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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)
We are submiting our coments in the form of two attachments.

(Late Submission)
Attached are the comments submitted by Ed Anderson Director, Network Services - Nevada System of Higher Education (NSHE) on behalf of NSHE, The Nevada Dept. of Transportation (NDOT), and teh Nevada Department of Information Technology (DoIT)

(Late Submission)
Attached, in both Word (.doc) and Adobe (.pdf) formats, are the comments of the MSS & ATC Coalition in response to the joint NTIA and RUS request for information.

(Late Submission)
April 8, 2009

Ms. Bernadette McGuire-Rivera
Associate Administrator
Office of Telecommunications
and Information Applications
National Telecommunications
and Information Administration
U.S. Department of Commerce
1401 Constitution Ave., N.W.
Washington, D.C. 20230

Mr. David P. Grahn
Associate General Counsel
U.S. Department of Agriculture
Rural Development
Room 2017
Mail Stop 1423
1400 Independence Avenue SW
Washington, DC 20250-3201

(Docket No. 090309298-9299-01)

Dear Ms. McGuire-Rivera and Mr. Grahn:

Global Crossing submits this letter to urge the National Telecommunications and Information Administration (“NTIA”) and the U.S. Department of Agriculture (“USDA”) to establish a process that matches parties interested in deploying middle-mile broadband facilities with parties interested in deploying last-mile broadband facilities so as to avoid purely speculative (and potentially wasteful) investments in broadband facilities and optimize the effectiveness of the Broadband Technology Opportunities Program (“BTOP”) administered by the NTIA and the rural broadband grants and loan program administered by the USDA.

In laying out the goals of the BTOP program, Mark G. Seifert, Senior Advisor to the Assistant Secretary of NTIA, stated:

“First, we want to create jobs.”

“Second, we want to begin to close the broadband gap in America. We, therefore, want to extend high-capacity pipes closer to users in rural, remote, and underserved communities. As Congress has instructed, other entities will be able to connect to those pipes, which will spur competition and get service to people and businesses.

The high-capacity pipes referred to by Mr. Seifert are commonly known as “middle-mile” facilities that connect rural carriers to the Internet. Typically, these middle-mile facilities are the sole connection available to the Internet and can span literally hundreds of miles. Not surprisingly, the cost of these facilities is exorbitant and inhibits the growth of broadband speed and capacity in the last mile. It is fair to say that until there is a likelihood that middle-mile links will be available, it is difficult or impossible to deploy last-mile facilities in unserved and underserved areas. This is especially true for those areas where middle-mile facilities comprise the majority of costs associated with broadband deployment.

Global Crossing is a Tier 1 Internet backbone operator with substantial investment in telecommunications networks here in the United States and around the world. As the only Tier 1 Internet backbone operator with end to end IPv6 implementations as well as an ability to run legacy IPv4 dual stack we are also well poised to provide enhanced security and functionality to all middle/last mile facilities and the end users served by them. By providing training, education and experience on the more advanced IPv6 platform we can also contribute directly to Administration goals of training the workforce on technologies of the future. We are eager to make investments in middle-mile facilities in support of last-mile broadband efforts. Indeed, Global Crossing is currently working with existing rural carriers to identify potential middle-mile routes that would be eligible to receive funds under the BTOP and rural broadband grant and loan programs. However, our efforts appear limited to providing improved access to broadband in underserved areas of the United States rather than providing broadband access to unserved areas.

In order to provide access to broadband service to consumers residing in unserved areas of the United States, Global Crossing would have to deploy middle-mile facilities on a purely speculative basis. This is because it is unknown at this time if any entity is willing to invest in last-mile broadband facilities in unserved areas. The conundrum – or “chicken and egg” problem – is that entities based in the unserved areas aren’t willing to deploy last mile broadband facilities because they do not know if anyone will make available reasonably priced middle-mile facilities. The problem for Global Crossing and companies like us is that identifying potential partners in unserved areas is by definition a logical impossibility because the areas are unserved. (In underserved areas there are broadband providers already serving consumers to some extent and thus easily identifiable.) But in unserved areas there are no existing broadband providers and it is impossible to know who is willing to make such synergistic or mutually dependent investments

Hopefully the application process will reveal entities willing to make such investments, but the viability of those applications would be greatly enhanced if they were matched with applications regarding middle-mile investments. For this reason, Global Crossing urges the NTIA and USDA to establish a process whereby last-mile providers and middle-mile providers can be paired up in support of a more complete effort to provide broadband service to unserved areas. This would greatly enhance the effectiveness of the BTOP and rural broadband programs and avoid having broadband stimulus monies going to purely speculative ventures that may not advance the goals of the BTOP program or the rural broadband grants and loans programs.

As the NTIA and USDA make available the list of applicants to the BTOP and rural broadband programs, Global Crossing recommends that the lists be categorized geographically and functionally. This will allow applicants, or prospective applicants, to more easily identify potential synergistic applications. Parties should then be able to request that their application be considered in conjunction with each other. In effect, NTIA and USDA would be creating an information exchange and facilitating the sort of deal-making that is so difficult to achieve at this point due to a lack of information about potential applicants and a lack of transparency into the business plans of potential applicants. NTIA and USDA would of course have to weigh the synergistic opportunities as part of their evaluation of the applications and even allow for a period during which applicants could revise their applications to acknowledge the synergistic opportunities with other applicants, something Mr. Seifert contemplated in his testimony.

Global Crossing believes that proceeding in this fashion will result in a more comprehensive, and less speculative, deployment initiative, reduce waste, and deliver more broadband capabilities to a greater number of consumers. For these reasons, Global Crossing urges the NTIA and USDA to consider this recommendation.


Paul Kouroupas
Vice President, Regulatory Affairs

(Late Submission)
I live in a seculded spot in a rural, mountainous area & I have no affordable options for broadband access. I could probably get broadband via satellite, but the cost would be around $90 per month, which is more than I can afford, especially in the current economic times. It is getting to the point that it's almost impossible to manage without high-speed internet access, but that's my situation. The really sad thing is that if I had high-speed access, I could do more tele-commuting, which would save on travel costs & also vehicle emissions. I am an Information Systems Manager for a school system in western NC. How crazy is that, to be a computer professional who has no broadband access at home? Please help me to get access. Please see attachment.

(Late Submission)
Comments of the City of Palo Alto, CA are attached

(Late Submission)
See attachment.

(Late Submission)
The attached describes an April 14, 2009, meeting with NTIA staff and
David Townsend & Mark Kennet.

(Late Submission)
Please find attached Comments on behalf of Media Access Project.



Parul P. Desai
Vice President
Media Access Project
1625 K Street, NW
Suite 1000
Washington, DC 20006
p. 202-454-5683
f. 202-466-7656

(Late Submission)

(Late Submission)
The statute says for RUS:

"No area of a project funded" may receive funding from TOPS

How will that allow coordinated projects?

Nicholas P. Miller
Miller & Van Eaton, P.L.L.C.
Suite 1000
1155 Connecticut Avenue. N.W.
Washington, D.C. 20036-4320
phone (202)785-0600
fax (202)785-1234

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telephone: (202) 785 0600.

(Late Submission)
Please find attached written response from Commonwealth of Pennsylvania, Governor's Office of Administration, related to joint RFI issuance from NTIA/RUS re [Docket No. 090309298-9299-01].


(Late Submission)
Attached are the comments and a proposed business model between a State Trust Land Management orginization and private industry to identify and build out significant broadband infastructure across Washington State.

(Late Submission)
Attached is a proposal and comment on the NTIA TOP Sustainable Broadband Adoption Grant Program. This is the result of two years of field research in driving broadband adoption and economic and community development through the utilization of the Internet in rural west Tennessee. We have attached the program synopsis and comments as a file.


Paul Van Hoesen
Director, cTechnology, Inc.

(Late Submission)
Please see attached file for comment.

(Late Submission)
Please find attached the Comments of the National EBS Association
(NESBA) in Docket No. 090309298-9299-01.

Respectfully submitted,

Todd D. Gray
Counsel for NESBA

Todd D. Gray
Attorney at Law

1200 New Hampshire Avenue, NW Suite 800
Washington, DC 20036-6802
T 202-776-2571

F 202-776-4571

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(Late Submission)
Please see the attached document.

(Late Submission)
Please accept the comments of Cinergy MetroNet, Inc.

(Late Submission)
Attached is NWT Enterprises, Inc. comment on the BTOP RFI

(Late Submission)
Please find attached comments on behalf of the American Heart
Association and its American Stroke Association in response to your
request for written comments about the broadband initiatives in the
American Recovery and Reinvestment Act.


Stephanie Mohl
Government Relations Manager
American Heart Association/American Stroke Association
Office of Legislative and Regulatory Affairs
1150 Connecticut Ave., NW
Suite 300
Washington, DC 20036
202-785-7950 (fax)

Go Red For Women.
Join the movement to wipe out heart disease. Visit:

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

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

(Late Submission)
Dear NTIA and RUS administrators,

As part of the Telecommunications industry here in the U.S., let me ask that we carefully consider the use of the stimulus dollars being considered for our struggling industry. While the inflow of dollars will be greatly appreciated, and will obviously help generate more orders and therefore jobs here in the U.S., it would be mindful to make sure that the flow of funds does NOT flow right back out and over to foreign companies/interests.

Zhone Technologies, Inc. is one of the very few companies that still relies on our own technologies and workforce to produce a leading edge product. And we have been extremely successful at that. So let's make sure that those that have worked so hard receive their due rewards and are not left on the sidelines as the dollars slip out of our hands and into someone's that is not so deserving.

Thanks for your time.

Michael E. Shelton

Corporate Facilities Manager

Zhone Technologies, Inc.

Michael E. Shelton

Zhone Technologies, Inc.

Corporate Facilities Manager

Head of Security

(O) 510.777.7368

(F) 510.777.7488

(Late Submission)
Attached is a summary of a meeting between OPAD stafff and Connected
Nation, held on March 4, 2009. Please post the summary on the NTIA

(Late Submission)
Please See Attachment

(Late Submission)
Dear Dr. McGuire-Rivera,

Please find attached Ernst & Young's responses to RFI 090309298-9299-01,
American Recovery and Reinvestment Act of 2009 Broadband Initiatives. The
attached file is in Microsoft Word 2003 format.

We hope that this response will prove useful to you in navigating the
challenging path forward in implementation of the Act's mandate. Please
do not hesitate to contact us with any questions, concerns, or requests
for clarification as to any of the content of the attached.

Best regards,
Gaeron McClure

Gaeron R. McClure | Partner | Transaction Advisory Services

Ernst & Young LLP
200 Plaza Drive, Secaucus, NJ 07094, United States of America
Office: +1 201 872 1460 | Cell: +1 214 587 9701 |
Fax: +1 866 430 9675

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

Jason Goldman


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

(Late Submission)
To Whom It May Concern:

Please find attached comments from the Continua Alliance directed to
criteria considerations for the BTOP grants.

We appreciate the opportunity to file on behalf of our 180 members.


Chuck Parker

Executive Director

Continua Health Alliance

For further questions:

direct 781 724-8872

office 503 619-0867

(Late Submission)
The City of Chicago is filing the attached comments with the National Telecommunications and Information Administration (“NTIA”) of the U.S. Department of Commerce and the Rural Utilities Service (“RUS”) of the U.S. Department of Agriculture in response to the joint request for information on the American Recovery and Reinvestment Act of 2009 Broadband Initiatives.

Docket No. 090309298-9299-01

If you require further clarification on the City of Chicago's comments, please contact Dean Tsilikas, as he will be serving as the initial point of contact.

We thank you for this opportunity to provide our input, and look forward to the overall success of this important initiative.

(Late Submission)
Please include me on the correspondence list for Broadband Technology
Opportunities Program.



Randy Eckels

Chief Operating Officer

Sting Communications

120 South 16th Street

Lebanon, PA 17042

(717) 270-1979 x4527

(Late Submission)
Mr. Wilhelm and Ms. Brown:

I have extensive experience in wireless infrastructure (7 yrs) and in City
Management (7 yrs).

I have Master's degrees in Public Administration and in Urban & Regional
Planning, as well as AICP Planning Certification.

I believe I might be able to help the NTIA with the difficult tasks ahead,
and would like to find a position where I could make a difference.

Towards those ends I've attached a resume and references.

Would there be someone I could contact to discuss this further?

Thanks for your time and consideration.


Anvil Partners logo.jpgRobert E. Smith, AICP

314 North 5th Street
Wilmington, NC 28401




(Late Submission)
See attachment.

(Late Submission)
Give priority to existing municipal ISPs that have already taken on the burden of serving unserved/underserved areas. Consider distributing a portion of the funds to these ISPs by formula (based on population in the area served). See attached.

(Late Submission)
Please find attached comments pertaining to the American Recovery and Reinvestment Act of 2009 Broadband Initiatives. These comments are provided from the eXtension Foundation, a national Internet-based educational network providing 24/7/365 access to objective, science-based information from land-grant universities and partners nationwide. It is an integral part of and complements the community-based Cooperative Extension System.

(Late Submission)
Only wireless solutions can support one-to-one computing for our students and time is of the essence in deploying the broadband networks proposed in the ARRA. See

(Late Submission)
Comments attached.

(Late Submission)
Comments relating to P.L. 111-5 and P.L. 110-385 are attached.

(Late Submission)
April 10, 2009

Ms. Anna Gomez
Deputy Assistant Secretary
National Telecommunications and Information Administration
1401 Constitution Avenue, NW
Washington, DC 20230

Dear Deputy Assistant Secretary Gomez:

On behalf of Women Impacting Public Policy (WIPP), representing more than a half million business owners and women in business, we urge NTIA to consider the critical implications of broadband deployment for small and women-owned businesses.
Businesses of all sizes have been negatively impacted by the recession, but small businesses – a vital engine of economic growth - have been hit especially hard. The American Recovery and Reinvestment Act represents an unprecedented opportunity to help address long-standing challenges that so many American small businesses face. For many small businesses, the road to economic recovery requires access to new and emerging technologies such as broadband. If deployed in a rapid, efficient, and transparent way; NTIA funding will play a crucial role in making broadband more accessible to small businesses owners and will help ensure that the United States can thrive in a 21st century economy.
Specifically, expanding access to advanced telecommunications technologies and services via broadband will spark the creation of new service providers, innovations, and exciting applications for which small businesses depend on to thrive. Such advancements are the most vital and efficient way to deliver information, services, and products such as e-commerce transactions including customer credit-card purchases, online/real-time chat customer assistance and supplier-partner transactions. These services are important touch-points for small businesses to engage customers, suppliers and partners beyond traditional person-to-person, point-of-sale interactions in an Internet global economy. Likewise, small businesses are increasingly seeking global opportunities via broadband connections to reach markets, customers and suppliers outside of traditional local and regional centers.
To that end, we strongly encourage the NTIA to quickly, efficiently, and transparently disperse the stimulus funding to state and local governments so that unserved and underserved small businesses can get on the road to recovery. While financial support and leadership from the federal government is important, state and local governments have the best understanding of what their communities need, can assist in transparent and accountable delivery of broadband, and are in the best position to create effective public-private partnerships to meet specific needs by leveraging private-sector expertise in network construction and management. The best way to gain the benefits of stimulus funding is to ensure that broadband gets to the unserved areas first. That is why we strongly recommend disseminating the funds through an existing model of state-based mapping. It is imperative that these much needed resources get dispersed quickly, without adding network conditions or requirements that will delay or discourage participation by the most capable providers.
We are excited about the prospect of bringing broadband accessibility to all small business owners and are grateful for NTIA’s hard work in ensuring the grants process is fair and efficient. Delivery of next-generation broadband services can not wait – we thank you in advance considering the needs of small businesses as you look forward to spurring economic growth through advanced telecommunications technology.


Barbara Kasoff
Women Impacting Public Policy

(Late Submission)
Please add me to your distribution list for updates about BTOP.
Thank you

COLIN CLOSE | Research & Program Coordinator
Police Department | 965 Sonoma Avenue | Santa Rosa, CA 95404
Tel. (707) 543-3556 | Fax (707) 543-3557

(Late Submission)
See the document submitted below.

(Late Submission)
This correspondence came into the Office of the Assistant Secretary on
March 4, 2009.

James V. Wasilewski
Office of Congressional Affairs
National Telecommunications and Information Administration
U.S. Department of Commerce
(202) 482-2476

>>> Ebony Griffin 3/4/2009 11:20:30 AM >>>
Good Morning,

Please see the attached.

Ebony S. Griffin
Administrative Assistant for the Senior Advisor
U.S. Department of Commerce
National Telecommunications and Information Administration
Assistant Secretary's Office

(Late Submission)
The American Farm Bureau's Comments are attached. Please respond to
this email if you have any trouble with the attachment.

(Late Submission)
Ms. McGuire-Rivera

Please consider our attached comments as you develop final guidelines.
Document provided as a PDF and in Word 2003.


Patricia A. Groot,

Grants Administrator

County of Fluvanna

132 Main Street

Palmyra VA 22963

434.591.1910 x 1081 voice

434.591.1911 fax

711 VA Relay

(Late Submission)
Ex Parte Letter to Secretaries Locke and Vilsack

(Late Submission)
see attachment

(Late Submission)
See attached file.

(Late Submission)
See attachment

(Late Submission)

(Late Submission)
Please see attached

(Late Submission)
See attached.