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Joint Broadband Technology Opportunities Program Request for Information

March 12, 2009
Docket Number: 

American Recovery and Reinvestment
Act of 2009 Broadband Initiatives


(Late Submission)
It is important that all citizens have equal access to technology and the benefits it can bring to citizens and communities. It is vital technology access is provided to low-income and at-risk population, espcially to at-risk school students and their familites. We must work to bridge the "technology gap" for these students.

(Late Submission)
The attached describes a March 20, 2009 meeting with OPAD staff and
Space Data plus Counsel.

(Late Submission)
See attached

(Late Submission)
Please find in the attached PDF file the comment from ASSIA Inc. 303 Twin Dolphin Drive, Suite 203 Redwood City CA 94065-1417

(Late Submission)

(Late Submission)
Please accept the comments of JAB Wireless, Inc. regarding the Notice on
the American Recovery and Reinvestment Act of 2009 Broadband

Thank you.

Jeff Kohler

JAB Wireless, Inc.

400 Inverness Parkway, Suite 330

Englewood, Colorado 80112

Ph. 303-945-7599

(Late Submission)
The State of Colorado (“Colorado”) supports the comments previously filed by NASCIO, NGA, and NARUC. These comments compellingly argue that substantial state involvement in the NTIA’s Broadband Technology Opportunities Program (“BTOP”) and RUS’s Distance Learning, Telemedicine, and Broadband Program will help these agencies effectively accomplish their goals under the American Recovery and Reinvestment Act (“ARRA”) in every state. In particular, Colorado strongly urges NTIA and RUS to allow states to have a significant role in determining where grants are directed within their regions. Relative to the respective federal agencies, most states are better positioned to understand the needs of their citizens, factors affecting broadband deployment, and the partnerships and projects that will produce the greatest results as well as evaluate whether those projects are implemented successfully. In short, the states can share the workload with NTIA and RUS by assisting in the selection—and oversight—of the grants awarded to the most deserving recipients.

Colorado believes that NTIA and RUS should allow the states to score grant applications that are generated from within their regions. The scoring criteria should be objective, publically available, and developed in consultation with relevant stakeholders. Colorado believes that this process will best enable states to communicate their priorities to NTIA and RUS. If NTIA and RUS are guided by Colorado's scoring in selecting projects within Colorado for funding, the goals of the ARRA are most likely to be accomplished. Ideally, the NTIA and RUS would not only encourage the use of such a scoring system, but would empower states engaging in this process (as Colorado intends to do) by refusing to consider applications that did not go through this process.

Further, under the BTOP, states can apply directly for grants for activities that will increase broadband access in underserved and unserved areas and for community resource centers and adoption programs. One such way the State of Colorado intends to participate in the BTOP is to apply for a block grant, which will be sub-granted to private entities for broadband projects in Colorado. Colorado believes NTIA should recognize that such a block grant program will be an effective way to ensure value-laden projects and successful outcomes. Additionally, this type of funding structure would enable Colorado to assist NTIA in the necessary follow-up to make sure that the grant recipients are held to high standards of accountability. Finally, to facilitate such applications, the NTIA should make clear that the 20 percent funding match required under the BTOP would be waived for the State under this type of “block grant” arrangement on the understanding that it would apply to the subsequent sub-grantees awarded the funding.

Finally, in formulating a national mapping and data collection strategy, NTIA should take into consideration that some states, such as Colorado, have already begun mapping projects using non-ARRA and/or Broadband Data Improvement Act funds. In addition to being guided by the experiences of Colorado and other states, NTIA should clarify that matching fund requirements can be satisfied by money that has recently been spent on such projects. The NTIA should also be cautioned not to condition any grants on data collection or reporting requirements that would require a change in state law. Such requirements would be likely to limit the chances that a national mapping initiative would be successful and could hamper existing state projects. Further, NTIA and RUS should encourage the FCC to make the Form 477 census tract broadband data available to the states to enhance and expedite their individual mapping activities and to ensure a minimum level of broadband mapping granularity.

The State of Colorado looks forward to partnering with NTIA, RUS, and the FCC in ensuring that our nation has a successful broadband strategy. Please contact John Conley (303-764-7707; or Dara Hessee (303-764-7709; with any comments or questions.

(Late Submission)
Please accept the attached filing from Bresnan Communications, LLC;
Cequel Communications, LLC dba Suddenlink Communications; Mediacom
Communications Corporation; and Midcontinent Communications.

Should you have any questions, please feel free to reach me at the
contact info below.

Rob Schill

Director of Federal Affairs, e-Copernicus

(Executive Director, VTIC)

317 Massachusetts Ave., NE, Suite 200

Washington, D.C. 20002

Direct: 202-292-4604

(Late Submission)

NTIA Help Desk
Department of Commerce
National Telecommunications and Information Administration
Office of Spectrum Management
Herbert C. Hoover Building (HCHB)
U.S. Department of Commerce / NTIA, Room 4625
1401 Constitution Avenue, N.W.
Washington, D.C. 20230
Office: 202-482-4631

>>> Peter Swire 4/10/2009 11:21 AM >>>

Hello: I just tried filing comments for [Docket No. 090309298*9299*01]. I'm not sure if the attachment made it properly -- the confirmation statement did not include the attachment. Here is the attachment, on this email, so I hope you can consider this to fit with the confirmation. I will be away from my computer today after this. My phone is 240.994.4142 if any problems/questions. Thank you, Peter Swire ----------------- Prof. Peter P. SwireC. William O'Neill Professor of LawMoritz College of Law of the Ohio State UniversitySenior Fellow, Center for American Progress(240) 994.4142,>


(Late Submission)
This submittal is the official testimony of ViTAL Economy to the American Recovery and Reinvestment Act. This submittal is an update and replaces previous communications. Please see the attached PDF submittal testimony.

(Late Submission)
see attached

(Late Submission)

My name is George Rogers III, I am a member of the Rosebud Sioux Tribe and
CEO to Bestin Broadband Inc, Consultant and General Contractor to the
Aberdeen Area Tribal Chairmen's Health Board.

Here is my abbreviated input to the panel as our information is designed to
garner further input from your offices.

Please review our progress thus far and understand our intent to become a
viable resource for your offices in the very near future in regard to Indian
Country Technology.

This information has been shared and discussed with the FCC Tribal Liaison
office and is understood to be potentially viable. It will be submitted to
the FCC as an item adress ITEM #4 in the current FCC RFI...

It is shared with you here as an example our our capabilities as a combined
force currently in place within Indian Country. However, we feel the actual
responsible agency is the DOI, thus it is addressed to the DOI Scty. as a
way to start the ball moving....

All supporting documentation was developed from October 08 Forward with
Direct intention of intersecting with the process now currently underplace.
The information has been reviewed by our team as also being viable and
potentially economically cost savings an issue we by necessity are forced to
consider, which results in a more sustainable model for the country in
regards to Telehealth Coverage.

We are looking forward to further discussions.

Kindest Regards,
George Rogers III

(Late Submission)
Please see attached.

(Late Submission)
Most suppliers to US broadband operators produce most or all of their
equipment in Asia. Please provide a strong, credible application of the
stimulus bill's Buy American provision. Otherwise Billions of our dollars
could go to vendors manufacturing in Asia. There are still some vendors
keeping manufacturing here and those should be given preference.

Randy Stone, President

Frontier Computer Corp.

4025 Bronze Way

Dallas, TX 75237

800-527-6438, ext. 102

Direct# 214-330-3302
Fax# 214-331-5489

(Late Submission)

Story 1. Costa Rica's battle for popularity – A delicate balance
Story 2. U.S. chamber backs ending Cuban trade embargo
Story 3. 100,000 monthly to use new Heredia rail line

Story 1.
Costa Rica's battle for popularity – A delicate balance

They used to call Alajuela, the second biggest town in Costa Rica's warm central valley, Villa Hermosa, or "pretty city".
Any Sunday morning in the main square will show you why.
It is laid out in the usual Spanish colonial style, the centre of a grid of streets where civic powers meet. But the cathedral, the town hall and the bank look down not on some barren plaza, but on a lively ornamental park.
Costa Rica is rich in plant and bird life, all nurtured by fertile volcanic soils, and the Parque Central de Alajuela is loud with squawking parrots and pigeons splashing in the rococo fountain, under palm trees which zoom like frozen fireworks into the blue sky.
And at 10am every Sunday, on the back echo of the cathedral clock, a conductor taps his baton on the music stand, and the municipal orchestra strikes up its first selection from the great canon of European and American brass band music.
But the opening piece that week was Rossini's overture to William Tell. This became the theme tune to The Lone Ranger, on TV but it is from an opera about a small country's patriotic resistance to foreign tyranny.
Continued below….

Would you prefer to view a PDF version? If so, follow the link below.

It was appropriate here because Alajuela is the home-town of Costa Rica's national hero, Juan Santamaria, who died 150 years ago.

There is a museum dedicated to him, just a block away from the Parque Central. I asked a school girl who Juan Santamaria was. "He's the drummer boy who expelled the filibusters [pirates]" she said instantly.
"He carried the torch that drove out the American invaders."
She was referring to a crucial incident in the thwarting of William Walker, a fanatical US adventurer who landed in Nicaragua with an army of mercenaries in 1855, declared himself president and set about conquering all Central America with a view to instituting slavery and building a ship canal.
Among the improvised civilian militias who opposed him was Juan Santamaria, a poor lad who looked after his widowed mother.
Walker's mercenaries were holed up in a town called Rivas in a building with a thatched roof, and the only way to get them out was to set it on fire.
Two other men were shot down before Juan Santamaria managed to set the roof ablaze. He died the next day, of a combination of wounds and fever but the smoked-out Walker ended up before a firing-squad in Trujillo, Honduras in 1860.
Tourism riches
A century and a half on, visitors to Costa Rica are likely to be holding the Lonely Planet travel guide and be looking for a good cup of coffee and an internet connection.
And they will probably find both and be welcomed.
Costa Rica's number one earner is now tourism, overtaking coffee and bananas, melons and meat.
Time was when Costa Rica was famous for cutting down its forests for cattle ranches to make hamburgers for the US. But then people realised that Costa Rica had an ecological and biological diversity that was worth more alive than dead.
Visitors will pay to see the life of wet and dry tropical forest, rain forest, cloud forest. They want to surf in warm seas and ride horses and watch an active volcano from a Jacuzzi. Ornithologists and twitchers will pay a lot for what one guide, in his mangled English, described as "bird-squashing".
Thus over a quarter of the country is now protected in reserves and national parks, and they market the country under the slogan "Pure Life"
Economic 'upset'
It was the last country in the isthmus to sign CAFTA, the Central America Free Trade Agreement, which opens up all markets to the superpower in the north.
The chill wind of economic liberalism may upset some cosily corrupt arrangements, especially among the trade unions, but President Oscar Arias argues that his small trading country had to sign or be passed over by Washington in favor of other Central American signatory countries, and to stay competitive with these countries.
In turn, Cuba, Venezuela and Bolivia formed a People's Union to share food and doctors and energy. Hugo Chavez, the ex-military populist who runs oil-rich Venezuela was invited to Oscar Arias's inauguration but did not make it.
Costa Rica would love to get a deal on cheaper petrol, however, and recently signed a deal with China to build a new 300 million US dollar refinery with a view to keeping up with growing demand for petro fuels and keeping prices as low as possible for consumers in the future.
Chavez has since made nice with Arias and crude is flowing north from Venezuela to Costa Rica for refining.
Arias's first cabinet, which included five women, was said to have more PhDs in it than any governing body in the Americas. They are smart enough to keep lines open to both north and south.
Like Alajuela's fine musicians they can play rancheras and sambas as well as the theme tune of "The Lone Ranger".

Story 2.
U.S. chamber backs ending Cuban trade embargo
The head of the U.S. Chamber of Commerce says lifting the near five-decade long U.S. embargo on Cuba will bring significant economic opportunities to American and Cuban workers alike. He made the case Tuesday at a news conference in the U.S. Congress.

The man, Thomas Donahue, said his group is supporting the efforts of some U.S. lawmakers to end the trade embargo on Cuba. He said engaging with Cuba will help the Communist nation move toward a more democratic society.

"I would say that if you want to open up Cuba to the things that we value, then send a whole lot of Americans down there to talk about what life is really like, to talk about economic opportunity, to go down there and take along with them opportunities to trade and invest and develop," said Donahue.

The U.S. imposed an economic embargo on Cuba in the early 1960s when it moved toward communism and aligned with Russia during the Cold War.

U.S. President Barack Obama eased restrictions on travel and money transfers to Cuba by Cuban Americans last month in a gesture to its Communist rulers. But, he left the embargo in place and urged them to take the next step, by increasing political freedom.

Donahue says lifting the embargo
will give U.S. businesses significant opportunities to sell agricultural and manufactured goods to Cuba and to develop offshore oil fields. He says those opportunities are seized instead by other countries.

Rep. Jeff Flake, a Republican, said
at the news conferencehe supports opening up to Cuba even though he is not sure how its government would react.

"I think the experience has been around the world that economic freedom and reform typically precedes political freedom and reform. It does not always happen, but it is more likely than not," said Flake. "But in this case we should do it because it is in our interest and every American should be able to travel wherever they want unless there is a compelling national
security reason and there is not one

Charles Rangel, House Ways and Means Committee chairman, is leading efforts in Congress to end the embargo on Cuba. The New York Democrat said the embargo gives Cuba's rulers a scapegoat for their mistakes and lifting it will boost the U.S. standing on the world stage.

But Cuban American representatives in Congress strongly oppose any relaxing of restrictions on relations with Cuba. They say increased revenue from tourism and trade only would strengthen the government of President Raúl Castro.

Roger Noriega is a visiting fellow at the American Enterprise Institute in Washington and a former State Department official in the George W. Bush administration. He says Americans who call for unilateral concessions to Cuba are lobbying on
" What these people are doing when they go down and make their deals is aid and abet a regime that is keeping 11 million Cuban people in bondage," he said. "Why would any American businessmen want to keep in power a regime that has destroyed the Cuban economy."

Noriega says maintaining sanctions will give the U.S. leverage to press Cuba's rulers to release political prisoners and grant their citizens political rights.

Story 3.

100,000 monthly to use new Heredia rail line
Government officials are expecting about 94,000 persons a month to take a trip on the new San José-Heredia line. And they said there will be 42 trips a day on the 9.67-kilometer (6-mile) route.

Now that one of the last administrative steps has been taken, setting the fare, rail service is expected to begin during the last half of this month. Those who take the train will be able to avoid the continual traffic jam between La Uruca and Heredia Centro.

The one-way fare will be 350 colons, about 62 U.S. cents at the current rate of exchange. The Authoridad Reguladora de Servicios Públicos announced the fare Wednesday. The government rail company, Instituto Costarricense de Ferrocarriles, got just five colons less than it had requested.

The train will make two stops along the route, including one at Cinco Esquinas in Tibás.

The Authoridad was the agency that computed the likely number of riders. That would be about half capacity for the new rail cars.

The rail agency bought cars from the Spanish-owned Ferrocarriles Españoles de Vía Estrecha. The price regulating authority said that the fare structure will be published in the La Gaceta official newspaper around May 14. That will be the last administrative step.Transport officials originally planned to resume the service in December and then April. There were problems with the rail bed, and many of the wooden ties have been replaced with modern concrete ones.

The rail agency suffered some embarrassment when President Óscar Arias Sánchez took a rail trip to Heredia to celebrate that province's birthday. A car jumped the track during the trip.

The San José end sports a new terminal just north of Parque Nacional and just west of the former Estación al Atlántico on Avenida 1.

The government said it will seek a concessionaire to take over the line and convert it to electricity.

The track has several grade crossings, including two just west of Hospital Calderón Guardia. There are no signals or crossing gates, and the train blows its horn repeatedly as it approaches a crossing.

The 10-kilometer valley train from Pavas to San Pedro has been involved in accidents and there have been three deaths.

(Late Submission)
Comments of the three Commissioners are attached

(Late Submission)
Attached letter contains comments on behalf of the Navajo Nation.

(Late Submission)
see attached

(Late Submission)
Mahaska Communication Group respectfully submits the attached document as our comments to the NTIA and RUS.

(Late Submission)
Please see attached pdf. Thanks you.

(Late Submission)
Supplemental Comment to NTIA
On Behalf of DSSA Strategies
Don S. Samuelson, President

This is a supplemental comment to complement the earlier comments I made on specific questions set out by NTIA in the Federal Register, Vol. 74, No.47/Thursday, March 12, 2009/Notices. It is a comment on question #15, “other issues that NTIA should consider in creating BTOP within the confines of the statutory structure established by the Recovery Act.” I hope it can prompt additional commentary and discussion.

15 The purposes of the stimulus programs were to create jobs in the short run, and to provide structural investments that will have positive benefits on the U.S. economy in the long run. The degree to which these individual applications advance these two overarching objectives of the stimulus program needs to be incorporated into the evaluation of applications for support to both NTIA and RUS.

There needs to be a common denominator by which to review the various funding proposals to be reviewed by NTIA. They are going to involve various program purposes, technologies, size and geographical area of request. A standardized evaluation methodology needs to be developed – like the SAT and LSAT tests which were developed to provide a standard measurement that could be used to evaluated applicants from colleges and law schools, with very different competitive structures in high schools and colleges and grade definitions.

One element of a standardized evaluation system would be to consider would be to make determinations on the basis of dollars requested (with an appropriate adjustment for the actual net costs to the government) for loan guarantees, loans and grants. A second would be the nature, number of immediate and indirect jobs that will be created by the proposed project over various time horizons up to September, 2010 and for the two subsequent years. The third would be to describe the nature of the “positive externalities” that are intended to result from the funding of the application and a reasonable explanation to support those estimates of future benefits.

(Late Submission)
To Whom It May Concern:

My name is Andrew Ramsey and I am writing in response to the 15 questions
issued relative to the BTOP initiative. I work for Troy Cablevision, Inc.
located in Troy, AL. Troy Cablevision is currently seeking grant monies
pursuant to the Stimulus Package and the Broadband Technology Opportunities
Program. We feel like the stimulus package offers an opportunity to fund
broadband projects in rural areas that would otherwise not be financially
feasible. We currently supply fiber to the home technology in 3 counties of
Southeast Alabama. Fiber to the home is the most cost effective, high
quality, and efficient means of broadband deployment. It is our position
that these efforts will allow educational and economic growth potential for
rural children and residents of Southeast Alabama that would rival those
opportunities our urban counterparts currently enjoy. Construction into the
rural areas will immediately create additional jobs which will have an
ancillary effect of sustaining all the businesses that make up our
communities. Like the road and highway systems built in this country a
century ago; this new infrastructure will allow the farmers, and citizenry
of the Second Congressional District to take their products to market
nationally and internationally from the comforts of our homes.


Andrew Ramsey

Troy Cablevision, Inc.

1006 S. Brundidge Street

Troy, AL 36081

Office: 334.770.3359

Cell: 205.535.0398

(Late Submission)
See the document submitted below.

(Late Submission)

(Late Submission)
Our comments are in the attached PDF file.

(Late Submission)
Attached, please find comments prepared in response to the Federal
Register notice concerning the ARRA Broadband initiative.

Thank you for the opportunity.

Matt Fritz
Office of M. Jodi Rell
State of Connecticut

(Late Submission)
Attached are the comments from Cumberland Internet, Inc. regarding the
proposed Broadband Technology Opportunities Program.

Attached comments are in a Word format dcoument titled
rural-broadband.doc. We are also including a PDF format of the same
document, in case there are formatting issues. titled rural-broadband.pdf.

Thank you.

(Late Submission)
Attached please find the comments of Pend Oreille County Public Utility District #1

(Late Submission)

On behalf of Fibertech Networks, please accept the attach comments and
maps regarding the American Recovery and Reinvestment Act of 2009 -
Broadband Initiatives.

The purpose of these comments are to help educate and inform the
National Telecommunications and Information Administration, the U.S.
Department of Commerce, the Federal Communications Commission and the
Department of Agriculture, about Fibertech Networks, the fiber optic
network resources it has constructed, operates and has available for
lease, as well as our ability to efficiently extend fiber to where it is
needed as the agencies embark on their goal of deploying high-speed
Internet service in rural and underserved areas. It is our hope that
the funding will be utilized to leverage existing open-access fiber
networks such as ours and to help fund network deployment where no such
commercial infrastructure exists.

Fibertech is also offering its assistance in adding its network maps to
the NTIA's goal of establishing a comprehensive nationwide inventory map
of existing broadband service capability and availability in the U.S.,
and would be available to provide its maps in a desired electronic

We ask that you review our maps and include them into your discovery
process. We hope for an open process and the ability to compete for
funded projects where our open-access fiber network model may be of
assistance to the program. We also welcome the opportunity to answer
any additional questions and look forward to the opportunity to work
with the FCC, NTIA and the USDA and help us all realize the true benefit
of high-speed broadband that these rural and underserved areas need in
order to survive, prosper and compete.

We have mailed 5 bound copies of the attached information as well. We
look forward to supporting your initiatives where appropriate.

Thank you,

Michael C. Hurley

VP - Sales & Marketing

Fibertech Networks, LLC

300 Meridian Centre

Rochester, NY 14618


(Late Submission)
TelePulse Technologies is proud to respond to this RFI and hopefully add
value to the efforts to get needed services in a financially efficient and
future-proof capable manner to rural, un-served and underserved communities.
We believe we can best add value by commenting on areas 4 (Establishing
Selection Criteria for Grant Awards); 5 (Grant Mechanics); 7 (Grants for
Innovative Programs to Encourage Sustainable Adoption of Broadband Service)

Jess Posey
CEO & President
TelePulse Technologies Corporation
Tel: 1-856-264-3961

(Late Submission)
Dear Sirs & Madams:

Please accept these comments of the National Association of
Manufacturers regarding the NTIA Broadband Technologies Opportunity
Program. If you have any questions, please do not hesitate to contact
me at the phone numbers and email address below.



Marc-Anthony Signorino
Director, Technology Policy
Direct: (202) 637-3072
Cell: (202) 494-1290

National Association of Manufacturers
1331 Pennsylvania Avenue, NW Suite 600
Washington, DC 20004-1790

Check out our blog at

(Late Submission)
My name is Victoria Proffer, I am the CEO of St. Louis Broadband, LLC,

A bit about my background. I built the first dial-up network for our proposed fixed wireless coverage area, so I have been an ISP for sixteen years, I have been involved in fixed wireless for ten of those years and owned and operated St. Louis Broadband, a fixed wireless service provider in the metro St. Louis area for the last six years.

St. Louis Broadband provides services to business in the Westport area. We provide service to small business and are their technical partner, as well as large business where we back-up their wired services.

As a member of WISPA and a WISPA Legislative Committee I have worked answering the questions that NTIA has sent out. However, as a WISP I have been actively involved in developing a plan for my community.

St. Louis Broadband has been looking at a project that we have named ShowMe Broadband, We have been working on this project for the past two years. I have attached a coverage map of this area. There are several pockets, in the nine county area, of residential homes that range from 500 to 2500 population that are totally unserved. As well as there are the same pockets that are underserved with only one provider.

We talked to community leaders, colleges, hospitals, home owners association, as well as recently the state of Missouri regarding our project.

Because of envisioning this project two years ago in some locations we are currently “shovel ready” and ready to start construction today. However the State recently spoke of possible “rights of ways” for tower location in exchange for broadband services to State locations like prisons, court houses, etc. These areas still need to be examined for possible use.

One of St. Louis Broadband’s customers is the American Red Cross. We have been providing them service over the past five years, as well as technical support. One thing that we have been discussing during this time frame is our geological area and how dangerous it can be.

I feel that our project is one of the most important in the state of Missouri, if not in the nation. Our location is in the southeast portion of Missouri. This location has some interesting and challenging features due to the Precambrian geology. This area also hosts the New Madrid fault zone.

In some of the counties that we are proposing our fixed wireless solution, they are just now starting to install 911 services, I know of one county that there is no 911 service at all. Also another factor that makes this situation more vulnerable is because most of these counties, due to their rich ore where a part of a chain of mines, there are mazes of honeycombs that whole communities sit on.

“THE HIGHEST EARTHQUAKE RISK in the UNITED STATES outside the West Coast is along the New Madrid Fault. Damaging tremors are not as frequent as in California, but when they occur, the destruction covers over more than 20 times the area because of underlying geology.

A DAMAGING EARTHQUAKE in this AREA, 6.0 or greater, occur about every 80 years (the last one in 1895). The results would cause serious damage to schools and masonry buildings from Memphis to St Louis.”

As one can see from the above statement we are way past our deadline for this quake. Doubled in with the fact of communities sitting on top of this honeycomb of mines, it is a disaster waiting to happen. Add in the fact that these communities have little or no communications, it makes this another Katrina or worse in our midst.

St. Louis Broadband has designed a network with a triple fiber redundancy from different National Access Points, in the event that we could lose fiber connectivity, as well as we have added redundant satellite feeds. The tower network itself has a “self healing” distribution ring. We are limiting the use of guyed towers and opting for self-supporting towers for “earthquake prevention”.

Because of these towers being in great locations for wind in the fall/winter and solar in the spring/summer, rather than installing diesel powered generators for backup we have added solar and wind devices. We have also added a 4.9 GHz network for First Responders. We want all counties in our network to have access to this, we feel that this is very important.

We also feel it is important to include telemedicine programs, as well as distance learning. This network will be fully capable of supporting both.

What do we need from NTIA to provide this?
• Make emergency infrastructure a priority. While we understand the importance of bringing broadband to rural areas we feel that the loss of potential life is priority. These applications above all should receive first consideration.
• Keep it simple. While we recognize that certain information needs to be provided to disburse ARRA monies, don’t make the project unattainable because of complicated studies or too much government involvement.
• Let the States be involved. We realize that distributing the funds directly to the States is not what Congress intended. We also understand that this would add another layer of government that is not necessary. However we also realize that State involvement is crucial to understand the resources and support services that can be utilized. We feel that the States should support the applicable grants and be kept fully aware of the process, as well as the construction phases of each network.
• Flexibility. When designing a network of this magnitude, sometimes one runs into trouble. While it is easy to calculate the nuts and the bolts, building in the two year time frame may require slight changes of plans, such as easement issues, vendor issues, labor issues, etc. Let the States be involved in monthly project meetings where these changes could be discussed and approved. Let the States be the NTIA local authority.
• Complete Funding. When projects offer multiple goals of the ARRA Grant directives, allow complete funding of projects rather than the 20% commitment. My personal feeling is that we are going to see the “Pioneers of Broadband” involved in this project. These are the guys and gals that developed the fixed broadband solution. These are not the AT&T nor Verizon companies. These “Pioneers” have put up their homes to build their networks, risked everything to make this technology available for the masses. These companies compete daily with the ILECs who receive federal funding. These are the same ILECS that have “cherry picked” their networks and have put this country into the current situation it is in, with limited broadband access. We believe that companies that have received past federal funding should be exempt from this grant. These funds should also be available to draw upon immediately once a grant has been awarded. It is the guys that are operating the companies with less than $1 million in annual revenue that are going to build the American Broadband Backbone. These are the more “bang for the buck” guys, because they have had to be, nothing has been handed to them or easy for them, and I do speak from experience. These guys are true Americans that work hard for a living to bring the technology of fixed wireless to America.
• Give small and economically challenged businesses a break. We are a woman owned business, as well as Viet Nam veteran run and owned. To establish a SBA 8(a) certification it not only takes a great deal of time, but of money as well. Either use the self-certification set by the SBA for WOSB or streamline the SBA 8(a) certification process. These businesses should receive at least a 5% priority.

I hope the views of our company has helped and I hope to see the NTIA do what is right for America in this crucial time. Let our grandchildren know in the years to come that you made the right decision today.

Victoria Proffer
CEO – St. Louis Broadband

(Late Submission)
Dear Sir:

Over the past month we, at the Columbia Institute for Tele-Information at Columbia University, have been conducting research on the economic impact (particularly job creation) of the Broadband Technology Opportunities program. One of the outputs of this research is included in attachment.
As the paper indicates, while the estimates of jobs to be created as a result of investing $7.2 billion in broadband deployment are fairly robust, our calculated amounts are moderate (approximately 127,800 jobs over four years).
On the other hand, our research indicates that a bigger employment impact can be achieved as a result of the enablement effect of broadband on firm creation, innovation, new services and business growth. However, our research also indicates that there is a large degree uncertainty on the effectiveness of broadband deployment on the latter impact. In fact, it would appear that this effect could be greater if broadband deployment is combined with, for example, employment generation programs in the targeted geographies.
In this context, it would be necessary to introduce in the grant evaluation criteria an assessment of how will broadband deployment be combined with other economic development programs.
In addition, we believe the broadband program would provide the opportunity to launch further research on the actual economic effects of deploying broadband in underserved and unserved areas. The results of this research conducted while the program is being implemented would allow the creation of a set of tools aimed at further refining the process of grant allocation.
I would, therefore, suggest that, as part of the management of the program some funds are assigned for the implementation of an economic impact research effort.
Sincerely your,
Raul Katz
Adjunct Professor, Division of Finance and Economics (Columbia Business School)
Director, Business Strategy Research (Columbia Institute for Tele-Information)

(Late Submission)
See attached document that was submitted by email on April 13, 2009.

(Late Submission)
Please see attachments

(Late Submission)
Comments have been submitted via the attached pdf. file.

(Late Submission)
See attachment.

(Late Submission)
Please find attached comments from the Bill & Melinda Gates Foundation in response to the Department of Commerce’s request for comments on NTIA’s Broadband Technology Opportunities Program. Should you have any questions or require additional information regarding the content of this submission, please do not hesitate to contact me. Thank you for the opportunity to comment.

(Late Submission)
Please see attached

(Late Submission)
Letter Attached

(Late Submission)
Please see attached comments on Mapping.

(Late Submission)

Please accept the attached response, in HTML and MS Word formats, to the
NTIA and RUS joint RFI on broadband programs in the American
Reinvestment and Recovery Act of 2009 on behalf of the Rural
Telecommunications Congress.


-- Greg

Greg Laudeman

President, Rural Telecommunications Congress

Project Manager, Enterprise Innovation Institute
, Georgia Tech

5 S. Public Sq., Suite 104

Cartersville, GA 30120

Phone: 706-271-5521

Fax: 770-387-4001



(Late Submission)
Attached are comments submitted on behalf of the People of California and Governor Arnold Schwarzenegger.

(Late Submission)

To: Barbara Brown, NTIA/BTOP at (202) 482-4374 or

Mary Campanola, USDA/RUS at (202) 720-8822 or

Re: Public Input on NTIA/BTOP and USDA/RUS grant guidelines and
Emailed April 13th, 2009 to and

Online at
Formatted Word doc:

From: Frank Odasz, Lone Eagle Consulting
2200 Rebich Lane, Dillon, Montana 59725
PH: 406 683 6260, Cell: 406 925 2519

Barbara and Mary,

With great respect and all seriousness Lone Eagle Consulting submits the
attached document regarding recommendations for NTIA/BTOP and USDA/RUS
grant guidelines and accountability. The Executive Summary is below.

Red, White and Blue,

Frank Odasz
Lone Eagle Consulting
PH 406 683 6270

America’s Historic Challenge to Fund Mass Innovation
without the risks of political backlash due to lack of documented

Executive Summary:

The U.S. Government needs to enact an effective ongoing process immediately
for identifying the best broadband training innovations for national
replication and distribution. Consider creating an Office of Broadband Best
Practices for Sustainable Families focused on identification and
dissemination of best practices as they emerge – with rapid turn-around
using social media and video-storytelling of successful replicable strategies.

Presuming “any” training program can turn broadband access into jobs in the
short term is an example of the naiveté of the U.S. government having not
paid close enough attention to the impacts, or lack thereof, of ten years
of lessons learned from broadband deployment. Best practices are not at all
obvious to anyone. Ideal curriculums for community technology centers,
(CTCs) and/or citizen engagement methodologies for local community networks
to produce socio-economic capacity are still in their infancy. What gets
measured - gets done.

America’s ideal opportunity related to the Obama administration’s new
openness is to design these grants programs with incentives to create an
intelligent “self-learning community” where grantees are tasked with
effective visible collaborative sharing of innovations as they emerge.
Grantees should to be required to publically maintain web postings of their
measurable outcomes, replicable training strategies, essential content,
sharable curriculum, and success stories using new media. Peer evaluations
via social media have proven to be very effective. Consider that perhaps
the only way to manage assessments for the volume of projected projects is
through peer evaluations and social media as has been demonstrated on
Youtube and many other such sites.

NTIA/USDA can provide funding incentives as well as social recognition for
effective online peer mentoring, community service engagement levels, and
cross-project sharing of essential online resources. NTIA/USDA programs
must become a smart celebration of American innovation, such that the whole
world benefits.

This can only happen by intent and design.

Frank Odasz
Lone Eagle Consulting
Ph/Fax: 406 683 6270
Cell: 406 925 2519

"In times of change, learners inherit the earth" - Eric Fromm

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

Thank you.

Jami Kubacki ~ Operations Assistant ~ Agri-Valley Communications, Inc.
~ ~ 989-453-4420 (office) ~ 989-550-0810 (cell)

(Late Submission)
Broadband Stimulus Comments. Please see Attachment.

(Late Submission)
Please accept the attached comments from Commissioner Paul Bergman, Lake County, Minnesota

Wilma Rahn, Administrative Clerk of the Board
Lake County Board of Commissioners
601 Third Avenue
Two Harbors, MN 55616
(218) 834-8320 Fax: 218-834-8360

This e-mail message is intended only for the addressee(s) and contains information that may be confidential and/or legally protected. If you are not the intended recipient, please notify the sender by reply e-mail and immediately delete this e-mail. Use, disclosure or reproduction of this e-mail by anyone other than the intended recipient(s) is strictly prohibited. No representation is made that this e-mail or any attachments are free of viruses. Virus scanning is recommended and is the responsibility of the recipient.

(Late Submission)

>>> Cynthia Pols 4/13/2009 4:22:06 PM >>>
I submitted comments on behalf of the Triangle J (NC) Cable Broadband
Consortium on the BTOP program a few minutes ago. However, they have
appeared on the NTIA website. Is there something wrong with the
website? I
have attached a copy of the comments on question to make sure that they
included in the docket for this proceeding.

Thanks for your attention to this matter.

Cynthia M. Pols

(Late Submission)
Please add me to your correspondence list.


David L. Dyer

City Administrator

City of Galva

210 Front Street

Galva, IL 61434

Phone: (309) 932-2555

Fax: (309) 932-3306