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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)
The National Caucus and Center on Black Aged (NCBA) is submitting comments to the NTIA because we believe that the manner in which the $4.7 billion of funds in the stimulus package allocated for broadband deployment is distributed is critically important for the low-income and minority consumers we represent. Through this Congressionally-approved grant program the NTIA can vastly improve the lives of millions of seniors by expanding access to advanced telecommunications technologies and services.

(Late Submission)
The attached were submitted yesterday, and I received a confirmation of
their receipt, but they are inaccessible from NTIA comment website. I
converted them to PDF format for ease of transmission.

Robert Haga

Chief of Staff to Commissioner Chong


505 Van Ness Avenue

San Francisco, CA 94102

(415) 703-3700


(Late Submission)
Attached herewith is USTelecom's Comments in the above-referenced
docket. Please accept the attached filing for your records.

Thank you.

Meena Joshi

Law & Policy


607 14th Street, NW, Suite 400

Washington, D.C. 20005

P: (202)326-7273

F: (202)315-3351

NOTE: This message, and any attachments, is intended only for the
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delete it without re-publication or printing and notify me immediately.

(Late Submission)
I am in support of this program.

(Late Submission)
Comments attached

(Late Submission)
From: Jerry Baxley

RE: Comments regarding grants for broadband.

Executive Statement of Facts.
The United States finds itself at many crossroads at this time in its history.
Certainly the restoration of the economy has to be foremost on the mind of everyone. However, the cross that will light our way to the future is the growth of "affordable, high capacity bandwidth" or broadband across this country.

The time has come to stop thinking of speeds like DSL or ADSL. It is time to be looking at speeds in the 10Mbps and up range, as we are challenged in this stimulus package to implement many practices that will be very bandwidth intensive.

It is time to rethink what we currently call a "network". The network these funds should help fund are "smart networks" that do allow delivery of not only electronic medical records but clearinghouse and medical back office management. This "smart network" should allow for the secure storage of not only electronic medical records, but banking and business records of its subscribers.

It is time the business subscriber got 10Mdps symmetrical bandwidth for less than $500 per month. And at the same time was able to pay a reasonable "per gigabyte" rate for storage.

It is time the residents of any state were able to get not only a minimum of 5Mbps symmetrical affordable, high speed bandwidth for less than $50 per month; but they should also be able to get 250+ HD TV channels for less than $60 a month.

Most important of all, any family anywhere, regardless of economic position should be able to have for themselves or their children, computer access without putting them in a further economic hardship.

This is not outside the realm of the current technological world. It is just out of the realm of incumbent mindsets.

I am attaching a very, very brief synopsis that supports the mindset that "It is cheaper to build a new smart network than it is to fix an old dumb network"


Jerry Baxley
Montgomery, Alabama 36104

(Late Submission)

In reference to the telecommunications portion of the Presidents Stimulus
package, I wholeheartedly support a strong, credible application of the
Bill's "Buy American" provision to the broadband program. Lets insure, as
the bill was originally intended, that American jobs are created and
sustained in order to "stimulate" OUR economy. Therefore, I urge you to
award any monies to American companies whose engineering and manufacturing
operations lie here in the USA. Thank you for your consideration. I will be
very interested in your response.

Wayne A. Nichols

504 Doherty Avenue, SE

New Prague, MN 56071

952.223.4653 Home - 651.325.1183 Cell

(Late Submission)

(Late Submission)
Referenced Comments are attached in .pdf format.

(Late Submission)
Good Morning:

Will the RUS List of Materials be used? We utilize the RUS Buy American
provision in our program to identify domestic and non-domestic equipment
and I have attached a copy of this list. We are currently experiencing a
"tsunami" of new applications to get on the List and I suspect that
these vendors are anticipating that our List may be used to ensure that
any Buy American concerns are addressed. I am asking for a "heads-up"
because I want to prepare myself and our Branch; as I understand it
temporary positions are in play to handle the stimulus but not for
support our listing efforts. The RUS List of Materials would be the most
efficient mechanism to ensure any Buy American concerns are meet because
we have an extensive list of broadband vendors that are already trained
to understand our Buy American provision and any additional requirements
can be efficiently dispatched and screened for compliance (with
additional help). If not, I would like to know so I can tell these
vendors that our List of Materials will not be used, thank you and Happy


Advance Services Div., Technical Support Branch
USDA Rural Development - Utilities Programs

Phone: 202-720-0675, Fax: 202-720-1051

(Late Submission)
comments attached

(Late Submission)
Please accept the attached comments from the Advanced Emergency
Communications Coalition on the ARRA NTIA RUS broadband programs.

Should you have any question please feel free to reach:

Richard Taylor

c/o e-Copernicus

317 Massachusetts Ave, NE

Washington, DC 20002


Rob Schill

Director of Federal Affairs, e-Copernicus

(Executive Director, VTIC)

317 Massachusetts Ave., NE, Suite 200

Washington, D.C. 20002

Direct: 202-292-4604

(Late Submission)

Dear Sir or Madam:

Attached please find the comments of Granite Broadband, LLC signed and
submitted by its President, Franklin Cumberbatch.

If it is possible to acknowledge receipt by email response it would be
greatly appreciated.


Kara Tollett Oakley

(Late Submission)
please see attached file

(Late Submission)
Attached please find the comments of Stephouse Networks. Please note that this filing is being made at 8:42 pm PDT on April 13, 2009.

(Late Submission)
Please see attached.

(Late Submission)
Please accept the attached comments.

(Late Submission)
TIA letter to U.S. Department of Commerce and U.S. Department of Agriculture on the ARRA "Buy American" provision.

(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 Sancom, Inc.

Kristy Szabo
On Behalf of Sancom, Inc.

(Late Submission)
Please accept these comments on behalf of the Hispanic Information and
Telecommunications Network

Should you have any questions please contact:

Contact: Joe Dolan

Office: 646-731-3635


Hispanic Information and Telecommunications Network

Building #292, Suite #211

63 Flushing Avenue, Unit 281

Brooklyn, NY 11205-1078

Rob Schill

Director of Federal Affairs, e-Copernicus

(Executive Director, VTIC)

317 Massachusetts Ave., NE, Suite 200

Washington, D.C. 20002

Direct: 202-292-4604

(Late Submission)
Attached are the comments filed by the Michigan Public Service
Commission to the NTIA/RUS joint request for information filed on behalf
of Robin Ancona, Director of the Telecommunications Division. I have
attached a signed PDF version as well as a Word version per the

Cindy Stephens

Telecommunications Division

(517) 241-6063

(Late Submission)
Comments of Utopian Wireless Corporation attached.

(Late Submission)
Attached, please find the Comments of Cellular South to the Joint
Request for Information on the Broadband Technology Opportunities
Program. The Comments are being submitted in both PDF and Word formats.
If you have any trouble with the attachments, please let me know.

Eric B. Graham | Vice President of Government Relations | Cellular
South, Inc.

1018 Highland Colony Parkway | Suite 300 | Ridgeland, MS 39157

Office 601.974.7601 | Fax 601.974.7199 |

(Late Submission)
Please see attched pdf

(Late Submission)
See attached file.

(Late Submission)
Next Generation Broadband Inc
Submitted to the Federal Communications Commission
March 31, 2009

Recommendations Regarding the Application of Broadband Stimulus Funds

Next Generation Broadband, founded in 2001, is a broadband networking and software company that specializes in advanced application technology that enables automation and enhanced services for broadband networks. Located in the District of Columbia, Next Generation Broadband has developed and deployed, both domestically and internationally, systems that allow for advanced functionality such as fully automated customer installations, customer device management and session managed services.

NGB thanks the FCC for the opportunity to submit comments in relation to the proposed Broadband Stimulus funding, which we believe will provide insight and an alternative perspective to the Commission in determining the appropriate use of the funds allocated by Congress to achieve its aims in promoting the use and availability of broadband service to the highest level in the United States.

Comment on Application of Broadband Stimulus Funds
NGB’s interest in providing comments to the FCC is to suggest ways in which advanced technologies, like our own, can be used to enhance and leverage the investment that the government, and in particular the Department of Commerce’s National Telecommunications and Information Administration (NTIA) and the Department of Agriculture’s Rural Utilities Service (RUS) FCC and the Department of Agriculture to extend the use and availability of broadband services across the country. In this respect, Next Generation Broadband would like to comment on how advanced software based technology can support:
• Making access to broadband services more accessible to underserved and unserved markets through automation of systems supporting the broadband networks
• Reducing installation and operating costs through automation to make broadband generally more affordable
• Making systems at service providers more flexible to allow a greater variety of services that can address underserved markets
• Offering Pay-As-You-Go broadband to allow customers to buy broadband on an as needed basis
• Leveraging innovation and efficiency of productized software solutions to quickly impact these market segments
• Insuring US global leadership in advanced applications for broadband networks, which can then be exported, resulting in an increased and extended return on the government funds invested

Reducing Installation Costs Allows Operators to Offer Service to More Consumers
Beyond the investment in the core infrastructure, for both wireline or wireless networks, a key barrier to subscriber take-up is the cost of installation and activation of service. This cost on average is $100-150 per subscriber depending on a variety of factors. By automating all or part of the installation process through advanced software applications, this number can be reduced by at least 50%. Reducing this fixed cost, allows operators to:
• Offer services without an annual commitment
• Have more flexibility in pricing of services
• Loosen credit requirements for new customers
• Potentially lower cost of service

Flexible Systems in an Operator’s Data Center allows Economical Support of Underserved Markets
At the present, it is very difficult for operators to handle different groups of users in a unique manner, weather its low-income families that need subsidized service or government sponsored entities. Currently all subscribers have to be managed in the same manner, due to the inflexibility of the operator’s backe-end systems. Next Generation Broadband has developed software that resides in the operators’ central data center that can identify and direct different types of users to different product or service options in a cost effective automated manner. The possible benefits include:
• Special services and pricing for different groups of users
• Government sponsored subscriber segments that are provided free or subsidized service
• Virtual secondary networks for government or educational entities that can leverage the primary network of the service provider

Pay As You Go Broadband Makes Broadband more Affordable to a Larger Base of Subscribers
For most underserved markets, the service cost is a key impediment, new pricing options such as Pay as You Go” can be implemented that do not require a high monthly fee for broadband usage. Pay As You Go broadband also removes issues around credit checks. This service class is a model already used in the cellular telephone space with some success, and NGB has already had discussions with a number of large broadband service providers in North America and in Europe on our session management system that allows a cost effective means of automating the control and pricing of pay as you go services. Benefits include:
• Reduce need for credit checks
• Eliminating requirement for high fixed monthly payment by subscriber
• Cost effective solution for occasional users
• New service option for subscribers on a fixed income

Product Based Software Solutions Allow Immediate Impact and Access for the Underserved Markets
In making broadband services more accessible to underserved markets there are multiple options such as hardware based solutions or custom built applications. These options are very expensive and can take years to implement. Product based software solutions, from small innovative companies like Next Generation Broadband, are existing technology that can be deployed quickly and can have immediate impact on underserved markets. This technology is applicable to cable, DSL and wireless based networks. Productized software solutions allow:
• System deployments in months instead of years
• Impact on underserved markets in months instead of years
• Proven technology that has been previous deployed, supporting a national footprint both in the US and internationally
• Lower operational and technology risks for operators and service providers

Investing in Technology Developed by Small Businesses can be Leveraged and Exported Globally
The US has an opportunity to be a global market leader in developing advanced applications and software systems that expand functionality of broadband networks. Investment in these systems can be leveraged in international markets and have a multiplier effect beyond addressing underserved markets in the US. Government support of the capital expense of these technologies can help insure the leadership of US companies in this space. This type of innovation, historically originates from small businesses such as Next Generation Broadband, resulting in:
• New jobs created in the US to support the development and deployment of these applications
• US based intellectual property that can be sold and exported to overseas markets
• Global recognition of US as market leader in broadband technology
• Creation of cottage industries to support extensions of core technology

About Next Generation Broadband
Next Generation Broadband has installed systems both domestically and internationally to large broadband service providers, enabling automation and advanced functionality on broadband networks. Some of our systems include: auto installation for broadband data and VoIP, session managed solutions for pay as you go and free user trials, as well as, systems to identify and manage different types of broadband devices such as PCs, cable modems, gaming devices and home networking equipment. Currently NGB is developing new products for wireless and video networks.

NGB’s core team has worked at many key broadband service providers like, AT&T, Verizon, USWest, Time Warner, Telstra, Road Runner, and others. Our executive team has experience across international markets in Asia, Europe, South America as well as North America. Market experience includes Japan, Korea, Singapore, Hong Kong/China, Singapore, Australia, New Zealand in Asia and Oceania, and in Europe, the Netherlands, France, United Kingd

(Late Submission)
The attached documents describe the goals of the new Schools, Health and Libraries Broadband Coalition.

(Late Submission)
Please see attachment

(Late Submission)

(Late Submission)
Dear Ms. McGuire-Rivera:

On behalf of InLine, I would like to submit the following comments
regarding the American Recovery and Reinvestment Act of 2009 Broadband
Initiatives. As a Total Solutions Provider, InLine believes that
extending broadband capabilities throughout the nation is key to
spurring economic development and promoting efficiencies in public and
private service operations. We look forward to the opportunity to work
in conjunction with the NTIA, RUS, and state and local agencies in these

If you require more detail or clarification, please do not hesitate to
contact me.


Vickie Edwards, MPA

Grant Specialist

InLine Connections

vickie edwards, MPA | Grant Specialist
InLine Connections> Solutions Through Technology
600 Lakeshore Pkwy
Birmingham AL, 35209
205-278-8106 [p]
All Quotes from InLine are only valid for 30 days. This message and any attached files may contain confidential information and are intended solely for the message recipient. If you are not the message recipient you are notified that disclosing, copying, distributing or taking any action in reliance on the contents of this information is strictly prohibited. E-mail transmission cannot be guaranteed to be secure or error-free as information could be intercepted, corrupted, lost, destroyed, arrive late or incomplete, or contain viruses. The sender therefore does not accept liability for any errors or omissions in the contents of this message, which arise as a result of e-mail transmission. If verification is required please request a hard-copy version.

(Late Submission)
please see attached PDF file. please email Janice Chan at in case of any problems opening/reading the file.

(Late Submission)

Attached please find the response from the Arizona Telecommunications

and Information Council (ATIC) NTIA Broadband Technology Opportunities



Oris Friesen, Vice Chair

Arizona Telecommunications and Information Council (ATIC)


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(Late Submission)
To Whom it May Concern:

Attached, you will find the comments of Cheetah Wireless Technologies, Inc. ("CWTI") in response to the NTIA/RUS Joint Request for Information under NTIA Docket No. 090309298-9299-01.

Respectfully Submitted,

Mitchell Gonzalez
President and CEO
Cheetah Wireless Technologies, Inc.

(Late Submission)
Attached are Comments of the Benton Foundation and the University of Illinois at Urbana Champaign Graduate School of Library & Information Science on
Measuring the Success of the Broadband Technology Opportunities Program.

(Late Submission)
see attachment, please

(Late Submission)
See attached

(Late Submission)
Please find attached Governor Dave Freudenthal's comments on the broadband stimulus program

(Late Submission)
On behalf of Native Public Media, I hereby submit its initial comments
with respect to the BTOP program (Docket no. 090309298-9299-01).

John Crigler

Unless expressly stated otherwise, any federal tax advice contained in
this communication (including attachments) is not intended to be used,
and cannot be used, for the purpose of avoiding federal tax penalties.

This e-mail is for the sole use of the intended recipient(s). It
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you believe that it has been sent to you in error, please notify the
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fifth floor
1000 potomac street nw
washington, dc 20007-3501
TEL 202 965 7880 x 2521 FAX 202 965 1729

(Late Submission)
This message from the law firm of Dow Lohnes PLLC, may contain
confidential or privileged information. If you received this
transmission in error, please call us immediately at (202)776-2000 or
contact us by E-mail at Disclosure or use of any
part of this message by persons other than the intended recipient is


On behalf of our client Cox Communications, Inc., I am transmitting to
you herewith an electronic version of Cox's comments in response to the
joint request for information and notice of public meetings of the
National Telecommunications and Information Administration and the Rural
Utilities Service. The comments are submitted in the form of a
Microsoft Word document.

Please inform me if any questions should arise in connection with this

J.G. Harrington

Counsel to Cox Communications, Inc.

Dow Lohnes PLLC
1200 New Hampshire Avenue, NW
Suite 800
Washington, DC 20036-6802
T 202-776-2818
F 202-776-2222

(Late Submission)
It looks like my email didn't properly show the attachment. I am re-posting to make sure.

(Late Submission)
Advanced Emergency Communications Coalition comments on ARRA NTIA RUS Broadband Programs

(Late Submission)











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(Late Submission)
This is actually a question/concern. Two days ago, I submitted a comment, along with two documents in pdf format, to this site. So far, I don't see any evidence to suggest you have received them. I'm attaching the confirmation page I got, in case it will help you locate them. Thank you! Sara Wedeman

(Late Submission)
Attached, in both Word (.doc) and Adobe (.pdf) formats, are the comments of
the Montana Telecommunications Association (MTA) in response to the joint
request for information of the Departments of Commerce (National
Telecommunications and Information Administration) and Agriculture (Rural
Utilities Service) re: Docket No. 090309298-9299-01.

Please feel free to call or reply if you have any questions or comments.


Geoff Feiss
Montana Telecommunications Association
406.442.4316 (office)
406.594.0424 (mobile)

Serving Montana¹s telecommunications industry for 55 years

NOTE: this communication may contain confidential and privileged material
not intended for use or dissemination beyond the recipient.

(Late Submission)
Please find comments in Docket Number 090309298-9299-01 attached.
Rene True
Executive Director

(Late Submission)
Dear Ms. McGuire-Rivera, we are preparing a BTOP submission, and had the
following questions for clarification.

We have included them in a Microsoft Word document, but have also copied
them into the email due to the many different versions of Word in use today.

We thank you in advance for your assistance.

Most Sincerely,

Bill Boone

William T. Boone

Director, Center of Innovation for Agriculture

P.O. Box 7350

Tifton, Georgia 31793

Phone 229-391-6883

Fax 229-391-6880

Center of Innovation for Agribusiness

Rural Broadband Fixed Wireless Initiative

April 2009

Bernadette McGuire-Rivera

Associate Administrator

Broadband Technology Opportunities Program

U.S. Department of Commerce

Room 4812

1401 Constitution Avenue, N.W.

Washington, DC 20230

Dear Ms. McGuire-Rivera:

The absence of affordable internet connectivity in rural America today is
preventing economic growth, hindering agricultural innovation and stifling
our ability to educate our children and prepare our workforce. Nowhere is
this truer than in rural South Georgia, Northwest Florida, and Southeast
Alabama. Broadband internet access is the most important, over arching and
affordable economic development tool we can provide to rural America.

Our South Georgia collaborative intends to apply for a portion of the
Broadband Technology Opportunities Program funds, as outlined in the
American Recovery and Reinvestment Act.

Budgetary estimates to establish the Wireless High Speed Internet Connection
are approximately $1 million per rural county. This varies with the size of
the county and the number of towers needed to provide adequate coverage for
the communities, shops, homes and farms. When compared to a local county,
who was just awarded $3.2 million to connect fiber optic cable to 85% of the
geography in the county, this is a substantial savings and a higher rate of
homes covered. This will vary with the size of the county and the number of
towers needed to provide adequate coverage.

Our initial program will include up to 50 counties.

We have the following questions:

* Will the USDA RUS program allow a multi-state and multi-county
grant for a "smart grid" type rural broadband project?

* How will the funds for broadband stimulus projects be awarded?
Directly to the grant requestor or will the funds have to go through the

* Will the states be able to dictate which projects get funded with
these grants (both NTIA and RUS)? How much influence will they be able to

* How will the grant funds be distributed? Fully funded with
reporting? Or as a draw down based on monies spent? Or draw down based on
P.O. like the RUS Broadband Loan program?

* Can any of the stimulus money be used to conduct engineering
assessment and design of project?

* Can engineering assessment and design be considered part of the
20% match requirement?

* Will there be a new set of guidelines that allow broadband
borrowers to borrow in market areas where there are presently USDA or
Commerce borrowers?

* Will there be guidelines for incumbents to either deploy
ubiquitous broadband or lose their protected borrower status?

* When will the new grant applications be available or is it
appropriate to use the current grant applications? What are the projected
timelines for the applications; submission and action on the application?

Respectfully Submitted,

W.T. Boone

Director, Center of Innovation for Agribusiness


(Late Submission)
see attached

(Late Submission)
Please accept these comments on behalf of New EA (dba Flow Mobile). For
further information you may reach:

Sree Tangella, President and CEO

New EA

1915 North Kavaney Drive

Bismarck, ND 58501

Office: 701.255.9500

Mobile: 650.704.7888


Thank you.

Rob Schill

Director of Federal Affairs, e-Copernicus

(Executive Director, VTIC)

317 Massachusetts Ave., NE, Suite 200

Washington, D.C. 20002

Direct: 202-292-4604

(Late Submission)
Please see attached letter.

(Late Submission)
Dear Sir or Madam:

Please find attached the Comments of Utopian Wireless Corporation filed in Docket number 090309298-9299-01. These comments were also filed through the Web comment filing system.

Please contact me with any questions. Thank you.


Clare C. Liedquist
Utopian Wireless Corporation
VP, Licensee Relations
Tel: (240) 821-9700, ext. 203
Fax: (301) 656-2328