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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)
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.


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.


Scott Bashore

Scott W. Bashore
Manager of Broadband Services

w 703.771.5578
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

C. Allen Shaffer

Direct Dial 614.227.4868



Bricker & Eckler LLP
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Main 614.227.2300
Fax 614.227.2390

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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)

(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.


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 |

Greenberg Traurig

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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)

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.

(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

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


Jessica L. Stoller
Wisconsin Dept of Commerce
Policy Initiatives Advisor
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
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 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.


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.


David Eckmann
Director of Core Business Development, Legal & Regulatory Affairs
FPL FiberNet, LLC
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


(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 // //


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

(Late Submission)

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

Dave Duncan, CAE


Iowa Telecommunications Association

2987 100th Street

Urbandale, IA 50322


(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)

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

(Original -

BTOP RFI Sectional Links - Table of Contents.doc
(Original -


"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 -


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 (

Brad Bowman

(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

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 to mid-sized CT programs.
6. Affordability in broadband must also be addressed- for residents, non-profit community service providers, and small businesses.

Answers to the questions are addressed in the attachments provided.

(Late Submission)
Broadpoint, Inc.'s comments are attached. Please contact Russell Fox, Counsel for Broadpoint, Inc., at 202-434-7300 with any questions concerning this filing.

(Late Submission)
Attached hereto are the comments of the Broadband Diversity Supporters.
Please confirm receipt.

Deborah J. Salons, Esq.
Drinker Biddle & Reath LLP
1500 K Street, NW
Washington, D.C. 20005-1209
(202) 354-1340 (direct)
(202) 842-8465 (fax)

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Thank you very much.

(Late Submission)
Please include us in your email list. Our email is:
Also , AlphaStar International is seeking partnership with Rural WISPs. Telco's, Cable TV Systems , municipalities, schools , no-profit organizations , hospitals ,libraries , Native American , vendors and suppliers and other entities to apply to the broadband stimulus fund.
Since the year 2000 ,we have deployed an IP hybrid network ;terrestrial for users ( WiMax , WiFi ,mobile and fixed or wire-lines ) with satellite back-haul only. Immediate employment and deployment ( matter of weeks ) of broadband in the rural ,remote , mountainous and maritime locations with value added service such as VOIP ,VOD ,VPN etc . Also redundancy and disaster recovery.
AlphaStar is also seeking to hire employees, management teams and consultants in all phases. both in CT and the field nationwide.
Please read attachments and visit

Contact phone : 203 979 2700
or email :

(Late Submission)
April 13, 2009

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

SUBJECT: Docket No. 090309298-9299-01 Request for Information

To Whom It May Concern:

On behalf of the Greater Philadelphia Urban Affairs Coalition (GPUAC), I am submitting comments on the development of the Broadband Technology Opportunities Program (BTOP). GPUAC is pleased that the Recovery Act appropriated $4.7 billion in funding to the National Telecommunications and Information Administration (NTIA). This funding will be used to develop and expand broadband services to unserved and underserved areas and improve access to broadband by public safety agencies.

Now celebrating our 40th year of service, GPUAC is committed to improving the lives of working families in the Philadelphia region. GPUAC’s mission is to unite government, business, neighborhoods, and individual initiative to improve the quality of life in the region, build wealth in urban communities, and solve emerging issues. As a fiscal sponsor, we represent a coalition of more than 90 grassroots organizations, with over 500 employees serving tens of thousands of residents throughout Philadelphia, Southeast Pennsylvania, New Jersey and Delaware. As an organization that drives change, GPUAC offers programs that build wealth in our communities and improve the life chances of youth and young adults.

Our primary concern with the allocation of all of the funding provided through the Recovery Act is that it will not be invested equally in all communities. We are especially concerned about urban neighborhoods that have been disenfranchised and faced with unemployment rates already in the double digits. The following comments regarding the development of the BTOP is in response to this concern.

1. Question 4.c. Establishing Selection Criteria for Grant Awards: The Recovery Act establishes several considerations for awarding grants under the BTOP. In addition to these considerations, NTIA may consider other priorities in selecting competitive grants.
How should the BTOP prioritize proposals that serve underserved or unserved areas?

GPUAC Response: In prioritizing proposals that serve underserved or unserved areas, the BTOP should prioritize neighborhoods, especially in urban areas, where a majority of residents are not accessing Broadband services in their homes. Looking at who currently is subscribing to broadband services demonstrates that access to broadband contributes to the digital divide.

Studies have shown a substantial discrepancy in household income and access to broadband. From 60 to 85 percent of homes with incomes earning over $100,000 have broadband connections compared to 10 to 25% of homes with incomes below $25,000 (Horrigan, J.B, 2008 & Kohlenberger , 2007). In addition to the socioeconomic digital divide, there is a racial divide. While two-thirds of whites (67%) have internet access, less than half of African Americans (40%) and slightly over one-third of Latinos (38%) are able to go online from their homes.

2. Question 5. A. Grant Mechanics: The Recovery Act requires all agencies to distribute funds efficiently and fund projects that would not receive investment otherwise.
What mechanisms for distributing for distributing stimulus funds should be used by NTIA and USDA in addition to traditional grant and loan programs?

GPUAC Response: Given our concern that Recovery Act funds be invested in disenfranchised communities, GPUAC believes that nontraditional mechanisms for distributing funds should be used by NTIA and USDA. It is not likely that the Recovery Act dollars will be invested equally in all communities, if our traditional, bureaucratic pipelines for distributing government funds are used. The individuals left out will be those who need these funds the most.

We believe that NTIA and USDA, as well as all government agencies with authority over Recovery Act funds, should work with nonprofit, intermediary organizations that have the expertise and capacity to infuse funds into struggling neighborhoods. Strong intermediaries, such as GPUAC, have the flexibility to expeditiously distribute funds, the necessary connections to leaders in each neighborhood, and a proven track record of awarding, monitoring and evaluating government contracts. We can ensure that these funds are allocated to distressed neighborhoods.

3. Question 6.b. Grants for Expanding Public Computer Center Capacity. The Recovery Act directs that no less than $200,000,00 of the BTOP shall be awarded to grants that expand public computer center capacity, including at community colleges and public libraries.
What additional institutions other than community colleges and public libraries should be considered as eligible recipients under this program?

GPUAC Response: First and foremost, GPUAC strongly supports the increased funding to expand public computer center capacity. As discussed above, we are concerned about the widening digital divide between income groups and race. Internet users who depend on “third places” for access – places other than home or work – are disproportionately likely to live in households earning less than $30,000. In addition, one-fourth of African-Americans and Latinos access the internet from a “third place.”

In determining other places, we urge NTIA to consider nonprofit organizations that work with families from low-income and disenfranchised communities, including churches and other faith-based organizations. Many nonprofit organizations located in these neighborhoods have the public space and infrastructure to provide these computers to their neighbors. In addition, the community members are likely to be receiving support from these organizations or the organizations have the ability to reach-out to low-income families that currently have no access to computers.

In conclusion, thank you for the opportunity to provide comments on the BTOP. GPUAC strongly believes that this program will have an impact on increasing access to broadband connections and narrowing the digital divide.


Sharmain Matlock-Turner
President & CEO

(Late Submission)
Please see the attachment. These comments are submitted on behalf of the CIOs at the four research universities in Mississippi.

(Late Submission)
Attached are comments of a coalition of non profit and public interest
organizations. I can be the point of contact for this filing, and my info
is below.

Thank you,

Beth McConnell
Executive Director
Media & Democracy Coalition
2044 S. Darien St., Philadelphia PA 19148
1133 19th St., NW, 9th Floor, Washington DC, 20036
Phone: 267-918-7207
Fax: 509-756-0392