission)
Stratsoft is a broadband mapping specialized consultancy located in Massachusetts. Many mapping endeavors fall gravely short of the needs to equate telecommunications delivery to populations, businesses needs and public safety. Inadequate maps risk expensive errors in proposals, bidding management, and ultimately successful delivery. Inadequate here means too little directly pertinent data and inadequate back end charts and graphs for one key stroke evaluation output. An attached document provides detail. Seeing maps that work can show this. We are happy to meet with government or bidders to educate and work with them on this project. Michael Tattersall, CEO, Stratsoft LLC Direct line 978-371-2299

(Late Submission)
Please see attachment for comments of GVNW.

(Late Submission)
Many thanks for your work on this project. Please let me know if we can be
of help.



Bill Triplett, Sr. Advisor to the Federal Co-Chairman

Office of the Federal Co-Chairman -- Delta Regional Authority

www.dra.gov // www.healthydelta.com // www.dramultimodal.com

202-689-4134








(Late Submission)
Congressional Letters to BTOP



(Late Submission)
Please refer to the attached letter.

(Late Submission)
Please accept the attached comments for your consideration.

Best regards,

Vince Jordan | President/CEO
p: 720.204.2934 | skype: vtjordan
vjordan@ridgeviewtel.com |www.ridgeviewtel.com
1880 Industrial Circle Ste. C | Longmont, CO 80501
Live to Ride - Ride to Live
It's the Journey, not the destination...Journey well


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(Late Submission)
Comment Attached.

(Late Submission)
Attached is an electronic copy in Word format of comments filed by the
Wireless Communications Association International, Inc., which were also
submitted today in pdf format via the NTIA website. Please let me know
if you have any questions.

Best regards,

Fred



------
Fred Campbell, President & CEO
Wireless Communications Association International
1333 H Street, Suite 700 West
Washington, DC 20005
t: 202-452-7823
m: 703-470-4145
www.wcai.com




(Late Submission)


Attached are the comments of the Iowa Telecommunication Association in
Docket No. 090309298-9299-01 for filing.



Dave Duncan, CAE

President

Iowa Telecommunications Association

2987 100th Street

Urbandale, IA 50322

515.867.2091

www.i-t-a.net






(Late Submission)
Please ensure that funding opportunities will filter down to grassroot organizations. We are a non-profit 501c3 organization that trains the underemployed and unemployed population of the Washington, DC area in the skill of data installation. This trade directly relates to the type of jobs the Broadband grant should generate.

Once again please ensure small grassroot organizations can participate. Please ensure ex-offenders can participate. Employers are restricted from hiring qualified ex-offenders because of insurance refusal to grant employers liability insurance if they hire ex-offenders. The skill to perform cable lines is not complicated. We can give many employment and many people access to the internet.

Attached is our company brochure and a brief abstract about Building Inside Out. Thank You...Teresa Gilchrist

(Late Submission)
Please see attached comments.

(Late Submission)
RESPONSE TO BTOP RFI - NTIA and RUS JOINT REQUEST FOR INFORMATION - FINAL (attached)

Summary includes:

Executive Summary | Preamble & Abstract | FCC Broadband Definitions | Document Summary
Municipal Wireless History | 3.65GHz WiMAX | 3.65GHz WiMAX - Municipal Operations
ARRA - Broadband Benefits | Digital Access, Inclusion & Literacy | Public/Private Partnerships | Private Sector Investment | Job Creation | Summary of BTOP Public Meetings | Document Conclusion | Addendum A - Response to National EBS Association Comments Regarding Use of the 2.5GHz EBS Band to Achieve BTOP Initiatives

This is an update to summary posted on BTOP April 1, 2009 RESPONSE TO REQUEST FOR INFORMATION -- NTIA-RUS BTOP INITIATIVES -- COMPLETE SUMMARY
(Original - http://www.ntia.doc.gov/broadbandgrants/comments/68A4.pdf)

BTOP RFI Sectional Links - Table of Contents.doc
(Original - http://www.ntia.doc.gov/broadbandgrants/comments/68A5.doc)

ADDED ADDENDUM A -

"Response to National EBS Association Comments Regarding Use of 2.5GHz EBS-Based Wireless Broadband Facilities to Achieve BTOP Initiatives"

"The 2.5GHz Educational Broadband Service - Rural Telecommunication and Energy Cooperatives vs. Urban and Suburban Markets"

"The Backwards Lease"

Direct Links to Addendum A
Word - http://www.ntia.doc.gov/broadbandgrants/comments/7667.5%20Ghz%20Band.doc

PDF - http://www.ntia.doc.gov/broadbandgrants/comments/7668.5%20GHz%20Band.pdf

UPDATED BTOP RFI Sectional Links - Table of Contents.doc (attached)

Graphics include:
Current Sprint, Clearwire and FCC 2.5ghz EBS Lease Business Model.gif

Proposed NTIA, RUS 2.5ghz EBS Lease/Operating Business Model.gif

Reference: NEBSA Comments (http://www.ntia.doc.gov/broadbandgrants/comments/6F1B.doc)

Brad Bowman
bbowman@accessdelray.org

(Late Submission)
What role and support can the telecommunications design and engineering
firms in this country position themselves for in support of this
evolutionary process?



Gordon Caverly, RCDD, CWNA

Regional Vice-President

Mid-State Consultants

www.mscon.com

810-621-5656 (work)

810-845-6999 (cell)





Gordy Formal June 05 cropped






(Late Submission)
The following comments are submitted on behalf of the 58 rural incumbent local exchange carriers (Rural ILECs) and the centralized equal access providers (CEA Providers) listed therein.

(Late Submission)
Please see attached pdf document.

(Late Submission)
Communities Connect Network (CCN) is a statewide coalition of public, non-profit and private organizations working to ensure technology opportunities for all.
We represent 200+ organizations in the State of Washington providing technology access and learning opportunities. According to a recent study by the University of Washington, these organizations (CTs) receive more than one million visits per year.
We bring expertise in broadband deployment and adoption, a clearinghouse for research and training, and education about best practices and the needs of digital inclusion programs. Communities Connect Network was instrumental in creating the Washington State Community Technology Opportunity Grant Program and facilitating the awarding of grants for digital inclusion programs. We developed and manage a multi-sector state Digital Inclusion Council. We encourage the NTIA to consider formation of a national digital inclusion council and support these state councils.
We know from experience and research that you can offer valuable online content and applications like medical information or job applications, but if residents can’t afford a broadband connecton, don’t have a working computer, know where to find the content, or how to use the web effectively, then ARRA won’t attain it’s goal of reaching the most vulnerable populations and these residents, small businesses and non-profits will not become sustainable purchasers of broadband services. Our comments here focus on how to use the ARRA funds to link and support increased demand for and adoption of broadband. For instance, low-income residents and seniors will understand how to use broadband after receiving training and could benefit from low-cost computer distribution programs. The disabled need adapted equipment and training to take advantage of broadband. Technology training and web marketing assistance help enable disadvantaged business sustainability and new entrpreneurs...and greater demand for broadband.

Summary of our recommendtions:
1. NTIA and RUS should strengthen support for broadband adoption programs that increased demand, going beyond the minimum amounts set in the ARRA for public access and adoption programs. Broadband adoption programs increase user take-rates and support broadband sustainability. This is especially important for rural and low-income communities.
2. The $450 million allocated to public computing and the “innovative adoption programs” should be considered the minimum available for these purposes.
3. There should be different definitions and criteria for underserved in adoption programs vs deployment programs. Definitions and proposals focused on speed alone do not address the adoption needs of vulnerable populations in urban and rural settings for broadband application awareness, skills training, end-user hardware and software, and technical support. Community Technology Centers (CTC’s) should be eligible and receive funding, in addition to colleges and public libraries, for public access, training and adoption funds,
4. Local and regional programs that regrant to deliver services should be eligible and are an effective way to ensure use of best practices, enable greater reach to underserved populations and to deliver locally responsive community-based initiatives.
5. NTIA and RUS should support capacity building networks which promote best practices and strategic coordination. In Washington State, CCN provides training, program evaluation and other services which would otherwise be unavailable and unaffordable for small