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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)
I hope this finds the Afternoon Roundtable on the Role of the States.

"It's the network"

Someone will have to actually visit and test drive the new technology. WE HAVE NEW TECHNOLOGY. Will one of you on the panal take the challange and vist and test drive a 15 millisecond handoff, fast roaming between nodes; 300 Mbps data rates per node; and excellent seamless convergence capabilities to traditional wireless carriers that we have?

If not, then the State will have to be given the guidelines for how to do this.

(Late Submission)
please see attached, thank you.

(Late Submission)

>>> "Miron, Luc" 4/13/2009 7:14:42 PM >>>
It appears that the Commonwealth of Pennsylvania electronic submission
(copy attached) timestamped at 4:22pm on NTIA web site did not upload
properly. The PDF attachment converted into something completely
illegible. Link to defective upload is here:

I have re-submitted the Governor's Office submission.

Thanks for your attention to this matter.

Luc M Miron JD MBA
Governor's Office of Administration
Commonwealth of Pennsylvania

From: Miron, Luc
Sent: Monday, April 13, 2009 4:22 PM
To: ''
Subject: Commonwealth of PA submission [Docket No.


Please find attached written response from Commonwealth of
Pennsylvania, Governor's Office of Administration, related to joint RFI
issuance from NTIA/RUS re [Docket No. 090309298-9299-01].

Comments have also been electronically posted on NTIA website.

Thanks for your consideration of this matter.

Luc M. Miron JD MBA
Governor's Office of Administration
Commonwealth of Pennsylvania
Harrisburg, PA 17120


(Late Submission)
Please add me to future correspondences and e-mails

Comments and Information attached

(Late Submission)
I am resubmitting my comments, this time with formatting and in the form of a letter, so it will be easier to read.

(Late Submission)
Rural broadband provider Brett Glass, d/b/a LARIAT, respectfully submits the attached comment (see PDF file) for your consideration.

(Late Submission)
Comments of CostQuest Associates and the LinkAmerica Alliance are attached.

CostQuest Associates and the LinkAMERICA Alliance believe 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 this proceeding.

CostQuest Associates and the LinkAMERICA Alliance are experienced broadband
mapping and assessment firms that encompass all key disciplines including
but not limited to broadband mapping, technology deployment assessment,
modeling of likely deployment costs, and the identification and assessment
of demand-side broadband applications.

CostQuest Associates and the LinkAMERICA Alliance submit the attached
comments for you review and consideration.

FYI - The comments were also submitted using the online form, but it appears
that the form is not working.

Mike Wilson

Vice President, Professional Services

CostQuest Associates

Bellevue, Washington



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(Late Submission)

Unlicensed spectrum is critical for the development of wireless computer networking. The pressing demand for wireless Internet provides us an opportunity to reconsider this experiment in unlicensed spectrum. "Community Mobile" is the template for new networks in the unlicensed spectrum that would promote the development of wireless Internet and our national interests.

(Late Submission)
Shared Spectrum Company respectfully submits the attached comments in response to the joint Request for Information issued by the National Telecommunications and Information Administration and the Rural Utility Service on the implementation of the broadband provisions of the American Recovery and Reinvestment Act of 2009 (Recovery Act).

(Late Submission)
The attached describes an April 14, 2009, meeting with NTIA staff and
David Townsend & Mark Kennet.

(Late Submission)
fyi, just wanted to doubly ensure our comments were included in the policy deliberatioms for allocations of the broadband stimulus funding. Thank you.

Eric Jensen
Policy Counsel
National Tribal Telecommunications Association
519 Tennessee Ave
Alexandria, VA 22305
(703) 683-3742
pcs: (703) 868-8325

(Late Submission)
See attached.

(Late Submission)
To Whom It May Concern:

Attached please find comments of PCIA-The Wireless Infrastructure Association and The DAS Forum. We file these comments in response to the Joint Request for Information and Notice of Public Meetings, 74 Fed. Reg. 10716 (Mar. 12, 2009).

Please confirm receipt of these comments via reply email.

Best Regards,

Jackie McCarthy

Jackie McCarthy, Esq.
Director of Government Affairs
PCIA, The Wireless Infrastructure Association
901 N. Washington Street, Suite 600
Alexandria, VA 22314
(o): (703) 535-7407
(m): (703) 851-6777

(Late Submission)
The Heart Beacon is awaiting a response from the Department of Homeland Security and is in the publication stage of the patent process. It is intended to be self funding and sustaining with
Native American indigenous sovereign nations leading.

The Heart Beacon is the basis for telecommunications infrastructure failover such as what would be tested at the Department of Energy NISAC facility yet was developed for low bandwidth tactical radio links to support operational schemes in harsh / remote (rural) environments.

- The heartbeat is simply an interval in time to gather more state meta than usual that in turn sets up enhanced network management mechanisms referred by the military as "maneuvering the network"
aiding in "spontaneous integration" of adhoc groups.

- It has been trained to soldiers implementing these procedures in conditions that would approximate less than optimal first responder conditions and is primarily a training challenge since these
procedures have been in use by the military for over a decade and in use by the DHS on their Blackberry and other handheld devices since 2004.

- APCO / NENA regulations stipulate the heartbeat sub protocol and heart beat messages as do financial SWIFT protocol systems and military network warfare systems = the same common denominators.

Without consistent, common use of these common denominators in use on every networked device on the planet a Single Integrated Operational Picture SIOP a.k.a. the grail as stated by Office
Secretary of Defense OSD IT personel is not achievable any time soon.

The military provides 20% of its own communications and the remainder it leases from telcos and large government contracts like NETWORX. The military would realize an 80% greater usage rate of their Network Centric Warfare and First Responders would be able to achieve data interoperability, synchronicity and the benefits of network centric operations -- not
to mention effectively respond to the next 9/11 type scenario currently impossible due to different data transaction formats and different data harvesting intervals... etc.

Steven J. McGee |SAW Concepts LLC|Simple Wins Concept LLC CEO / Scribe for The Heart_Beacon|
PO Box 28 Oceanport NJ| 07757-1354|
Office: 732.229.7275|Cell:732.768.5440|
Secure E-Form:

(Late Submission)
submitted as attachment.

(Late Submission)
Comments of Brian Mefford, Chairmain & CEO of Connected Nation

(Late Submission)
Please devote resources now proposed for wireless broadband to fiber optic broadband and DSL instead.
Please consider these points:
1)The biological effects due to increased rf radiation must be examined and considered for all deployments. Each frequency has a unique bioactivity that must be determined.
2)New rf exposure standards based on the BioIntiative Report (publ. 08/07) need to be determined. (
3)According to a study by the European Fiber to the Home Council, the CO2 emissions of the information and communications technology industry (ICT) exceeds that of the entire aviation industry. Most of these emissions are caused indirectly through the electricity produced to power the equipment and keep it cool. Next-generation fiber optic networks that carry exponentially more data than the old copper networks and are ten times more energy efficient. This is due to the fact that the loss of signal in optical fiber is less than in copper wire, which means lower-power transmitters can be used instead of the high-voltage electrical transmitters needed to amplify the signal in copper wires.
4)Many proposed systems could use wireline and/or fiber optic technology for the end of the line service to homes, etc.
Possible Solutions: Broadband over Telephone lines

Used in most cities

Infrastructure is already in place

Microfilters must be used because they allow your phones to work properly by blocking the High Frequency DSL signals from being transmitted through the telephones. DSL filters should be plugged into EVERY phone jack that has a phone.

786 kbps download speeds

Fiber Optics -

Download speed up to 2.5Gbps

Loss of signal in optical fiber is less than in copper wire, which means lower-power transmitters can be used instead of the high-voltage electrical transmitters needed to amplify the signal in copper wires.

Less susceptible than metal wires to interference.

Basic systems are capable of sending signals up to 5 Km over Multimode fiber and up to 80 KM over Singlemode without repeaters.

The photons traveling down a fiber cable are immune to the effects of electro-magnet and RF inference.

Almost unlimited capacity

Most secure - requires a detectable cut in cable to access impossible to passively listen or to tap into a fiber optic circuit.

Thank you,
P.S. See attachement - current cell antenna news in France

(Late Submission)
Please see attached comments from the State of Alaska.

Jack Kreinheder
Office of Management and Budget
State of Alaska

(Late Submission)
Please see attached.

(Late Submission)
Please allow me to comment on the dire employment situation we Americans
are facing.

I am a Manufacturing Engineer for Zhone Technologies, Inc., located in
Largo,Florida. We manufacture leading edge digital access, and
communications equipment. We are one of a dwindling number of
electronics firms that manufacture in the United States, because so many
companies choose to manufacture overseas. However, we have proven that
American workers can still compete, and that American technology is
still viable.

Regarding the Stimulus Package, which has provisions for $7.2B to expand
broadband, it is estimated that 60% of broadband infrastructure projects
will go to equipment vendors like us. However, many manufacturers build
their products in Asia. While I don't believe in outright protectionism,
I do feel that the investment dollars from this stimulus bill should be
targeted to promote the employment of Americans, and not create more
jobs for Asians.

Americans depend on their jobs for food, clothing, shelter, provisions,
and something other workers don't have to worry about, health care!

Please help Americans, by influencing the Departments of Commerce and
Agriculture to apply the Buy America provision, and avoid sending half
the $7.2B in broadband stimulus funds to support jobs in Asia.

Thank you very much.

Kenneth Daniels
Manufacturing Engineer
Zhone Technologies, Inc.
Largo, Florida

(Late Submission)
See attachment

(Late Submission)
Please add us to the Broadband Correspondence list regarding the BTOP
program.Thank you!

C. Allen Shaffer

Direct Dial 614.227.4868



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

Main 614.227.2300
Fax 614.227.2390

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(Late Submission)
Infinera is the leading producer of long-haul optical neworking equipment in North America. We have pleasure in enclosing our recommendations for the broadband stimulus program. We have two principal recommendations, listed below, and a full discussion is in the attached letter from our CEO.

(1) The stimulus program guidelines should support US-based technologies and US companies that invest in R&D in the US.

(2) The guidelines should support green technologies, i.e. energy-efficient optical networking technologies.

Thank you.
Best wishes,
Jeff Ferry
Director, Communications

(Late Submission)
My name is Jim Lindsey.

I am the director of Telecommunications for an Engineering and mapping
firm in Littleton Colorado.

Our firm is interested in any information and or updates available
regarding the Broadband stimulus act.

We would like to get involved by offering our services to the government
and or recipients of funds under this act.

Any information that would help us in getting plugged in would be
greatly appreciated.

If any information is requested from our firm, please feel free to
contact me via phone or e-mail.


Jim Lindsey

Director of Telecommunications

8201 Southpark Lane, Suite 200, Littleton, Colorado 80120

OFFICE (303) 339-5397 | MOBILE (303) 523-8102


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(Late Submission)
Please see attached file.

(Late Submission)

Attached please find the Solix and Vangent comments for the Broadband
Technology Opportunities Program.

Should you have further questions, please do not hesitate to contact me
on 973-581-7676

Eric Seguin

Vice President

Solix Inc.

100 South Jefferson

Whippany NJ 07981

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(Late Submission)
Please see attachment below.

(Late Submission)
Attached, please find the CONXX response to the NTIA/RUS BTOP RFI. If you
have any questions, please feel free to contact me at either of the numbers

Best regards,

Dave Kartchner

David E. Kartchner

Executive Vice President


434 N Centre Street

Cumberland, MD 21502

240-580-2763 . Mobile 801-699-9300

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(Late Submission)


Administre su propio Negocio -



Escriba en Asunto REMOVER a:

(Late Submission)
April 13, 2009

The Honorable Anna Gomez
Deputy Assistant Secretary
Herbert C. Hoover Building (HCHB)
U.S. Department of Commerce / NTIA
1401 Constitution Avenue, N.W.
Washington, D.C. 20230

Dear Secretary Gomez:

For over 30 years, the Labor Council for Latin American Advancement (LCLAA) has provided a voice for Latino working families. As the main representative of approximately 1.7 million Latino trade unionists, we strongly believe in the social and economic empowerment of our communities and work tirelessly as an advocate for the rights of our Latino workers.

In a time of economic turmoil and job uncertainty, we must ensure that Congress continues to support legislation and programs that promote job creation and investment and not burdensome regulations. To this end, the LCLAA applauds the 2009 American Recovery and Reinvestment Act, which includes more than $7 billion for broadband deployment.

As our methods of communications become more sophisticated, access to broadband is no longer a luxury but a necessity. Minority and low-income communities have been disproportionately affected by the widening digital divide and need access to educational opportunities as well as life-saving health care programs. Broadband enables our Hispanic families to bridge this digital gap and can facilitate their social and economic advancement during this time of need.

As a leader in the Hispanic community, LCLAA strongly encourages the National Telecommunications and Information Administration (NTIA) to quickly, efficiently, and transparently disperse the funding from the stimulus to the state and local leaders to get these activities off and running. It is also imperative to get the mapping process underway quickly so communities can accurately identify underserved and unserved areas and direct resources.

To this end, the NHLA recommends the following four principles:

1) Get Broadband to All Parts of the Country – Mapping current availability of broadband is critical to ensuring that money is used efficiently and effectively. Identifying areas of need throughout all fifty states through the mapping process will provide information on broadband availability by community and allow for efficient dispersal of funds.

2) Reliance on state and local expertise – State and local leaders have a thorough understanding of what their communities need. By awarding grants to these leaders, there will be a greater likelihood that state and local government along with community-based organizations can identify qualified providers with sustainable business plans to ensure that broadband systems can reach those areas in greatest need first through the creation of public-private partnerships.

3) Transparency and Accountability – Eliminating potential waste and inefficiencies are essential to maximizing the benefits of the stimulus money. As state and local leaders help guide deployment, there must be a built-in mechanism for providing transparency to ensure funds are used appropriately.

4) Prioritize Communities of Need – Funding must focus first and foremost on deployment to those communities where no broadband connections exist. State and local organizations along with qualified providers can help focus attention on such unserved and underserved areas first, followed by the other communities that also need additional broadband access.

Delivery of next-generation broadband services will spur innovation, investment and create good paying jobs, while also helping provide solutions to some of the country’s biggest challenges like health care, education and energy efficiency. Technology and broadband is a gateway to social, political, and economic empowerment for all working families across our nation.


Gabriela D. Lemus
Executive Director

(Late Submission)
Could CDFI's evaluate locate, evaluate, and monitor projects?
They serve a demographic and sometimes geographic area.

(Late Submission)
See Attached Comments

(Late Submission)
Thank you for inviting public comment.on how these Broadband Technology
Opportunities Program funds should be administered for broadband
deployment. I represent an active citizens group in Northwest California
called Mendocino Coast Broadband Alliance. We have been working to get
broadband for two years. We have done mapping of our communities,
surveys and public education. We have been trying to get providers to do
the deployment. The California Advanced Services Fund (CASF) program has
guidelines which have failed to materialize connection for our areas.

We are intimate with CASF and see the flaws in the process from the end
user point of view. We understand that you are looking at CASF as a
prototype so you should know its flaws and why the money is not able to
be awarded as expected. We want to offer our point of view on these
limitations to success and suggestions on how it must be changed if we
are to get connected. We do not stand a chance unless changes are
made.Other rural areas are also being left out because of flawed
guidelines. We offer many facets of their program flaws so you can avoid
the same mistakes.

Our comments speak to many aspects of your program questions and most
relevant to this question - What are the most effective ways to offer
broadband funds to ensure that they'll assist rural residents that lack
access? The three page attached report is simply written and the points
are clear (hopefully). There are quite a few points to be considered
from the grassroots, end user point of view so please do read them and
take them to heart. Much time is devoted to the companies at the top so
we hope you will give adequate attention to how this is going to be able
to really serve the mandate and connect ALL American households.

Thank you for reading our suggestions. We need broadband connection in
this isolated but highly active and educated area.

Peace be with you,
Shirley Freriks
Mendocino Coast Broadband Alliance

(Late Submission)
See Attachments

(Late Submission)
See attached.

(Late Submission)
Attached document was submitted via website, but it wasn't clear if the attachment went through successfully. Therefore, I am e:mailing a duplicate copy.

Kenneth F. Mason
Frontier Communications
Docket No. 090309298-9299-01

Christine Burke
National Manager, Funding Programs
Frontier, A Citizens Communications Company

(Late Submission)

NTIA Help Desk
Department of Commerce
National Telecommunications and Information Administration
Office of Spectrum Management
Herbert C. Hoover Building (HCHB)
U.S. Department of Commerce / NTIA, Room 4625
1401 Constitution Avenue, N.W.
Washington, D.C. 20230
Office: 202-482-4631

>>> "Becker, Rick" 4/14/2009 2:37 PM >>>

Resubmission in PDF format. --Rick W. Becker
Office of the CIO and NITC
State of Nebraska

rick.becker@nebraska.govFrom: Becker, Rick
Sent: Monday, April 13, 2009 2:09 PM
To: ''
Subject: Comments - Docket No. 090309298*9299*01

Comments attached in PDF and Word formats. --Rick W. Becker
Office of the CIO and NITC
State of Nebraska

(Late Submission)
Comments attached.

(Late Submission)
Are you searching for community coverage in rural areas or would you
prefer a county wide approach?

Verlyn Veldhouse,
Vice President

Your Total Communications Solution Provider
14910 Grover Street
Suite 300
Direct 402-938-5115
Office 402-597-3333
Fax 402-597-3577
Alternate 800-824-1636

(Late Submission)
Since 1992, ViTAL Economy, Inc. has been facilitating regional economies, throughout North America, on the development of regional frameworks to address the “digital divide”. Over these years we have learned that reversing the “digital divide” is as much about changing behavior and mindset of public, private, community leaders and the average citizen as it is about building broadband infrastructure to increase access to broadband services. We have learned that “if you build it they often may not come”. Please accept the attached white paper as the ViTAL Economy submittal.

(Late Submission)
Comments on the NTIA BTOP Program.

(Late Submission)
Attached are comments submitted on behalf of the People of California and Governor Arnold Schwarzenegger.

(Late Submission)
I mailed a previous submittal. I am concerned it could not be read properly in the format this box revises a letter. Therefore I am submitting the whole 'Comment Letter' again as an attachment with the additional attachments referenced in the Comment letter. Thank you for your patience and consideration of error.

Thank you

(Late Submission)
This program would do the public a great service if it would provide grant monies to rural small business wireless broadband providers such as Business Machines Plus.

We are a startup trying to provide wireless to areas not serviced by any high speed service except satelite. We currently service about a 5 mile radius and have request for areas we can not quite quite reach due to terrain. The major tower companies make it cost prohibitive for us to rent space and purchasing our own towers and installing them is expensive.

We feel if we could erect a few more towers, we could serve the area quite well, but can not justify the expense due to our return on investment (ROI). I am sure the major players would say the same, but they seem to concentrate on the areas that will produce the best ROI (high concentration of potential subscribers).

You might consider making RURAL your primary consideration in making a grant,rather than who might be able to write the best grant proposal. Look at the demographics and availability of high speed as your primary consideration. If you do, then put us on the list for an application.

Thank you,

Michael Cramer
Business Machines Plus, Inc. and Little Falls Wireless

(Late Submission)
See attached

(Late Submission)
Comment attached

(Late Submission)
See Attached

(Late Submission)
The Open Internet Coalition, including the undersigned entities, strongly support the provisions of the Broadband Technology Opportunities Program (“BTOP”), which is included as part of the American Recovery and Reinvestment Act (“the Stimulus Act”) signed into law by President Obama on February 17, 2009.

Among other things, the Stimulus Act states that the purpose of the BTOP is to (1) provide improved access to broadband service to consumers residing in unserved and underserved areas and (2) stimulate the demand for broadband, economic growth, and job creation.

We enthusiastically support these goals. It is widely recognized that the Internet fuels innovation, education, and jobs. Consequently, we support the notion that the BTOP is a key ingredient in developing a comprehensive broadband plan that provides ubiquitous, affordable high speed Internet connections to all Americans.

The Stimulus Act requires the Assistant Secretary of the National Telecommunications and Information Administration (“NTIA”), in cooperation with the Federal Communications Commission, to “publish the non-discrimination and network interconnection obligations that shall be contractual conditions of grants awarded.” These conditions “include at a minimum adherence to the principles contained in the Commission’s broadband policy statement.”

We would like to emphasize our enthusiastic support for this common-sense notion that grant recipients must adhere to general openness principles. The open character of the Internet marketplace is what has fed the engine of economic and job growth in the information, communications, and technology sector for over a decade.

In publishing the nondiscrimination obligations, we urge the Assistant Secretary to include these contractual conditions, in addition to requiring adherence to the FCC’s Broadband Policy Statement—

Grant recipients, offering service to the public, A) must not operate their networks in such a way that privileges, degrades, prioritizes, or discriminates against any lawful Internet content application or service transmitted over the grant recipient’s network; and B) must offer bandwidth for Internet access upon reasonable request, on rates, terms, and conditions that are just, reasonable, and nondiscriminatory. Nondiscrimination shall not be construed to prohibit a grant recipient from engaging in reasonable network management consistent with the principle of nondiscrimination.

In publishing the network interconnection requirements, we urge the Assistant Secretary to require that grant recipients establish sufficient interconnection to provide consumers with robust access to the Internet.

Moreover, the nondiscrimination and interconnection obligations should apply in a technologically and platform neutral manner, to all grant recipients, regardless of whether the recipient provides wireless services, wireline services, or satellite services.

In addition, the NTIA should give priority to those qualified applicants with plans to deploy high speed fiber or wireless infrastructure, especially in those areas where access to such infrastructure is non-existent or inadequate. Using federal dollars to create a one-time investment in permanent fiber infrastructure is in most cases the most efficient use of federal dollars, which will benefit the public and a wide array of entities that rely on the Internet for commerce, health care, education, and other communications.

If you or your staff have any questions, please contact Markham Erickson at or at (202) 624-1462.


Markham C. Erickson
Executive Director

Adaptive Marketing LLC
Aegon Direct Marketing Services
American Association of Law Libraries
American Library Association
Association of Research Libraries
Circumedia LLC
Computer & Communications Industry Association
Cornerstone Brands, Inc.
Data Foundry
The Digital Media Association (DiMA)
EarthLink, Inc.
Electronic Retailing Association
Entertainment Publications
Free Press
Hawthorne Direct
Iceland Health Inc.
Interval International
Media Access Project
Media Partners Worldwide
Mercury Media
Merrick Group
New America Foundation
New Edge Networks, Inc.
North Texas Technology Council
Product Partners
Public Knowledge
Sling Media
Sony Electronics, Inc.
Success in the City
Washington Bureau for ISP Advocacy
Windward Instruments

(Late Submission)
Please see comment attached as: "NTIA comments Lafayette JASTJ.rtf"