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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)
Attached please find the comments of the American Cable Association relating to the American Recovery and Reinvestment Act of 2009's Broadband Initiatives (Docket No. 090309298-9299-01). Please feel free to contact the undersigned should you have any questions.


Jeremy M. Kissel
Cinnamon Mueller
2156 Wisconsin Ave, NW
Washington, DC 20007
202.609.7793 (direct)
202.747.5870 (fax)

(Late Submission)
To Whom It May Concern:

Attached is a copy of the comments filed earlier this evening by Rural
Cellular Association (RCA) in Docket No. 090309298-9299-01. The same
filing was also submitted electronically via NTIA's webpage (

Please do not hesitate to contact me if you have any questions regarding
the information provided.


Todd B. Lantor
Lukas, Nace Gutierrez & Sachs, LLP
1650 Tysons Blvd.
Suite 1500
McLean, Virginia 22102
Phone: (703) 584-8671
Fax: (703) 584-8694

Counsel to Rural Cellular Association

If you have received this message in error, please contact me because it
may contain information that is confidential or protected by the
attorney-client privilege.

(Late Submission)
Flow Mobile Comments on NTIA RUS Broadband Programs

(Late Submission)
Please see attached letter commenting on criteria for broadband stimulus efforts to increase use of broadband

(Late Submission)
To whom it may concern:

Please find attached our specific comments regarding specific questions raised in the Request for Information (RFI) Docket No. 090309298-9299-01 American Recovery and Reinvestment Act of 2009 Broadband Initiatives:
Thank you for the opportunity to provide input on this important grant program.

(Late Submission)
see attachment

(Late Submission)
See Attached File

In the Matter of:

Joint National Telecommunications and Information Administration- Rural Utilities Service Request for Information )

Docket No. 090309298-9299-01


Telcordia Technologies (Telcordia) hereby submits comments to the National Telecommunications and Information Administration (NTIA) and the U.S. Department of Agriculture (USDA) in the above-captioned proceeding. Telcordia is a global leader in the development of fixed, mobile, and broadband communications software and services. Our products and services enable communications service providers, enterprises, suppliers, and government entities to successfully deploy innovative and advanced services across the full spectrum of communications and information networking. Since our beginnings as part of Bell Labs, Telcordia has been acknowledged for the breadth and depth of our technology and expertise and for our unique contributions as leaders and coordinators across the industry. Telcordia engineers and consultants have supported private and public entities world-wide in deploying high-performing and reliable communications infrastructure. Telcordia also has extensive experience managing major programs and building and operating real-time information and transaction systems. Telcordia has been at the forefront of innovation in ADSL (Asymmetric Digital Subscriber Line), ATM/SONET (Asynchronous Transfer Mode / Synchronous Optical Network), AIN (Advanced Intelligent Network), optical networking/WDM (Wave Division Multiplexing), wireless (3/4G, cellular, mobility), and security. Telcordia experts hold leadership positions in the industry’s most respected standards bodies and forums including ATIS (Alliance for Telecommunications Industry Solutions), ITU (International Telecommunication Union), TIA (Telecommunications Industry Association), TMF (TeleManagement Forum), IEEE (Institute of Electrical and Electronics Engineers), and OMA (Open Mobile Alliance Broadcasting).
Telcordia shares the goals announced in the American Recovery and Reinvestment Act of 2009 (ARRA) to ensure the speedy deployment of cutting-edge technologies, and to nurture a vibrant and growing high-technology sector based in the United States. We realize the risks inherent in administering an expansive grant program on a tight timetable as well as the necessity of ensuring that lasting benefits are realized with deployments that are scalable, secure, and robust and do not quickly become obsolete. At the same time, we believe that proactive steps can be taken to ensure that the BTOP and RUS programs deliver their promised benefits to the American people in a timely, efficient, and cost-effective manner. We offer our comments and technical expertise as NTIA and USDA develop rules and procedures to implement the Broadband Telecommunications Opportunity Program (BTOP) and Rural Utilities Service (RUS) grants as statutorily established in the ARRA.

I. Risk Mitigation and Security
The acquisition, installation, configuration, and systems integration of billions of dollars of new telecommunications equipment and software poses both exciting challenges and significant risks. Ensuring that the monies are spent promptly and wisely and that true and measurable benefits are returned requires a well-defined program with clear rules for participation and oversight processes which are proactive, light-weight, and transparent. A successful program will generate both a far greater number of qualified proposals than current funds can support, and also a wide range of very diverse proposals. Adequate personnel are required with the necessary expertise, experience, and program management skills as well as efficient procedures and systems for the rapid review, prioritization, and oversight of projects. A well-designed program will reduce risks via: the adequacy of the grant application process in soliciting critical information for evaluation and selection; the timeliness of the selection process in yielding transparent and uncontested priorities; and the effectiveness of monitoring procedures in guiding the rollouts and overseeing tax payer funds.
Creating trust in the expanding broadband infrastructure by ensuring security, privacy, and assurance is another critical element of risk reduction. The benefits of broadband access and services can only be achieved if citizens, businesses, and organizations trust the network, services, and applications. Broadband deployments must safeguard users’ privacy; insure the security of information, applications, and transactions; protect against denial-of-service and other attacks; and provide access controls so that sensitive digital information is available only for necessary and authorized use. Our expanding national broadband network will only be as strong as its weakest link, so it is critical that security, privacy, and assurance requirements be rapidly developed, uniformly adopted, tested, and certified to ensure trust in the infrastructure.
Telcordia recommends that the NTIA and RUS address the following factors in the applications, review, selection, and monitoring of the BTOP and RUS grant programs. Attention to these factors will help ensure effective deployments that fully deliver promised benefits:
• End-to-end planning for efficient operation, maintenance, upgrades and capacity enhancements across the lifecycle of the infrastructure;
• Ease of use so that network infrastructure will enable institutions and citizens in setting up services, accessing applications and connecting devices simply and easily;
• Cost-effective operations support systems to maintain network infrastructure proactively to ensure service quality and avoid stranded capital;
• Flexibility and evolvability so that the infrastructure can expand and scale to meet new and growing needs and to support emerging technologies, particularly in edge devices and applications;
• Robust and fault-tolerant network management systems and governance policies to enable rapid identification of faults and restoration of services; and
• End-to-end security and privacy methods and practices to reduce vulnerabilities, defend against intrusions, and ensure the security of transactions and the privacy of information.

II. Broadband Mapping
Much of the debate on broadband infrastructure capability, policy, and goals in the U.S. suffers from a lack of consistent and objective data and the Broadband Mapping program will go a long way towards redressing this critical need. We urge the NTIA and RUS to also include appropriate measurement and analysis components in their grant programs which will provide a foundation for a consistent, nation-wide broadband mapping program capable of informing both public policy makers and consumers. Without such metrics and analytics, it will be harder to efficiently determine compliance, assess progress towards societal goals, and quickly determine the appropriate course corrections that are virtually certain in such a large and complex undertaking. The question of providing meaningful broadband access extends beyond the ‘last mile’ connectivity issue to include appropriate interconnection between a broadband access provider and the wider telecommunications infrastructure including network interconnection, backhaul infrastructure, metropolitan and regional network capability, and core network bandwidth, and it is important that these issues be included in the mapping effort.
To support nation-wide objectives, data collected across the states must be consistent and comparable. A coherent, nationwide, dynamic picture of broadband availability, adoption, usage, and affordability is vital. By far the most cost effective way to do this is to establish standard data collection requirements, systems and procedures once that all states can adopt. Without appropriate coordination and consistency at the national level, 50 individual efforts are likely to lead not only to a fragmented and incomplete view of broadband in the U.S., but also to significantly greater total costs as individual states design separate approaches and methodologies.
In particular, Telcordia recommends the following for the broadband mapping effort.
• Include on-line data reporting requirements for all service providers and government entities that are not only practical and cost effective, but also adequate in terms of comprehensiveness and level of detail. The effort provides a unique and valuable opportunity to streamline, reduce, and coordinate reporting requirements on service providers of all types.
• Data collection should count not only the ‘pipes,’ but also the traffic levels and service types that flow through them. Reliable and accurate, data will map the availability, usage, quality, and costs of broadband, across all broadband technologies (wired, wireless, satellite, broadband over power line) and both upstream and downstream.
• The metrics and analysis system should include capability for processing the raw metrics information to create synthesized performance indices. These indices will enable consumers, business owners, service providers, and policy-makers to easily assess the status of available broadband infrastructure and its performance and make relevant comparisons.
• A publically-accessible information repository would make information available for consumers and businesses to create value-added linkages (mash-ups) with appropriate security and privacy safeguards for citizens and organizations. It is abundantly clear that very rapid change is a defining feature of broadband applications, devices, and technologies and we urge the NTIA and RUS to use automated and dynamic systems that provide up-to-date statistics and information. The data repository will enable modeling, forecasting, and analysis of the data to support identification of success factors and lead to improved decision making and advances in broadband deployments over time.
• The broadband map and metrics collection should be based upon an agreed-upon set of terminology, identifiers, and standard descriptions for broadband telecommunications equipment and services. This common set of terms and information will not only support uniform collection of data for the broadband map, but will also serve as an important resource for streamlining operations and integration across the broadband deployments.

III. Best Practices Clearing House
To make the most of the available resources for broadband deployment under the ARRA, the NTIA and RUS should ensure that current deployments are able to fully leverage the lessons learned from the past. There is ample opportunity to significantly shorten the learning curve and improve the successes of such deployments via the identification and dissemination of best practices. This in turn will deliver substantial savings in time and money and enable the aggressive time schedule for the stimulus plan to be met with sound deployments that deliver benefits to organizations, companies, and citizens. A Best Practices Clearing House can quickly offer vendor-agnostic and technology-neutral guidelines across the range of deployment issues from permitting and siting to network technology and evolution, and from management, operations, and maintenance to network and service evolution. By following the examples of best-of-breed systems, NTIA and RUS can shorten or eliminate learning curves and meet aggressive time scales with vetted, low-risk deployments.
In particular, the Best Practices Clearing House will:
• Identify successful deployments with varying geography, demographics, and technology selections;
• Characterize and analyze success strategies for permitting, siting, and construction; regulatory and governance framework; and financial and operational models;
• Develop succinct and useful guidelines, case studies, and templates to expedite sound broadband deployments and achieve the speedy action demanded by the ARRA; and
• Disseminate best practices as a dynamic industry resource to advance the state-of-the-art in U.S broadband deployment.


For the foregoing reasons, Telcordia urges NTIA to adopt our recommendations on Risk Mitigation and Security, Broadband Mapping, and a Best Practices Clearing House.

Respectfully submitted,

By: ________________

Adam T. Drobot
President, Advanced Technology Solutions
Chief Technology Officer
One Telcordia Drive
Piscataway, New Jersey
(732) 699-2100

April 13, 2009

(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 Atkins Telephone Company.

Kristy Szabo
On Behalf of Atkins Telephone Company

(Late Submission)

Cheryl M. Johns

Assistant Chief Counsel, Telecommunications

Office of Advocacy

U.S. Small Business Administration

409 Third Street, S.W.

Washington, DC 20416

Phone (202) 205-6949

Fax (202) 205-6928



In order to receive:

Advocacy's News Releases via email; Advocacy's monthly newsletter "The
Small Business Advocate" via email; Advocacy's Small Business Research
and Statistics via email; Advocacy's Regulatory Communications via
email; Visit to
join the lists. To easily comment on important proposed regulations

(Late Submission)
Attached please find the comments of Nevesem, Inc. in Docket No.

Edgar Class
Wiley Rein LLP
1776 K Street NW
Washington, DC 20006
t: 202.719.7504
f: 202.719.7049

NOTICE: This message (including any attachments) from Wiley Rein LLP may constitute an attorney-client communication and may contain information that is PRIVILEGED and CONFIDENTIAL and/or ATTORNEY WORK PRODUCT. If you are not an intended recipient, you are hereby notified that any dissemination of this message is strictly prohibited. If you have received this message in error, please do not read, copy or forward this message. Please permanently delete all copies and any attachments and notify the sender immediately by sending an e-mail to

(Late Submission)
Congressional Letters to BTOP

(Late Submission)
Attached is an ex parte for a meeting held on March 12 with Apex
(meeting description plus Apex attachments).

(Late Submission)
Please see comments attached.

(Late Submission)
Broadband Technology Opportunities Program
United States Department of Commerce
Room 4812
1401 Constitution Avenue, N.W.
Washington, D.C. 20230


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
1105 E. 31st Street, Ste. G
Kansas City, MO 64108

(Late Submission)
I would like to be added to the correspondence list for the BTOP.

I would also like to have connectivity requirements for Webcast
connectivity for future meetings. I was unable to get any audio/video
from today's session and found that the streaming text worked only
sporadically so ended up relying heavily on refreshing the transcript.


Cynthia Berner Harris, Director of Libraries
Wichita Public Library
223 S Main, Wichita KS 67202
316-261-8520 (v) 316-219-6320 (f)

Please consider the environment before printing.

(Late Submission)
Please find attached, a letter from the Director of the Michigan Department of Information Technology and the Department's responses to the Request for Information regarding the NTIA and RUS Broadband Development Programs. Thank You for the opportunity to respond.

(Late Submission)
Alcatel-Lucent's comments are attached. Please contact me if you have
any difficulty with the document.

Kevin Krufky
Legislative Counsel
Global Government & Public Affairs
1100 New York Avenue, N.W.
Suite 640, West Tower
Washington, DC 20005
Direct: 202-312-5914
Mobile: 202-258-9535
Fax: 202-842-2817

Note: This message, and any attachments, is intended only for the
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message may be privileged, confidential or proprietary, and its use or
disclosure by other than intended recipient(s) is prohibited and may be
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and do not distribute or retain a copy of it.

(Late Submission)
Dear Sirs and Mesdames - Attached in Word format is the comment of
McCotter Hotel Operations, Inc. in the referenced ARRA Docket.

Donald J. Evans

Fletcher, Heald & Hildreth

1300 N. 17th St.

11th Floor

Arlington, VA 22209

703-812-0430 (phone)

703-812-0486 (fax)

(Late Submission)
See attached file

(Late Submission)
Please see attached.

Comments of the Alliance for Digital Equality

In response to your request for comment published on March 10, 2009, the Alliance for Digital Equality wishes to offer its perspective on the disposition of broadband funds provided by the ARRA with special focus on the issue of broadband adoption.

The Alliance for Digital Equality (ADE), a non-profit organization registered in the state of Georgia, was established two years ago as an advocate for communities that have not yet realized the full benefit of the information age revolution. In fulfillment of that mission, we seek to educate consumers about the benefits of broadband. With the help of local Digital Empowerment Councils in major American cities, we also act as a bridge between minorities and other underserved Americans and public policymakers on issues related to information technology.

Broadband Internet access is a transforming technology that can open the door to economic opportunity and individual empowerment, especially for minority communities that have often been the last to benefit from societal progress. Like electricity and telephone service before it, broadband is fast becoming an essential utility. Those who cannot or do not embrace it will lose out on vast opportunity. For those who are already lagging behind economically and socially, lack of broadband will tend to bury them even more firmly at the bottom of American society.

Thus, ADE enthusiastically welcomes the commitment of the new administration and the Congress to spread broadband throughout America and to designate a substantial portion of the economic stimulus package to programs that support both the deployment and adoption of broadband.

ADE’s Perspective on the Current Broadband Landscape

As we survey the broadband landscape, we see a mixture of good and bad. The rapid deployment of wireline network infrastructure by the private sector means that more than 90 percent of Americans live in communities where service is available, often from multiple providers, and some 60 percent of American households are currently wired to broadband. Wireless networks also are connecting more Americans every day to broadband Internet service, and minorities have readily embraced the wireless option. Although the digital divide between white and non-white Americans persists, it has narrowed significantly in recent years thanks to continued deployment and, especially, to declining prices. Narrowing this divide so that all Americans enjoy broadband service is ADE’s highest priority. To that end, we have consistently warned policymakers to avoid policies that would tend to add to the cost of broadband services and jeopardize recent progress by reducing the ability of lower-income Americans to afford broadband. Indeed, in light of the current recession, policies that boost costs could well force some lower income Americans to give up recently-acquired broadband service.

Despite the upward trend in broadband adoption, nearly 43.7 million households in urban America are without broadband, according to the US Census Bureau. Substantial pockets of rural America also lack access to broadband service especially where lower population density and greater geographic distances between potential subscribers erode the economic case for deployment. The present economic downturn could have a long term adverse impact on universal adoption by a large number of Americans to sign up for broadband service even where it is available. When asked by the Pew Foundation why they are not using broadband, more than half of non-Internet users and dial-up users said they aren’t interested, are too busy, or simply don’t want to switch. More than 15 percent of other hold outs said it was a waste of time, too difficult, or they were too old. Many of the 9 percent of adults who rely on dial up for broadband access said price was an important obstacle. Indeed, Pew data shows that lower income Americans make up a disproportionate number of those who do not have broadband service.

In light of this data as well as our ongoing consultations with community leaders around the country, ADE has developed a policy agenda to accelerate the spread of broadband in both currently unserved and underserved communities. While many of these policy proposals are outside the specific scope of the Broadband Technology Opportunity Program to be established by the NTIA or grants and loans to be provided by RUS, we believe they offer important context as you develop program criteria and also give texture to ADE’s specific comments below. Therefore, we have attached our broad policy recommendations as an informational resource.

ADE’s Specific Recommendations

Wide deployment of broadband infrastructure means that more than 90 percent of Americans have the opportunity to subscribe to broadband, but only about 60 percent of American households have in fact exercised the broadband option. Data indicates that low awareness of broadband benefits is the root cause of this gap. To close that gap, ADE urges NTIA and RUS to place a high priority on fulfilling ARRA’s mandate to “provide broadband education, awareness, training, access, equipment and support” to programs that promote greater use of broadband. Such digital literacy programs will stimulate adoption by familiarizing participants with technology and raising awareness of the benefits of broadband service.

We also note the Congressional directive to support organizations and agencies that seek “to facilitate greater use of broadband service by low-income, unemployed, aged, and other vulnerable populations.”

These types of targeted programs will directly address the concerns of those who now report little or no interest in broadband. Programs that directly deliver economic, educational and health opportunities will also spur adoption. Therefore, ADE encourages NTIA and RUS to support programs to introduce Americans to information technology and the Internet, provide training in IT skills, hands on experience with Broadband, and education about online safety. We also encourage funding for telemedicine programs that use broadband to deliver health care services and remote monitoring and support for programs that remotely connect individuals to academic opportunities and job training. Such tangible demonstrations will stimulate adoption among those Americans who are not subscribing to broadband because they do not fully appreciate its ability to improve their lives.

Of course, digital literacy alone will not deliver broadband for those who cannot afford to buy a computer and/or subscribe to a broadband service. Demonstrating the value of broadband will persuade some Americans that broadband is important enough to be included in their budget; they will discover that they can “afford” it. But, others simply lack the means. To address affordability issues, targeted programs that provide broadband access through community broadband centers in public locations such as libraries, schools, other government buildings or non-profit organizations merit consideration. We also encourage support for programs that provide free or low-cost computers and Internet connections to lower income Americans. In addition, stimulus program funds might be directed to the Federal Lifeline/Linkup program to provide discounts on broadband service for low-income Americans.

Programs that reduce barriers to adoption will accelerate progress toward America’s national goal of universal broadband by addressing the largest portion of those who do not currently enjoy broadband at home. However, these programs will not help the smaller number of Americans who live in communities where the network infrastructure does not deliver broadband service.

Thus, NTIA and RUS also must direct significant funding for programs that promote new deployment in areas where broadband connections are not now available. We believe part of the answer is so-called demand aggregation programs through public-private partnerships and local economic development authorities. By concentrating a large number of potential subscribers, demand aggregation can successfully build an economic case that will persuade network providers to deploy the necessary infrastructure.

In other instances, direct lending to service providers and grants to stimulate deployment may be the only way to overcome the financial barriers that discourage private investment in currently unserved areas. Importantly, we believe such direct deployment funding should be limited to those areas where broadband service is not currently available. Additionally, direct deployment funding should be limited to one provider in a community to increase the likelihood that the service will be economically sustainable over the long term. In our view, the government should not provide support for two providers in the same area as such “overbuild” funding might jeopardize long-term sustainability by reducing the number of some subscribers available to support the new service. We believe that every American in the 21st century should have equal access to affordable and reliable broadband, which will enhance the quality of life through the delivery of vital e-services in communities and particularly underserved and un-served neighborhoods across the United States.

Respectfully submitted,

Alliance for Digital Equality

Appendix I

Policy Agenda to Put Broadband in Every Home

National Policy

Build on initiatives funded in the stimulus bill through a combination of adoption and deployment strategies as identified below

1. Promote broadband deployment and adoption by resisting, reducing or eliminating taxes and policies that raise the cost of broadband service and hurt consumers; embrace policies that support and encourage investment in IT and broadband infrastructure.

2. Expedite development of a national broadband map and supporting data collection to guide broadband expansion strategies in underserved communities.

3. Provide digital opportunity grants and financial assistance to support local digital literacy and technology opportunity programs (TOPs), especially in minority and rural communities, and enable broadband adoption by those who cannot afford home broadband on their own.

4. Encourage broadband adoption by expanding the use of information technology and online services in sectors such as health care, education, and e-gov to raise the value of residential broadband.

5. Launch a public education campaign that raises awareness in minority, rural and underserved communities of the educational, economic, social and health care opportunities it provides.

6. Update the Universal Service Fund to provide direct support for build-out of broadband infrastructure in rural America and other unserved and underserved communities.

State and Local Policies

1. Initiate statewide broadband mapping and community IT-needs assessment programs to identify priority areas for broadband promotion and for training programs to build digital literacy and computer skills.

2. Develop public-private partnerships to address barriers to computer ownership and residential broadband adoption, and also to encourage local economic development strategies that stimulate broadband deployment by aggregating demand and developing “anchor” customers for advanced network services.

3. Provide subsidies, grants and computer recycling to provide low-cost computers and/or other broadband-capable devices including netbooks and smart phones to K-12 students from low-income households.

4. Incorporate computer literacy and digital skills training into school curriculum beginning in early elementary school. Establish grade-appropriate computer literacy testing as part of promotion requirements.

5. Establish community-based learning centers in underserved communities to develop computer literacy and proficiency in core office software programs and to demonstrate the value of broadband. Leverage this training to develop an IT-ready workforce that attracts job-creating businesses to minority communities.

6. Set up computer and Internet access sites in public venues such as libraries, schools, churches and government buildings in underserved communities to provide broadband for those who do not have service at home.

7. Promote broadband adoption by removing regulatory and other service barriers, including local video franchise licensing and excessive fees for rights-of-way access, that raise subscription costs to consumers.

(Late Submission)
Please find the attached Comments of Free Press, as submitted April 13th, 2009.

[note: these were submitted via the Web interface earlier today, but do not appear to have been received]

S. Derek Turner
Research Director
Free Press
o: 202.265.1490 ext. 28 
c: 650.201.6069

reform media. transform democracy.

(Late Submission)
Barbara Brown:

Please replace the previous submission with this revised version of the National Tribal Telecommunications Association's recommendations for the broadband stimulus program.

I would like to submit the attached statement on behalf of the National Tribal Telecommunications Association, comprised of the only 8 Indian Tribes (from 563 tribes) that have created their own regulatory telecommunications companies. NTTA is deeply concerned that the Broadband stimulus monies will not reach the communities that need broadband (and voice dialtone) connectivity the most: Indian Tribes. Included in our submission are specific positive recommendations for solutions that will balance out the imperative of the Department of Commerce, the Federal Communications Commission and the Department of Agriculture to reach the widest population in rural areas with communities that will never benefit from market force or private investment.

If you have any questions, please do not hesitate to contact me.

With Best Regards,

Eric Jensen
Policy Counsel
National Tribal Telecommunications Association, and,
Four Horizons Development Company
First Tribal Liaison Officer for the Federal Communications Commission
519 Tennessee Ave
Alexandria, VA 22305
(703) 683-3742
pcs: (703) 868-8325

(Late Submission)

>>> "Joshi, Meena" 3/16/2009 3:41 PM >>>
On behalf of USTelecom, the attached letter is mailed via the US
Service and is also being sent to you electronically as a courtesy.

Meena Joshi
Administrative Assistant

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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If you have received this electronic communication in error, kindly
delete it without re-publication or printing and notify me

(Late Submission)
AAPD comment is attached in Word.

(Late Submission)
To Whom It May Concern:

Please see the attached comments below in the file attachments. Thank you so much for your time and consideration.

Thank you,
Mayor Mark Hipsher

(Late Submission)
Please see attached comments from the Graduate School of Library & Information Science at the University of Illinois at Urbana-Champaign.

(Late Submission)
Please see attached cover letter (Ohio cover ltr) and response document (Ohio RFI response).

(Late Submission)

The initial meeting went very well and we want to thank you for the excellent efforts to provide both remote web and the teleconference access.


A critical issue has come up in our inquires to the FCC. As you are probably aware the FCC has set aside a range of radio spectrum for educational broadband service or (EBS) to be used by schools and the community for Broadband Wireless Access. This is the quickest and lowest cost method for a rural community to implement broadband services. In discussions with the FCC today case number 1162847 I was informed that the FCC has a freeze on new license applications for EBS and was provided with the attached document which in not on the FCC main page, but had to be searched for with the correct document code. The 2007 document attached in section 12 states that current filing freeze is in effect. If you go to apply for the license at the FCC web site you are un able to do so...


Section 12 of this document


"In this connection, we note that the Commission implemented a filing freeze with respect to all applications for new BRS and EBS licenses, as well as for major modifications of those licenses, in order to permit the orderly and effective resolution of issues in the BRS/EBS proceeding"


This is a major blockade to schools and rural communities to roll out broadband services. The reasoning is not clear but should be revisited quickly or it will seriously impact the ability of NTIA grantees to implement  services. Could you please pass this issue on to the stimulus committee and FCC. There is a Texas Federal Stimulus Meeting on the 14th where this well be read inot the record as well...




Brent K. Earley


Chairman - National Broadband Infrastructure Partnership




(Late Submission)
On behalf of EvenLink, Inc.LLC, we greatly appreciate the NTIA allowing the public to comment on this significant process. Please refer to the attached PDF filere: Comments to the National Telecommunications and Information Administration and the United States Department of Agriculture Rural Utility Service on Rules for Broadband Grants and Loans

(Late Submission)
Attached is a letter from Commissioner Moffet of the Kansas Corporation Commission. It supports key aspects of the proposal filed by NARUC earlier today.

(Late Submission)
Attached please find a letter from the Telecommunications Industry Association requesting that the U.S. Department of Agriculture’s Rural Utilities Service, as it establishes a timeline for administering the Rural Development Broadband Program pursuant to the American Recovery and Reinvestment Act of 2009, expedite the broadband grant and loan award process and provide the first round of such awards well prior to the end of the first quarter of Fiscal Year 2010 (FY 2010).

(Late Submission)
National Grange comments

(Late Submission)
See Attached

(Late Submission)
The Telecommunications Industry Association respectfully submits its Comments on the Joint National Telecommunications and Information Administration - Rural Utilities Service Request for Information, Docket No. 090309298-9299-01.

(Late Submission)
See Attacchment

(Late Submission)
[see attachment]

(Late Submission)
Please find and accept comments attached. Thank you!

Bartlett D. Cleland
IPI Center for Technology Freedom
p (972) 874-5139
f (972) 874-5144

(Late Submission)
See Attachment

(Late Submission)

To what degree is WiMax in general in scope, firms such as
Clearwire/Sprint have had "shovel ready" projects in place before the
may laze hit

Ps pls add me to any list you may have,



Jim Powers

Pre Sales Solutions Manager

Smtp: Voice: 212-966-0034 Fax: 212-274-1726
HD Video Conference IP: |
eTribeca, LLC. | 134 West 26th Street 10001 | New York | NY

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(Late Submission)
307 East Hardin Street Findlay, Ohio 45840
Phone: 419/422-3306 Fax: 419/420/3664

Tom Vilsack
Secretary, U.S. Department of Agriculture
Office of the Secretary
US Department of Agriculture
1400 Independence Ave., S.W.
Washington, DC 20250

April 13 2009

Secretary Vilsack:

The American Recovery and Reinvestment Act of 2009 (ARRA)charges the National Telecommunications Information Administration (NTIA) and the Rural Utilities Service (RUS) with the task of disbursing $6.85 billion dollars via grants for broadband infrastructure and adoption programs. The FCC has also recently announced its intent to develop a national broad­band plan.

The mission of Homework Central, Inc. is to improve children's academic achievement by providing a literacy-rich, safe and nurturing environment through one-on-one mentoring relationships with caring teenagers and adults. We are providing homework assistance to children who are academically at-risk and do not have stable academic assistance at home. During the school year 2008-2009, we have served 45 children of which 71 percent of their families are at or below poverty level and 33 percent are in an Individual Education Program at school.

A recent donation of three new computers through Connect Ohio enabled our program to help these at-risk children to reach their full potential. The No Child Left Offline program, which is made possible by the public-private partnership of Connect Ohio, is helping us to add a computer lab to our reading room and life skills activities area.

Next year's goal is to be able to serve up to 60 children in our program. Our ultimate goal is that additional community organizations will provide similar programs in their neighborhoods. We are dedicated to offering our assistance to these programs. To date, two other community organizations have patterned their programs after Homework Central, Inc.

As you implement the Broadband Data Improvement Act and the American Recovery and Reinvestment Act, and as you develop a national broadband plan for America, I urge you to support and fund programs such as Connect Ohio. The Connect Ohio program works across the state to stimulate demand for broadband and computer use through local technology planning, broadband mapping, local research, and digital literacy projects such as No Child Left Offline.

Every state should have a program like Connect Ohio.


Chuck Riley
Board Chairman

Ken Kuchno, Director, Broadband Division,Rural Utilities Service, USDA
Mark Seifert, Senior Advisor, NTIA
Dr. Bernadette McGuire-Rivera, Associate Administrator, Office of Telecommunications and Information Applications, NTIA
Scott Deutchman, Legal Advisor, Office of Commissioner Michael Copps, Federal Communications Commission

(Late Submission)
Bernadette McGuire-Rivera

Associate Administrator

Office of Telecommunications and Information Applications

RE: In the Matter of American and Reinvestment Act of 2009 Broadband
Initiatives; Docket No. 090309298-9299-01; Joint Comments of RNK and
Wave2Wave in Response to Joint Request for Information

Dear Associate Administrator McGuire-Rivera:

Attached please find the Joint Comments of RNK, Inc. d/b/a RNK
Communications and Wave2Wave Communications, Inc. hereby submitted in the
above referenced docket in Word format.


Matthew Tennis


333 Elm St., Suite 310
Dedham, MA 02026
t: 781-613-9148
f: 781-297-9836

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(Late Submission)
The attached describes a March 11, 2009 meeting with OPAD staff and a
LinKAmerica Alliance team led by CostQuest Associates. Associated
slides are also included.

(Late Submission)
See attachment

(Late Submission)
See attachment.

(Late Submission)
Comments and a Presentation are filed in the form of atttachments.

(Late Submission)
To Whom It May Concern:

Please add me to your correspondence list.

Thank you,

Allison Miller

921 SW Washington St, Suite 370

Portland, OR 97205

Direct Line: 503-414-0460

Fax: 503-227-8585

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(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 AT&T Inc.


Bruce R. Byrd
Vice President & General Counsel - Washington
AT&T Services, Inc.
1133 21st St., NW, Ste. 900
Washington, DC 20036
(202) 463-4148 (office)
(202) 286-2676 (mobile)

(Late Submission)
Dear sir or madam:

Out of abundance of caution, I'm emailing the attached comments on behalf of
Pend Oreille County Public Utility District #1, which, per the attached
receipt in the lower right corner, we filed electronically online earlier
this evening at 7:58 p.m. (PDT), which would have been 10:58 p.m. (EDT).
Unfortunately, however, your filing system logged us as having submitted
precisely at 12:00 a.m. on April 14, 2009. So, to avoid any
misunderstanding regarding this apparent inconsistency, we're re-submitting
the our comment filing ahead of what we understand to be the East Coast
midnight deadline. If you have any questions about this matter, or there's
a problem we should know about, please contact us right away. Or, if
there's no problem with your accepting our earlier online submittal, please
disregard this follow-up transmittal

THX and best regards,

Jeffrey Mayhook


34808 NE 14th Avenue

La Center, WA 98629

(360) 263-4340 office

(360) 263-4343 fax

(360) 609-3769 mobile

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(Late Submission)
Replacement comments.
Replacement comments for initial submission made on March 25, 2009. This submission includes: 1)Public testimony at March 24th public meeting, 2) final expanded replacement comments, plus supporting letters from 3) NSPE, and 4) ACEC.