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Joint Broadband Technology Opportunities Program Request for Information

March 12, 2009
Docket Number: 

American Recovery and Reinvestment
Act of 2009 Broadband Initiatives


(Late Submission)


DATE: April 13, 2009

RE: Response to request for Comments on Broadband Opportunities

Please see the attached PDF containing comments re: BTOP

Thank you and have a nice day.

Loredo Sola, Chair ECFiber 802-236-0735 cell

(Late Submission)
Please see attachment below.

(Late Submission)
April 13, 2009

Broadband Technology Opportunities Program
U.S. Department of Commerce Room 4812
1401 Constitution Avenue, NW
Washington, DC 20230

RE: East Central Vermont Community FiberNet BTOP Application

On behalf of the Two Rivers-Ottauquechee Regional Commission, I am pleased to support East Central Vermont Community FiberNet (ECFibernet) BTOP application for funding for their regional fiber to the home broadband deployment project.

In our work in regional planning with our 30 member towns, we encourage sustainable development that is village centered and also offers innovative solutions to commuting across our rural state. Many of our smaller villages and rural areas do not have high-speed broadband options for its residents and the larger internet providers' future plans for expansion are limited or progressing very slowly. ECFibernet's mission of creating a network combining financial sustainability, community ownership, and state-of-the art technology complements our regional planning goals of village centered services and innovative tools that are accessible to our rural areas and residents.

The small businesses that are typical of our area and the rest of Vermont and New Hampshire are increasingly reliant on high-speed communications to maintain or improve their competitive position. Our region is part of the larger bi-state Upper Valley area which includes Dartmouth College and the Dartmouth Hitchcock Medical Center in New Hampshire. These institutions have encouraged a cluster of related businesses, individuals and technologies across our region but many of these groups lack the broadband infrastructure to fully realize their potential. Extending high-speed broadband access to all our citizens will enable them to participate fully in the sustainable economy of the future.

TRORC supports this work, and I encourage the BTOP to fully fund the application as presented.


Peter G. Gregory, AICP
Executive Director


(Late Submission)
Please see attached program development comments and recommendations.

(Late Submission)
Attached are the comments of the U.S. Chamber of Commerce in response to the Joint Request for Information from the National Telecommunications Information Administration (NTIA) and Rural Utilities Service (RUS) on the broadband-related provisions in the American Recovery and Reinvestment Act of 2009 ("Recovery Act"), and to the Federal Communications Commission's (Commission) request for comments on its consultative role in helping to implement these provisions.

(Late Submission)
To whom it may concern:

Thank you for your time and consideration. Please see the below file attachment.

Thank you,
Mayor Mark Hipsher

(Late Submission)

(Late Submission)
Last week ADTRAN's CTO met with OPAD staff to discuss developments in broadband access technologies. The attached slides were the basis of the presentation. Although not specifically addressing the NTIA broadband grant program, ADTRAN is submitting this material into that record out of an abundance of caution, because some of the materials may be relevant to this proceeding.

(Late Submission)
Comment Provided In Attachment

(Late Submission)
Attachments submitted below.

(Late Submission)
Attached please find the comments that were sent to Secretary Locke,
Secretary Vilsack, Deputy Assistant Secretary Gomez and Acting
Administrator Newby regarding the Broadband Technology Opportunities
Program (BTOP) consistent with the requirements of the American Recovery
and Reinvestment Act of 2009 (ARRA).

If you have any questions, please feel free to contact Kristin Welsh,
vice president of strategic initiatives and business community liaison,
at (202) 626-2322 or

Crystal Childs

Project Manager, Federal Relations

American Hospital Association

325 7th St NW, Suite 700

Washington, DC 20004

(202) 626-2676

(Late Submission)
Attached is a letter relevant to this issue.

(Late Submission)
President of the Board, Southern Ohio Health Care Network
President, Reid Consulting Group LLC
PO Box 481
Chillicothe, OH 45601

6 April 2009

Broadband Technology Opportunities Program
National Telecommunications and Information Administration
U.S. Department of Commerce
1401 Constitution Avenue, N.W.
Washington, D.C.

Dear Policy Makers:

I congratulate the NTIA for the open and accessible process for soliciting ideas regarding use of the broadband funding in the American Recovery and Reinvestment Act of 2009 (ARRA). I offer these suggestions from the heart of rural America, coming from my twenty-year involvement in broadband expansion and from my thirty years living in Appalachia.

Focus First on the Un-Served
In the 34 county area of Ohio represented in Congressman Space's Connecting Appalachia initiative, fully 62% to 75% remain un-served by any type of broadband service. For the nearly 500,000 people living in this digital desert, the lack of broadband reduces career options, eliminates critical educational avenues, hampers health care innovation and cripples tourism. The situation in our area is not unique. Many parts of rural America suffer from similar gaping holes in broadband coverage.
Frequently, policy makers focus on the coverage of households rather than square miles. For instance, in Ohio broadband is reportedly available to 94% of the households (although this figure may be overstated). Yet 41% of the surface area of Ohio has no access to broadband.
Some have argued that building broadband into these sparsely populated areas amounts to building a bridge to nowhere. I urge you to reject this logic -- rural America is the source of all of our food, all of our energy and 44% of our soldiers. Simply abandoning us in a digital world amounts to a policy decision to abandon rural America, a choice we cannot afford to make for the long-term good of the country, the society and the environment.
The ARRA broadband funding offers the only feasible source of funds to address this glaring need in rural America.

Competitive Bidding and Partnerships with Carriers
Awarding funds to organizations committed to addressing 100% of the un-served in their region offers the best hope that the policy objectives will actually be met. Requiring that the services be competitively bid ensures that the best value options emerge.
For instance, in Connecting Appalachia we propose a model in which the Southern Ohio Health Care Network conducts competitive bidding to award contracts to commercial carriers, large and small, to provide the specified services. Serving 100% of the addresses in specific geographic blocks will be a key aspect of the resulting long-term contracts.
We are pursuing a similar model with the FCC funded Rural Health Care Pilot Project for which we have already secured $16 million in funding. Commercial carriers are best positioned to provide reliable and sustainable services. We need the external organization, though, to make sure that all of the public policy objectives are met.

Grants, not Loans
Loans will do little to spur investment in the un-served areas across the country due to the same low population densities that have discouraged carrier investment for decades. Given these realities, the goal of all-inclusive broadband remains unattainable without public grant funds to provide the capital infusion required to create a viable business model for carriers.

Zero Upfront Match Will Yield Sustainable Networks
During the current downturn, the economic conditions in Appalachia have deteriorated even faster than in the rest of the country. Even small match amounts can become an insurmountable obstacle to progress. However, with sustainable business models, over a five-year time horizon the pro forma shows that the commercial carriers will match the public investment at least 1:1.
For instance, in the Connecting Appalachia project to provide wireless coverage of the rural expanse, the five-year pro forma indicates that the participating carriers will spend $68 million to operate the network and provide customer service based on an upfront investment of $64 million from ARRA funds. We need the capital funds and a portion of the operating costs in the first two years, but beyond the business case become quite attractive.

Support for Project Management
Please don't forget to fund project and program management. As with the match, the lack of funding to pay for project management will stall many deserving projects. While it might seem odd that a region can't come up with a match and can't come up with project management funds in order to accept a big award of Federal funds - that is the reality.


Marcus Bost

(Late Submission)
Want to join BTOPs team. Have deep expertise in what you're doing. A
friend in the EDA suggested I write you.

Mr. Wilhelm and Ms. Brown:


Wireless communications infrastructure (7 yrs) - advocacy, strategy,
legislation, local regs., site deployment

City Management/Grants writing & administration (7 yrs) - City Manager,
Community Dev. Director

Master's degrees:

MPA -- Public Administration

MURPL -- Urban & Regional Planning

American Institute of Certified Planners - Planner Number 020647

I believe I can help the NTIA with the difficult tasks ahead, and would like
to find a position where I could make a difference.

Towards those ends I've attached a resume and references.

Would there be someone I could contact to discuss this further?

Thanks for your time and consideration.


Anvil Partners logo.jpgRobert E. Smith, AICP

314 North 5th Street
Wilmington, NC 28401




(Late Submission)
Attached is our submission to the United State Department of Commerce's National Telecommunication and Information Agency.

(Late Submission)
Please see attached.

(Late Submission)
Dear Sirs,

I was unable to attach this file via the online web form. Michelle
Carey suggested that I sent it to this e-mail address.

As an ISP that's been working to bridge the digital divide for a decade
now I thought it important to give you my thoughts on what *I* need to bring
better services and lower prices to my region.

Marlon K. Schafer
Odessa Office Equipment
(509) 988-0260

(Late Submission)
Please place me on your correspondence list for future information on grant
opportunities, both from stimulus funding and other sources.

Mike Norris
Assistant Director

Southeast Iowa Regional Planning Commission
200 Front St Suite 400
Burlington, IA 52601

Phone: 319-753-5107 x210
Fax: 319-754-4763

(Late Submission)
see attached

(Late Submission)
See attached files.

(Late Submission)
Broadband technology, much like other forms of information communications technology, is an "enabling technology" The purpose of this statement is to urge the RUS, NTIA, and FCC to apply the ARRA funding effectively by the use of strategically determined model projects. To advocate the spending of limited Federal funds for broadband as a means of stimulating the economy with one-time "shovel ready" construction projects underestimates the true economic value of broadband technology. (See attached statement in full)

(Late Submission)

Jay Weber
Executive VP
Direct: 720.200.8865
MyFax: 303.675.6090


Please add me to the ongoing correspondence list regarding the Broadband
Technology Opportunities Program (BTOP).

(Late Submission)
As these programs begin to roll out and grow there will be an increasing
need for design and engineering services. Will there be a common website or
government sponsored website of all qualified design firms that would be
available to assist with this design effort?

Gordon Caverly, RCDD, CWNA

Regional Vice-President

Mid-State Consultants

810-621-5656 (work)

810-845-6999 (cell)

Gordy Formal June 05 cropped

(Late Submission)
Comments in attached PDF file.

(Late Submission)

>>> Markham Erickson 3/10/2009 8:04 AM >>>

Attached is a letter faxed yesterday to Deputy Assistant Secretary Gomez regarding the BTOP.



Markham C. Erickson
Holch & Erickson LLP

The phone at my office's reception desk: +1 202.624.1460
The phone on my desk: +1 202.624.1462
My mobile phone: +1 202.744.4318
Skype name: m.c.erickson
Y! Instant Messenger name:
Email address:
Web address:

This email communication and any attachments are intended only for the individual or company to which it is addressed and may contain information which is privileged, confidential, and prohibited from disclosure or unauthorized use under applicable law. If you are not the intended recipient of this email communication, you are hereby notified that any use, dissemination, or copying of this email communication or the information contained in this email is strictly prohibited by the sender. If you have received this transmission in error, please return the material received to the sender and delete all copies from your computer.>


(Late Submission)
Please see attachment

(Late Submission)
Please see attached file.

(Late Submission)
See attached document

(Late Submission)

(Late Submission)
Attached are FiberTower Corporation's comments. Please contact Russell Fox, counsel to FiberTower Corporation, at 202-434-7300 with any questions concerning this filing.

(Late Submission)
The State of Alabama submits the attached comments pursuant to the American Recovery and Reinvestment Act of 2009 broadband grant and loan programs, Docket No. 090309298-9229-01.

The ConnectingALABAMA team believes the advancement of (a) broadband deployment on the supply-side and (b) broadband-based applications on the demand-side are vital enablers to the economic opportunity and quality of life for all Americans. As such, we stand in strong support of the Broadband Technology Opportunity Program (BTOP) advanced by the American Recovery and Reinvestment Act (ARRA).

Thank you in advance for considering the State of Alabama's comments.

Kathy Johnson, Director
Alabama Broadband Initiative & ConnectingALABAMA
Office of Governor Bob Riley
Alabama State Capitol
600 Dexter Avenue, EB-09
Montgomery, AL 36130
P: 334.353.8760
F: 334.353.1190

(Late Submission)
We are resubmitting our comments. The first version posted on the Web is garbled. Thanks.

(Late Submission)
Please find attached the comments from Jaguar Communications, Inc.

(Late Submission)
The Telecommunications Industry Association respectfully submits this letter urging NTIA to attribute pre-existing infrastructure investments necessary to BTOP projects to the statutorily-required 20 percent non-Federal match as in-kind contributions. This letter was filed electronically yesterday at 5pm, but has not yet posted.

(Late Submission)
Comments of the National Exchange Carrier Association, Inc. on BTOP

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(Late Submission)
Attached please find the Comments of Intrado Inc. and Intrado Communications Inc.

(Late Submission)
Please find attached a letter from Governor Dave Freudenthal of the State of Wyoming regarding the broadband stimulus inquiry.

Please let me know if you have any questions or concerns.
Tom Wilson
(307) 777-5701

(Late Submission)
The State of Alabama submits the attached comments pursuant to the American Recovery and Reinvestment Act of 2009 broadband grant and loan programs, Docket No. 090309298-9229-01.

The ConnectingALABAMA team believes the advancement of (a) broadband deployment on the supply-side and (b) broadband-based applications on the demand-side are vital enablers to the economic opportunity and quality of life for all Americans. As such, we stand in strong support of the Broadband Technology Opportunity Program (BTOP) advanced by the American Recovery and Reinvestment Act (ARRA).

Thank you in advance for considering the State of Alabama's comments.

Kathy Johnson, Director
Alabama Broadband Initiative & ConnectingALABAMA
Office of Governor Bob Riley
Alabama State Capitol
600 Dexter Avenue, EB-09
Montgomery, AL 36130
P: 334.353.8760
F: 334.353.1190

(Late Submission)
Please see attached comments.

(Late Submission)
Please review my attached comments on BTOP funding and rules. Thank You!!

(Late Submission)
Please find attached Filling Comments on Section 6001 of the American
Recovery and Reinvestment Act of 2009. These comments are being filed
on behalf of Van Horne Cooperative Telephone Company.

Kristy Szabo
On Behalf of Van Horne Cooperative Telephone Company

(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 the maps that work can show this. We are happy
to meet with any and all to educate in the hopes of going on to work
with this project. Michael Tattersall, CEO, Stratsoft LLC Direct line

(Late Submission)
Comment is over 10,000 characters. Submitting as attachment

(Late Submission)

Thank you for the opportunity to comment on the Broadband Opportunity
Program. Please see our attached comments.

Respectfully submitted.

Jane Morlok, CFO
Breda Telephone Corp.
112 East Main, P.O. Box 190
Breda, Iowa 51436

(Late Submission)
Transmitted as attachments below in both Word and PDF formats are the consolidated Comments of Spruce Knob Seneca Rocks Telephone, Inc. in both the NTIA/RUS Docket No. 090309298-9299-01 and the FCC's GN Docket No. 09-40. These Comments have been electronically filed via the NTIA's BTOP webpage and the FCC's ECFS system.

Please contact me if any questions arise.

Respectfully submitted,

Phyllis A. Whitten, Attorney-at-Law
Counsel to Spruce Knob Seneca Rocks Telephone, Inc.
1629 K Street, N.W., Suite 300
Washington, D.C. 20006
(202) 550-0722

(Late Submission)
Separate comments for RUS and NTIA are attached.

(Late Submission)
(If improperly formatted, please see attachment)

NTIA BTOP Public Comments - Docket Number 090309298-9299-01

Hello NTIA and RUS Administrators,

I hope you’ve been enjoying reading the nearly 1000 comments as much as I, and in the interest of time, I’ll try to keep my comments concise -

Please consider the following:

1. Giving priority to optical deployments - the speed at which of optical fiber can be lit is unlikely to be matched, or exceeded, by any other type of connection, wireless, copper or otherwise, in the next decade and can be scaled to nearly infinite speeds.

2. Giving priority to those who expand the reach, scope and capacity of non-commercial middle-mile networks, in particular those of -
a. Research and Educational Networks (RENs) - Support the expansion of RENs by enabling the direction participation of community-based organizations in the local, state and national RENs.
b. Institution Fiber Nets (iNet) - iNets should be encouraged to provide middle-mile backhaul to local community initiatives. Those that have usage agreements prohibiting these types of arrangements should be forced to revise these arrangements prior to receiving BTOP funding.

3. Giving priority to projects that address a community’s needs much like that of college campuses – enabling symmetrical near-wirespeed connectivity between all participants.

In conclusion, it is my hope that the BTOP program will be considered a venture investment in non-profit community-centric initiatives, which as public charities, will reinvest 100% of their assets into the growth and stability of the.

Since there are few if any significant non-profit telecommunications providers providing community-wide services, it is my hope that NTIA and RUS administrators will be supportive of new non-profit entrants who are actively scaling up to meet this challenge.

Many thanks for your time and attention, great job on the program so far and I look forward to speaking with some of you soon –

- Lou

Louis S. Klepner
Founder, NYC Community Fiber Project

(Late Submission)
Dear Sir or Ma'am:

I write in response to your Joint Request for Information and Notice of Public Meetings (Docket No. 090309298-9299-01). Please see the attached Microsoft Word 2003 document for our comments on Question 4 in the NTIA section of your RFI, pertaining to Establishing Selection Criteria for Grant Awards.

Please do not hesitate to contact us if you have any questions or technical difficulties with the attached.

Best regards,

Steven Glapa
VP of Product Management and Marketing
Zhone Technologies, Inc.
+1.510.777.7045 desktop
+1.408.921.1537 mobile

(Late Submission)
Please find attached the comments of AT&T Inc.

(Late Submission)
On behalf of USTelecom, please accept the attached letter for filing

Meena Joshi

Law & Policy


607 14th Street, NW, Suite 400

Washington, D.C. 20005

P: (202)326-7273

F: (202)315-3351

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