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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)
Please see the attached letter from Robert Vrij, President
Alcatel-Lucent, in response to a letter dated April 2, 2009 by Zhone's
CEO, Mory Ejabat, regarding the American Recovery and Reinvestment Act's
"Buy American" provision.


Michael Thomas McMenamin

Sr. Counsel - Managing Director

Americas Region


1100 New York Avenue, NW

Suite 640 West Tower

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Mobile: 703.307.4920

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(Late Submission)
See attachment below

(Late Submission)
The Rural Internet and Broadband Policy Group respectfully submits the attached document as our comments to the National Telecommunications and Information Administration and the Rural Utilities Service.

(Late Submission)
Attached are NASCIO's comment regarding the role of the state with broadband funding in the Recovery Act.


Pam Richardson Walker
Director, Government Affairs
444 North Capitol Street, N.W.
Suite 642
Washington, DC 20001-1511
T: (202) 624-8477
F: (202) 624-7745

(Late Submission)
Please find attached comments for the National Telecommunication and Information Administration (NTIA) and Rural Utilities Service (RUS) Broadband Provisions of the American Recover and Reinvestment Act of 2009. These comments are submitted in accordance with the instructions found in the Federal Register posting of March 12, 2009. These comments are submitted on behalf of the State of Florida. Thank you.

Don Winstead
Special Advisor
to Governor Charlie Crist
Telephone: 850-487-7914 (Assistant, Joan Morgan)
Direct Line: 850-488-5228
Cell: 850-528-6099

(Late Submission)
As an attendee of the Las Vegas public meeting, I noticed a lot of dialog and confusion around the definition of "broadband" -- specifically, how broadband should be defined for purposes of the recovery program.

As a 2006 appointee to the California Broadband Task Force (see and Chair of the group's Emerging Technologies and New Applications working group, we struggled with the exact same issue and conflicts, namely, not wanting to draw a firm line at a certain bandwidth which may arbitrarily exclude a specific technology, or make our findings obsolete a short while after our report was published.

To solve this issue, we recognized that "broadband" was a spectrum of bandwidths that enabled an end-user to perform online applications at a reasonable performance to that user. We also included certain "must-have" features for broadband (always-on, maximum ratio of downstream-to-upstream speeds). The definition, taken from page 12 of the report referenced above, is included as an attachment to this comment.

As you will see in the attachment, we recognized that broadband speeds are likely to improve by orders of magnitude in a very short period of time (as demonstrated by speed improvements to date), and included a catalog of applications and uses that are available at each of the bandwidth milestones. I believe that by viewing the broadband bandwidth spectrum using a scale that increases by factors of 10 (1Mbit, 10Mbit, 100Mbit, 1000Mbits, etc.) is a much more useful approach to defining broadband than just trying to define a narrow set of bandwidth speeds. Much like the Richter scale, which measures seismic activity in magnitudes 10 times larger than the previous level, I believe you will find such a view and definition of "broadband" to better serve everyone, and not threaten the future relevance of your findings.

If I can provide further information, please do not hesitate to contact me.

Bryan Martin
Chairman & CEO, 8x8, Inc. (Nasdaq: EGHT)

(Late Submission)
Maximum impact can be achieved through funding that goes through a knowledgeable state-wide intermediary that can underwrite, fund/finance a variety of regional and community based broadband projects, thus achieving greater reach and impact. See attached concept paper for how this could work in New Hampshire. The model is appropriate for other states as well.

(Late Submission)
Please see attached.

Hance Haney
Director & Senior Fellow
Technology & Democracy Project
Discovery Institute
1015 15th Street, N.W.
Suite 900
Washington, D.C. 20005
(202) 558-7083


(Late Submission)
Broadband Technology Opportunities Program (BTOP) - Response to Request for Information

BTOP focus should be on educating the public about the true benefits of ubiquitous broadband infrastructures with major emphasis on the formation of local Public/Private Partnerships (P3's) playing an integral role in establishing Community, Municipal, City or County wide broadband infrastructures, communications, internet access and services.

These ground level P3’s will invite carefully designed and GSA specific criteria that will lead to streamlining grant/loan application processes, network implementation and deployment, monitoring and transparency for BTOP initiatives in Urban, Suburban AND Rural markets.

Complete Summary -

Brad Bowman
Program Director,
Technology Committee, Delray Beach, Palm Beach County, FL.

(Late Submission)
See attached.

(Late Submission)
(Sent on behalf of Deborah Rudolph.)

Attached is IEEE-USA's comments on the new Broadband Technology
Opportunities Program (BTOP)
being established by the National Telecommunications and Information
Administration (NTIA) as contained
with Section 6001 of the American Recovery and Reinvestment Act of 2009
(Recovery Act).

Should you have any questions or need more information, please contact
Deborah Rudolph at (202) 530-8332, or at

Thank you.

Bernadette Concepcion
Staff Assistant, Government Relations
2001 L Street, N.W., Suite 700
Washington, DC 20036
+ 202 530 8365, phone
+ 202 785 0835, fax

IEEE. Fostering technological innovation and
excellence for the benefit of humanity.

Celebrating 125 Years of Engineering the Future


(Late Submission)
March 18, 2009

Dr. Bernadette McGuire-Rivera
Associate Administrator, Office of Telecommunication
and Information Applications
U.S. Department of Commerce
1401 Constitution Avenue, N.W.
Washington, D.C. 20230

Mr. David Grahn
Associate General Counsel
U.S. Department of Agriculture
Rural Development
Room 2017
Washington, D.C. 20250

Dear Dr. McGuire-Rivera and Mr. Grahn:

The members of the Independent Telephone and Telecommunications Alliance (ITTA) are mid-size telecommunications providers that serve nearly 30 million customers in 44 states. Our members serve some of the most rural parts of the country, where technological and geographical limitations, combined with market economics, create formidable challenges to high-speed Internet deployment.
Consistent with the points we made throughout the drafting of the American Recovery and Reinvestment Act of 2009 (ARRA), ITTA members strongly believe that the $7.2 billion in broadband stimulus money should be focused on unserved parts of our country. Building out broadband to the unserved will do more to create jobs and open up new economic opportunity than diverting money to other purposes. Making broadband available everywhere will also facilitate other ARRA objectives, such as intelligent transportation systems, electronic medical health records and smart-grid technology. Unless ARRA’s limited funds are focused on bridging the gap between the broadband haves and have nots, ARRA could actually widen today’s digital divide. ARRA is an excellent start to close existing broadband gaps, but it is vitally important to ensure that funding is utilized as efficiently as possible to extend broadband’s reach as far as possible. Thus, connecting the unserved should be the agency’s foremost priority.
The full potential of broadband remains beyond the grasp of many Americans living in rural and other high-cost and hard-to-serve parts of the country. A recent study by the U.S. Department of Agriculture highlighted that, due to higher costs and low adoption rates, at least 9.3% of rural households do not have access to any type of broadband services. In spite of the challenges of serving Rural America, ITTA members have invested hundreds of millions of dollars to bring the opportunity-building tool of broadband to 85-90% of their customers, which is in line with the availability in the more urban parts of our country.

Given current cost and demand conditions, however, we are unable to make a reasonable business case for building out broadband to the most rural areas that remain. This is why it is vitally important that the broadband stimulus funding be targeted as grants to areas that are currently unserved.
The broadband stimulus funding brings the opportunity to connect all Americans to broadband one step closer, and we must not let this opportunity pass us by. The stimulus funding is an important “down payment” on America’s broadband future, but the enormity of the task requires focus and discipline in this first step.

Curt Stamp
President, ITTA

(Late Submission)

During the two weeks of BTOP public meetings there were several comments and questions regarding the use of the 2.5GHz Educational Broadband Service (EBS) to facilitate implementation of BTOP initiatives.

This 2.5GHz band has been under a lot of scrutiny because of the way it was acquired by Sprint (Nextel) and Clearwire.

This 2.5GHz spectrum could be considered a VERY valuable Community asset and be used to greatly enhance the BTOP in all Urban, Suburban AND Rural markets within the United States.

This petition contains an introduction explaining the FCC rule and policy changes in the 2.5GHz band that allowed Sprint (Nextel) and Clearwire to negotiate long term leases with our local Community Colleges, Universities, School Boards, Churches and other local non-profits from which this spectrum was "acquired".

Due to the FCC policy and rule changes Sprint (Nextel) and Clearwire have acquired long term lease rights to our 2.5GHz band in over eighty-five percent of major metropolitan service areas (MSA)within the United States.

There are many questions and concerns surrounding these dealings. The public BTOP meetings helped to bring these concerns to light.

This is an extremely important issue and as 4G or WiMAX teeters on the fence of becoming a viable solution for BTOP initiatives it is important to examine and identify all assets available to bring the BTOP initiatives to frution and to develop a practical and sustainable nationwide broadband plan.

Petition Website:

Please see attachments below...

Thank you,

Brad Bowman
Program Director,

(Late Submission)
I am pleased to submit this white paper, formally endorsed by organizations that represent all 50 states, over 2200 colleges and universities, 30 state and regional networks, 44 corporations, and international reach to networks in 90 countries. America's state and regional network reach over 55,000 institutions including K-12 schools, community colleges, colleges and universities, libraries, hospitals, clinics, medical research centers, agricultural extension sites, museums, and community and performing arts centers.

(Late Submission)

>>> "Greg Johnson2" 5/1/2009 10:28:59 AM >>>

Ms. Francine Jefferson
TOP Program Officer
National Telecommunications and Information Administration

Herbert C. Hoover Building (HCHB)
1401 Constitution Avenue, N.W.
Washington, D.C. 20230

Dear Ms. Jefferson,

My name is Greg Johnson, and I am the CTO for the Virginia
University Health System (VCUHS), a major inner-city Academic Medical
Center, located in downtown Richmond Virginia. I am writing you to
the possibility of developing a grant proposal and submittal in support
our Electronic Medical Record system as well as other clinical and
non-clinical systems utilizing wireless technology.

Several months ago we opened up our new Critical Care Hospital (CCH) -
state-of-the-art facility designed to maximize the integrated usage of
wide variety of disparate wireless systems, ranging from 802.11
Networks, to Telemetry Systems, to ASCOM & Vocera VoIP communications
systems, paging systems, cell phones, sophisticated NICU monitoring
equipment, etc. The CCH has been extremely successful in its
of this wireless technology, resulting in improved patient outcomes,
greater patient care and patient safety. The backbone for this
cutting-edge technology is a system called The InnerWireless Horizon
System, which is essentially a passive Distributed Antennae System
which was installed during the physical construction of the CCH. This
system facilitates the usage of a wide array of wireless technologies
between the frequency range of 400 MHz to 6000 MHz , enabling and
ubiquitous, stable, and reliable coverage throughout this large (15
376,000 sq. ft.) facility. The success and adoption of the technology
been extremely well received by clinicians and patients alike. In terms
the complexity of the environment we have created, it is one of the
Institutions in the world that has achieved this level of integration

That's the good news. Now to the reason for my email. In the realm of
unintended consequences, we have created a situation wherein the rest
our Medical Center, which does not enjoy an InnerWireless backbone,
quickly become a "sore point" amongst our clinicians as they have
seen that they are not able to provide the same level of service, use
same level of integrated technology, or have the same level of
technology reliability as in the CCH. This is viewed as an
situation. However, in order for us to retrofit our pre-existing
structures (specifically our Main and North Hospitals both of which are
our Urban campus, as is the CCH), we would need to spend somewhere in
neighborhood of $3-$3.5M to bring the InnerWireless system into the
existing facilities.

It is our belief that by doing so, not only would the rest of the
Center enjoy the same high level of patient services as the new CCH
but it will raise the level of care in the Central Virginia area
significantly, as well as serve as a model for other Health Systems
throughout the country. Working in partnership with our vendor,
InnerWireless, we would like to work with you to help us in crafting a
proposal that would meet your grant submission criteria so that we
apply for a grant enabling us to achieve this retrofit and realize all
the benefits noted above.

I would very much appreciate setting up a time to either talk with you,
perhaps even meet with you in person, to discuss our proposal, and how
can go about developing this proposal. I should note that neither
nor my team, nor our partners at InnerWireless have any grant writing
experience, and would therefore need your assistance in developing a

Please feel free to contact me and/or Mr. Frank Lasky of InnerWireless
the numbers listed below, or via email. I look forward to speaking with
in the very near future.


Greg Johnson

Director & CTO
IT Technology & Engineering Services
VCU Health System Information Systems

Frank J. Lasky
Director of Sales
InnerWireless, Inc
15446 Legacy Way
Haymarket, VA 20169
(703) 754-7345 Wired
(571) 277-0458 Wireless
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VCU Health System

(Late Submission)

>>> John Chuang 4/13/2009 6:28:48 PM >>>
Dear sir or madam,

Please accept the attached comments of Cinergy MetroNet, Inc. I tried
to upload it online but your website seems to not be accepting any
additional filings. Please contact me if you have any questions.
Thanks for your attention to this matter.

John Chuang
Corporate Counsel
(913) 754-3339

IMPORTANT NOTICE: This e-mail message is from an attorney and is
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sender and delete it completely from your computer system.

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

Anna Gomez
Acting Assistant Secretary, Deputy Assistant Secretary for Communications and Information
Office of the Assistant Secretary, National Telecommunications Information Administration
US Department of Commerce
1401 Constitution Ave, N.W., Rm. 4701
Washington, DC 20230

April 13 2009

Assistant Secretary Gomez:

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)
Please see attachment.

(Late Submission)
See attachment

(Late Submission)
We have chosen to include our entire commentary in the attached document. Thank you.

(Late Submission)
Attached please find the comments for the BTOP and RUS programs. Thank

Jon Douglas

Director of Marketing Communications

Tel: 703-848-1221

(Late Submission)
I've attached [1] NARUC's letter signed by 90 commissioners representing 39 states [2] a handout hand-delivered to several NTIA/RUS staff with specific comments from several states [3] two related letters filed in this proceeding by two additional commissions endorsing key aspects of the NARUC filings.

(Late Submission)
Please see attachment

(Late Submission)
Dear Sirs and Mesdames - Attached in Word format is the comment of NTCH,
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 attachments.

(Late Submission)

(Late Submission)
I discovered a blooper on the first page of my comment, so am re-submitting a corrected copy. Hope you'll read this one and discard the previous version. Thanks!

(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 Association of Public-Safety Communications Officials (APCO) International.

(Late Submission)
See attachment

(Late Submission)

April 13, 2009

Broadband Technology Opportunities Program
U.S. Department of Commerce
Rm 4812
1401 Constitution Avenue, NW
Washington, DC 20230

Re: American Recovery and Reinvestment Act of 2009 Broadband
NTIA and RUS Joint Request for Information

Ladies and Gentlemen:

World Cable is pleased to have this opportunity to comment on the
Joint Request
for Information (the “ROI”) published by the National
Telecommunications and
Information Administration (“NTIA”) and the Rural Utilities Services
(“RUS”) on March
12, 2009. As discussed below, World Cable is seeks to assure that the
communities it
serves qualify for grants pursuant to the statutory goal of
“provid[ing] improved access to
broadband services to consumers residing in underserved areas of the
United States”.
World Cable urges NTIA to construe the term “underserved” to recognize
the needs of
ethnically diverse populations residing in urban areas, who are
frequently low-income
and financially disadvantaged and who are currently not receiving
affordable, sustainable
services. World Cable further urges NTIA and RUS to recognize that
not all
“underserved” populations live in rural or remote areas, but can also
live in quite urban
settings, literally around the corner from “well-served” populations.

World Cable provides very cost effective, creative triple-play
solutions to certain
residential buildings in New York City. The triple-play solution
provides a voice, video
and data services at cost effective rates in buildings in New York
City. World Cable
upgrades the infrastructure in buildings throughout New York where the
incumbent local
exchange carrier (ILEC) has no current upgrade plans and provides new
services to the
residents, mostly immigrants, at affordable prices that include
content from their nations
of origin. World Cable provides a very secure, cost effective Internet
access service
operating at up to 150 times the speed of dial up Internet access and
up to two times as
fast as dsl. Residential and small business customers are capable of
securely using World
Cable’s services anywhere in their homes and common areas. For the
past 5 years,
World Cable has contracted with residential property developers in New
York City to
provide a triple play of services in residential multi-family dwelling
Broadband Technology Opportunities Program
U.S. Department of Commerce
April 13, 2009
Page 2

encompassing nearly 30,000 residential units. Although World Cable
currently has
networks deployed only in properties in New York City, it is looking
to expand its
services to other major urban areas.

The American Recovery and Reinvestment Act of 2009 (the “Act”)
allocated a
total of $4.7 billion to NTIA for a new Broadband Technology
Opportunities Program
(“BTOP”). The Act sets forth that the BTOP is intended to provide
improved broadband
access in “underserved areas.” In support of the effort to provide
broadband service to
“underserved areas” the BTOP funds may be utilized to provide
broadband education,
training, access, equipment, and support to organizations that provide
outreach, access,
equipment, and support services to facilitate greater use of broadband
service by low-
income, unemployed, aged, and otherwise vulnerable populations and
stimulate the
demand for broadband, economic growth, and job creation. Consistent
with these
objectives, BTOP competitive grants are available, among other things,
for acquisition of
broadband equipment, instrumentation, networking capability, hardware
and software,
digital network technology, and infrastructure; deployment of
broadband services and
related infrastructure; facilitating access to broadband by
low-income, unemployed, aged,
and “otherwise vulnerable” populations in order to provide educational
and employment
opportunities; and other matters consistent with the purposes behind

As Free Press noted in a report published as recently as April 7,

“[f]or many urban residents, high-speed Internet services,
which typically cost $40 to $60 per month, are simply too
pricey. Compounding the Internet access problem, many
people are unable to afford a computer or lack the skills to
navigate the Web. And just like their rural counterparts,
some urban areas have been redlined by Internet service
providers that refuse to offer service to communities that
may not provide as large a financial return. Many urban
residents are locked out, unable to participate fully in the
digital era. They’re prevented from applying for jobs,
telecommuting, taking online classes or even finishing their
homework. It’s becoming increasingly clear that Internet
connectivity is key to a sound economy and could assist
those hit hardest by the economic downturn.”

It is therefore critical that the NTIA and RUS consider the
disadvantaged living in large, urban centers when establishing a
definition of what is
“underserved.” The Joint Explanatory Statement released by the
Congressional conferees
confirms than, in evaluating each application, NTIA must consider
whether an

“Wired Less: Disconnected in Urban America,” released April 7, 2009,
available at

Broadband Technology Opportunities Program
U.S. Department of Commerce
April 13, 2009
Page 3

infrastructure grant will increase the affordability of, and
subscribership to broadband.
Clearly, then, the mere availability in an urban area of a
multiplicity of broadband
providers does not mean that particular pockets and communities within
the area are not
“underserved” or that BTOP applicants who are prepared to build new
targeted to, and priced for, lower income areas should not be funded
even where other
providers may have facilities being offered at prices that simply do
not meet the needs of
this segment of the population. This population should not be
forgotten as these
definitions are established. Companies like World Cable are offering
creative solutions
for the disadvantaged members of our society, and with such
technological opportunities
each of those residents is able to put themselves in a position to
succeed. “Although
Internet usage is in general becoming more widespread, access remains
deeply structured
along existing lines of social inequality. Income, gender, geography
urban/rural location), race/ethnicity, level of education, age—all
continues to be
significant predictors of access and skill levels

Without access like the services
provided by World Cable, the “digital divide” for this population will
only continue to

Updating broadband access in the multiple dwelling unit complexes
(MDUs) in
which these vulnerable residents live is a highly efficient way to
implement the goals and
policies of the Act. Grant funds would be used for acquisition of
broadband equipment,
instrumentation, networking capability, hardware and software, digital
technology, and infrastructure and to deploy broadband services and
infrastructure. Indeed, but for the availability of BTOP funding, it
can be virtually
impossible to sustain a business case that allows for the lower
pricing that Free Press
notes will be an essential element of closing the “broadband” gap that
now exists
between the advantaged and disadvantaged elements of society.

Broadband access will provide increased opportunities for residents
served by
World Cable to seek employment, work from home, and study and learn
from home
through access to on-line educational opportunities for adults and
school-aged children
alike, and even facilitate over time the provision of telemedicine and
other health care
benefits within these vulnerable communities.

World Cable encourages NTIA to recognize such proposals as eligible
for BTOP
funding in an “underserved” area. World Cable also hopes to obtain
funding that will
allow these vulnerable populations to obtain the customer premises
equipment that are
also key to their ability to fully utilize the enormous advantages
that broadband provides.
Indeed, by providing these populations access to the number of
applications available to
other segments of the populace, and by providing content in their own
language, these

Mossberger, Caroline J. & Tolbert, Karen, 2006. “New Inequality
Frontier: Broadband
Internet Access.” EPI Working Paper No. 275. Available at

Broadband Technology Opportunities Program
U.S. Department of Commerce
April 13, 2009
Page 4

residents are able to reduce their overall monthly communication
costs, while also
accessing the crucial broadband services required in today’s economic

In conclusion, the term “underserved” must include those populations
in urban
centers who do not have access to affordable broadband facilities in
their residence. The
inclusion of these services will allow NTIA to achieve the objectives
of the BTOP:
increasing employment, introducing access to vulnerable, underserved
urban populations,
and providing service to those who would not be served during the time
contemplated by the Act as quickly or as affordably at sustainable
rates. We urge NTIA
and RUS to include these elements as part of its broad definition of


Bob Rasul M.D.
World Cable

(Late Submission)
Please see attached comments from the Commonwealth of Pennsylvania in response to the RFI jointly issued by NTIA/RUS.

(Late Submission)
I was able to get streaming text, but video and sound was unavailable. My flash Player and were working just fine on my computer. Perhaps, there were just limited connections available. My question is whether the panel will consider the municipal special purpose local Goverment Entity ("LGE") as a preferred model for grant oversight? Letting a community know that they "own" the network will help increase success.

As long as communities follow their own state law, where applicable (on providing cable tv or telecommunications, or refrain from anti competitive franchising where there is no state law on point) then the communities can become providers of telecommunications with public forum oversight of all the activities. But more importantly this provides a means to leverage momentum in both financing and penetration into rural areas.

James Driessen, JD/MBA BSME
305 N 1130 E
Lindon, UT 84042
wk 801.796.6924
mb 801.360.8044
fx 801.785.2744

(Late Submission)
On Monday, April 13, 2009, at 4:21 PM, Blooston, Mordkofsky, Dickens, Duffy, & Prendergast, LLP filed comments on behalf of 58 rural incumbent local exchange carriers (Rural ILECs) and the centralized equal access providers (CEA Providers), referred to as "The Rural Carriers".

Attached is an erratum containing an updated list of Rural Carriers, adding Peñasco Valley Telecommunications of Artesia, New Mexico.

(Late Submission)
Ms. Brown and Campanola;

During a teleconference today with DMS of Florida, there was mentioned a
release of dates for potential release of information.

In my review of the NTIA web site, , I am not able to find
any updates after May 18, 2009.

Can you provide us with options to review updated information on actual or
prospective dates for release of information and or of projected application
submission or RFP releases.

Thank you

Alfred Barr
Managing General Partner
Global Wireless Communications

Formerly VCS Interactive, LLC
550 N. Reo Street, Suite 300
Tampa, FL 33609
813-767-2270 - Cell phone
Web Site -

Click Hyperlink for video demo

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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 MLB Advanced Media, L.P.

(Late Submission)
See attached.

(Late Submission)
See attached comments of the City of Seattle

(Late Submission)
See attached file.

(Late Submission)
Attached is the response of the Rural Independent Competitive Alliance
("RICA") to the March 9, 2009 Joint Request for Information of NTIA and
RUS. RICA's member rural competitive local exchange carriers appreciate
the opportunity to comment on this vital matter.

I would be happy to discuss further any of the issues addressed.

Stephen G. Kraskin
Communications Advisory Counsel
2154 Wisconsin Avenue N.W.
Washington, D.C. 20007
Tel. 202-333-1770
Fax 202-333-5274

(Late Submission)

Enclosed for filing please find the Comments of FairPoint
Communications, Inc. and Northern New England Telephone Operations LLC,
d/b/a FairPoint Communications-NNE (collectively "FairPoint
Communications") to NTIA and RUS regarding Recovery Act broadband
If you have any questions regarding this information, please feel free
to contact me at (207) 791-3191 or

Andrew Landry, Esq.
Preti Flaherty Beliveau & Pachios
45 Memorial Circle, PO Box 1058
Augusta, ME 04332-1058

Tel. 207.623.5300
Fax 207.623.2914

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(Late Submission)
1 - Beehive Telephone was to attend the broadband summit in flagstaff today but oil leak in our plane caused us to ground it (the other one is in St.Lewis) so we won't make it,

2 - we are the largest rural wireless provider in Utah with a one gig back bone from Salt Lake City west to Elko, Nevada and from Idaho south to U.S.6 on the west site, and across Utah's highest mountains to the Lake Powell area and with signals over the Navajo Mt. Chapter of the Navajo Tribe.

3 - we are unable to bring these wireless signals into the Navajo's for reasons: 1) The BLM has not granted us rights of way on Nokai Done where exists an emergency landing strip we maintain and 2) the Navajo Tribe has not granted us a tiny parcel a mile from the Chapter House which would enable a solar power access point that would enable broadband to all of Rainbow City and the Chapter house with ten Gigabyte being available if desired. and 3) recognition we are a utility with all meaning thereto between the Tribe's treaty protection of utility property thereto. We have broadband throughout all of southern Utah from Colorado to Nevada. We are a member of the WISPA national wireless internet association. For more information see or
Art Brothers, CEO

(Late Submission)

Attached please find public comments submitted by Sacred Wind
Enterprises. Please contact my office if requiring further
clarification or different formatting.


John Badal, CEO
Sacred Wind Enterprises, Inc.
Tel. 505-821-5080
Fax 505-821-0226

(Late Submission)
> comments on RFI_v1.DOC>>
Please find enclosed for filing the Comments of Iowa Health Care, Inc.
in response to the Joint Request for Information of the Departments of
Commerce and Agriculture in the above-reference proceeding. One copy of
the Comments is signed in Adobe pdf format, and the other copy of the
comments (the substance of which is identical) is being filed in MS Word
format (as requested in the Public Notice) and is unsigned.

Thank you.

Sincerely yours,

Douglas G. Bonner
Counsel for Iowa Health System, Inc.

Douglas G. Bonner
Sonnenschein Nath & Rosenthal LLP

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(Late Submission)
Comments are submitted in a pdf attachment below

(Late Submission)
See attached filing.

(Late Submission)
Please see attached

(Late Submission)
Definition of Broadband

Broadband should be simply defined as the network capacity to deliver to all consumers that subscribe to a network, symmetrical Internet access speeds of a minimum of 10 mbps download and 10 mbps upload.

This will allow real-time bi-directional transmission of simultaneous voice, video and data services.

This will enable telemedicine which will reduce health care costs, increase healthcare access and thus improve the quality of the healthcare system as a whole.

This will enable distance learning which will improve the quality of education, increase access to quality education while simultaneously reducing the cost of education.

This will enable access to information services and emergency services thus increasing response times and preparedness for national disaters and emergencies for both the United States citizens and also the first responders.

I could go on but instead I will divest and attach an article that was written in 2001 that shows how broadband could grow the United States economy by 500 billion dollars, if national adoption of a minimum 10 mbps upstream and 10 mbps downstream policy were adopted by the Untied States.

Unfortunately, 9 years have passed, minimal gains have been made towards achieving these speeds and no legislation or policy has enacted to force the incumbent and profitablity providers of this access to increase speeds and as such serve a common good by imporiving the economy.

I am afraid to say that what we are seeing and having to address in the automobile industry with our Big Three automakers has manifested itself in the telecommunications arena.
Hopefully, history will not repeat itself and we will allow a open playing field with the end goal being to get a broadband service to all of our citizens that is swiftly deployed, affordable by all and not aimed at protecting the incumbents who choose to stifle competition through policy as opposed to focusing on strengthening our nations's economy and global ranking for the deployment of true broadband services.

(Late Submission)
Comments are contained in the two attachments.

(Late Submission)
CFA Comments Attached

(Late Submission)
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