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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)
Barbara: let me take one more revised submission of NTTA's broadbans stimulus recommendations.

Eric Jensen
Policy Counsel
National Tribal Telecommunications Association (NTTA)
519 Tennessee Ave
Alexandria, VA 22305
(703) 683-3742
pcs: (703) 868-8325


(Late Submission)
3G Americas Comments

(Late Submission)
Attached.

(Late Submission)
Comments submitted in pdf attachment.

(Late Submission)
I'd like to join the correspondence list for the Broadband Technology
Opportunities Program (BTOP).





James L. Baker, Chief

Information Technologies Group

SEDA - Council of Governments

201 Furnace Road

Lewisburg, PA 17837

voice: (570)524-4491 fax: (570)524-9190

www.seda-cog.org



"My job in the coming years will not be to attract companies... my job
will be to attract talent."
- Janet Miller, Nashville Area Chamber of Commerce






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

________________________________


On behalf of our client Cox Communications, Inc., I am transmitting to
you herewith a corrected version of Cox's comments in response to the
joint request for information and notice of public meetings of the
National Telecommunications and Information Administration and the Rural
Utilities Service. Please substitute the corrected version for the
document submitted earlier today.

Thank you for your assistance.

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

J.G. Harrington

Counsel to Cox Communications, Inc.


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



(Late Submission)
Brent Graden
Economic Development
City of Prestonsburg
200 North Lake Drive
Prestonsburg KY 41653
606-886-2335


To Whom It May Concern:

Broadband deployment and its use are critical to the development of
communities across America. Now, more than ever, it is a crucial step towards
competing in the global marketplace.

I am writing to convey the importance of ConnectKentucky. Their organization
is instrumental with their leadership in making progress happen. Their
affiliated programs such as the Computers 4 Kids program have made a
tremendous impact in rural communities. I know for a fact that two rural
libraries have just opened their doors in Floyd County due to the generous
donations of new computers for these locations. Their leadership has also lead
to Kentucky being ranked #1 in Broadband deployment in the United States.

ConnectKentucky was also instrumental in helping us make our entire town
(pop 5000) completely wireless for free for a cost of $8500. If you are
interested in how I did it, please call me at 606-886-2335 or go to meraki.com.

Clearly, they play an important part in the development of Kentucky and
beyond. In fact, their model has helped to shape ConnectedNation and other
state model programs dedicated to making America a force in development.

As you implement the Broadband Data Improvement Act, please make every
effort to ensure that ConnectKentucky is eligible for funding through the
American Recovery and Reinvestment Act. As we work together toward
economic recovery, it is crucial that the federal government offer funding and
support to existing public-private partnerships which have proven effective in
bridging the digital divide.

If not now, then when? If not us, then who?

Wise words indeed.


Sincerely,

(Late Submission)
See attached support letter

(Late Submission)





Copy of same attached as Word document





Emailed
to:
email to BTOP@ntia.doc.gov  
March 18, 2009.


 


 


Comments
made by


Steve
Smith


Chase 3000

Imperial style="">, NE, w:st="on">69033

308 882 3000; cell 308 883 3000

Internet Service Provider since 1996.


 


Table
of Contents


Executive
Summary –
highlighting the two answers we most want to emphasize.


NTIA’s
15 primary
questions and 52 sub-questions, in order


RUS’ 5
primary
questions and 10 sub-questions, in order


style="font-family: Symbol;">· style="font-family: "Times New Roman"; font-style: normal; font-variant: normal; font-weight: normal; font-size: 7pt; line-height: normal; font-size-adjust: none; font-stretch: normal;">       
NTIA/RUS
primary question in black.


style="font-family: Symbol; color: rgb(56, 118, 29);">· style="font-family: "Times New Roman"; font-style: normal; font-variant: normal; font-weight: normal; font-size: 7pt; line-height: normal; font-size-adjust: none; font-stretch: normal;">       
style="color: rgb(56, 118, 29);">NTIA/RUS specific
question in green.


style="font-family: Symbol; color: blue;">· style="font-family: "Times New Roman"; font-style: normal; font-variant: normal; font-weight: normal; font-size: 7pt; line-height: normal; font-size-adjust: none; font-stretch: normal;">       
style="color: blue;">Chase 3000 style="color: blue;"> answer in blue.


 


 


Executive
Summary


w:st="on">Chase 3000 style=""> has attempted to answer all of the questions asked by NTIA
and RUS.  However, the two answers we would like
to
emphasize the most regard the definitions of unserved and underserved
as well
as the criteria for judging applications. 
We highlight our answers to these questions here in the
executive
summary.


Definition
of
unserved and underserved.  For a more
detailed answer, please see our comments under 13a.


style="color: rgb(56, 118, 29);">a. For purposes of the BTOP, how
should NTIA, in consultation with the FCC, define the terms “unserved
area” and
“underserved area?”


style="color: blue;">The
numbers refer to points.  If your target area meets the definition,
then
you get the points.  The points are cumulative.



Unserved –


style="font-size: 10pt; font-family: Symbol; color: blue;"> style="">· style="font-family: "Times New Roman"; font-style: normal; font-variant: normal; font-weight: normal; font-size: 7pt; line-height: normal; font-size-adjust: none; font-stretch: normal;">        
10 Any
area with no
provider providing more than 1 Mb down and 512 kbps up. (prorated to
the
portion of the homes in the target in this category)


style="color: blue;">Underserved
– Any of the following with varying point scale depending on how many
of the
elements are met.


style="font-size: 10pt; font-family: Symbol; color: blue;"> style="">· style="font-family: "Times New Roman"; font-style: normal; font-variant: normal; font-weight: normal; font-size: 7pt; line-height: normal; font-size-adjust: none; font-stretch: normal;">        
3  To
maintain
computability with the FFC broadband statement, any area with only one
provider
of service would be considered underserved.


style="font-size: 10pt; font-family: Symbol; color: blue;"> style="">· style="font-family: "Times New Roman"; font-style: normal; font-variant: normal; font-weight: normal; font-size: 7pt; line-height: normal; font-size-adjust: none; font-stretch: normal;">        
1  Cannot
receive
symmetrical broadband service. 


style="font-size: 10pt; font-family: Symbol; color: blue;"> style="">· style="font-family: "Times New Roman"; font-style: normal; font-variant: normal; font-weight: normal; font-size: 7pt; line-height: normal; font-size-adjust: none; font-stretch: normal;">        

Receives average
peak time bandwidth of less than 2d/1u Mb .


style="font-size: 10pt; font-family: Symbol; color: blue;"> style="">· style="font-family: "Times New Roman"; font-style: normal; font-variant: normal; font-weight: normal; font-size: 7pt; line-height: normal; font-size-adjust: none; font-stretch: normal;">        

Receives
minimum peak time bandwidth of less than 5d/1u Mb .


style="color: blue;">For example, if an applicant area
has only one provider currently providing asymmetrical service of 3
mbps down
and 1 mbps up and only does so within the city limits and 50% of the
homes in
the census tract or zipcode qualify as unserved then the
unserved/underserved
score would be



3 pts for single provider

1 pts for asymmetrical service

2 pts for less than 5 down but more than 2 up.

5 pts for more than 25% of the homes in the unserved category.   (50%
of 10)



So a total of 11 points on the unserved/underserved scale.



Within many census tracts and zipcodes, there will be a portion of the
population that is served, underserved, and unserved.   Hence, NTIA
should permit an applicant to define the area to be served by the
application
however the applicant with a familiarity with the area feels is best. 
But, the applicant should also be required to report what services are
available within the same zip code and census tracts as the
application, even
if the applicant does not propose delivering service to those other
areas.  The applicant should be required to map the unserved and
underserved areas with all zipcode or census tracts the application
covers,
even if not all of the area is to be covered.  This will help NTIA in
its
mapping project and will also highlight not only who the applicant is
trying to
help but also who they are ignoring.


 


style="color: rgb(56, 118, 29);">b. How should the BTOP define
“broadband service?”


style="color: rgb(56, 118, 29);">(1) Should the BTOP establish
threshold transmission speeds for purposes of analyzing whether an area
is
“unserved” or “underserved” and prioritizing grant awards? Should
thresholds be
rigid or flexible?


style="color: blue;">Thresholds
should be flexible.  If two applicants are competing within a service
area
for a grant or loan, the one offering the faster service should receive
higher
scores.  Higher scores for symmetrical service.  Thresholds could be
based on Homes Per Square Mile (hpsm).  <5 hpsm - 5 Mbs; 5-50 hpsm -
10
Mbs; 50-500 hpsm - 20 Mbs;  >500 hpsm - 50 Mbs.


Suggested
criteria
and criteria weights.  See NTIA 4b. for a
more detailed list and explanation. 


style="color: rgb(56, 118, 29);">b. What should the weighting of
these criteria be in determining consideration for grant and loan
awards?


style="font-family: Symbol; color: blue;">· style="font-family: "Times New Roman"; font-style: normal; font-variant: normal; font-weight: normal; font-size: 7pt; line-height: normal; font-size-adjust: none; font-stretch: normal;">       
20% style="">     No broadband in an area, (at least 5/1
MB); 


style="font-family: Symbol; color: blue;">· style="font-family: "Times New Roman"; font-style: normal; font-variant: normal; font-weight: normal; font-size: 7pt; line-height: normal; font-size-adjust: none; font-stretch: normal;">       
20% style="">     Lack of competition in an area; 


style="font-family: Symbol; color: blue;">· style="font-family: "Times New Roman"; font-style: normal; font-variant: normal; font-weight: normal; font-size: 7pt; line-height: normal; font-size-adjust: none; font-stretch: normal;">       
20% style="">    Applicant providing universal service
throughout an area (census block?)


style="font-family: Symbol; color: blue;">· style="font-family: "Times New Roman"; font-style: normal; font-variant: normal; font-weight: normal; font-size: 7pt; line-height: normal; font-size-adjust: none; font-stretch: normal;">       
5% style="">       Average speed at peak usage being
provided to the end user;


style="font-family: Symbol; color: blue;">· style="font-family: "Times New Roman"; font-style: normal; font-variant: normal; font-weight: normal; font-size: 7pt; line-height: normal; font-size-adjust: none; font-stretch: normal;">       
5% style="">       Population loss over the last twenty
years; 


style="font-family: Symbol; color: blue;">· style="font-family: "Times New Roman"; font-style: normal; font-variant: normal; font-weight: normal; font-size: 7pt; line-height: normal; font-size-adjust: none; font-stretch: normal;">       
5% style="">       Unemployment rate; 


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5% style="">       Financial ability of the applicant to
complete project;


style="font-family: Symbol; color: blue;">· style="font-family: "Times New Roman"; font-style: normal; font-variant: normal; font-weight: normal; font-size: 7pt; line-height: normal; font-size-adjust: none; font-stretch: normal;">       
5% style="">       Sustainability of project;


style="font-family: Symbol; color: blue;">· style="font-family: "Times New Roman"; font-style: normal; font-variant: normal; font-weight: normal; font-size: 7pt; line-height: normal; font-size-adjust: none; font-stretch: normal;">       
20% style="">     Other factors – see 4b. for more detailed
list.


NTIA:


1.
The Purposes of the Grant Program: Section 6001 of the Recovery Act
establishes five purposes for the BTOP grant program.


a. Should a
certain percentage
of grant funds be apportioned to each category?


 


style="color: blue;">No hard
and fast percentage should be used.  NTIA
should use its best judgment to fairly apportion the funds.


 


b. Should
applicants be
encouraged to address more than one purpose?


 


style="color: blue;">Encouraged,
yes; but,  it should not be
required. 


 


c. How
should the BTOP leverage
or respond to the other broadband-related portions of the Recovery Act,
including the United States Department of Agriculture (USDA) grants and
loans
program as well as the portions of the Recovery Act that address smart
grids, health
information technology, education, and transportation infrastructure?


style="color: blue;">

 


style="color: blue;">Projects
that include these programs should receive more consideration.
 However,
these should be included as separate aspects of one’s grant and have
community participation (i.e. local hospitals would apply for IT,
Smart Grids would be the local utility company, and all would come
under
the umbrella of the application).  The applicant should identify
other complementary projects that can share costs, but NTIA should not
make the
approval of the IT portion contingent on other agencies or projects.


2.
The Role of the States: The Recovery Act states that NTIA may
consult the
States (including the District
of Columbia
, territories, and possessions) with
respect
to various aspects of the BTOP. The
Recovery Act also requires that, to the extent practical, the BTOP
award at
least one grant to every State.


a.
How should the grant program consider State priorities
in awarding grants?


style="color: blue;">Most State
Broadband Task Forces or regulatory agencies are dominated by one
segment of
the communications industry.  Permit the
State to highlight areas of need, but directly solicit input from a
variety of
State sources.  There are a number of
broadband advocates that are not tied directly to any one technology or
industry.  Provide public notice that the
NTIA will consider input from any source that wants to propose a
Statewide
broadband strategy and priority list. 


 


style="color: rgb(56, 118, 29);">b. What is the appropriate role
for States in selecting projects for funding?


style="color: blue;">State
involvement should be kept to a minimum, due to heavy political
influence at
the State level by certain industries.  A State might provide a letter
of
support or endorsement for projects they favor.  This might give a few
points toward NTIA scoring of the application.


3. Eligible Grant Recipients: The Recovery
Act
establishes entities that are eligible for a grant

under the program.  The Recovery Act requires NTIA to determine by rule
whether it is in the public interest that entities other than those
listed in
Section 6001(e)(1)(A) and (B) should be eligible for grant awards.


style="color: rgb(56, 118, 29);">a. What standard should NTIA
apply to determine whether it is in the public interest that entities
other
than those described in Section 6001(e) should be eligible for grant
awards?


style="color: blue;">Priority
should be given to entities that have experience in providing broadband
service,
which can be determined by those that complete the FCC required form
477.  If no existing broadband provider exists
for
an area or is unwilling to provide advanced services, then NTIA might
consider
any organization that proposes to provide service in such an area.


4. style="color: black;">Establishing
Selection Criteria for Grant Awards: The Recovery Act establishes
several style="color: black;">considerations for
awarding grants under the BTOP. style="color: black;">In addition to these considerations, style="color: blue;"> NTIA may
consider other
priorities in selecting competitive grants.
style="color: blue;">


style="color: rgb(56, 118, 29);">a. What factors should NTIA
consider in establishing selection criteria for grant awards? How can
NTIA
determine that a Federal funding need exists and that private
investment is not
displaced? How should the long-term feasibility of the investment be
judged?


style="font-family: Symbol; color: blue;">· style="font-family: "Times New Roman"; font-style: normal; font-variant: normal; font-weight: normal; font-size: 7pt; line-height: normal; font-size-adjust: none; font-stretch: normal;">       
No
broadband in an
area, (at least 5/1 MB); 


style="font-family: Symbol; color: blue;">· style="font-family: "Times New Roman"; font-style: normal; font-variant: normal; font-weight: normal; font-size: 7pt; line-height: normal; font-size-adjust: none; font-stretch: normal;">       
Lack of
competition in
an area; 


style="font-family: Symbol; color: blue;">· style="font-family: "Times New Roman"; font-style: normal; font-variant: normal; font-weight: normal; font-size: 7pt; line-height: normal; font-size-adjust: none; font-stretch: normal;">       
Applicant
providing
universal service throughout an area (census block?)


style="font-family: Symbol; color: blue;">· style="font-family: "Times New Roman"; font-style: normal; font-variant: normal; font-weight: normal; font-size: 7pt; line-height: normal; font-size-adjust: none; font-stretch: normal;">       
Minimum
or average
speed at peak usage being provided to the end user;


style="font-family: Symbol; color: blue;">· style="font-family: "Times New Roman"; font-style: normal; font-variant: normal; font-weight: normal; font-size: 7pt; line-height: normal; font-size-adjust: none; font-stretch: normal;">       
Population
loss over
the last twenty years; 


style="font-family: Symbol; color: blue;">· style="font-family: "Times New Roman"; font-style: normal; font-variant: normal; font-weight: normal; font-size: 7pt; line-height: normal; font-size-adjust: none; font-stretch: normal;">       
Unemployment
rate; 


style="font-family: Symbol; color: blue;">· style="font-family: "Times New Roman"; font-style: normal; font-variant: normal; font-weight: normal; font-size: 7pt; line-height: normal; font-size-adjust: none; font-stretch: normal;">       
Financial
ability of
the applicant to complete project;


style="font-family: Symbol; color: blue;">· style="font-family: "Times New Roman"; font-style: normal; font-variant: normal; font-weight: normal; font-size: 7pt; line-height: normal; font-size-adjust: none; font-stretch: normal;">       
Sustainability
of
project;


style="font-family: Symbol; color: blue;">· style="font-family: "Times New Roman"; font-style: normal; font-variant: normal; font-weight: normal; font-size: 7pt; line-height: normal; font-size-adjust: none; font-stretch: normal;">       
Immediate
Jobs created
(per 1,000 population);


style="font-family: Symbol; color: blue;">· style="font-family: "Times New Roman"; font-style: normal; font-variant: normal; font-weight: normal; font-size: 7pt; line-height: normal; font-size-adjust: none; font-stretch: normal;">       
Local vs
State income;


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Long term
jobs created
(per 1,000 population);


style="font-family: Symbol; color: blue;">· style="font-family: "Times New Roman"; font-style: normal; font-variant: normal; font-weight: normal; font-size: 7pt; line-height: normal; font-size-adjust: none; font-stretch: normal;">       
Net
neutral (if other
than wireless)


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Cost to
build per MB
per home;


style="font-family: Symbol; color: blue;">· style="font-family: "Times New Roman"; font-style: normal; font-variant: normal; font-weight: normal; font-size: 7pt; line-height: normal; font-size-adjust: none; font-stretch: normal;">       
End user
costs;


style="font-family: Symbol; color: blue;">· style="font-family: "Times New Roman"; font-style: normal; font-variant: normal; font-weight: normal; font-size: 7pt; line-height: normal; font-size-adjust: none; font-stretch: normal;">       
Form 477
completion; 


style="font-family: Symbol; color: blue;">· style="font-family: "Times New Roman"; font-style: normal; font-variant: normal; font-weight: normal; font-size: 7pt; line-height: normal; font-size-adjust: none; font-stretch: normal;">       
Private
money leveraged
(less than 80% from NTIA); 


style="font-family: Symbol; color: blue;">· style="font-family: "Times New Roman"; font-style: normal; font-variant: normal; font-weight: normal; font-size: 7pt; line-height: normal; font-size-adjust: none; font-stretch: normal;">       
Population
density;


style="font-family: Symbol; color: blue;">· style="font-family: "Times New Roman"; font-style: normal; font-variant: normal; font-weight: normal; font-size: 7pt; line-height: normal; font-size-adjust: none; font-stretch: normal;">       
Small and
disadvantaged
business;


style="font-family: Symbol; color: blue;">· style="font-family: "Times New Roman"; font-style: normal; font-variant: normal; font-weight: normal; font-size: 7pt; line-height: normal; font-size-adjust: none; font-stretch: normal;">       
State
supported; 


style="font-family: Symbol; color: blue;">· style="font-family: "Times New Roman"; font-style: normal; font-variant: normal; font-weight: normal; font-size: 7pt; line-height: normal; font-size-adjust: none; font-stretch: normal;">       
Combined
with other
projects; 


style="font-family: Symbol; color: blue;">· style="font-family: "Times New Roman"; font-style: normal; font-variant: normal; font-weight: normal; font-size: 7pt; line-height: normal; font-size-adjust: none; font-stretch: normal;">       
Percentage
of people
with broadband outside of the city limits;


style="font-family: Symbol; color: blue;">· style="font-family: "Times New Roman"; font-style: normal; font-variant: normal; font-weight: normal; font-size: 7pt; line-height: normal; font-size-adjust: none; font-stretch: normal;">       
Subsidies
received in
the past;


style="font-family: Symbol; color: blue;">· style="font-family: "Times New Roman"; font-style: normal; font-variant: normal; font-weight: normal; font-size: 7pt; line-height: normal; font-size-adjust: none; font-stretch: normal;">       
Technology
used;


 


style="color: blue;">Long term
viability of a project should consider the cost of providing the
service as
compared to the estimated end user price vs expected end user adoption
rate at
the specified price.


style="color: rgb(56, 118, 29);">b. What should the weighting
of these criteria be in determining consideration for grant and loan
awards?


style="font-family: Symbol; color: blue;">· style="font-family: "Times New Roman"; font-style: normal; font-variant: normal; font-weight: normal; font-size: 7pt; line-height: normal; font-size-adjust: none; font-stretch: normal;">       
20% style="">     No broadband in an area, (at least 5/1
MB); 


style="font-family: Symbol; color: blue;">· style="font-family: "Times New Roman"; font-style: normal; font-variant: normal; font-weight: normal; font-size: 7pt; line-height: normal; font-size-adjust: none; font-stretch: normal;">       
20% style="">     Lack of competition in an area; 


style="font-family: Symbol; color: blue;">· style="font-family: "Times New Roman"; font-style: normal; font-variant: normal; font-weight: normal; font-size: 7pt; line-height: normal; font-size-adjust: none; font-stretch: normal;">       
20% style="">    Applicant providing universal service
throughout an area (census block?)


style="font-family: Symbol; color: blue;">· style="font-family: "Times New Roman"; font-style: normal; font-variant: normal; font-weight: normal; font-size: 7pt; line-height: normal; font-size-adjust: none; font-stretch: normal;">       
5% style="">       Minimum speed at peak usage being
provided to the end user;


style="font-family: Symbol; color: blue;">· style="font-family: "Times New Roman"; font-style: normal; font-variant: normal; font-weight: normal; font-size: 7pt; line-height: normal; font-size-adjust: none; font-stretch: normal;">       
5% style="">       Population loss over the last twenty
years; 


style="font-family: Symbol; color: blue;">· style="font-family: "Times New Roman"; font-style: normal; font-variant: normal; font-weight: normal; font-size: 7pt; line-height: normal; font-size-adjust: none; font-stretch: normal;">       
5% style="">       Unemployment rate; 


style="font-family: Symbol; color: blue;">· style="font-family: "Times New Roman"; font-style: normal; font-variant: normal; font-weight: normal; font-size: 7pt; line-height: normal; font-size-adjust: none; font-stretch: normal;">       
5% style="">       Financial ability of the applicant to
complete project;


style="font-family: Symbol; color: blue;">· style="font-family: "Times New Roman"; font-style: normal; font-variant: normal; font-weight: normal; font-size: 7pt; line-height: normal; font-size-adjust: none; font-stretch: normal;">       
5% style="">       Sustainability of project;


style="font-family: Symbol; color: blue;">· style="font-family: "Times New Roman"; font-style: normal; font-variant: normal; font-weight: normal; font-size: 7pt; line-height: normal; font-size-adjust: none; font-stretch: normal;">       
2% style="">       Immediate Jobs created (per 1,000
population);


style="font-family: Symbol; color: blue;">· style="font-family: "Times New Roman"; font-style: normal; font-variant: normal; font-weight: normal; font-size: 7pt; line-height: normal; font-size-adjust: none; font-stretch: normal;">       
2% style="">       Local vs State income;


style="font-family: Symbol; color: blue;">· style="font-family: "Times New Roman"; font-style: normal; font-variant: normal; font-weight: normal; font-size: 7pt; line-height: normal; font-size-adjust: none; font-stretch: normal;">       
2% style="">       Long term jobs created (per 1,000
population);


style="font-family: Symbol; color: blue;">· style="font-family: "Times New Roman"; font-style: normal; font-variant: normal; font-weight: normal; font-size: 7pt; line-height: normal; font-size-adjust: none; font-stretch: normal;">       
2% style="">       Net neutral (if other than wireless)


style="font-family: Symbol; color: blue;">· style="font-family: "Times New Roman"; font-style: normal; font-variant: normal; font-weight: normal; font-size: 7pt; line-height: normal; font-size-adjust: none; font-stretch: normal;">       
1% style="">       Cost to build per MB per home;


style="font-family: Symbol; color: blue;">· style="font-family: "Times New Roman"; font-style: normal; font-variant: normal; font-weight: normal; font-size: 7pt; line-height: normal; font-size-adjust: none; font-stretch: normal;">       
1% style="">       End user costs;


style="font-family: Symbol; color: blue;">· style="font-family: "Times New Roman"; font-style: normal; font-variant: normal; font-weight: normal; font-size: 7pt; line-height: normal; font-size-adjust: none; font-stretch: normal;">       
1% style="">       Form 477 completion; 


style="font-family: Symbol; color: blue;">· style="font-family: "Times New Roman"; font-style: normal; font-variant: normal; font-weight: normal; font-size: 7pt; line-height: normal; font-size-adjust: none; font-stretch: normal;">       
1% style="">       Private money leveraged (less than 80%
from NTIA); 


style="font-family: Symbol; color: blue;">· style="font-family: "Times New Roman"; font-style: normal; font-variant: normal; font-weight: normal; font-size: 7pt; line-height: normal; font-size-adjust: none; font-stretch: normal;">       
1% style="">       Population density;


style="font-family: Symbol; color: blue;">· style="font-family: "Times New Roman"; font-style: normal; font-variant: normal; font-weight: normal; font-size: 7pt; line-height: normal; font-size-adjust: none; font-stretch: normal;">       
1% style="">       Small and disadvantaged business;


style="font-family: Symbol; color: blue;">· style="font-family: "Times New Roman"; font-style: normal; font-variant: normal; font-weight: normal; font-size: 7pt; line-height: normal; font-size-adjust: none; font-stretch: normal;">       
1% style="">       State supported; 


style="font-family: Symbol; color: blue;">· style="font-family: "Times New Roman"; font-style: normal; font-variant: normal; font-weight: normal; font-size: 7pt; line-height: normal; font-size-adjust: none; font-stretch: normal;">       
0% style="">       Combined with other projects; 


style="font-family: Symbol; color: blue;">· style="font-family: "Times New Roman"; font-style: normal; font-variant: normal; font-weight: normal; font-size: 7pt; line-height: normal; font-size-adjust: none; font-stretch: normal;">       
0% style="">       Percentage of people with broadband
outside of the city limits;


style="font-family: Symbol; color: blue;">· style="font-family: "Times New Roman"; font-style: normal; font-variant: normal; font-weight: normal; font-size: 7pt; line-height: normal; font-size-adjust: none; font-stretch: normal;">       
0% style="">       Subsidies received in the past;


style="font-family: Symbol; color: blue;">· style="font-family: "Times New Roman"; font-style: normal; font-variant: normal; font-weight: normal; font-size: 7pt; line-height: normal; font-size-adjust: none; font-stretch: normal;">       
0% style="">       Technology used;


style="color: rgb(56, 118, 29);">c. How should the BTOP
prioritize proposals that serve underserved or unserved areas? style=""> Should the BTOP consider USDA broadband grant
awards and loans in establishing these priorities?


style="color: blue;">Priority should be given to projects
that will create backhaul infrastructure that will permit additional
communities to be added.  For example, if a project is in community Z
and
the necessary bandwidth to serve the community is available from a tier
2
provider in community Q, then by funding this project everyone between
community Q and Z will benefit by the backhaul infrastructure that is
created.  This will lower the costs of other projects funded privately
and
would leverage the grant federal money to the greatest extent
possible.   So if the choice were between a project in community U vs
Z, then Z might be preferred because it created more backhaul and
leveraged the
federal money the most.   


style="color: rgb(56, 118, 29);">d. Should priority be given to
proposals that leverage other Recovery Act projects?


style="color: blue;">Coordinating
multiple agency projects should be done at the agency level, as the
applicant
will not be able to control the timing to permit multiple focus
projects on
schedule.


style="color: rgb(56, 118, 29);">e. Should priority be given to
proposals that address several purposes, serve several of the
populations
identified in the Recovery Act, or provide service to different types
of areas?


style="color: blue;">Whatever provides the most efficient
and effective use of the money should be encouraged.


style="color: rgb(56, 118, 29);">f. What factors should be
given priority in determining whether proposals will encourage
sustainable
adoption of broadband service?


style="color: blue;">End User
Price, community education, and proven track record of the applicant. style="">  Affordable prices for the end user will
increase participation.  While most
people are able to know how to effectively use broadband, many need
assistance
in identifying how broadband can be best used. 
And, many need to be inspired with new ideas so they can create
jobs for
themselves.  A strong community support
system will help increase broadband adoption and sustainability.


style="color: rgb(56, 118, 29);">g. Should the fact that
different technologies can provide different service characteristics,
such as
speed and use of dedicated or shared links, be considered given the
statute’s
direction that, to the extent practicable, the purposes of the statute
should
be promoted in a technologically neutral fashion?


style="color: blue;">The
technology that is best for the end user should be the primary
determinant with
a formula that reflects that if the cost exceeds $x per possible end
user
($2,500?), a different technology with lower bandwidth ability may be
necessary.  No one technology should be
preferred over another, except in that it gives the end user the best
possible
choice within some financial framework.


style="color: rgb(56, 118, 29);">h. What role, if any, should
retail price play in the grant program?


style="color: blue;">Some
projects will cost much more than others to deploy.  Some areas are far
from a Tier 1 or 2 provider and the recurring costs will be much
greater for
bandwidth.  In these cases, the higher retail cost is a sign of greater
need for federal assistance.  Cost alone should not be the determinant;
however, any proposal should be reviewed for sustainability, given the
projected prices.  And, projects should
be held to the pricing they quoted in the application to NTIA (with
unforeseen
but necessary changes being justified in writing to and accepted by
NTIA).


5. style="color: black;">Grant Mechanics:
The Recovery Act requires all agencies to distribute funds efficiently
and style="color: black;">fund projects that
would not receive investment otherwise. style="color: rgb(56, 118, 29);">


style="color: rgb(56, 118, 29);">a. What mechanisms for
distributing stimulus funds should be used by NTIA and USDA in addition
to
traditional grant and loan programs?


style="color: blue;">Given the
difficult credit situation, many operations will not be able to cash
flow their
portion of any project.  A solution would
be for a third party to provide grant funds on a matching basis for any
approved purchase as it is made.  Another
option would be to permit the grant funds to be used as a loan
guarantee on a
commercial operating or construction type loan. 
For an applicant to cash flow the entire project and then get
reimbursement after the fact will eliminate many otherwise excellent
applicants.


style="color: rgb(56, 118, 29);">b. How would these mechanisms
address shortcomings, if any, in traditional grant or loan mechanisms
in the
context of the Recovery Act?


style="color: blue;">It would
eliminate the lack of credit and ease the cash flow issue, which is one
of the
primary goals of the Recovery Act.


6. style="color: black;">Grants for
Expanding Public Computer Center Capacity: The Recovery Act directs
that not style="color: black;">less than $200,000,000
of the BTOP shall be awarded for grants that expand public computer style="color: rgb(56, 118, 29);"> center
capacity,
including at community colleges and public libraries.
style="color: rgb(56, 118, 29);">


style="color: rgb(56, 118, 29);">a. What selection criteria
should be applied to ensure the success of this aspect of the program?


style="color: blue;">Look at
all of the pilot programs of this type that have been funded by RUS
over the
years and see which were successful. Use elements from these programs
to create
the criteria.  Also, consult with the
Gates Foundation, which has operated similar programs.


style="color: rgb(56, 118, 29);">b. What additional
institutions other than community colleges and public libraries should
be
considered as eligible recipients under this program?


style="color: blue;">Communities
with a high elderly-to-youth population are in the greatest need of
public
computer capacity, along with someone to provide education.  This is
where
computer literacy is the lowest.  Any
entity that can provide long-term funding for these resources should be
eligible.


7. style="color: black;">Grants for
Innovative Programs to Encourage Sustainable Adoption of Broadband
Service: style="color: black;">The Recovery Act
directs that not less than $250,000,000 of the BTOP shall be awarded for style="color: rgb(56, 118, 29);"> grants
for innovative
programs to encourage sustainable adoption of broadband services.
style="color: rgb(56, 118, 29);">


style="color: rgb(56, 118, 29);">a. What selection criteria
should be applied to ensure the success of this program?


style="color: blue;">Jacobellis
v. Ohio
-
http://en.wikipedia.org/wiki/Jacobellis_v._Ohio - Like the famous porn
case -
How do you define porn?  The Courts say, “You know it when you see
it.” 
Have the reviewers flag what they consider to be the most innovative
proposals,
then have a special group of reviewers pick the best from the flagged
applications.


style="color: rgb(56, 118, 29);">b. What measures should be
used to determine whether such innovative programs have succeeded in
creating
sustainable adoption of broadband services?


style="color: blue;">Percentage
of people with broadband now vs number with broadband x number of years
later.  Number of new businesses in the community after x years. 
Number of new employees after x years.  Wage growth as compared to a
community without broadband.


8. style="color: black;">Broadband Mapping:
The Recovery Act directs NTIA to establish a comprehensive style="color: rgb(56, 118, 29);"> nationwide
inventory
map of existing broadband service capability and availability in the
style="color: rgb(56, 118, 29);"> United
States that
depicts the geographic extent to which broadband service capability is
style="color: rgb(56, 118, 29);"> deployed
and available
from a commercial provider or public provider throughout each
style="color: rgb(56, 118, 29);"> State. style="color: rgb(56, 118, 29);">


style="color: rgb(56, 118, 29);">a. What uses should such a map
be capable of serving?


style="color: blue;">Identifying
unused broadband capacity that providers can access.  Who has excess
capacity and at what locations it is available.  Where doesn't capacity
exist?  Which community can't get broadband, even if they have fiber to
the premise, because there is insufficient backhaul in the region? 
Identifying capacity available to each home and business, using
something like
Google Earth or Microsoft Live Search maps.  Fixed wireless providing
propagation maps.  Fiber providers providing fiber deployment maps,
etc.  Identifying which providers can provide service to a specific
home
or business.  Permit an end user to provide speed test results for a
specific location (some way of verifying accuracy would be necessary so
that a
hostile competitor doesn't provide false information or a compromised
machine
doesn't incorrectly place blame.)  


style="color: rgb(56, 118, 29);">b. What specific information
should the broadband map contain, and should the map provide different
types of
information to different users (e.g., consumers versus governmental
entities)?


style="color: blue;">Yes, different
users need different information.  Internet
Providers need access to information.  POP site x has x GB of available
bandwidth for sale.  Time of availability.  “No capacity available
during the day, but x GB available from 11pm to 6am,” for instance 
What
towers and buildings can be used as repeaters.  


style="color: blue;">

 


style="color: blue;">Consumers
want to know what providers can provide service to the home or
business.


style="color: rgb(56, 118, 29);">c. At what level of geographic
or other granularity should the broadband map provide information on
broadband
service?


style="color: blue;">Perhaps two maps.  One,
official map with data collected from the providers, reporting what
they can
do.   The second map the same, but with a user-generated overlay of
information from the public reporting on their specific locations.


style="color: rgb(56, 118, 29);">d. What other factors should
NTIA take into consideration in fulfilling the requirements of the
Broadband
Data Improvement Act, Pub. L. No. 110-385 (2008)?


style="color: rgb(56, 118, 29);">e. Are there State or other
mapping programs that provide models for the statewide inventory
grants?


style="color: rgb(56, 118, 29);">f. Specifically what
information should states collect as conditions of receiving statewide
inventory grants?


style="color: blue;">Where fiber exists -- both backhaul accessible
by providers and where it is accessible by the end user. 
What fiber exists that the State prohibits
access to? (For example, Nebraska
prohibits public utilities from selling their excess fiber bandwidth,
as it
would provide competitive pressure for telephone companies). style="">  A breakout of bandwidth availability for
those within city limits, as compared to those outside of city limits. style="">  In many rural areas, DSL/Cable is available
within the city limits but unavailable outside of the city limits. style="">  Yet, the States will often report information
on a zip code or census basis which does not reflect the lack of
broadband for
a significant portion of any community. 
What is the average minimum speed available during peak hours? style="">  As most providers report maximum speed and
will not honestly report actual minimum speeds, an independent source
of
information is needed.  


style="color: rgb(56, 118, 29);">g. What technical
specifications should be required of state grantees to ensure that
statewide
inventory maps can be efficiently rolled up into a searchable national
broadband database to be made available on NTIA’s website no later than
February 2011?


style="color: blue;">Searchable database with a common
set of fields created by NTIA.


style="color: rgb(56, 118, 29);">h. Should other conditions
attach to statewide inventory grants?


style="color: blue;">Set a timeline.  Accept
alternative sources of information, as long as it is in the proper
format and
from a reputable source.  Some States will fail to deliver an accurate
or
timely map.  Permit alternative sources of information, if a State
fails.  Some companies will refuse to release
information about the services they provide. 
Such a failure should make them ineligible for grants and loans
and
should make it possible for someone to receive assistance to overlay
the area
without protest from the non-cooperative entity.


style="color: rgb(56, 118, 29);">i. What information, other
than statewide inventory information, that should populate the
comprehensive
nationwide map?


style="color: rgb(56, 118, 29);">j. The Recovery Act and the
Broadband Data Improvement Act (BDIA) imposes duties on both NTIA and
FCC
concerning the collection of broadband data. Given the statutory
requirements
of the Recovery Act and the BDIA, how should NTIA and FCC best work
together to
meet these requirements?


9. style="color: black;">Financial
Contributions by Grant Applicants: The Recovery Act requires that the
Federal style="color: black;">share of funding for
any proposal may not exceed 80 percent of the total grant. style="font-size: 7.5pt; color: black;">8 style="color: black;">The
Recovery Act also
requires that applicants demonstrate that their proposals would not have
style="color: rgb(56, 118, 29);"> been
implemented during
the grant period without Federal assistance.
style="font-size: 7.5pt; color: black;">9 style="color: black;">The Recovery Act style="color: rgb(56, 118, 29);"> allows
for an increase
in the Federal share beyond 80 percent if the applicant petitions NTIA
style="color: rgb(56, 118, 29);"> and
demonstrates
financial need.


style="color: rgb(56, 118, 29);">a. What factors should an
applicant show to establish the “financial need” necessary to receive
more than
80 percent of a project’s cost in grant funds?


style="color: rgb(56, 118, 29);">b. What factors should the
NTIA apply in deciding that a particular proposal should receive less
than an
80 percent Federal share?


style="color: blue;">Past loans
and grants to deploy fiber to within three miles of every home in an
area but a
failure to use that existing infrastructure. 
An existing partial deployment.  A
failure to complete a deployment in a timely fashion. 


style="color: rgb(56, 118, 29);">c. What showing should be
necessary to demonstrate that the proposal would not have been
implemented
without Federal assistance?


10. style="color: black;">Timely Completion
of Proposals: The Recovery Act states that NTIA shall establish the style="color: rgb(56, 118, 29);"> BTOP
as expeditiously
as practicable, ensure that all awards are made before the end of
style="color: rgb(56, 118, 29);"> fiscal
year 2010, and
seek assurances from grantees that projects supported by the programs
style="color: rgb(56, 118, 29);"> will
be substantially
completed within two (2) years following an award.
style="font-size: 7.5pt; color: black;">10 style="color: black;">The
Recovery style="color: black;">Act
also requires that grant recipients report quarterly on the recipient’s
use of
grant funds style="color: black;">and
the grant recipient’s progress in fulfilling the objectives of the
grant
proposal.11 style="color: black;">The
Recovery Act permits NTIA to
de-obligate awards to grant
recipients that demonstrate an
style="color: rgb(56, 118, 29);"> insufficient
level of performance, or wasteful or
fraudulent spending (as defined by NTIA in
style="color: rgb(56, 118, 29);"> advance),
and award these funds to new or existing
applicants.


style="color: rgb(56, 118, 29);">a. What is the most efficient,
effective, and fair way to carry out the requirement that the BTOP be
established expeditiously and that awards be made before the end of
fiscal year
2010?


style="color: blue;">A public web site that provides
answers to formally submitted questions about the programs. style="">  Prompt availability of funds. 


style="color: rgb(56, 118, 29);">b. What elements should be
included in the application to ensure the projects can be completed
within two
(2) years (e.g., timelines, milestones, letters of agreement with
partners)?


style="color: blue;">Timelines.  Failure to
meet the timelines results in
notice of failure.  Repeated failures
results in loss of control over the project by the applicant and
project to be
put out to bid for anyone else to complete.


11. style="color: black;">Reporting and
Deobligation: The Recovery Act also requires that grant recipients
report style="color: black;">quarterly on the
recipient’s use of grant funds and progress in fulfilling the
objectives of the style="color: black;">grant proposal. style="color: rgb(56, 118, 29);"> The
Recovery Act
permits NTIA to de-obligate funds for grant awards that
style="color: rgb(56, 118, 29);"> demonstrate
an
insufficient level of performance, or wasteful or fraudulent spending
(as
style="color: black;">defined by NTIA in
advance), and award these funds to new or existing applicants. style="color: rgb(56, 118, 29);">


style="color: rgb(56, 118, 29);">

 


style="color: rgb(56, 118, 29);">a. How should NTIA define
wasteful or fraudulent spending for purposes of the grant program?


style="color: blue;">Use of money other than what was in
the application (unless written request to do so went to NTIA and was
accepted).
Failure to deliver on services promised.  Failure to deliver on the
applicant’s financial share.


style="color: rgb(56, 118, 29);">b. How should NTIA determine
that performance is at an “insufficient level?”


style="color: blue;">This
question isn't being asked, but the provider should be provided with
ample
warning that NTIA suspects a problem. 
Then, the provider should be given an opportunity to correct the
problem
in a timely fashion.


 


style="color: blue;">Failure to
meet timelines and milestones laid out in the approved grant or loan.


style="color: rgb(56, 118, 29);">c. If such spending is
detected, what actions should NTIA take to ensure effective use of
investments
made and remaining funding?


style="color: blue;">Advertise
the details of the project, the spending to date, the projected balance
needed
to finish the project and auction off the remaining project to the
entities
applying to finish the job.


12. style="color: black;">Coordination with
USDA’s Broadband Grant Program: The Recovery Act directs USDA’s style="color: rgb(56, 118, 29);"> Rural
Development
Office to distribute $2.5 billion dollars in loans, loan guarantees, and
style="color: rgb(56, 118, 29);"> grants
for broadband
deployment. The stated focus of the USDA’s program is economic
style="color: rgb(56, 118, 29);"> development
in rural
areas. NTIA has broad authority in its grant program to award grants
style="color: rgb(56, 118, 29);"> throughout
the United States.
Although the two programs have different statutory structures, the
programs
have many similar purposes, namely the promotion of economic development
style="color: rgb(56, 118, 29);"> based
on deployment of
broadband service and technologies.
style="color: rgb(56, 118, 29);">


style="color: rgb(56, 118, 29);">a. What specific programmatic
elements should both agencies adopt to ensure that grant funds are
utilized in
the most effective and efficient manner?


style="color: blue;">Permit
each agency to review any application that provides service within the
same zip
code in order to reduce duplication and conflict.


style="color: rgb(56, 118, 29);">b. In cases where proposals
encompass both rural and non-rural areas, what programmatic elements
should the
agencies establish to ensure that worthy projects are funded by one or
both
programs in the most cost effective manner without unjustly enriching
the
applicant(s)?


style="color: blue;">Require the project to provide
universal service within the target area. 
If there are two competing applications for an area with similar
coverage, consider giving priority to the application that provides
universal
service to the larger area.  Many
operations may want to focus on just the most financially rewarding
portions of
a community and ignore the homes and businesses the Recovery Act
specifically
is attempting to help.  Permitting such
targeted services will limit the potential customer base of any entity
attempting to provide service to the most needy.  Universal
service within an area receiving a
grant using mixed technology will result in the most people being
helped.


style="color: blue;">Look at what an existing operation
currently provides.  Does it provide
service to just those within the city limits? 
Has it made any attempt to provide service to those outside of
the city
limits?  Does its application propose to
upgrade the service for those it already provides service to but
ignores others
within their geographic area?  For
example, many telephone companies provide DSL within city limits but
provide no
service to those outside of the city limits. 
Does the application address those that the company has ignored
in the
past?


13. style="color: black;">Definitions: The
Conference Report on the Recovery Act states that NTIA should consult style="color: rgb(56, 118, 29);"> with
the FCC on
defining the terms “unserved area,” “underserved area,” and “broadband.”
style="color: rgb(56, 118, 29);"> The
Recovery Act also
requires that NTIA shall, in coordination with the FCC, publish
style="color: rgb(56, 118, 29);"> nondiscrimination
and
network interconnection obligations that shall be contractual
style="color: rgb(56, 118, 29);"> conditions
of grant
awards, including, at a minimum, adherence to the principles contained
in
style="color: black;">the FCC’s broadband
policy statement (FCC 05-15, adopted August 5, 2005). style="color: rgb(56, 118, 29);">


style="color: rgb(56, 118, 29);">a. For purposes of the BTOP,
how should NTIA, in consultation with the FCC, define the terms
“unserved area”
and “underserved area?”


style="color: blue;">The
numbers refer to points.  If your target area meets the definition,
then
you get the points.  The points are cumulative.



Unserved –


style="font-size: 10pt; font-family: Symbol; color: blue;"> style="">· style="font-family: "Times New Roman"; font-style: normal; font-variant: normal; font-weight: normal; font-size: 7pt; line-height: normal; font-size-adjust: none; font-stretch: normal;">        
10 Any
area with no
provider providing more than 1 Mb down and 512 kbps up. (prorated to
the
portion of the homes in the target in this category)


style="color: blue;">Underserved
– Any of the following with varying point scale depending on how many
of the
elements are met.


style="font-size: 10pt; font-family: Symbol; color: blue;"> style="">· style="font-family: "Times New Roman"; font-style: normal; font-variant: normal; font-weight: normal; font-size: 7pt; line-height: normal; font-size-adjust: none; font-stretch: normal;">        
3  To
maintain
computability with the FFC broadband statement, any area with only one
provider
of service would be considered underserved.


style="font-size: 10pt; font-family: Symbol; color: blue;"> style="">· style="font-family: "Times New Roman"; font-style: normal; font-variant: normal; font-weight: normal; font-size: 7pt; line-height: normal; font-size-adjust: none; font-stretch: normal;">        
1  Cannot
receive
symmetrical broadband service. 


style="font-size: 10pt; font-family: Symbol; color: blue;"> style="">· style="font-family: "Times New Roman"; font-style: normal; font-variant: normal; font-weight: normal; font-size: 7pt; line-height: normal; font-size-adjust: none; font-stretch: normal;">        

Receives average
peak time bandwidth of less than 2d/1u Mb .


style="font-size: 10pt; font-family: Symbol; color: blue;"> style="">· style="font-family: "Times New Roman"; font-style: normal; font-variant: normal; font-weight: normal; font-size: 7pt; line-height: normal; font-size-adjust: none; font-stretch: normal;">        

Receives
minimum peak time bandwidth of less than 5d/1u Mb .


style="color: blue;">For example, if an applicant area
has only one provider currently providing asymmetrical service of 3
mbps down
and 1 mbps up and only does so within the city limits and 50% of the
homes in
the census tract or zipcode qualify as unserved then the
unserved/underserved
score would be



3 pts for single provider

1 pts for asymmetrical service

2 pts for less than 5 down but more than 2 up.

5 pts for more than 25% of the homes in the unserved category.   (50%
of 10)



So a total of 11 points on the unserved/underserved scale.



Within many census tracts and zipcodes, there will be a portion of the
population that is served, underserved, and unserved.   Hence, NTIA
should permit an applicant to define the area to be served by the
application
however the applicant with a familiarity with the area feels is best. 
But, the applicant should also be required to report what services are
available within the same zip code and census tracts as the
application, even
if the applicant does not propose delivering service to those other
areas.  The applicant should be required to map the unserved and
underserved areas with all zipcode or census tracts the application
covers,
even if not all of the area is to be covered.  This will help NTIA in
its
mapping project and will also highlight not only who the applicant is
trying to
help but also who they are ignoring.


style="color: rgb(56, 118, 29);">b. How should the BTOP define
“broadband service?”


style="color: rgb(56, 118, 29);">(1) Should the BTOP establish
threshold transmission speeds for purposes of analyzing whether an area
is
“unserved” or “underserved” and prioritizing grant awards? Should
thresholds be
rigid or flexible?


style="color: blue;">Thresholds
should be flexible.  If two applicants are competing within a service
area
for a grant or loan, the one offering the faster service should receive
higher
scores.  Higher scores for symmetrical service.  Thresholds could be
based on Homes Per Square Mile (hpsm).  <5 hpsm - 5 Mbs; 5-50 hpsm -
10
Mbs; 50-500 hpsm - 20 Mbs;  >500 hpsm - 50 Mbs.


style="color: rgb(56, 118, 29);">(2) Should the BTOP establish
different threshold speeds for different technology platforms?


style="color: blue;">Speed
should be based on the end user, not on how the service is delivered.  


style="color: rgb(56, 118, 29);">(3) What should any such
threshold speed(s) be, and how should they be measured and evaluated
(e.g.,
advertised speed, average speed, typical speed, maximum speed)?


style="color: blue;">Minimum
speed and average speeds are the most important factor.  What will the
provider deliver during the busiest periods?  Advertised speeds and
maximum speeds are meaningless and should not be used.  Many triple
play
providers advertise 3 Mb or 5 Mb service, which is max the client can
get; but
during peak times, they may deliver only dialup speeds.     


style="color: rgb(56, 118, 29);">(4) Should the threshold
speeds be symmetrical or asymmetrical?


style="color: blue;">Symmetrical
should be rewarded with higher scores, but not required.


style="color: rgb(56, 118, 29);">(5) How should the BTOP
consider the impacts of the use of shared facilities by service
providers and
of network congestion?


style="color: blue;">Network
congestion is a major determinant in end user satisfaction and should
be a
major factor in deciding which applications are funded.  Minimum
service
delivery to x percentage of the clients during peak times should be a
major
factor. 


style="color: blue;">

 


style="color: blue;">NTIA
should consider requiring shared facilities to prorate available
capacity based
on percentage of financial contribution, as measured by both initial
infrastructure costs and in the recurring costs.  If one of the
entities
oversells their share of the shared facility, then their service
offering will
suffer and the market will reduce their market share.


style="color: blue;">

c. How should the BTOP
define the
nondiscrimination and network interconnection obligations that will be
contractual conditions of grants awarded under Section 6001?


style="color: rgb(56, 118, 29);">(1) In defining
nondiscrimination obligations, what elements of network management
techniques
to be used by grantees, if any, should be described and permitted as a
condition of any grant?


style="color: blue;">The
primary owner of a shared facility must place equipment that will
permit the
distribution of bandwidth commiserate with the financial contribution
provided
by each party sharing the facility.  The
primary owner must not be permitted to oversubscribe the available
bandwidth.  The facility and its network
management must be open to independent review to assure honest and
accurate
management. 


style="color: blue;">

 


style="color: blue;">The
percentage of the network that must be open and shared should be set by
the
applicant during the application process and approved by NTIA when
giving the
grant.  Anyone wanting to access this
portion of the network must make an initial payment to the primary
owner at a
rate proportional to the contribution made by the primary applicant and
must
make recurring cost contributions proportional to the bandwidth
accessed.


style="color: rgb(56, 118, 29);"> (2) Should the
network interconnection
obligation be based on existing statutory schemes? If not, what should
the
interconnection obligation be?


style="color: rgb(56, 118, 29);">(3) Should there be different
nondiscrimination and network interconnection standards for different
technology
platforms?


style="color: blue;">Technologies
that provide service to end users at less than 5 Mb should be exempted
from the
network interconnection obligations.


style="color: blue;">

 


style="color: blue;">If the
interconnection policy is based on the number of homes per square mile
instead,
then the providers to the very remote and unpopulated areas can be
encouraged
to use the most appropriate technology without overloading the design.
 
 


style="color: rgb(56, 118, 29);">(4) Should failure to abide by
whatever obligations are established result in deobligation of fund
awards?


style="color: blue;">Yes.


style="color: rgb(56, 118, 29);">(5) In the case of
infrastructure paid for in whole or part by grant funds, should the
obligations
extend beyond the life of the grant and attach for the useable life of
the
infrastructure?


style="color: blue;">For a
fixed number of years -- five or ten years. 
The useable life of the infrastructure is dependent on the
technology
used and the maintenance of the infrastructure. 
One does not want to encourage poor maintenance to shorten the
useable
life and, hence, shorten the obligation. 
Instead, set a fixed period of time for each technology.


style="color: rgb(56, 118, 29);">d. Are there other terms in
this section of the Recovery Act, such as “community anchor
institutions,” that
NTIA should define to ensure the success of the grant program? If so,
what are
those terms and how should those terms be defined, given the stated
purposes of
the Recovery Act?


style="color: blue;">NTIA should not require the
applicant to obtain a commitment from anchor institutions as a
condition of the
project receiving approval. 


style="color: blue;">Service should not be free to the
anchor institutions, since cost is an effective way of metering a
limited
resource. 


style="color: blue;">Anchor institutions are likely to
subscribe to the broadband service if the overall project is approved.


style="color: rgb(56, 118, 29);">e. What role, if any, should
retail price play in these definitions?


style="color: blue;">Any retail
price consideration should also take into consideration the costs
associated
with providing service to an area.  Some
areas will have much higher costs of placing the service and much
higher costs
of obtaining bandwidth.   Rural areas far
from population centers have a higher bandwidth cost from Tier 1 or 2
providers
and, hence, must have a higher retail price in order to make a project
work.   A better measure is retail price
minus cost per subscriber.  It is not
good to make this a cost plus based system, since such gives the
provider an
incentive to inflate costs. However, measuring the net per subscriber
may be an
effective way for NTIA to audit unjust enrichment; but, it should not
be used
as a method to reward grants.


14. style="color: black;">Measuring the
Success of the BTOP: The Recovery Act permits NTIA to establish style="color: rgb(56, 118, 29);"> additional
reporting
and information requirements for any recipient of grant program funds.
style="color: rgb(56, 118, 29);">


style="color: rgb(56, 118, 29);">a. What measurements can be
used to determine whether an individual proposal has successfully
complied with
the statutory obligations and project timelines?


style="color: rgb(56, 118, 29);">b. Should applicants be
required to report on a set of common data elements so that the
relative
success of individual proposals may be measured? If so, what should
those
elements be?


style="color: blue;">Possible elements might include:


style="font-family: Symbol; color: blue;">· style="font-family: "Times New Roman"; font-style: normal; font-variant: normal; font-weight: normal; font-size: 7pt; line-height: normal; font-size-adjust: none; font-stretch: normal;">       
Percentage
of actual subscribers
of possible subscribers.  (competitive
market or sole provider)


style="font-family: Symbol; color: blue;">· style="font-family: "Times New Roman"; font-style: normal; font-variant: normal; font-weight: normal; font-size: 7pt; line-height: normal; font-size-adjust: none; font-stretch: normal;">       
Average
minimum speed
provided, as measured by independent party


style="font-family: Symbol; color: blue;">· style="font-family: "Times New Roman"; font-style: normal; font-variant: normal; font-weight: normal; font-size: 7pt; line-height: normal; font-size-adjust: none; font-stretch: normal;">       
Was the
project
completed on time?


style="font-family: Symbol; color: blue;">· style="font-family: "Times New Roman"; font-style: normal; font-variant: normal; font-weight: normal; font-size: 7pt; line-height: normal; font-size-adjust: none; font-stretch: normal;">       
Was the
project
completed at or under budget?


style="color: black;">

 


style="color: black;">15. Please
provide comment on any other issues that NTIA should
consider in creating BTOP

within the confines of the statutory
structure established
by the Recovery Act.


style="font-family: Symbol; color: blue;">· style="font-family: "Times New Roman"; font-style: normal; font-variant: normal; font-weight: normal; font-size: 7pt; line-height: normal; font-size-adjust: none; font-stretch: normal;">       
Limit
project and
agency overlap.  Multiparty applications
are more likely to result in time delays and problems unless there is a
clear
process for conflict resolution that does not involve the courts. style=""> 


style="border-style: none none solid; border-color: -moz-use-text-color -moz-use-text-color windowtext; border-width: medium medium 1.5pt; padding: 0in 0in 1pt; margin-left: 19.05pt; margin-right: 0in;">

style="color: black;">

 



style="color: black;">

 


style="color: black;">RUS: style="color: rgb(56, 118, 29);">


style="color: black;">The provisions regarding the RUS
Recovery Act broadband grant and loan activities are found in style="color: rgb(56, 118, 29);"> Division
A, title I
under the heading Rural Utilities Service, Distance Learning,
Telemedicine
style="color: black;">and Broadband Program
of the Recovery Act.


style="color: black;">1. What are the most effective
ways RUS could offer broadband funds to ensure that rural style="color: rgb(56, 118, 29);"> residents
that lack
access to broadband will receive it?
style="color: rgb(56, 118, 29);">


style="color: black;">For a number of years, RUS has
struggled to find an effective way to use the Agency’s style="color: rgb(56, 118, 29);"> current
broadband loan
program to provide broadband access to rural residents that lack
style="color: rgb(56, 118, 29);"> such
access. RUS
believes that the authority to provide grants as well as loans will give
style="color: rgb(56, 118, 29);"> it
the tools necessary
to achieve that goal. RUS is looking for suggestions as to the best
style="color: rgb(56, 118, 29);"> ways
to:


style="color: rgb(56, 118, 29);">a. bundle loan and grant
funding options to ensure such access is provided in the projects
funded under
the Recovery Act to areas that could not traditionally afford the
investment;


style="color: blue;">Combine the loan and grant programs
so that the loan payback rate might be less than 100%.  
Set the loan payback rate to a long period
of time.   Open the loan program up to
entities other than telephone companies. 
 Reducing the loan payback rate to
60% or such would dramatically increase the demand on the loan funds. style=""> 


style="color: rgb(56, 118, 29);">b. promote leveraging of
Recovery Act funding with private investment that ensures project
viability and
future sustainability; and


style="color: blue;">Award loans and grants to those
providing the highest percentage of private investment. 
For example, a grant applicant willing to
invest 40% instead of 20% might receive a higher score. 
Note that this will favor entities that have
access to credit or that are utilities that have a source of revenue
that is demand-independent.    


style="color: rgb(56, 118, 29);">c. ensure that Recovery
Funding is targeted to unserved areas that stand to benefit the most
from thi style="color: rgb(56, 118, 29);">s funding opportunity.


style="color: blue;">Require any applicant for loan or
grant funds to provide universal service at an average minimum
speed during
peak times to anyone who wants it anywhere within a county or census
tract.  Setting different bandwidths for
those within small town city limits and those outside the city limits. style=""> 


style="color: blue;">If an existing telephone company
wants to leverage their existing fiber deployments which were
subsidized with
prior government loans and grants, then permit any entity that wants to
provide
universal service within a targeted county, zipcode, or census tract to
interconnect to that fiber.


style="color: blue;">Limiting the use of the existing government
subsidized infrastructure limits those who can provide service to the
unserved
areas and limits the private financing available to match the new
funding
opportunities.


2. In what
ways can RUS and NTIA best align their Recovery
Act broadband activities to make
style="color: rgb(56, 118, 29);"> the
most efficient and effective use of the Recovery Act
broadband funds?
style="color: black;">In the Recovery Act, Congress provided funding
and
authorities to both RUS and the style="color: rgb(56, 118, 29);"> NTIA
to expand the development of broadband throughout the
country. Taking into
style="color: black;">account the authorities and limitations provided
in the
Recovery Act, RUS is looking for style="color: rgb(56, 118, 29);"> suggestions
as to how both agencies can conduct their
Recovery Act broadband activities
style="color: rgb(56, 118, 29);"> so
as to foster effective broadband development. For
instance:


style="color: rgb(56, 118, 29);">a) RUS is charged with
ensuring that 75 percent of the area is rural and without sufficient
access
needed for economic development. How should this definition be
reconciled with
the NTIA definitions of “unserved” and “underserved?”


style="color: blue;">The definitions should match as
closely as possible.  The only added
element to the RUS definition is the rural element.  Within
many census tracts and zipcodes, there
will be a portion of the population that is served, underserved, and
unserved.   Hence, RUS should permit an
applicant to define the area to be served by the application however
the
applicant wants.  But, the applicant
should also be required to report what services are available within
the same
zipcode and census tracts as the application, even if the applicant
does not
propose delivering service to those other areas.  The
applicant should be required to map the
unserved and underserved areas with all zip code or census tracts the
application covers, even if not all of the area is to be covered. style="">  This will help NTIA in its mapping project
and will also highlight not only who the applicant is trying to help
but also who
they are ignoring.


style="color: blue;">Unserved – Any area with less than 1
Mb down and 512 kbps up. 


style="color: blue;">Underserved – Any of the following
with varying point scale depending on how many of the elements are met:


style="font-family: Symbol; color: blue;">· style="font-family: "Times New Roman"; font-style: normal; font-variant: normal; font-weight: normal; font-size: 7pt; line-height: normal; font-size-adjust: none; font-stretch: normal;">       
To
maintain
computability with the FFC broadband statement, any area with only one
provider
of service would be considered underserved. 


style="font-family: Symbol; color: blue;">· style="font-family: "Times New Roman"; font-style: normal; font-variant: normal; font-weight: normal; font-size: 7pt; line-height: normal; font-size-adjust: none; font-stretch: normal;">       
Cannot
receive symmetrical
broadband service.   


style="font-family: Symbol; color: blue;">· style="font-family: "Times New Roman"; font-style: normal; font-variant: normal; font-weight: normal; font-size: 7pt; line-height: normal; font-size-adjust: none; font-stretch: normal;">       
Receives
minimum peak
time bandwidth of less than 5 Mb down and 1 Mb up.


style="font-family: Symbol; color: blue;">· style="font-family: "Times New Roman"; font-style: normal; font-variant: normal; font-weight: normal; font-size: 7pt; line-height: normal; font-size-adjust: none; font-stretch: normal;">       
Receives
minimum peak
time bandwidth of less than 10 Mb down and 3 Mb up.


style="font-family: Symbol; color: blue;">· style="font-family: "Times New Roman"; font-style: normal; font-variant: normal; font-weight: normal; font-size: 7pt; line-height: normal; font-size-adjust: none; font-stretch: normal;">       
Any
census tract or
zipcode where more than 25% of the homes or businesses are unserved.


style="color: blue;">Bandwidth
thresholds should be flexible.  If two applicants are competing within
a
service area for a grant or loan, the one offering the faster service
should
receive higher scores.  Higher scores for symmetrical service. 
Thresholds could be based on Homes Per Square Mile (hpsm).  <5 hpsm
- 5
Mbs; 5-50 hpsm - 10 Mbs; 50-500 hpsm - 20 Mbs;  >500 hpsm - 50 Mbs.


style="color: rgb(56, 118, 29);">b) How should the agencies
structure their eligibility requirements and other programmatic
elements to
ensure that applicants that desire to seek funding from both agencies
(i) do
not receive duplicate resources and (ii) are not hampered in their
ability to
apply for funds from both agencies?


style="color: blue;">NTIA and RUS should compare the
zipcodes of the areas to be serviced by applicants to their program. style="">  Any area where there is an overlap should
cause NTIA and RUS to consult with each other on the overlapping
applications.


style="color: black;">

 


3. How should
RUS evaluate whether a particular level of
broadband access and service is
style="color: rgb(56, 118, 29);"> needed
to facilitate economic development? Seventy-five
percent of an area to be funded under the Recovery Act must be in an
area that
USDA determines lacks sufficient “high speed broadband service to
facilitate
rural economic development.” RUS is seeking suggestions as to the
factors it
should use to make such determinations.
style="color: rgb(56, 118, 29);">


style="color: rgb(56, 118, 29);">a) How should RUS define
“rural economic development?” What factors should be considered, in
terms of
job growth, sustainability, and other economic and socioeconomic
benefits?


style="color: blue;">There are two elements.  1) style="">  Is
enough bandwidth available to the community? 
In other words, is there enough fiber to the community that
bandwidth
can be distributed to all of the potential demand?  If
not, then backhaul investment must be made
before the end user infrastructure can be deployed. 


style="color: blue;">2) 
If the backhaul infrastructure exists, then what bandwidth can
be
delivered to the end user?


style="color: blue;">Most of rural w:st="on">America has lost population
because
of the dramatic increase in agricultural productivity but a failure of
these
communities to diversify their economic base from agriculture. style="">  As a result, when a farm grows due to more
efficient
operations, the individual leaves and all of the jobs associated with
servicing
that individual leave as well.


style="color: blue;">Any area that has lost more than x%
of its population over the last ten or twenty years is in the greatest
need of
economic development.  Broadband
deployment in such areas will permit a diversification from the
agricultural
economy. 


style="color: rgb(56, 118, 29);">b) What speeds are needed to
facilitate “economic development?” What does "high speed broadband
service" mean?


style="color: blue;">There are two categories of rural
broadband users.  Those who want to
conduct business from afar.  These
individuals need VPNs, VOIP, and the ability to do large file
transfers, both
up and down.  Such individuals would
benefit greatly from minimum average symmetrical bandwidth speeds of at
least 5
MB.   Higher speeds are possible and
beneficial, but the minimum should be defined as:


style="color: blue;">A minimum average symmetrical
bandwidth speed of at least 5 MB and capable of doing VPNs, VOIP, and
GB file
transfers in both directions.


style="color: blue;">The backhaul bandwidth to provide
this service to multiple users simultaneously is required.


style="color: blue;">The other category of user is the
casual user who doesn’t require higher speeds but simply wants them. style=""> 


style="color: blue;">To facilitate greater economic
development, one needs to increase the number of individuals who fit
into the
first category.  The infrastructure must
exist before the economic development, based on broadband, can exist.


style="color: rgb(56, 118, 29);">c) What factors should be
considered, when creating economic development incentives, in
constructing
facilities in areas outside the seventy-five percent area that is rural
(i.e.,
within an area that is less than 25 percent rural)?


style="margin: 0in 0in 12pt 0.75in; text-indent: -0.25in;"> style="font-family: Symbol; color: blue;">· style="font-family: "Times New Roman"; font-style: normal; font-variant: normal; font-weight: normal; font-size: 7pt; line-height: normal; font-size-adjust: none; font-stretch: normal;">       
Will the
development
happen without the funding?


style="margin: 0in 0in 12pt 0.75in; text-indent: -0.25in;"> style="font-family: Symbol; color: blue;">· style="font-family: "Times New Roman"; font-style: normal; font-variant: normal; font-weight: normal; font-size: 7pt; line-height: normal; font-size-adjust: none; font-stretch: normal;">       
Will the
development
create infrastructure that will increase the backhaul infrastructure to
the rural
areas?


4. In further
evaluating projects, RUS must consider the
priorities listed below. What value
style="color: rgb(56, 118, 29);"> should
be assigned to those factors in selecting
applications? What additional priorities
style="color: rgb(56, 118, 29);"> should
be considered by RUS?

 
Priorities
have been assigned to projects that will: 1) give end-users a choice of
internet
style="color: black;">service
providers, 2) serve the highest proportion of rural residents that lack
access
to style="color: black;">broadband
service, 3) be projects of current and former RUS borrowers, and 4) be
fully style="color: black;">funded and ready to
start once they receive funding under the Recovery Act. style="color: rgb(56, 118, 29);">


style="color: rgb(56, 118, 29);">a)  What additional
priorities should be considered by RUS?


style="color: blue;">Has the existing telephone
company extended broadband beyond the small town city limits? style="">   Has it deployed last mile service? 
Does it have under-utilized, government-subsidized
fiber through its territory?   If so,
then priority should be given to competitors. 
This will meet the FCC broadband directive that competition is
the right
of the end user and it will spur the existing provider to deploy more
quickly
and provide a higher level of service. style="color: rgb(56, 118, 29);">


style="color: rgb(56, 118, 29);">

 









(Late Submission)
Education is critical to any and all additional consumer adoption of Broadband. Public Relations and community relations programs that can inform, educate and engage targeted publics is critical to the success of the government's goals and objectives of the Broadband Technologies Opportunity Program.

We would like to see concerted, targeted and valuable regional efforts that yield measurable results funded by the program.

(Late Submission)
Dear BTOP
I urge you to consider the following:
1. establish the definition of “unserved area,” as (everyone without 5 megabit symmetric service)
2. the definition of “underserved area,” (everyone without 20 megabit symmetric service)
3. the definition of “broadband, (5 megabit symmetric service)
4. the non-discrimination obligations that will be contractual conditions of BTOP (broadband technologies opportunity program) grants (wholesale access to anyone)
5. the network interconnection obligations that will be contractual conditions of BTOP
grants. (it is important that the interconnections be made available at fair and reasonable rates for providers who want to provide service in rural areas and need access to interconnects)
Here are additional critical things that should be looked at:
1. Please make immediate loan guarantees available immediately. We can turn 7.2 Billion into 72 Billion in buying power.
2. Shortening approval process to 60 days for RUS and NTIA.
3. Northern States should receive funding first because of winter elements that preclude us from developing networks after the first part of November.
4. Allowing municipalities to meet the 20% equity requirements with debt on par with the RUS/NTIA
5. Open Access which requires competitive pricing creates better networks for consumers and competitive pricing.

I urge you to consider the above ideas. I believe it is critical that we upgrade the rural communication infrastructure because rural America always is the last to get the quality communication infrastructure because companies cannot justify the “ROI” Please consider fiber as the technology that best serves our rural areas for the next 30-50 years. Please spend the money wisely by choosing the best technology available.

Sincerely,
Christopher Swanson
719 3rd Ave
Two Harbors, MN 55616

(Late Submission)
Comment Attached

(Late Submission)
See Attachment

(Late Submission)
The City of Miami submits the following comments in response to the RFI
regarding ARRA BTOP, Docket #090309298-9299-01.



Peter Korinis

Chief Information Officer

City of Miami, Florida






(Late Submission)
Please find attached comments of Governor Jon S. Corzine, State of New Jersey.

(Late Submission)
On behalf of the Commonwealth of Kentucky, and Governor Steve Beshear,
the Finance Administration Cabinet and Commonwealth Office of Technology
submit the attached comments in response to a federal request for
information on the American Recovery and Reinvestment Act's Broadband
Technology Opportunities Program (BTOP), which was issued jointly by the
National Telecommunications and Information Administration (NTIA) and
the USDA's Rural Utilities Service (RUS).



Enclosures.




(Late Submission)
The Honorable Anna Gomez
Deputy Assistant Secretary
Herbert C. Hoover Building (HCHB)
U.S. Department of Commerce / NTIA
1401 Constitution Avenue, N.W.
Washington, D.C. 20230

Dear Secretary Gomez:

For three decades, the U.S.-Mexico Chamber of Commerce has helped minority-owned businesses bridge differences in legal, regulatory and economic systems, as well as promote competitive environments for economic growth. For this reason, the U.S.-Mexico Chamber of Commerce urges the National Telecommunications and Information Administration (NTIA) to quickly, efficiently, and transparently disperse the over $7 billion in funding from the stimulus bill to the states to begin the process of mapping and deployment to communities in need.

To expedite the flow of funds, the NTIA should award grants to states or regional public-private partnerships with experience in implementation. While financial support and leadership from the federal government is important, state and local governments have the best understanding their cities and towns. They are in the best position to create effective public-private partnerships to meet specific needs and to identify the experienced private sector providers in network construction and management. Additionally, state and local government can support mapping data that will help classify those communities that are unserved and underserved. These are areas that the NTIA must prioritize to bridge this digital divide for many families and small businesses.

Throughout the process, the NTIA must require transparency in deployment and accountability of all parties involved. For instance, coverage maps for each state should be made available online to the public and update as more information becomes available. Additionally, any state proposal should include detail time frames, funding updates, and expenditure reports. However, NTIA must be careful not to include regulatory provisions that dissuade growth and investment. The focus must stay on broadband deployment to businesses and communities instead of ill-considered Internet regulatory policies that would delay deployment and the accompanying stimulative effect that Congress intended.




While many members of the U.S.-Mexico Chamber of Commerce benefit from broadband Internet access, other members in rural or underserved areas often lack access to high-speed broadband internet. As a result, these businessmen and women lose out on the opportunities that broadband Internet provides. Access to broadband should not depend on where a business is located. All businesses, particularly our members working with international customers, clients and vendors, must be connected with high speed Internet to compete in the global marketplace.

Former Federal Communications Commission Chairman Reed Hundt recently remarked that the key to expanding investment in these difficult economic times is to make it “irresistible for private companies to invest in infrastructure.” The U.S.-Mexico Chamber of Commerce could not agree more. As minority business owners employing many Americans across the country, we know that improving broadband access will not only create jobs to stimulate the economy, but it will also provide millions of Americans with the tools to improve the quality of jobs in our economy.

On behalf of the U.S.-Mexico Chamber of Commerce we ask that you use the broadband stimulus money to help spur private sector investment in broadband infrastructure, the critical component to ensuring our members and their businesses thrive in the 21st century and achieve their objectives in the global economy.



Sincerely,


Albert Zapanta
President & CEO

(Late Submission)
Attached comments regarding access to broadband for people with disabilities from NCAM, Inclusive Technologies.

(Late Submission)
Signed.Letter.#163.Sen.Brownback.04-14-2009_BB.pdf




(Late Submission)

Attached for filing this 13th day of April 2009, is The National Telecommunications Cooperative Association's comments in response to the Joint Request for Information and Notice of Public Meetings by the National Telecommunications and Information Administration and the Rural Utilities Service, Docket RUS Docket No. 090309298-9299-0, 74 Fed. Reg. 10716, March 12, 2009

Thank you.

Rita H. Bolden
Administrative Coordinator/Paralegal, L&I
National Telecommunications Cooperative Association
The Voice of Rural Communications
703-351-2023 (direct) 703-351-2027 (fax) rbolden@ntca.org




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(Late Submission)
This is the second set of remarks from FirstMile.US and focuses on job creation enabled by broadband.

(Late Submission)
Please see comment attached.

(Late Submission)
NTIA/RUS:
Please see attached the "Comments of Open Range Communications Inc"
filed in response to the NTIA/RUS Request for Information in Docket
No.090309298-9299-01. Should you have any questions please contact me at
the address below.

Joe D. Edge, Esquire
Drinker Biddle & Reath LLP
1500 K Street, N.W., Suite 1100
Washington, DC 20009
Phone: 202-842-8800
Direct: 202-842-8809
Fax: 202-842-8465
Email: joe.edge@dbr.com

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(Late Submission)
please see attachment

(Late Submission)
Pulse Broadband, www.pulsebroadband.net, a Missouri company headquartered in St. Louis, with offices in Texas and New Mexico appreciates the opportunity to offer the attached comments to the NTIA. Pulse constructs and operates next generation fiber-to-the-home (FTTH) technology. Our FTTH technology is a full last mile fiber solution. Our patented architecture is significantly less expensive to build and maintain than other full fiber solutions, without sacrificing bandwidth scalability or reliability. This means that advanced services can be deployed profitably in rural settings. In addition to the FTTH technology solution, our turn-key management company partners with rural companies, cooperatives and municipalities serving rural customers to help them deploy and manage advanced telecommunications services and give members access to best-in-class broadband Internet, telephone and television services.

(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.

George Rice
Executive Director
APCO International

(Late Submission)
I would like to make two comments, the first responding to the topic of the definition of broadband, and the second to the topic of stimulating broadband investment once federal funding is exhausted.

The definition of broadband is essential if it is important to attract private sector funding and ensure that state-of-the-art infrastructure is financially sustainable. Mission critical users who would consider using rural areas for business continuity purposes are good examples of those who would use rurally based facilities as long as the broadband services they need meet their market-based requirements for being cost effective and resilient. I am working with a number of mission critical organizations who are considering placing mission critical communications and data in rural areas for that purpose. But, they need to have a definition of broadband that would include the best of all kinds of technologies including fiber and wireless that serve their applications. They would concur that a definition of broadband should include the phrase: "resilient diverse routes, diverse carriers and diverse technologies". This would make it possible for them to use the best technologies (whether fiber or wireless) that best meets their applications and circumstances, with competitive pricing since there would be multiple carriers without monopolistic strangleholds, and diverse routes so that the risk of downtime can be minimized.

The second issue revolves around the topic of ongoing funding once federal funds are exhausted. In this case, there is a strong tie between broadband resiliency and renewable energy development. In the case of mission critical users, many may hold off purchasing the use of renewable energy until prices come down for the technology or energy costs go up significantly. However, there are scenarios that mission critical facilities users must consider if they are to be compliant with a fire code for business continuity, the NFPA 1600. They are all-hazards scenarios that include situations where inexpensive foreign fuels and the electric grid may be unavailable. Two such scenarios are geomagnetic storms and the electromagnetic pulse (EMP) effect of high-altitude nuclear burst. If mission critical facilities users are to consider those scenarios where cheap energy is "off the table", then they could cost-justify renewable energy now-- as long as they protect the renewable energy systems from the same electromagnetic effects that will take down the electric grid in the first place.
Instant Access Networks, LLC and collaborating institutions are working with a number of mission critical facilities users across the country to provide EMP-protected renewable energy systems supporting EMP-protected modular data and communications centers. Many of these will be deployed in rurally based Business Continuity Tech Parks that will provide urban areas with the broadband connectivity to the rural areas that their business continuity plans demand. In turn, these Business Continuity Tech Parks will provide market based support for the long term maintenance and support of broadband in a number of underserved rural areas. At the same time, it supports the concept of a very resilient diverse route, diverse carrier and diverse technology system. This program can be explored further by contacting the Executive Director of Public Technology Institute (www.pti.org) or Charles (Chuck) Manto, the CEO of Instant Access Networks.

Charles Manto has been involved in economic development and broadband for nearly 30 years, leading research and publications concerning broadband, rural economic development and related technology and applications. He also served as a senior executive to a competitive local exchange carrier for operations. He holds 5 related patents and has others pending. Broadband deployment strategies and policy recommendations appear on the state of Maryland website, www.marylandtedco.org.

(Late Submission)
BTOP Fast-Track Partial Loan Guarantee Proposal

The Rural Fiber Alliance represents rural fiber deployers and their supporters who believe that all Americans deserve equal access to the global gold standard of broadband: full fiber networks. RFA members are pragmatic practitioners focused on creating self-sustaining networks that strive to maximize the impact of every dollar spent on deployment, be it public money or private.

The biggest obstacle to laying fiber to every last building in rural America today is NOT the economic viability of rural fiber or project sustainability.  It is the lack of sufficient private capital, a reality exasperated by the current credit crunch. In fact many RFA members have rural fiber projects that would already have been funded and deployingif it weren’t for the private capital markets seizing up in the fall of 2008.

To that end, the RFA has developed the following proposal to transform a reasonable portion of the BTOP budget at RUS and NTIA into fast-track partial loan guarantees that can both free up billions in private capital and do so in a matter of weeks.

Details of the program are attached to this comment as a Word doc.

(Late Submission)
Please see the attached report of the 2008 Aspen Institute Communications Policy Conference. At a follow up meeting, participants noted three additional significant points:
1. Not all grants will succeed. It is important to understand from the beginning that with bold initiatives there will be some failures.
2. Evaluation should be built into the projects from the beginning. At the least, applicants could be asked what plans and measures they intend to take with respect to evaluating the project on an ongoing basis.
3. Funds should be spent on helping people gain access to these grants in areas and with populations that are not expert in grant writing.

(Late Submission)
See attachment.

(Late Submission)


>>> "Christopher White" 4/8/2009 11:21:49 AM
>>>
This is a resend.


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thereof, may be privileged and confidential.



________________________________

From: Christopher White
Sent: Wednesday, April 08, 2009 11:18 AM
To: BTOP@ntia.doc.gov
Cc: Christopher White; mseifert@ntia.doc.gov;
bmcguire-river@ntia.doc.gov; ken.kuchno@usda.gov
Subject: New Jersey Division of Rate Counsel's comments on Request for
Information


Enclosed are comments for filing in Docket No.090309298-9299-01.


This e-mail, including any attachments, is intended solely for the
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(Late Submission)


Markham C. Erickson

Holch & Erickson LLP

400 N. Capitol Street NW

Suite 585

Washington DC 20001



The phone at my office's reception desk: +1 202.624.1460

The phone on my desk: +1 202.624.1462

My mobile phone: +1 202.744.4318

Skype name: m.c.erickson

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Email address:
merickson@holcherickson.com

Web address: www.holcherickson.com



This email communication and any attachments are intended only for the
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dissemination, or copying of this email communication or the information
contained in this email is strictly prohibited by the sender. If you have
received this transmission in error, please return the material received to
the sender and delete all copies from your computer.






(Late Submission)
Communities Connect Network (CCN) is a statewide coalition of public, non-profit and private organizations working to ensure technology opportunities for all.

We represent 200+ organizations in the State of Washington providing technology access and learning opportunities. According to a recent study by the University of Washington, these organizations (CTs) receive more than one million visits per year.
We bring expertise in broadband deployment and adoption, a clearinghouse for research and training, and education about best practices and the needs of digital inclusion programs. Communities Connect Network was instrumental in creating the Washington State Community Technology Opportunity Grant Program and facilitating the awarding of grants for digital inclusion programs. We developed and manage a multi-sector state Digital Inclusion Council. We encourage the NTIA to consider formation of a national digital inclusion council and support these state councils.
We know from experience and research that you can offer valuable online content and applications like medical information or job applications, but if residents can’t afford a broadband connecton, don’t have a working computer, know where to find the content, or how to use the web effectively, then ARRA won’t attain it’s goal of reaching the most vulnerable populations and these residents, small businesses and non-profits will not become sustainable purchasers of broadband services. Our comments here focus on how to use the ARRA funds to link and support increased demand for and adoption of broadband. For instance, low-income residents and seniors will understand how to use broadband after receiving training and could benefit from low-cost computer distribution programs. The disabled need adapted equipment and training to take advantage of broadband. Technology training and web marketing assistance help enable disadvantaged business sustainability and new entrepreneurs...and greater demand for broadband.

Summary of our recommendtions:
1. NTIA and RUS should strengthen support for broadband adoption programs that increased demand, going beyond the minimum amounts set in the ARRA for public access and adoption programs. Broadband adoption programs increase user take-rates and support broadband sustainability. This is especially important for rural and low-income communities.
2. The $450 million allocated to public computing and the “innovative adoption programs” should be considered the minimum available for these purposes.
3. There should be different definitions and criteria for underserved in adoption programs vs deployment programs. Definitions and proposals focused on speed alone do not address the adoption needs of vulnerable populations in urban and rural settings for broadband application awareness, skills training, end-user hardware and software, and technical support. Community Technology Centers (CTC’s) should be eligible and receive funding, in addition to colleges and public libraries, for public access, training and adoption funds,
4. Local and regional programs that regrant to deliver services should be eligible and are an effective way to ensure use of best practices, enable greater reach to underserved populations and to deliver locally responsive community-based initiatives.
5. NTIA and RUS should support capacity building networks which promote best practices and strategic coordination. In Washington State, CCN provides training, program evaluation and other services which would otherwise be unavailable and unaffordable for small to mid-sized CT programs.
6. Affordability in broadband must also be addressed- for residents, non-profit community service providers, and small businesses.

Answers to the questions are detailed in the attached documents.

(Late Submission)
Enclosed please find a comment letter from the Office of the Mayor, City of Los Angeles

-- Jim

Jim B. Clarke
Director of Federal Relations
Mayor Antonio R. Villaraigosa
City of Los Angeles
200 N. Spring Street, Room 303
Los Angeles, CA 90012
213-922-9743 / 213-978-0720 fax





(Late Submission)
See attached

(Late Submission)


________________________________

From: Jeff Campbell (jeffrcam)
Sent: Wednesday, April 15, 2009 3:55 PM
To: 'btop@nita.doc.gov'
Cc: 'Mark Seifert'
Subject: Notice of Ex Parte Discussion/Cisco Systems


On March 23, 2009, Jeffrey A. Campbell, Senior Director of Technology
and Trade Policy for Cisco Systems, Inc. spoke telephonically with Mark
Seifert, Senior Advisor to the Assistant Secretary, NTIA regarding the
applicability of the "Buy America" provisions of the American Recovery
and Reinvestment Act of 2009 to the Broadband Technology Opportunities
Program. Mr. Campbell indicated that Cisco did not believe that
broadband grants under BTOP constituted a "public work" which would
subject them to the "Buy America" requirement. Mr. Campbell also
indicated in the alternative that if the grants were determined to be
covered, then a public interest waiver of the "Buy America" requirements
should be granted for all electronics equipment used in broadband
networks.


Jeffrey A. Campbell
Senior Director, Technology and Trade Policy
Global Policy and Government Affairs

campbell@cisco.com
Phone :202-354-2920
Fax :202-354-2930


Cisco Systems, Inc.
1300 Pennsylvania Avenue, NW
Suite 250
Washington, DC 20004
United States
www.cisco.com









(Late Submission)
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 (see attached FCC 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...

Regards,

Brent K. Earley

Chairman - National Broadband Infrastructure Partnership

214-912-6882
www.nbip.org
admin@nbip.org

(Late Submission)



Michael Tracy-Ireland
Project Manager
NYSED Project Management Office
Rm. 301
89 Washington Avenue
Albany, NY 12234
518.474.6261
pmo@mail.nysed.gov
P Do you really need to print this e-mail?



(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 Communications 1 Network Inc.

Kristy Szabo
On Behalf of Communications 1 Network Inc.
605-995-1786




(Late Submission)
National Telecommunications & Information Administration
and Rural Utilities Service
Joint Request for Information
Docket No. 090309298-9299-01

COMMENTS OF THE RURAL MOBILE BROADBAND ALLIANCE
(RuMBA) USA

Background

The Broadband Technology Opportunities Program (BTOP), created by the 2009 Recovery and Reinvestment ACT, presents an opportunity for the Federal Government to help support the creation of our nation’s first Next Generation Mobile Network (NGMN) (4G) Grid. The Grid is a cost-effective, IP-based mobile broadband 4th generation/backward-compatible network architecture that can rapidly be deployed in unserved, underserved areas and rural communities. RuMBA believes that (4G) Internet-based network technology is more economical and ’green’ than wired networks, and does not require expensive upgrades.

The build-out of a mobile broadband communications network will lead to immediate job retention and growth, and act as a long term economic stimulus, as envisioned in the 2009 Recovery Act. It should also provide essential communications and emergency alerting services in rural communities.

COMMENTS
RuMBA considers the following key minimum standards to be essential in determining the way forward in broadband deployment in rural areas:

1. Ubiquitous: Our telephones and modems must seamlessly work everywhere: in rural, suburban and urban areas, so as to cover the additional 2 million square miles of broadband coverage needed.

2. All areas of continental US must have availability of E-911, with location service, and an emergency cell broadcast system with weather and disaster alerting (SMS). Katrina-like outages are unacceptable.

3. Whether in the car, on the tractor, at home, in school or at work, and all areas in between, our nation relies on mobility; our networks must reflect our lifestyle needs.

4. Affordable: Rural Americans need competitive pricing for services and devices. Rural residents need the same access to services and devices as the rest of the country, at a fair price.

5. An investment must be made in next generation systems that can be operated at a profit and maintained by our local small town carriers. In expanding broadband connectivity, let’s look at the best, fastest, more dependable and affordable technologies, not yesterday’s.


PUBLIC SAFETY
With regards to point (2) above, Title VI states that grants should be issued to projects that “construct and deploy broadband facilities that improve public safety broadband communications services”. RuMBA considers it imperative that any mobile platform selected should support single-site, Phase II, E911 emergency cell broadcast, cell site priority calling and other critical public safety features. Providers should demonstrate their ability to provide and carry over their networks, emergency alert services (EAS) such as: severe weather watches and warnings, tornadoes, hurricanes, fires, earthquakes, Amber Alerts, and other natural and manmade emergency information relevant to people living in rural areas.

RuMBA believes that a healthy competition among providers will ensue only if Mobile broadband be given primary consideration for BTOP funding. Although fixed wireless broadband has been paramount to the expansion of high-speed Internet, the US experience, over the last twenty years, with personal communications services has proven that end users desire to take their communications services with them. Mobile service is now the primary means for voice communications, and broadband services will follow the same path:

- According to Informa Research, 75% of wireless users will subscribe to mobile broadband services by 2013
- Mobile broadband is growing three times faster than fixed broadband – according to studies done by Pyramid Research.

NTIA QUESTIONS:

Broadband:
The FCC defines “Basic Broadband” as 768 kbps to 1.5 Mbps, and several tiers of service (called generations) above 1.5 Mbps. Other entities have defined broadband as 100kbps and above, or 256 kbps and above. RuMBA recommends a separate definition of broadband for wireless networks, and that 4G-ready Infrastructure be deployed in all rural areas, unserved and underserved areas, allowing for the gradual implementation of the fastest radio speed available. The IP-based infrastructure chosen should allow for interoperability of radio access, whether 2G, 3G or 4G, on technologies ranging from GSM, CDMA, UMTA, LTE and WiMax. That wireless connectivity should meet the definition of Broadband.

Peak-Use Connection Speed: (True Connection Speed measured during peak usage times) Providers should guarantee a minimum peak-use connection speed.

Unserved Area: When less than 20 per cent coverage of a geographical area is present, the area is unserved.

Underserved Area: Where 80 per cent of the geographical area is covered, by broadband providers, with remaining 20 per cent without coverage, the area is underserved.

Broadband Penetration: Broadband penetration can be measured as the ratio of broadband subscribers to Internet subscribers/users.

Broadband Availability: Broadband availability is the portion of the population of an area that may subscribe to a broadband connection at prices comparable to those available in non-rural areas.

Selection Criteria for Grants
1. A primary consideration should be the applicant’s ability to provide broadband access to the greatest number of users possible, at the lowest possible cost, particularly, in rural, unserved and underserved areas.
2. The type of technology to be deployed. Although neutrality should be the rule, differences in technologies should be considered, when a particular technology can deliver a better broadband experience, to the greatest number of users, at the lowest possible cost, per customer and area covered.
3. The long-term sustainability of the deployed network should be a consideration. It should not require continuous government funding.
4. Solutions presented by providers with a proven track record of broadband deployment, should be prioritized.
5. Within mobile broadband technologies, there exists situations specific to rural areas, where legacy system architectures, which work well for schools and hospitals, have held back the delivery of services in many areas. Fortunately, there are wireless providers that offer cost-effective solutions that are non-municipal based, and that are available in wider areas, while offering more simple billing functions.
6. Speed is important, but as stated above, should take the back seat to deployment of robust mobile (4G) options that can be upgraded as new technologies emerge.
7. A competitive environment should prevail, allowing for lower prices to emerge as a result of competition.
8. Projects that are ‘shovel ready’ and deployable in the shortest possible time, need be given special attention

Selection Criteria for Grants Issued under the Special Allocation for “Innovative Programs to Encourage Sustainable Adoption of Broadband Services”
1. Solutions that can significantly reduce providers operating cost in rural markets should be given selection priority.
2. Customer take-up rates and operating profitability are measures that can be used to determine whether a program has succeeded.

NTIA should determine that it is in the public interest for private sector entities, including equipment and network vendors, to be eligible for grant awards.
1. Eligibility for funding should be open to all entities, including private sector providers and equipment makers, as long as the proposal meets the litmus test of public interest. Most network build-out work is performed by network and equipment vendors, thus, the need to include such entities in the application and selection process. A likely scenario will be service providers and equipment makers filing joint applications.

RUS Questions

BROADBAND SPEED CONSIDERATION, as long as the currently available minimum speed established by the FCC is available, the following should be prioritized:
1. The availability of services from multiple providers, in a competitive environment, is more conducive to end user satisfaction, as there will be a choice of services that best fit each person’s technical requirements and ability or desire to pay.
2. RUS should prioritize broadband projects that will benefit the most residents in rural and underserved areas.
3. End users should have a choice of Internet service providers
4. RUS should prioritize applicants that have the funds to commence and complete projects
5. RUS should evaluate, from existing grants’ recipients, effectiveness of the provider in expanding broadband coverage, and level of satisfaction of existing customers.


Conclusion
RuMBA USA recommends that the federal government select applicants for funding from a variety of perspectives, that:
- Providers are able to deploy broadband in the largest possible unserved and underserved geographical area, cost-effectively, and within the time frame established.
- Applicants have a proven track record of successfully deploying networks, beginning with an established customer-base, however small.
- That mobile broadband – 4th Generation IP-based - be evaluated as an optimal solution for rural areas, thereby enabling viable and sustainable businesses in remote areas where such economic activity was not previously possible.

(Late Submission)
ZeroDivide is a 501(c)(3) public foundation that has invested more than
$45 million over the past 10 years in innovative programs that encourage
sustainable adoption of broadband services in unserved and underserved
communities. ZeroDivide provides financial support, capacity building
and technical assistance to nonprofit organizations that benefit
low-income, minority, immigrant, non-English speaking, LGBT, aged and
disability communities.



The following comments are in response to the American Recovery and
Reinvestment Act of 2009 Broadband Initiatives, Joint request for
information and notice of public meetings (Docket No.
090309298-9299-01):



NTIA should award grants to intermediaries with experience in
identifying, funding and supporting innovative technology programs that
increase sustainable adoption of broadband service in unserved and
underserved areas.



For-profit entities should be incentivized to partner with non-profit
entities that are also applying for BTOP funding.



Proposals which leverage other Recovery Act projects should be
encouraged, but such leverage should not be a requirement to receive
funding.



Applicants should be encouraged, but not required, to address more than
one purpose of the BTOP grant program.



States should not have an advisory role in the allocation of grant funds
if they themselves are applicants.



Funding should be diversified across multiple organizations within a
state and not sole-sourced to one entity within a state.



Organizations that can immediately provide 20% matching cash toward a
project should be given greater weighting than those organizations with
a contingency to raise matching funds from external sources.



The broadband mapping effort should include the mapping and tracking of
broadband adoption, in addition to broadband availability.



NTIA should consider the following factors in establishing selection
criteria for grant awards to stimulate the demand for broadband:



1. A proven track record (5 or more years) in stimulating demand for
broadband availability, adoption, and accessibility in unserved and
underserved communities.



2. Strong indigenous support within/by members of the targeted
communities in specific geographic areas, evidenced by needs/demand
assessment or survey data.



3. Proven cost-effective approaches, which leverage both public and
private sector resources.



4. All Computer Centers and NTIA-funded programs should be accessible
to individuals with disabilities.



5. Experience in creating a reasonable level of sustainable economic
impact/revenue generation (i.e. social enterprise), which will support
sustained broadband usage and ongoing adoption within economically
challenged communities.



6. Demonstration/proposal of replicable models of change which can be
propagated across multiple geographic/cultural/ethnic/socio-economic
vulnerable communities.



7. Potential for projects to scale. NTIA should direct funding
toward projects that can be scaled or replicated immediately as well as
toward targeted, innovative models that can be scaled in the future.



8. Development of relevant, culturally and linguistically competent
content for underserved consumers and broadband applications by
community-oriented entrepreneurs.



These recommendations are based upon our lessons learned over the past
decade and focus largely on the purposes of the Act to support broadband
adoption, demand, training, education and job creation in unserved and
underserved communities.



I have also attached ZeroDivide's full comments in Word format and
submitted these comments online via
http://www.ntia.doc.gov/broadbandgrants/form.cfm.



ZeroDivide looks forward to being an applicant for funding under the
BTOP program. Through our experience, we have learned that information
and communications technology is a powerful tool to increase economic
opportunities, create jobs, improve educational achievement, enhance
health and well-being, and increase civic engagement in communities.



Thank you,


John Hoffman
Director, Business Development
ZeroDivide
415.773.0388 x314
425 Bush Street, Suite 300
San Francisco, CA 94108
zerodivide.org




(Late Submission)
Please see attached for comments and proposal. Our project plan is complete with financials and shovel ready upon approval.

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

Contact phone : 203 979 2700
or email :
contactus@alphastar.com

(Late Submission)
Please let me know if you have any questions. Thank you!!

(Late Submission)
Please find attached our submission regarding implementation of the RUS
Broadband program under the ARRA.

Sincerely,

Loredo Sola, Chairman
East Central Vermont Community Fiber



(Late Submission)
Dear NTIA Representative:



Kindly add myself and our company to the Broadband Initiative Correspondence
List. We are excited and anxious to get involved in continuing this
critical architecture process!



Please advise. Many thanks!



Best Regards,





Derek E. Brooks

President & Chief of Operations

INSIDE CABLE, INC.

85 Rangeway Road, Floor #1

Billerica, MA 01862

(781) 367-9881 - Direct

dbrooks@inside-cable.net

http://www.inside-cable.net





Full Service Telecom/Datacom Network Infrastructure SOLUTIONS



*Please Note New ICI Address, & Contact Information!






(Late Submission)
See attached

(Late Submission)
Attached are the comments of Montana Independent Telecommunications Systems
(MITS) in the above noted docket, Request for Information on the ARRA 2009
Broadband Initiatives.



Please let me know if there are any questions at all. Thank you.







Bonnie Lorang

MITS - Montana Independent Telecom Systems

blorang@mitstel.com 406-594-9662 or 406-443-1940



MITS members, providing quality telecommunications service to rural
Montanans for over fifty years, include Nemont Telephone Cooperative, Inc.,
Project Telephone Co., Triangle Telephone Cooperative, Inc., Central Montana
Communications, Inc., Northern Telephone Cooperative, Inc., InterBel
Telephone Cooperative, Inc., and Mid-Rivers Communications.






(Late Submission)
Please find attached comments of the City of New York regarding the
American Recovery and Reinvestment Act of 2009 Broadband Initiatives,
Docket No. 090309298-9299-01.







Kate Hohman

Project Manager

Department of Information Technology and Telecommunications

75 Park Place, 9th Floor

New York, NY 10007

Phone: (212) 513-6484

Fax: (212) 788-6528






(Late Submission)
For each proposal, Service Level Agreement definitions should be included
that form the contract with the user and may be tiered by performance and
pricing with a basic SLA that is affordable for the market and supports
collaboration, interaction and multimedia applications, with the proposals
specifically outlining how the proposed implementation supports VoIP, video
streaming, and video interaction/collaboration.



These SLA should define the bandwidth in mbps for the uplink and downlink,
the latency and ability to support low-latency applications, and a measure
of Quality of Experience and a means for the subscriber to assess the QoE
and provide feedback to the provider.



All connections should be Internet Protocol compliant and support IPV6. As
part of the reporting mechanism, compliance to these SLA's and reporting of
the metrics for QoE should be included and assessed as part of the
fulfillment of the accepted proposal.





cid:image001.jpg@01C986E5.56034F20

Rob Franzo

Principal Consultant

+1.616.604.1229

rob@wireless2020.net

www.wireless2020.net






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