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Joint Broadband Technology Opportunities Program Request for Information

March 12, 2009
Docket Number: 

American Recovery and Reinvestment
Act of 2009 Broadband Initiatives


(Late Submission)
Please see attached Comments of the Wireless Internet Service Providers Association ("WISPA").

(Late Submission)

Native Public Media (“NPM”) promotes access to and ownership of all media by Native communities. It regards the Broadband Technology Opportunities Program (“BTOP”) as an opportunity to bring advanced communications systems to Tribal Lands that have limited access to, and virtually no ownership of communications media.

In awarding BTOP grants, NPM urges NTIA and RUS to take into account the unique nature of Tribal Lands and the trust relationship between the federal government and Indian Tribes as sovereign, governmental entities. By any standard likely to be adopted, Tribal Lands are “unserved” or “underserved.” Improving the communications infrastructure on Tribal Lands is critical to Tribal self-government, economic development and nation building, and to the health, safety, and welfare of Native Americans.

(Late Submission)
Please see the attached letter.

(Late Submission)
On behalf of Melissa Newman (202-429-3120) and Larry Sarjeant (202-429-3112) of Qwest, attached hereto are the Comments of Qwest Corporation, for filing with the National Telecommunications and Information Administration of the Department of Commerce and the Rural Utilities Service of the Department of Agriculture in response to the Joint Request for Information in Docket No. 090309298-9299-01, American Recovery and Reinvestment Act of 2009 Broadband Initiatives.

Ross Dino
Director, Law Department
1801 California Street, 10th Floor
Denver, Colo. 80202
303-383-6594 (voice)
303-896-1107 (facsimile)
720-218-3778 (cell)
303-840-8189 (home)

(Late Submission)
Attached are the comments of WildBlue Communications, Inc., Hughes
Network Systems, Inc., Intelsat Corporation and National Rural
Communications Cooperative to the joint request for information, Docket
No. 090309298-9299-01.

Thank you for your consideration.

David Brown

Senior Vice President and General Counsel

WildBlue Communications, Inc.

(Late Submission)
Please find comments in Docket Number 090309298-9299-01 attached.
Tom Fritz
Executive Director
Connect Ohio

(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 Gardonville Cooperative Telephone Association.

Kristy Szabo
On Behalf of Gardonville Cooperative Telephone Association

(Late Submission)

John Ridgway
Manager - Telecom
Iowa Utilities Board
"Life is a long lesson in humility"

(Late Submission)
A comparison among Backbone Networks
Hybrid WiMax/Satellite (AlphaStar) Vs. Pure Two Way Satellite (Hughes Net) Vs. Fiber (Global crossing)
According to Mr. Mark G. Seifert, Senior Advisor to the Assistant Secretary of NTIA, The first two goals of NTOP are:
2-Closing the broadband gap “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. a€ AlphaStar ( ) is proposing a creative network to meet the goals of employment and deployment IMMEDIATELY.
AlphaStar is proposing an IP based hybrid network which uses WiMax to the user and satellite for backhaul purposes only. AlphaStar developed and deployed this model since the year 2000. It is simple network to deploy, consisting of a satellite dish on a tower or a high building to send and receive data from satellites attached to WiMax antenna to send and receive data to the final user. The final user needs only to have a wireless device to receive access and most of these devices are self installed.
AlphaStar network idramaticallyly different and it is much improved over the current pure two way satellite broadband in the market today (for example, Hughes Network)
First. The two-way satellite network requires the installationon of a dish and set-top box at the final user’s premises. This increases the cost to the provider and consumer. The hybrid network does not require a dish and set top box at the final user premises. This eliminates all the associated cost to the consumer and the provider. Accordingly the hybrid network makes the cost of consumer access more affordable than the pure satellite networks in the market today both in capital expenditure to connect and the cost of the monthly access. It follows that the AlphaStar hybrid model offers more affordable service than the pure satellite model deployed in the market today and hence encourage more users to connect.
Second. The hybrid model allows the mobility of the users whether they use WiMax or Wi-Fi as it integrates seamlessly with the end user wireless devices.
Third. AlphaStar believes that the optimal use for satellite is push technology. The hybrid model includes an extensive caching mechanism. The end user will interact with the cache most of the time except when the cache calls for information from the satellite. This also cuts cost since satellite time is used for caching purposes only. This cost saving would make it affordable for the user. Further the use of local cache minimizes the latency of pure satellite networks.
Fourth. AlphaStar model is based on leasing bandwidth from satellite companies. It gives AlphaStar flexibility in the selection and use of the appropriate band ( Ku ,C, Ka and L bands , fixed and mobile satellite systems ) , location and freedom from the enormous cost of launching satellite constellation. It also allows the leasing of bandwidth on demand. Again that is a cost saving that can be passed to the users and encourages them to connect to thInternetet.
Meanwhile the hybrid network is more superior to the fiber and legacy networks. For example Global Crossing correctly states in a comment on this forum “The high-capacity pipes referred to by Mr. Seifert are commonly known as the 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” Global Crossing concludes that the cost of for fiber companies or laying down legacy IPv4 dual stack is “exorbitant” and “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€
AlphaStar is definitely a high-capacity pipe on the sky in parallel to those underground and can totally bypass all of the terrestrial networks and still provide broadband to the entire country instantly. AlphaStar is truly the middle mile facility that the sole connection between the intent and EVERWHERE in the homeland. Satellite multicast to the nation and operates independently of all of the legacy networks. The AlphaStar hybrid network of terrestrial/satellite is neither exorbitant nor speculative. First it is deployed without major capital expenditure in advance. Unlike the fiber networks The AlphaStar network is not based on the risky notion of “build it and they will come”. Second, AlphaStar network is built on an incremental basis. The cost of setting up a location is few thousand dollars and dishes can be moved among different markets depending on need or demand. It follows that the model is not speculative since the supply follows demand without the huge capital expenditure required for laying out fiber. The major cost is satellite time and that is also incremental and the cost is affordable today. Third, unlike fiber the AlphaStar network can be deployed within weeks not years without digging and associated delays. Finally, deployment of the AlphaStar network follows employment. People can be hired in these high unemployment communities immediately and broadband would be provided in matter of days or weeks from hiring. The economics of the hybrid network will induce higher adoption in the rural markets as desired by the stimulus bill.
Global Crossing also correctly 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”. AlphaStar joins Global Crossing in making this request. AlphaStar is seeking partners, JV with rural wireless companies, Telcos and cable systems. Entrepreneurs are welcome as their initial investment is minimal. Furthermore , Global Crossing and other fiber networks would benefit from peering with AlphaStar at least until their fiber networks are fully deployed. Even few years from now, fully deployed fiber networks still will need AlphaStar redundancy given the vast areas to be covered and need for prudent disaster recovery in rural communities.
Email contact
203 979 2700

(Late Submission)
Please see attached comments of Texas Statewide Telephone Cooperative, Inc.

(Late Submission)
On behalf of segTEL, Inc., attached are segTEL's comments for submission in
NTIA/RUS Docket No. 090309298-9299-01. Please contact me if you have any
questions concerning this filing.


Jeremy Katz
Chief Executive Officer
segTEL, Inc.

(Late Submission)

(Late Submission)
Please see PDF attachment

(Late Submission)
See attached file.

(Late Submission)
See Attached Comments

(Late Submission)
Attached please find the comments of the City of Shafter, California

(Late Submission)
To whom it may concern,

Please find attached the comments of the Public Interest Spectrum Coalition
on grant criteria, provided as an Adobe PDF document. Please contact me if
there are any problems with regard to this document.

Respectfully submitted,

Mehan Jayasuriya
Public Knowledge

Mehan Jayasuriya
Policy Analyst
Public Knowledge
202.518.0020 x108

(Late Submission)
See attached Comments of Rural Cellular Association.

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

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

3 - we are unable to bring these wireless signals into the Navajo area for two reasons: 1) The BLM has not granted us rights of way on Nokai Done where exists an emergency landing strip we maintain and 2) the Navajo Tribe has not granted us a tiny parcel a mile from the Chapter House which would enable a solar power access point that would enable broadband to all of Rainbow City and the Chapter house with ten Gigabyte being available if desired. opolus other rights of wayl and 3) recognition we are a utility with all meaning thereto between the Tribe's U.S. treaty protections of utility property thereto. We have broadband throughout all of southern Utah from Colorado to Nevada, including educational broadband on behalf of the University of Utah EdNet. We are a founder member of the WISPA national wireless internet association. We design and manufacture antennas for coastal marine and wireless internet uses worldwide - (plus under license from Motorola) For more information see or ow write % the above
Art Brothers, CEO

(Late Submission)
The Telecommunications industry has escaped many of the environmental & public health regulations that has been mandated for most industries and businesses where potential health hazardous have been found. The decision that all broadband telecommunications represents clean green technology closes us off to the true realty of the industry.

I ask this commission to consider decades of health research evidence that has shown electromagnetic radiation of different frequencies has the potential to impact health and well being. Despite the 'No harm' contending scientists, well over 50% of the thousands of research studies conducted have shown varying types of electromagnetic frequencies and products interfere with the biological processes and the environment. (1)(2). It is time to give those studies due consideration when making determinations for broadband funding.

Our concern should not only be the interference that electronic products have with each other, but as well, the interference with living systems.

Time to follow the lead of many European Countries, public health bodies and European Parliament’s Environment Committee. The health science has been compelling enough for many to revise RF/microwave safety standards to much lower thresholds, and declare precautionary warnings and new policies on wireless products and facilities.(3)(4)

Our own National Academy of Science has taken notice of the science. It has called for a comprehensive research program(5) to study many of the unknowns that still exist, especially how multiple sources and 24 hour long term exposures of radio/microwave wireless radiation impacts health. Most past research has focused on a single sources, frequencies and short term duration of electromagnetic exposure sources.
Based of the scientific evidence and the many questions that still remain, I ask this commission to take health and environmental risks of electromagnetic radiation emission into consideration in determining cost benefit analysis of broadband technologies.

I ask for the following Criteria and Needs to be considered by this Commission:

1. Favor Wireline Broadband technologies whenever possible, i.e. fiber, shielded cable, etc. Its speed, security and capacity far exceeds wireless broadband technologies. It is relatively clean of any RF/Microwave emissions.

2. Give States stronger authority to decide where and what type of Broadband technology should be deployed for different applications and in different regions of their state.

3. Establish provisions where States set up programs to inventory their wireless installations – the information readily available to the public.

4. Before an area receives new Wireless, or in some cases, Wired broadband installation, devise monitoring and assessment strategies. These monitoring strategies should be modeled in some degree to our air pollution monitoring systems. They should include information gathering of health profiles for a targeted population before and after broadband installation becomes operational. Similar procedures should be deployed for monitoring electromagnetic emissions in the targeted area. This data should be readily available to the public under Freedom of Information Act. These strategies are paramount to fill the void of real time data in keeping information current between the association of health impacts with levels of electromagnetic radiation.

5. Follow the lead of the European Parliament’s Environment Committee motion to require wireless devices be “assessed before they are put on the market and, more generally, for thresholds to limit the degree of household exposure to microwaves”: “….to impose labeling requirements whereby the transmitting power would have to be specified and every wireless-operated device accompanied by an indication that it emitted microwaves”.(4)

6. Allow states to designate Wireless Free Zones, or zones which reflect lowest possible electromagnetic emissions for frequencies 100 Khz to 300 Ghz - emission levels which have been agreed upon by stakeholders and professionals alike.

7. Smart Grid technology deployment should be examined for its capacity to emit stray voltage from the many high frequency applications implemented. Stray voltage can have a harmful effect for those in an exposed environment.(6)

8. Ensure safe and additional Grounding techniques are found for the new High Frequency applications to eliminate Stray Voltage in ambient environments.

9. Broadband Over Powerlines should be considered under the same designation as Wireless, unless it can be determined it does not emit stray voltage or ambient radio/microwave radiation.


(1) Attached is a sampling of summarized referenced studies describing biological impacts of EMFs. Attachments are as follows:
a. Pubmed Abstract Summaries
b. Periodical Website Reviews of Research Studies
c. Spreadsheet of Published Studies

(2) Websites that inventory, describe principally electromagnetic radiation health studies

(3) See attachment:
Worldwide Wireless Safety Initiatives

(4)See Attachment
EU Environ Committee Wireless Precautionary Actions

(6) Health Effects of Dirty Electricity or Stray Voltage - Abstract
Grounding techniques for Stray Voltage:
Other related websites: See section “Need for adequate Grounding”

(Late Submission)
Please see attached letter

(Late Submission)
Filed on behalf of Bresnan Communications, LLC; Cequel Communications, LLC dba Suddenlink Communications; Mediacom Communications Corporation; and Midcontinent Communications

(Late Submission)
Refer to PDF attachment

(Late Submission)

Dear Sir or Madam:

Sage Telecom, Inc. "Sage" files in the above-referenced
docket its Comments in the matter of American Recovery and Reinvestment
Act of 2009 (the "Recovery Act") Broadband Initiatives. Should you have
any questions regarding this filing, please do not hesitate to contact
the undersigned.

Respectfully submitted,

Robert W. McCausland

Vice President and Secretary

Sage Telecom, Inc.

805 Central Expressway South

Suite 100

Allen, TX 75013-2789

Tel: (214) 495-4878

CONFIDENTIALITY NOTICE: The information contained in this ELECTRONIC
MAIL transmission is CONFIDENTIAL. It may also qualify as privileged
work product or proprietary information. This information is intended
for the exclusive use of the addressee(s). If you are not the intended
recipient, you are here by notified that any use, disclosure,
dissemination, distribution (other than to the addressee(s)), copying,
or taking of any action because of this information is strictly

(Late Submission)
Please see the attachment detailing my comments about wireless technologies. The attachment is MS Word version 2002, titled NTIA comment.

Thank you for your attention to this matter.

Steen Hviid

(Late Submission)
Please find attached to this e mail the Garrett County Maryland
Coalition response to the NTIA Request for Information regarding the
BTOP and RUS Broadband Grant/Loan programs under the Ammerican Recovery
and Reinvestment Act of 2009.

We are please to submit this response, and look forward to working with
the NTIA and RUS as we develop our plans for improving broadband
services in Garrett County Maryland.

Please address any questions to me at the contact information shown

Thank you.

Frank Shap
Assistant Director
Garrett County Department of Economic Development
203 South 4th Street, Room 208
Oakland, MD 21550
301-334-1986 office
301-616-1615 mobile

This message and any files transmitted with it are intended only for the individual(s) or entity named. If you are not the intended individual(s) or entity named you are hereby notified that any disclosure, copying, distribution or reliance upon its contents is strictly prohibited. If you have received this in error, please notify the sender, delete the original, and destroy all copies. Email transmissions cannot be guaranteed to be secure or error-free as information could be intercepted, corrupted, lost, destroyed, arrive late or incomplete, or contain viruses. Garrett County Government therefore does not accept any liability for any errors or omissions in the contents of this message, which arise as a result of email transmission.

Garrett County Government,
203 South Fourth Street, Courthouse, Oakland, Maryland 21550

(Late Submission)
The National Conference of Black Mayors (“NCBM”) , National Black Caucus of State Legislators (“NBCSL”), National Organization of Black Elected Legislative Women (“NOBEL”), National Black Caucus of Local Elected Officials (“NBC-LEO”), and National Organization of Black County Officials (“NOBCO”) respectfully submit these comments in response to the above-referenced joint request for information.
The present economic crisis is undeniably the worst since the Great Depression of the 1930s. African-Americans are disproportionately affected by economic downturns. According to the U.S. Department of Labor, 663,000 jobs were lost in March of 2009 , thereby pushing the overall unemployment rate up to 8.5%. The African-American unemployment rate currently stands at a shocking 13.3% , rivaling the total unemployment rate between 1930 and 1931 .
There are many reasons for these disparities. During the 1930s, segregation, Jim Crow laws, and other forms of racism kept many African-Americans out of work. Today, individuals without broadband access are unable to use the internet to apply for jobs online and to develop the skills that are critical for 21st century jobs—21st century jobs that, at a minimum, rely on skills that many of us take for granted, such as using email, web browsers, and standard word processing software. Although we currently lack granular broadband mapping data to illustrate the relationship between broadband adoption rates and quarterly employment trends, a 2008 Pew Research Center study indicated that the rate of home broadband adoption amongst African-Americans was just 43% in April of 2008, compared to 55% of adults overall. Therefore, it would be quite a risky gamble to conclude that African-American unemployment rates can be improved without assigning priority status to low-income rural and urban communities.
While President Roosevelt’s New Deal successfully led to a recovery in the overall economy, it left African-American workers and businesses largely on the sidelines. We cannot afford for that to happen again. Thus, we ask that NTIA and RUS consider the following:
Meaningful Broadband Mapping
Ongoing, longitudinal, and granular broadband mapping studies, with poverty, unemployment, race and language data at the street level to track the geographic imprint of de facto segregation, are critical for identifying unserved and underserved communities. Without this data, government agencies will be unable to assess the extent of broadband coverage and target strategies to maintain the broadband infrastructure.

Public-Private Partnerships and Broadband Technology Plans
State and local government leaders are in the best position to understand the needs of their communities and the ways in which broadband can best stimulate their regional economies. Thus, NTIA and RUS should award grants to states or regional public-private partnerships. Further, NTIA and RUS should encourage each state to create a broadband technology plan with specific benchmarks for ensuring the deployment needs of priority areas.

Asssigning the Highest Priority to First Class Service to Unserved and Underserved Communities
NTIA and RUS should assign priority consideration to proposals that address service disparities in unserved and underserved communities.

Funding for HBCUs
NTIA and RUS should award funding to HBCUs that assist in correcting broadband service disparities.

Defining Underserved and Unserved Communities
In defining underserved and unserved communities, NTIA and RUS should account for factors such as poverty, unemployment, race and language.

Broadband Adoption in Minority and Low-Income Communities
The highest priority for broadband adoption grants should be assigned to stimulating broadband adoption and telecom literacy for low income, minority communities.

Accountability and Transparency in the Broadband Deployment Process
NTIA and RUS should coordinate projects so as to eliminate potential waste and redundancy. Coverage maps must be made available to the public online to allow the public to comment and ensure accountability.
Infrastructure projects of this magnitude are rare, which is why this must be done right. Millions of Americans, due to a lack of access to broadband, are effectively excluded, marginalized, and inhibited from applying for and acquiring the skills they need to thrive in the 21st century. Access to digital tools of socio-economic and political empowerment, like those provided by broadband infrastructure and applications, could reduce healthcare disparities, improve the quality of education for African Americans and provide greater entrepreneurial and job creation opportunities in our communities. By taking these steps, the administration would exponentially expand the long-term impact of the one-time allocation of economic stimulus dollars.
We strive to ensure that our constituents are full beneficiaries of the promise and potential of America’s increasingly digital economy. It is our hope that NTIA and RUS will act on this opportunity to ensure that broadband is built out to all Americans, by all Americans, and for the benefit of all Americans.

President Senator Margaret Carter
National Organization of Black Elected Legislative Women
President Representative Calvin Smyre
National Black Caucus of State Legislators

President City Commissioner Daisy Lynum
National Black Caucus of Local Elected Officials

Executive Director Linda Haithcox
National Organization of Black County Officials

Executive Director Vanessa Williams
National Conference of Black Mayors

(Late Submission)
See attached files.

(Late Submission)
Comments of EarthLink, Inc. and New Edge Networks, Inc.

(Late Submission)
see attached letter

(Late Submission)
See Attached Comments

(Late Submission)
See attached letter from ad hoc coalition of telecom manufacturing companies

(Late Submission)

(Late Submission)

(Late Submission)
I filed these comments yesterday, but am hoping you will consider this
amended version instead. The substance is the same, but two additional
organizations have added their name to the filing.

Thank you,
Beth McConnell

On 4/13/09 5:07 PM, "Beth McConnell" wrote:

> Attached are comments of a coalition of non profit and public interest
> organizations. I can be the point of contact for this filing, and my info is
> below.
> Thank you,
> Beth McConnell
> Executive Director
> Media & Democracy Coalition
> 2044 S. Darien St., Philadelphia PA 19148
> 1133 19th St., NW, 9th Floor, Washington DC, 20036
> Phone: 267-918-7207
> Fax: 509-756-0392

Beth McConnell
Executive Director
Media & Democracy Coalition
2044 S. Darien St., Philadelphia PA 19148
1133 19th St., NW, 9th Floor, Washington DC, 20036
Phone: 267-918-7207
Fax: 509-756-0392

(Late Submission)
Errata to Comments submitted by National Rural Electric Cooperative Association on April 13, 2009

(Late Submission)
Proposed rules for BTOP

(Late Submission)
HITN Comments on NTIA RUS Broadband Stimulus Programs

(Late Submission)
Please add me to the list


Brian Beenhouwer | Product Manager

Fibertech Networks, LLC | 300 Meridian Centre|Rochester, NY 14618

Phone: 585-697-5129 Fax: 585-442-9709

(Late Submission)
Please see attachement

(Late Submission)

>>> "Charles Walters" 4/13/2009 6:56:56 AM
I submitted comments yesterday on behalf of Walters & Associates, Inc.
at 7:01 p.m. However, I do not see my comments posted on the website.
Your assistance is greatly appreciated. I am attaching another copy of
my submission.

Charles E. Walters, ASA

(Late Submission)
On behalf of EvenLink, LLC, we greatly appreciate the NTIA allowing the public to comment on this significant process. Please refer to the attached PDF for comments to the National Telecommunications and Information Administration and the United States Department of Agriculture Rural Utility Service on Rules for Broadband Grants and Loans(As authorized by the American Recovery and Reinvestment Act of 2009)

(Late Submission)
Comments are attached in .pdf format.

(Late Submission)
0251 - Gomez Signed Letter to Gov. Kulongoski 05-19-2009(2)_BB.pdf

(Late Submission)
Attached is ACD Telecom's comments.

(Late Submission)

(Late Submission)
Will we receive any kind of confirmation that our comments were accepted?

John Ridgway
Manager - Telecom
Iowa Utilities Board
"Life is a long lesson in humility"

> -----Original Message-----
> From: Ridgway, John [IUB]
> Sent: Monday, April 13, 2009 2:07 PM
> To: ''
> Subject: Responses to the Joint Request for Information
> > >
> John Ridgway
> Manager - Telecom
> Iowa Utilities Board
> (515)281-4034
> "Life is a long lesson in humility"

(Late Submission)
The criteria used by RUS in making evluations of stimulus support applications ought to be based on the twin stimulus objectives of: (1) the creation of jobs and businesses; and (2)the preparation of rural economies to compete successfully in serving global markets.
In addition, there should be explicit recognition that the costs to the government of "loan guarantees" are substantially less than "grants."