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Joint Broadband Technology Opportunities Program Request for Information

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

American Recovery and Reinvestment
Act of 2009 Broadband Initiatives

Comments

(Late Submission)
Attached are the comments of the National Emergency Number Association
(NENA) in response to the NTIA/RUS RFI concerning the Recovery Act
broadband initiatives. The comments were also submitted online.



Best regards,



Patrick Halley

Government Affairs Director

NENA




(Late Submission)
See attached

(Late Submission)
Please see the attachment.

(Late Submission)
Please find attached the Comments of Iowa Health System, Inc. in response to the Joint Request for Information.

(Late Submission)

March 31, 2009

Via Electronic Mail

Bernadette McGuire-Rivera
Associate Administrator
Office of Telecommunications and Information Applications
Broadband Technology Opportunities Program
U.S. Department of Commerce, Room 4812
1401 Constitution Avenue, N.W.
Washington, DC 20230


Re: Docket No. 090309298-9299-0 1





Dear Ms. McGuire-Rivera:


Stratum Broadband submits the attached comments and attachment relative to
the American Recovery and Reinvestment Act of 2009 Broadband Initiatives.
We are pleased that the NTIA and RUS are moving forward with this most
important work. Broadband is the essential connection in many ways for the
nation and increasingly the global economy. It is essential to promoting
economic growth in all communities, both large and small.


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



Respectfully submitted,


\s\

John Reynolds
Partner
Stratum Broadband
john.reynolds@stratumbroadband.com


(See attached file: Stratum Broadband ARRA RFI Response.doc)(See attached
file: Blueprint for Big Broadband.pdf)



(Late Submission)
Please see attached.

(Late Submission)
See attached.

(Late Submission)
Attached, in both Word (.doc) and Adobe (.pdf) formats, are the comments
of SkyTerra Communications, Inc. in response to the joint NTIA and RUS
request for information.

> >

Emily J. H. Daniels | Pillsbury Winthrop Shaw Pittman LLP
--------------------------------
Tel: 202.663.9378 | Fax: 202.663.8007
2300 N Street, NW | Washington, DC 20037-1122

Email: emily.daniels@pillsburylaw.com

www.pillsburylaw.com




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(Late Submission)



_________________________________________________________________
Windows Liveâ„¢: Keep your life in sync.
http://windowslive.com/explore?ocid=TXT_TAGLM_WL_allup_1a_explore_042009


(Late Submission)
Comment is attached as pdf

(Late Submission)
As per the instructions in the instructions provided in the Federal
Register notice, I hereby submit the attached set of comments on behalf
of the American Legislative Exchange Council. Both the attached pdf
document and the attached Word document are identical in content. (This
e-mail is not considered to be part of those comments.)



Best Regards,



Seth

____________

SETH COOPER

Director, Telecom & IT Task Force

American Legislative Exchange Council (ALEC)

Office: 202-742-8524

Cell: 202-302-3428

FAX: 202-466-3801

sethcooper@alec.org






(Late Submission)
Comments re: access to broadband for people with disabilities attached. Submitted by NCAM & Inclusive Technologies

(Late Submission)
TO WHOM IT MAY CONCERN:

We are pleased to respond to NTIA, U.S. Department of Commerce; Rural Utilities Service, U.S. Department of Agriculture's joint request for information relative to the American Recovery and Reinvestment Act of 2009.

Attached please find an MS Word document which contains responses to the preliminary questions. We are excited about these opportunities, and appreciate the opportunity to provide input at this stage of the process.

We look forward to submitting several innovative, direct and partnership proposal submissions for future NTIA consideration.

Respectfully Submitted,

William Wells, Jr.
True Broadband Networks, LLC.
Managing Partner
1109 E. 31st Street, Ste. G
Kansas City, MO 64108
816.234.8783
wwells@truebtv.com
www.trueh2o.com

(Late Submission)
As noted following the Conclusion, this document reflects extensive review, analysis and the collective judgment of an international team of leaders in the communications industries whose experience spans technical, financial, economic and legal arenas. As such, it is not presented as representative of any one national government, carrier, academic institution, legal practice or consultancy, but rather as the collective and agreed upon view of many individuals who remain committed to the health of the world’s electronic communications infrastructure.

(Late Submission)
Please see the attached letter from R. Bruce Josten, Executive Vice President for Government Affairs at the U.S. Chamber of Commerce, urging the NTIA to adopt rules that would award Broadband Technology Opportunities Program grants funded by the American Recovery and Reinvestment Act of 2009 on an expedited basis to reputable applicants who demonstrate that they have ready-to-go projects that will bring broadband to unserved areas or spur broadband adoption.

Sincerely,
Jason Goldman

===

Jason D. Goldman
Counsel, Telecommunications & E-Commerce
Environment, Technology & Regulatory Affairs Division
U.S. Chamber of Commerce
1615 H Street, NW
Washington, DC 20062
Tel: 202-463-5949
Fax: 202-887-3445
E-mail: jgoldman@uschamber.com

(Late Submission)
Kathy tried to send this twice and it would not go through. Trying from
my email address too.



Carla A. Anderson |SVP/COO | e-Copernicus | 317 Massachusetts Ave. NE:
Suite 200 | Washington, DC 20002 | Office: 202.292.4603 | Mobile:
202.498.6936 | Fax: 701.794.3356



From: Johnson, Kathy [mailto:Kathy.Johnson@governor.alabama.gov]
Sent: Monday, April 13, 2009 11:55 PM
To: BTOP@ntia.doc.gov
Cc: Anderson, Carla; Johnson, Kathy
Subject: Docket No. 090309298-9229-01 - ARRA Broadband Initiatives
Importance: High



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
E: kathy.johnson@governor.alabama.gov

W: www.connectingalabama.gov

No virus found in this incoming message.
Checked by AVG - www.avg.com
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04/13/09 17:56:00




(Late Submission)
The attached comments were submitted earlier today in Word format via email pursuant to the Federal Register instructions. We are submitting them via Web Comment Word attachment as well to ensure inclusion in the record.

(Late Submission)
Good afternoon;

I have attempted to submit the attached comments in .pdf format at
http://www.ntia.doc.gov/broadbandgrants/form.cfm per the March 12, 2009
Federal Register Notice. However, whenever I attempted to do so, a
message appeared saying that "comments were required," so I am uncertain
if the submission via the web page for was successful.

In any event, per the instructions in the Federal Register notice, I am
also submitting the comments, attached to this message. Please let me
know if you have any questions. Thank you,

Steve

Steve Pastorkovich
OPASTCO Business Development Director/
Senior Policy Analyst
202-659-5990 ext. 217
http://www.opastco.org




(Late Submission)
Mark -

Attached is the CWA Ex Parte on the Buy America provisions. You will find a CWA proposal to streamline implementation of these provisions. I am happy to discuss this further with you.

Debbie


Debbie Goldman
Telecommunications Policy Director and Research Economist
Communications Workers of America
501 Third St N.W.
Washington, D.C. 20001
202-434-1194 (phone)
202-434-1201 (fax)
dgoldman@cwa-union.org



(Late Submission)
As I discussed with George, attached is a letter noting the meeting I
and others from my office had with NTIA about the BTOP program, as well
as the handout that was discussed during the meeting.



Radhika Karmarkar

Senior Counsel for Regulatory and Legislative Affairs

NYC Department of Information Technology and Telecommunications

75 Park Place, 9th Floor

New York, NY 10007

212-788-6565








(Late Submission)
Six suggestions for innovation in ownership and business models and technology

Larry Press, Professor, IS, California State University, Dominguez Hills
Charles Brown, The Emergency Communications Leadership and Innovation Center
Patrick Lanthier, The Emergency Communications Leadership and Innovation Center

This note is a summary of the attached paper, which is also available at:
http://www.uic.edu/htbin/cgiwrap/bin/ojs/index.php/fm/article/view/2374/2159.

The paper argues that the BTOP should:

1. Be pessimistic about our ability to create competition through legislation and regulation.
2. Support commodity IP connectivity, not differentiated services.
3. Study current municipal ownership and business models and policies in cities and local areas around the nation and world.
4. Encourage and evaluate innovation in ownership and business models in the local "middle mile" - to learn what works and what does not.
5. Encourage and evaluate projects that push ownership and control of portions of the access network out to home and building owners.
6. Encourage experimentation with last-link wireless, using existing standards like IEEE 802.11 and custom hardware and software.

Since divesture in 1984, we have hoped that legislation and independent regulation could bring about competition in telecommunication markets. However, the large broadband incumbents have benefited from public subsidy without living up to commitments to install fiber, and have used their power to defeat attempts to establish competition. They have also insisted on a service-oriented business model, selling telephone, television and other services rather than service-independent connectivity, leading to inefficient allocation of resources and allowing for cross-service subsidy.

Our access networks are aging, and will be stressed by increasing video traffic. Following the lead of some Asian and European nations, we are beginning to roll out next-generation access networks based on fiber and wireless technology. We will have fiber to all urban and many rural homes and buildings in the long run. The question is not whether we are going to deploy new access infrastructure; the question is "who will own it?"

The BTOP is not large enough to procure and deploy our next generation access networks, but we should use it to encourage and evaluate innovation in ownership and business models and technology.

For example, consider the monthly cost of fiber-based, residential Internet service in several cities:

* Stockholm, 100/100 Mbps: $11
* Seoul, 100/100 Mbps: $24
* Hong Kong, 100/100 Mbps: $35
* Tokyo, 100/100 Mbps: $61
* Amsterdam, 100/100 Mbps: $127
* Lafayette, Louisiana municipal network, 50/50 Mbps: $58
* Lafayette, Louisiana Cox Cable, 50/5 Mbps: $140
* US where available, Verizon FIOS, 50/20 Mbps: $145

Can we explain the large speed and cost differences?

The Cox Cable offering in Lafayette, Louisiana is the slowest and is only five dollars a month less than Verizon FIOS. The municipal network in the same city is faster and cheaper, but the Cox network reaches more neighborhoods, and Cox competes with temporary sale prices where there is overlap.

Stockholm is at the other extreme. They have a municipal network that reaches every block in the city. Unlike Lafayette, they do not offer consumer service over their fiber, but lease network access to anyone who would like to offer service. The Internet service providers, including incumbent telephone and cable companies, compete on an equal footing.

As a result, there are many competing service providers in Stockholm, and the city owns the expensive, long-life assets like fiber, rights of way, conduit, and tunnels, and the service providers own the electronic equipment that is relatively cheap and is upgraded frequently as technology improves.

This is only one, partial example. The BTOP should fund ongoing study of municipal projects. We have conducted studies to characterize the state of the Interent in many nations, using a framework developed by ourselves and colleagues. However, national context explains only a portion of the variation among cities. The city or local area, not the nation, is the relevant unit of analysis in this case, and a framework for characterizing the state of the Internet in a local area should be developed and used.

Going beyond the middle mile, we should encourage projects that push ownership and control of access networks out to home and building owners. In some cases, these may involve fiber to the structure. (Such a trial is underway now in Ottawa, Canada). Others may bring fiber to the curb or block and rely upon wireless technology in the last link. This may take many forms - point to multipoint links, local mesh networks, radios that adapt when interference is detected, etc. Whichever technologies are used, they should present standard interfaces, and the hardware should be packaged in self-install kits for mass distribution through chains like Home Depot or Radio Shack.

We will be living with the fiber and high-speed wireless infrastructure we build today for many decades. We will also be living with its owners. BTOP funds can be used to study what others have done and experiment with innovative ownership and business models and technology.

(Late Submission)
Attached please see comments from the Rural Mobile Broadband Alliance (RuMBA) USA

(Late Submission)
Attached please find a copy of the joint comments of the Vermont Department of Public Service, the Massachusetts Broadband Institute, and the Massachusetts Department of Telecommunications and Cable.

(Late Submission)
Here is a brief filing address mainly NTIA Question 7 on selecting grant
recipients for rural broadband projects.



Micah Singer

+1-310-279-4701 (direct)

+1-888-350-6664 (fax)

micah@voiplogic.com

VoIP Logic






(Late Submission)
Department of Commerce
National Telecommunications and Information Administration and the Department of Agriculture Rural Utilities Service

Washington, D.C. Joint request for information: American Recovery and Reinvestment Act of 2009 Broadband Initiatives )
)
) Docket No. 090309298-9299-01


The Wisconsin Technical College State Board is the governing body of the Wisconsin Technical College System (WTCS). The WTCS has 16 technical college districts throughout Wisconsin, which offer more than 300 programs awarding two-year associate degrees, one- and two-year technical diplomas and short-term technical diplomas. In addition, the System is a major provider of customized training and technical assistance to Wisconsin’s business and industry community and the primary provider of adult basic education services in the state. More than half of all adults in Wisconsin have accessed the technical colleges for education and training in the last decade. We appreciate this opportunity to comment on the broadband funding available in the American Recovery and Reinvestment Act of 2009 (ARRA). Following are comments regarding specific RUS/NTIA questions.

Effective ways to offer broadband funds to ensure that rural residents receive it
To ensure that un-served and under-served populations gain access to broadband services, proposals that include public/private partnerships should be given priority for infrastructure funding. Such projects should finance infrastructure to connect Community Anchor Institutions broadly defined to include Universities, Technical and Community colleges, Schools, Libraries, Museums, Health care facilities and other institutions that are able to aggregate regional entities, are geographically dispersed and are accessible to the public. The WTCS supports such a project filed in this same docket by WiscNet (Wisconsin’s Research, Education, and Public Service Network); Go-GIG!

If bandwidth can be expanded or brought to CANs (Community Area Networks) or Community Anchor Institutions, then local users only need to get local connections, which is much cheaper than the long distances between communities. Once we pay for the anchor sites – then the local ISP / providers can afford to connect public users on extra fiber that would be run when the Anchor Institutions are connected. Local users may still need to pay for the local connections, but the return on investment for the vendors should be less, so fees can be less to the users.

The $200 million for public computing centers should give priority to proposals that involve collaboration between libraries and community colleges and which leverage the existing broadband assets and capacity of both or multiple entities. To best leverage existing broadband capacity, and to ensure that the public can truly take advantage of new infrastructure or expanded capacity, services and staff associated with improving public access should be an eligible use of these funds, including training services, security, user support services, and equipment upgrades.

Eligible Grant Recipients
Community Area Networks (CANs) operated or managed by the public sector, not-for-profits, or by the private sector should be eligible entities. Priority should be given to CANs that serve areas with large low income populations or un- and under-served populations.

Establishing Selection Criteria for Grant Awards
In addition to the specific criteria referenced in the Recovery Act, priority or preference in the grant ranking process should be given to:
• Applications that seek to expand existing programs, infrastructure and services
• Applications that provide long-term benefits (e.g., fiber)
• Applications that show collaboration or partnerships, (e.g., CANs), and
• Applications that demonstrate a large regional or statewide impact.

Grant Mechanics
Give priority to applications that build on existing programs and services and that have a track record the applicant can document. Consider a more streamlined application process for grants requesting less than $50,000. Have reasonable limits on the length of the grant application form.

Grants for Expanding Public Computer Center Capacity
The nation’s technical and community colleges have significant investments in broadband capacity that could be leveraged with the nation’s public libraries physical capacity to maximize the number of public computing centers established through the ARRA funding. Key needs of such collaborative proposals include:
• Expanded bandwidth
• Security
• Ongoing user training and support
• Ongoing maintenance and equipment upgrades

To encourage leveraging of existing resources, the $200 million for public computing centers should give priority to proposals that involve collaboration between libraries and community colleges and which leverage the existing broadband assets and capacity of both or multiple entities. To best leverage existing broadband capacity, and to ensure that the public can truly take advantage of new infrastructure or expanded capacity, services and staff associated with improving public access should be an eligible use of these funds, including training services, security, user support services and equipment upgrades.

Innovative Programs to Encourage Sustainable Adoption of Broadband Services
The economic effect of expanding the nation’s broadband infrastructure will be reduced if the majority of end users of this structure (businesses, consumers) do not have the equipment, technical skills or knowledge to access the system. Educational and community service organizations with established programs for delivering this technical skill and knowledge and whose service area includes un-served or under-served populations, should be eligible to apply for grants for education, awareness, training, access, equipment, and support under Section 6001(b)(3) ).

Financial Contributions by Grant Applicants
Allow in-kind contributions to be considered as the “match”. Specifically, for public computing center projects, in-kind match should be required to demonstrate existing broadband and public access assets.

(Late Submission)
Please find the attached written comment from Free Press, as filed April 13, 2009.

(Late Submission)
Please see attached document- My effort to build awareness of the unique advantages smaller companies offer.

(Late Submission)
Attached as .pdf file

(Late Submission)
Walters & Associates, Inc. respectfully submits its Comments regarding Spectrum Valuation Issues to the Joint National Telecommunications and Information Administration - Rural Utilities Service Request for Information, Docket No. 090309298-9299-01.
Attachments

(Late Submission)
Please see attached letter.

(Late Submission)
Please find attached the submission from The Quilt and StateNets organizations in response to the Department of Commerce's request for comments on NTIA's Broadband Technology Opportunities Program. Should you have any questions or require additional information regarding the content of this submission, please contact me. Thank you for the opportunity to comment.

Jen Leasure
President and CEO
The Quilt
www.thequilt.net

(Late Submission)
I am attching my comments in a WORD document and in a pdf file.

(Late Submission)
Please open the attached pdf. Thank you for the opportunity to comment.

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

(Late Submission)
See attached.

(Late Submission)
See Attached Comments

(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 Enhanced Telecommunications Corp.

Kristy Szabo
On Behalf of Enhanced Telecommunications Corp.
605-995-1786



(Late Submission)
Please accept this updated version of our comments in place of the previous comments we submitted to NTIA. Please remove the prior version, which included tracked changes.

Best,
Ken Eisner
Managing Director, OE Ventures
One Economy Corporation
202.256.2897 m

(Late Submission)
Please see last paragraph of this article concerning Broadband, and senior health & fiber to the home.

(Late Submission)
State of Washington
Comments in Response to Federal Request for Information Regarding
The American Recovery and Reinvestment Act of 2009 Broadband Initiatives
Docket Number 090309298-9299-01

Executive Summary

The State of Washington's comments are focused on the following topic areas: The Purposes of the Grant Program; The Role of the States; Eligible Grant Recipients; Establishing Selection Criteria for Grant Awards; Broadband Mapping; Financial Contributions by Grant Applicants; Reporting and De-obligation; Coordination with USDA's Broadband Grant Program; and Definitions. Also included are responses to the Rural Utilities Service's (RUS) questions one through four.

Our goal in responding was to urge NTIA and RUS to preserve maximum flexibility in the manner that grants under the ARRA are considered and awarded. We also believe it is critical for states to have a meaningful and substantial advisory role in determining which projects meet the criteria set forth in the ARRA and any further federal requirements established by NTIA. The states can provide a comprehensive and localized understanding of their economic condition and broadband deployment challenges. Their views of where efforts to introduce or enhance broadband investment and encourage increased consumption are vital to ensuring that the greatest overall benefits are realized for those projects selected under the auspices of the BTOP program.

We urge the NTIA reviewers to consider Washington's detailed responses in the development of the program.







State of Washington
Comments in Response to Federal Request for Information Regarding
The American Recovery and Reinvestment Act of 2009 Broadband Initiatives
Docket Number 090309298-9299-01

NTIA
The Purposes of the Grant Program

Washington State supports the development of NTIA guidelines for ensuring that broadband recovery funds are directed towards the purposes of the American Recovery and Reinvestment Act of 2009 (ARRA): reaching unserved and underserved populations; supporting broadband education, awareness, training, access, equipment, and support; improving access to broadband by public safety agencies; and stimulating the demand for broadband, economic growth, and job creation.
We do not support allocating a pre-set percentage of funds to each of the purposes enumerated under Section 6001(b) of the ARRA. Different areas of the United States have achieved different levels of progress in providing broadband infrastructure, access, education, training, equipment and support. Varying levels of progress make it problematic to assign a certain percentage of funds to each purpose set forth in the ARRA.
We support an approach that encourages fund applicants to address more than one legislative purpose in their requests, and, when possible, identifies opportunities to leverage other fund sources in support of their funding requests. We also believe that providing high-speed access to schools, universities, libraries, community centers job training centers, hospitals and public safety personnel is critical.
On balance, determining whether it is more important to invest in infrastructure than to invest in mapping or provide education and training will be a location-based issue. Please refer to "The Role of the States" below for additional comments relating to prioritization and meeting the goals of the ARRA.
The Role of the States
The State of Washington supports a meaningful and substantial advisory role for the states in determining which projects meet the criteria set forth in the ARRA and any further federal requirements established by NTIA. The states can provide a comprehensive and localized understanding of their economic condition and broadband deployment challenges. Their views of where efforts to introduce or enhance broadband investment and encourage increased consumption are vital to ensuring that the greatest overall benefits are realized for those projects selected under the auspices of the BTOP program.
Like many states, Washington has its own initiative underway to assess and establish improved conditions for broadband deployment and adoption in the state. It is crucial that NTIA's BTOP rules tap into and complement such state efforts by establishing a consultative relationship with each state to evaluate, rank, and prioritize all public and private proposals submitted to the agency under the BTOP program. Serious consideration should be given to those projects specifically prioritized by a state's official designee that promote economic recovery in a manner most consistent with the statutory criteria of the BTOP program while fully considering local conditions.
The state consultative process should include at least four key components to maximize its effectiveness.
First, NTIA should request that each designated state official or agency adopt or have in place a defined and state-sanctioned process to engage all stakeholders in a broad outreach effort to ensure wide-ranging awareness of the resources available under the BTOP program for broadband infrastructure deployment and to promote broadband adoption by consumers.
Second, NTIA should require that each applicant for BTOP funding be required to file contemporaneously with the state its application and all supporting documentation.
Third, NTIA should set forth broad criteria for states to use in reviewing and ranking applications, while allowing states the flexibility to consider specific factors reflecting state and local conditions.
Finally, assuming that states have an ongoing role in monitoring and reporting on the effectiveness and compliance of accepted projects, each successful applicant for BTOP funding should be required to allow access to and share any relevant information, including books and supplementary records pertaining to their project(s), with appropriate state officials to assist the state and NTIA in evaluating each grantee's compliance with the terms and conditions of their BTOP award.
Eligible Grant Recipients
With two exceptions, the eligible recipients identified in the ARRA are sufficient to ensure that the public's interest in expanding broadband development and deployment are met.
We encourage the NTIA to allow eligible entities to include new types of partnerships among public, nonprofit, and for-profit entities either to provide broadband infrastructure or to stimulate or aggregate demand for services. Such partnerships may be to create leverage and linkages between different infrastructure providers or demand-side entities to target certain unserved and underserved areas better, or offer higher speeds or more services or greater affordability in existing areas.
Washington also supports making BTOP and RUS grants and loans available to private organizations or companies that have existing broadband capabilities or investments that seek to utilize funding to expand existing infrastructure into underserved or unserved service areas, regardless of technology.
Successful applicants should have a track record of providing quality telecommunications and information services to the public, and we fully expect that innovative grant proposals will come from the private, public, and non-profit sectors. The determination of whether an entity other than those described in Section 6001(e)(1)(A) and (B) is in the public interest depends on the particulars of the grant proposal. Assuming the applicant has demonstrated financial bona fides and technical competencies, and commits to comply with the terms of the ARRA, the NTIA should find that it is in the public interest that the applicant be eligible to compete for grant awards.
The NTIA should also consider applications from non-profit and public regranting programs for the purposes of community technology literacy and broadband access programs reaching vulnerable populations.
Finally, Washington believes the NTIA should reserve the power to make exceptions to the grant eligibility criteria in cases where no eligible entity comes forward for a specific location, and an entity or group of entities can show that they share the characteristics and overall goals of otherwise eligible, similarly situated, recipients.
Establishing Selection Criteria for Grant Awards
Although it may be desirable to rank or prioritize factors and criteria for awarding grants, Washington believes that NTIA should retain sufficient flexibility amongst the statutory criteria such that any mix of supply and demand side projects may be funded under the BTOP program.
Simply stated, not all states are the same. Each state has its own social demographics, geography, and economic conditions, among other factors. More specifically, from a broadband perspective, each state has different broadband deployment levels, competitive alternatives, and consumer adoption practices and levels. While some geographically large states may have broad swaths of un-served or partially-served areas, other smaller, more densely populated states, may have more urbanized requirements pertaining to broadband adoption. Similarly, opportunities for computer training may be different in different communities. BTOP criteria need to be sufficiently flexible to anticipate and address the requirements of both situations.
Accordingly, Washington strongly believes that NTIA should resist efforts adopt rigid or inflexible selection criteria in an effort to apply a "national"solution or approach to determining grant awards where different approaches for different states would address better local conditions.
Washington would support a rebuttable presumption for"sustainable adoption of broadband services" which assigns a heavier weight to grant proposals that come from existing broadband infrastructure providers, public or private, and demand-side programs that have a proven track record.
We disagree with the suggestion that a statewide map or mapping initiative should be a prerequisite to receiving BTOP funding for infrastructure. While it may be true that a broadband map can be a useful tool to identify un-served areas of a state, other resources or avenues also exist to facilitate identification of unmet broadband requirements. State economic development agencies, state commissions, and state or local government task forces or committees may well have meaningful insight and opinions on undeveloped areas ripe for broadband investment. Indeed, an ad hoc group established by the Washington Legislature recently completed a comprehensive study of factors influencing broadband investment and adoption throughout the state and made recommendations regarding a potential mapping endeavor. While that process may someday lead to a statewide broadband map, there is simply no need to wait for the outcome of the state mapping exercise to begin tapping BTOP funding when suitable information from alternative sources already exists.
We also urge that each grant applicant be required to certify in some form that it is not seeking similar or identical support from the RUS broadband program as a means to "double dip" federal funding for their particular project(s). While Washington understands that NTIA and RUS may plan to coordinate in some fashion to prevent double dipping, a self-certification process for project proponents provides an added layer of awareness and prevention of such an outcome. We support the recommendation from NASUCA asking that federal agencies establish an interagency task force to address this matter and other important matters of coordination.
Finally, regarding the potential displacement of private investment by BTOP funds, the NTIA should not give weight to an applicant that proposes an infrastructure project in an area where a broadband infrastructure provider is already offering affordable and reliable high-speed internet services.
Broadband Mapping

On December 1, 2008, Washington published a legislatively commissioned report on High-Speed Internet Deployment and Adoption Strategy Recommendations for the State of Washington. The Report addresses topics covered in the ARRA and the Broadband Data Improvement Act (P.L. 110-385) in substantial depth, including Geographic Information System (GIS) based mapping. The link to the Report and related materials is http://dis.wa.gov/hiswg/default.htm.

In addition to addressing a variety of topics related to high-speed access, deployment, adoption, and listing specific GIS mapping criteria, the Report recommends several additional features that should be included in GIS maps.

Of particular note is the recommendation that the map include an application layer to illustrate what level of various applications could be facilitated in different geographic areas. Application attributes can be appended to the GIS mapping database to create color-coded maps displaying the uppermost high-speed application available in each area and other information. As an example, mapped areas could display various levels of application classes ranging from basic email and You Tube video, to telecommuting, telemedicine, and smart/intelligent building monitoring. These types of application classes can be fundamental to determining whether an area is underserved and whether the service provided can facilitate economic development.

The Report also notes that the GIS maps could be combined with "Wiki"-type inputs from consumers to both add to, and verify information from, other sources. A Wiki enabled map could also help identify variations in offered versus realized services, including determination of an average service level in any given area (this would further help determine the viability of applications that are dependent upon certain guaranteed service levels within any given area). The map could also provide links to high-speed internet information from available websites of providers, including service type and pricing.

NTIA and RUS should work together to specify the geographic level required for mapping data, and should consider recently adopted FCC reporting requirements that specify census tract level reporting and yet to be determined service availability reporting requirements. NTIA and RUS should also define the data requirements necessary to ensure that statewide inventory maps can be rolled up into a searchable national broadband database so that states can build their data sets accordingly.

Financial Contributions by Grant Applicants

The assessment of the "financial needs" of an applicant, and whether or not the NTIA should provide greater than 80 percent of a project/activity's cost should be assessed on a case-by-case basis, taking into account the totality of economic and financial circumstances. Should NTIA determine that for-profit infrastructure providers are "eligible entities" in the public interest, then such providers should provide the full 20 percent matching requirement. However, if a for-profit entity enters into a partnership with a governmental entity, or non-profit organization it may assert a "financial needs" waiver based on a combination of economic circumstances.
NTIA and RUS should be generally aware of economic and financial distress in state and local governments and other public entities throughout the country, and specifically in Washington State today. The agencies should use publicly available data on the economic and budget circumstances, which are widely available from a number of sources, regarding the specific circumstances of the applicant. The NTIA and RUS should consider various forms of in-kind contributions that a state, local government, or political subdivision may be able to contribute toward the 20 percent match requirement, such as assigned personnel, and office and administrative overhead. The NTIA should consider some of the following specific factors in reviewing a waiver for "financial need".

- Reaching the largest number of households/customers at the highest possible speed for a particular project (referenced in Sec. 6001(h)(2)(B));
- How much previous work the applicant has done, either alone or with a state agency or task force, in getting the proposal or project to the status of "shovel-ready";
- How quickly the particular projects or activity can be started and completed;
- The number of jobs created by the applicant and/or projects, what impact that may have on the unemployment rate.
- The economic condition of the community where services would be provided.
Reporting and De-obligation
NTIA and RUS should require grantees to use independent third party quality assurance practitioners to ensure compliance with the commitments identified in the grant application, and the requirements of the ARRA and related acts.

Quarterly reporting by an independent third party quality assurance practitioner, together with the grantee's quarterly reports on progress toward achieving the objectives of the grant proposal, provides a means for regular monitoring of grant activities, and early warning if the objectives of the grant are not being met.

Third party quality assurance services are widely available and routinely used to provide oversight and reporting for all manner of projects. The purpose of quality assurance is to increase the probability of a project's success. Projects are more likely to be successful when the project managers and sponsors are provided with insightful, competent, timely, independent and objective assessments of how well the project team is executing its objectives. Quality assurance provides its greatest value when engaged in the early initiation phases of a project, and continued throughout the project lifecycle. Quality assurance services are considered to be a part of total project cost and should be budgeted accordingly.

Washington State prefers quality assurance practitioners with professional credentials appropriately related to oversight activities, and recent experience managing and assessing projects of similar size, risk and complexity. Practitioners should also be aware of the political and legal environment in which the projects operate.

NTIA and RUS could use quality assurance reporting to assess whether projects are progressing appropriately in light of the projects' milestones and deliverables, and could receive early warning of risks that could prompt additional corrective action and reporting in cases where risks are deemed unacceptably high. The threshold at which funds are deobligated should be determined by NTIA and RUS after a thorough review of all relevant circumstances.
Coordination with USDA's Broadband Grant Program

NTIA and RUS should issue a unique identifier to all eligible entities who desire to make application for ARRA funding. That identifier should be linked to the applicant's eligibility status and geographic location. Applicants applying for funding under the ARRA should be required to use their unique identifier when applying to NTIA and RUS, and to state whether they have applied to NTIA, or RUS, or both, at the time of their application. In this way, NTIA and RUS can track the activity of all eligible entities and ensure that grant funds are utilized in the most efficient and effective manner possible, without unjustly enriching any particular applicant. In addition, we urge RUS and NTIA not to limit the possibility of any "unserved area" from maximizing potential benefits under both programs through some arbitrary constraint. We believe that both statutes (Division A, Title I for RUS and Division B, Title VI for NTIA) allow an applicant to develop innovative ways to serve such "unserved areas" by combining various elements of each into a comprehensive proposal, and the implementing rules should allow this.

Definitions

Broadband: Washington recommends that broadband or high-speed internet service be defined similar to the FCC broadband tiers with the exception of the lowest tier, so the first tier would be > 768 kilobits per second (kbps) download and > 200 kbps upload. For the purposes of the ARRA grants, we believe that there should be flexibility in the definition so that the minimum level of service is based on the community, geography and need. We recognize that some communities may require a higher minimum level of service to meet their needs. Top tier research-intensive universities and government laboratories, for example, will require much higher speeds than ordinary consumers.

We believe that Washington's definition balances the data gathering needed to provide a realistic assessment of high-speed internet service within the state, coupled with the requirements already placed on providers by the FCC. The definition does not place an additional requirement on service providers because the data that would be categorized as broadband under the FCC's definition is information that would be characterized as high-speed internet under the state's definition.
Underserved: Besides defining high-speed internet service in terms of speed tiers (upload and download speed pairings), Washington feels that various levels of high-speed internet should be defined by the applications that can be enabled by different speed tiers, especially for purposes of determining whether an area is underserved, or where the service provided can facilitate economic development.

When settling on definitions, NTIA should consider not only whether a given set of speed tiers is equivalent to "broadband" or high-speed service, but also whether an area is "underserved" if the speeds available are not sufficient to support users' needs.

Rural: Washington's statutory definition of rural is limited to "rural county" and means a county with a population density of fewer than one hundred persons per square mile or a county smaller than two hundred twenty-five square miles. We recommend that NTIA and RUS select a definition of "rural" appropriate for the greatest number of states based on existing legal definitions, and currently implemented eligibility standards.

RUS
What are the most effective ways RUS could offer broadband funds to ensure that rural residents that lack access to broadband will receive it?
Washington supports a mix of grants and loans that is heaviest on the loan side. It is our understanding that the loan program allows RUS to leverage the funds available to it. This, in turn, increases the availability of funding for broadband projects. Existing loan programs administered by the RUS have proved effective in deploying telecommunications infrastructure in rural America. Although the loan program is an effective tool, there may be instances in which a direct grant is preferable given local circumstances. For example, there may be very low density pockets of unserved areas in rural America where the economics of even a low-interest loan do not make sense. Thus, deploying a mixture of loans and grants under the administration of the RUS, with the assistance of the states in a consultative role, will assure the greatest availability of broadband infrastructure throughout the nation.
We also urge that each grant applicant be required to certify in some form that it is not seeking similar or identical support for the same project from the RUS broadband program as a means to "double dip" federal funding for their particular project(s).
In what ways can RUS and NTIA best align their Recovery Act broadband activities to make the most efficient and effective use of the Recovery Act broadband funds?

NTIA and RUS should issue a unique identifier to each eligible entity that applies for ARRA funding. That identifier should be linked to the applicant's eligibility status and geographic location. Applicants applying for funding under the ARRA should be required to use their unique identifier when applying to NTIA and RUS and to state whether they have applied to NTIA or RUS or both at the time of their application. In this way, NTIA and RUS can track the activity of all eligible entities and ensure that grant funds are utilized in the most efficient and effective manner possible, without unjustly enriching any particular applicant. In addition, we urge RUS and NTIA not to limit the ability of an applicant to apply for support under both programs if a combination of support is not duplicative and furthers the deployment of broadband service into unserved areas. We believe that the both statutes (Division A, Title I for RUS and Division B, Title VI for NTIA) allow an applicant to develop innovative ways to serve such unserved areas by combining various elements of each into a comprehensive proposal, and the implementing rules should allow this.

How should RUS evaluate whether a particular level of broadband access and service is needed to facilitate economic development?

Broadband access and service has become the price of entry for economic areas. Need should be evaluated on a case-by-case basis taking into account the broadband needs of the businesses currently located in an area as well as the industries that area hopes to recruit in the future.

Also, see Washington's comments in response to NTIA's questions above concerning the definition of "underserved" and the relationship between economic development and different levels of high-speed internet service.
In further evaluating projects, RUS must consider the priorities listed below. What value should be assigned to those factors in selecting applications? What additional priorities should be considered by RUS?
In evaluating proposals, RUS must examine whether the proposed project (1) gives end-users a choice of internet service providers, (2) serves the highest proportion of rural residents who lack access to broadband service, (3) is submitted by a current or former RUS borrower, and (4) is fully funded and ready to start once it receives funding, and (5) addresses barriers to adoption. Of these five specific factors, we believe that items 2 and 4 should be assigned the highest priority given that they best meet the overriding goals of the ARRA and promotion of broadband deployment. The first factor, "giving end-users a choice of internet service providers," should be assigned the lowest priority; in our view, focusing on choice of service may well be a wasteful exercise that diverts l necessary funding to those rural areas lacking even a single broadband provider. The fourth priority listed should be assigned a higher value because it best meets the overriding goals of the ARRA in terms of economic development and creating jobs.
We urge the RUS to coordinate closely with the NTIA in identifying additional priorities.
 

(Late Submission)
This is a corrected copy of the 12-page slide deck I submitted last week. The only thing that is different in this version is the last bullet point on page ten, which should now makes a lot more sense than it used to.

(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

>>> "Patrick Sullivan" 4/14/2009 8:54 AM >>>

I loaded this letter onto the NTIA filing system yesterday, and wanted
to confirm its inclusion in the record. Patrick SullivanDirector,
Technical and Government AffairsThe Telecommunications Industry
Association10 G Street, NEWashington, DC 20002202-346-3244
(O)703-581-2579 (C)




(Late Submission)
Attached please find the comments of Stayton Cooperative Telephone Company

(Late Submission)
It is our pleasure to submit this letter in response to the Joint Request for Information released March 10, 2009 by the U.S. Department of Commerce's National Telecommunications Information Administration (NTIA) and the U.S. Department of Agriculture's Rural Utility Service (RUS) concerning the Broadband Technology Opportunities Program (BTOP).




Douglas M. Williams
Founder and CEO
RF CHECK Incorporated
2658 Del Mar Heights Rd. #274
Del Mar, CA 92014
Ofc: 877.RF.CHECK - Cell: 619.840.5548
E-Mail: doug@rfcheck.com



(Late Submission)
Please put some restrictions on equipment purchased with Stimulus monies
not made in America. Have each recipient file why they did not but
American before they can use this money.



KISS= Keep It Sweet and Simple, If the equipment that the company needs
is not manufactured in American then let them purchase wherever they
want.



Thanks and Have a Great Week.





A.J. Passarella

General Manager

Loretto Telephone Company, Inc.
136 South Main Street
Loretto, Tennessee 38469
________________________________


Phone 931-853-4351 x112

Fax 931-853-4329

Email ajap@LorettoTel.com






(Late Submission)
See attached letter.

(Late Submission)
Our comments are attached

(Late Submission)
Per instructions contained in the Department of Commerce and Department of Agriculture Notice: American Recovery and Reinvestment Act of 2009 Broadband Initiatives, dated March 9, 2009, I attach
comments of MLB Advanced Media, L.P.

(Late Submission)
Attached please find the comments of SouthernLINC Wireless in response
to the NTIA and RUS joint request for information on the Broadband
Technology Opportunities Program. The filing is submitted in duplicate,
one version in Word format and one in PDF format.

Regards,

Holly
Holly Henderson
External Affairs Manager
678.443.1670


>
>



(Late Submission)
Please find attached our comment on the criteria to be used by the National Telecommunications and Information Administration ( NTIA) and the United States Department of Agriculture's Rural Utility Service (RUS) in evaluating applications for grants, loans and guarantees under the American Recovery and Reinvestment Act of 2009 Broadband Initiatives.
 

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