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Getting Started on an NTIA Broadband Stimulus Application

LAKE FOREST, Ill., August 10, 2009 – Here’s a step by step guide to completing an National Telecommunications and Information Administration application in a bid to receive money for broadband projects. The guts of the application will consist of one or two page narratives in the following areas: project proposal, project benefits and innovation, awareness campaign, impact evaluation, technical strategy, project timeline, budget and budget narrative.

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Editor’s Note: The following guest commentary appears by special invitation of BroadbandCensus.com. BroadbandCensus.com does not necessary endorse the views in the commentary, but invites officials, experts and individuals interested in the state of broadband to offer commentaries of their own. To offer a commentary, please e-mail commentary@broadbandcensus.com. Not all commentaries may be published.

The staff of BroadbandCensus.com has produced a four-page report on the essentials of the Broadband Initiative Program-Broadband Technology Opportunities Program Notice of Funds Availability, which is available for purchase for $25.00, at http://broadbandcensus.com/special-reports.

By Don Samuelson, Guest Commentary, BroadbandCensus.com

LAKE FOREST, Ill., August 10, 2009 – Here’s a step by step guide to completing an National Telecommunications and Information Administration application in a bid to receive money for broadband projects.

The deadline for the first round of NTIA broadband submissions is August 14.  The first step is going to Broadband USA and clicking on the application link: http://broadbandusa.sc.egov.usda.gov/download_app.htm

You’ll find 47 topics, many of them essentially administrative.  However, the guts of the application will consist of one or two page narratives in the following areas:

  • Project Proposal: Problem, Solution and Outcomes
  • Project Benefits and Innovation: New Subscribers/Cost Per Subscriber
  • Awareness Campaign: Identifying and Capturing the Market
  • Impact Evaluation: What Real Differences Have Been Made
  • Technical Strategy and Organizational Capacity
  • Project Timeline and Challenges
  • The Budget and Budget Narrative

The evaluation scoring will be: Project Purpose (30%), Project Benefits (25%), Project Viability (25%) and Project Budget and Sustainability (20%).  The purpose of this short paper is to help Public Housing Authorities get started in thinking how they might develop a winning proposal that advances overall agency objectives.

Project Purpose

NTIA’s objective in providing adoption grants is to move vulnerable populations across the digital divide, to create new – and permanent – users of the Internet.  The assumption is that once public and Housing and Urban Development housing families and seniors experience the benefits of broadband and the Internet they will be motivated to be self-sufficient and shoulder more of the burden of their own well-being.  Costs can be reduced.  Access to services can be increased.  The overall quality of life will be improved.

An applicant will have to paint a “before” and “after” scenario.  Here is a description of the current status of computers, Internet access and use/adoption in the individual units.   The assumption is that the percentages will be very low.  Here is the intervention strategy to promote greater interest and use.  These are the projections of use adoption and use at the end of the intervention.  The percentages should be high. This data can be collected by surveys and performance updates.

But a key word is “sustainable.”  The use and adoption must continue.  Equally important, the use has to be paid for.  The major problem with the Housing and Urban Development Neighborhood Networks program was that while more than a thousand computer training centers were created under the program, there was no permanent funding to pay for program needs: instruction, maintenance, broadband connectivity and software and hardware upgrades.

It would be smart to think of this new program in terms of teaching residents to fish rather than being a permanent source of fish.  The use by seniors of the CTC in the building should be an initial step on the path to a permanent life on the Internet.  In two years the CTC can be shut down, all of the seniors will have computers and Internet in their units and a sustainable adoption will have been achieved.

Innovation

The innovation in the proposal is in using the on-site CTC as a collection point and launching pad, not as a permanent function.  It may well be that new applications and group discussions can take place in the CTC.  But the residents will have crossed the digital divide and the collaborations and life-long learning efforts of the future can take place in the individual units and not in the CTC.

The future I’ve postulated will need computers and Internet connections for all residents, not just for the limited number of devices in the CTC, connected by a wireless Local Area Network.  Where will they come from?  Ideally, the computers in the units should be refurbished computers and “thin clients.” The advantage of thin clients (or refurbished computers converted to think clients) is that they are inexpensive to buy and inexpensive to maintain. There are not many things to go wrong.  It can be a “plug and play” device. Donated and refurbished computers can count as the local “match” at NTIA.  The NTIA grant can fully subsidize Internet connections for a year, and at a 50 percent rate the second year.  The initial computers/thin clients can be paid for by NTIA.  The “sustainability” can be achieved by having residents fully pay for their Internet connection in year three along with upgrades, new computers and peripherals. The goal of the program is not to support on-site CTCs. The goal of the program is to use on-site CTCs for marketing the benefits of broadband and the Internet, and to prompt residents to cross the digital divide.

The Awareness Campaign

A short one-page survey should be the first step in the awareness campaign.  The survey should be oriented to current conditions (computer, dial-up or broadband Internet access, etc.), the current interests of the residents and their thoughts on how they intend to use broadband access.  The results of the survey will inform the basis for small focus-group meetings, to identify local Internet advocates/leaders and to build an outreach corps.  Inviting residents to illustrate their Internet activities on an electronic white board before larger groups of residents could demonstrate practical uses by peers.  It would be helpful to send e-mail to the children, grandchildren and friends of the residents to explain the Internet adoption program and to request support.  Once relevant content is developed and accessible over the Internet, a Web site can be developed to promote communications and collaborations among residents, and can provide access to the program to seniors on the building waiting list, and neighborhood seniors.

Impact Evaluation

Progress can be tracked throughout the entire two year program.  The survey will provide the base-line information.  Periodic interim reports can be generated related to: (1) filling out the survey; (2) participation in focus groups; (3) attendance at training sessions; and (4) the successful completion of training modules — not unlike the various progressions in Cub Scouts and Boy Scouts.  But thc key measurements will relate to the acquisition and use of a free computer and Internet access in the unit. Even more important will be the percentage of residents who will pay for Internet connectivity after the subsidy period is ended and the residents who will pay themselves for connectivity, hardware upgrades and software.  Other important measurements will relate to the uses made of the Internet connection and the amount of time spent on the Internet.

Technical Strategy

The on-site CTC should function like a 21st century classroom, with desktop terminals, a teacher’s station, an electronic whiteboard, a broadband connection and electronic curricula.  The CTC should have a color printer and other peripherals essential to the educational/training functions of the CTC.  It would be helpful to have webcasting capability in the CTC so that instructional programs. panel discussions and illustrations of resident work could be “broadcast” throughout the building creating virtual meetings for all of the building residents.  The all-building virtual meeting developed for Internet/computer training purposes can be used for many other uses as well.

How do we find affordable computers or thin clients for all of the building residents? First, the free refurnished computers or thin clients are “awarded” to residents who complete successfully a training course in the CTC.  So they are rolled out over a period of time.  Second, there is a ready pool of discarded computers everywhere in the United States – at least for the time being – resulting from the upgrading of personal computers in corporations, law and accounting firms and government.  The refurbishing process is relatively simple, easily done by middle and high-school students with little oversight.

The question remains how the broadband connectivity is distributed throughout the building – normally by a combination of hardwiring to the heavy Internet users (management office, CTC, maintenance office, etc.) on the main floor and wireless distributions throughout the building. This solution will have to be developed out of the specific circumstances of each location and the overall needs of the adoption program.

Project Timeline

Assuming that grant is awarded on October 1 and all of the detailed planning is done after you have survived the first cut, the first step will be surveys, focus groups and the “pre-selling” of the program. The second step will involve the preparation of the training curriculum, the program website and the recruitment of the site director.  A good start on this can be done before the actual award is made.  The whole system should be operational by the holidays and the first two four-week training program should have been completed.   The whole program can be completed in 2010. The whole program is three months of planning, three months of start-up and a year of operation.

Project Challenges

The biggest challenge will be to plan and implement the outreach in terms of generating benefits that are practical value to seniors, and to gently overcome the natural resistance to try something new.   This will have to be a fun learning experience, not unlike races for little kids, where everyone can feel good about their progress because it is advancing them along a path they have concluded will have value. The second challenge will be to find a program manager/instructor who has the collection of diverse training skills that can make this program happen.  The third challenge is to find a local source of refurbished computers that can fit the PC or thin client needs of the program in sufficient numbers to provide a computer for every resident. The fourth challenge is to identify affordable broadband connections for the residents. The fifth challenge is to find, review and arrange for on-line curricula that is responsive to the interests of residents that can provide a core “package” of applications that meet the interests and needs of seniors.

The Budget and Budget Narrative – Program Eligible and Matching Costs

There are certain eligible program costs that can be paid for by the NTIA grant. In general, they related to computers, furniture, equipment, training, connectivity and maintenance. They are costs directly related to the development of the adoption program.  The cost of space would normally not be covered unless it was to be devoted exclusively to the function of the CTC.  Once a cost has been determined to be “eligible,” 80 percent of the program costs can be paid for by the NTIA grant, and 20 percent needs to be covered by separate matching funds.  The Budget Narrative needs to document and explain each cost element with respect to hourly rates, unit costs, projected quantities and the reasonableness of the projected cost.  The budget needs to tie in to the overall program.

Donald S. Samuelson has more than 30 years of experience in government-assisted housing and real estate development. He has a passion for applying broadband to provide solutions in the fields of education and training. E-mail him at DSSA310@aol.com, or contact him by phone at 847-420-1732.

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Steve Lacoff: A New Standard for the ‘Cloudification’ of Communications Services

The cloudification of communications services makes it easy to include voice, data, SMS, and video within any existing service.

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The author of this Expert Opinion is Steve Lacoff, general manager of Avalara for communications

The line of demarcation between what has traditionally been considered a telecommunications service was once very clear. It was tangible – there were wires, end points, towers, switches, facilities. Essentially, there was infrastructure required to relay voice or data from point A to point B.

Today that line is fuzzy, if not invisible. The legacy infrastructure remains, but an industry of cloud-based services that don’t require the physical connections has exploded. Voice, data, SMS, and video conferencing can now be conveniently delivered OTT. Enabled by simple API integrations, businesses can embed just one of these services or a complete communications platform-as-a-service (CPaaS) into an app, service, or product.

Cloudification is a game changer

This “cloudification” of communications services makes it easy to include voice, data, SMS, and video within any existing application, product, or service. These are essential components for many business models.

Consider these services we have come to rely on in our daily lives: food or grocery delivery, ride services, and business and personal communications. These require multiple methods of communication with shoppers, drivers, co-workers, watch party groups, and external business partners.

The exciting news is there is no end in sight. Use cases will continue to evolve and growth will continue to skyrocket. The scale cloud delivery accommodates is massive. These untethered, easy to embed communications services are a critical differentiator for both business-to-business and business-to-consumer buyers, and the lifeblood of the businesses providing both the end user subscriptions and the APIs.

In fact, one industry juggernaut saw H1 YoY video application service demand grow nearly 600% in 2020.

Not surprisingly, as business demand for these services increases smaller CPaaS players continue to enter the market to quickly snag market share. According to a recent IDC study, “the global market revenue for CPaaS reached $5.9bn in 2020, up from $4.26bn in 2019, and is expected to reach $17.71bn by 2024.”

Merger and acquisition activity is aligned with this hockey stick growth forecast. Large telcos, SaaS providers, and even other CPaaS providers are all on the hunt. Whether they want to add additional features to punch up their products or eliminate the competition in a very tight, nuanced market, the end game is clear – as the market expands, the players will ultimately contract leaving only the most competitive offerings.

Don’t let communications tax take you by surprise

One of the least understood risks when adding cloud-based voice, data, SMS, or video conferencing to an existing product or service is new eligibility for and exposure to the complex world of communications taxation. Making mistakes can get costly very quickly.

Here are some of the key pitfalls to keep an eye on:

  • Expanded nexus: Understanding communications tax nexus is different – and exceptionally more complicated – than sales tax. There are approximately 60,000 federal, state, local, and special taxing jurisdictions, each with uniquely complex rules that tend to change at their own pace. Rules are very different for each service.
  • More complex calculations: The more communications services you provide via API, the more complicated communications taxes will be. Each feature can be taxed at different rates in each individual jurisdiction, or the whole bundle can be taxed at one rate. It’s critical to monitor monthly to avoid audit issues.
  • Maintaining overall compliance: Just as tax rates and rules need to be maintained, so must tax and regulatory filing forms in each jurisdiction. Some of these are very long and require significant detail.  They must be filed in a timely, accurate cadence to avoid additional audit risk.

Bottom line: Don’t assume, be prepared! As these communications services become more pervasive a larger swath of technology providers will find themselves liable for communications tax. The more your business falls behind, the more it can cost you.

It pays to be proactive and prepared. Tax and legal advisory experts can help determine your level of risk, and tax and compliance software providers can help you keep up with changing rules and regulations. Don’t underestimate the ongoing value of networking with peers who are either struggling to answer the same questions or have already overcome the hurdles you’re facing today.

Steve Lacoff is General Manager of Avalara for Communications. With a focus on data, VoIP, and video streaming, Steve has spent 15 years in various product and marketing leadership roles in communications and technology industries, including Disney’s streaming services and Comcast technology solutions. Steve now drives business strategy on today’s changing industry landscape and associated tax impacts. This piece is exclusive to Broadband Breakfast.

Broadband Breakfast accepts commentary from informed observers of the broadband scene. Please send pieces to commentary@breakfast.media. The views expressed in Expert Opinion pieces do not necessarily reflect the views of Broadband Breakfast and Breakfast Media LLC.

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Jonathan Marashlian: The Legal Landscape Emerging for Robocalls Under the TRACED Act

The biggest risk is likely to come through enforcement actions by state attorneys general and civil litigation, says Marashlian.

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Jonathan Marashlian, Managing Partner of Marashlian & Donahue, LLC, The CommLaw Group, is the author of this Expert Opinion

Requirements for voice service providers emerging from the TRACED Act and the Federal Communications Commission orders that followed have changed the risks and threats to voice service providers.

Voice service providers have just passed some major milestones: Certifying SHAKEN and/or robocall mitigation in the FCC database and refusing calls from unregistered upstream providers. Does that mean it is time to kick back and relax?

Not at all. The legal landscape in the new STIR/SHAKEN era is much larger and more diverse than mere technical compliance with FCC requirements.

We are already seeing clear and unmistakable signs that compliance with the bare minimum requirements established by the FCC—implementing STIR/SHAKEN and robocall mitigation plan procedures—is insufficient to mitigate the myriad of business risks arising from the government onslaught against the scourge of illegal robocalling.

Reading the tea leaves, the biggest risk or threat is likely to come through enforcement actions by state attorneys general and civil litigation initiated by private parties. Wherever the legal landscape provides the opportunity to recover damages, class action plaintiff’s lawyers and attorneys for large enterprise consumers of voice services, such as call center operators, are certain to seize upon those opportunities.

‘Know your Customer’ rules come to the telecom industry

We anticipate that questions around the meaning of and extent to which the “Know Your Customer” requirements apply in different contexts will ultimately be answered through litigation and enforcement, and less so through the FCC regulatory rulemaking process. Questions around damages and who is or can be held responsible for originating, passing, or terminating illegal robocalls are also going to be fleshed out by regulatory enforcement and private litigation.

Perhaps the most significant risk, even more so than the FCC, are the federal and state consumer protection laws that are being developed around robocall mitigation. Starting with the Federal Trade Commission (FTC), where the FTC’s strict “known or should have known” standard is applied to hold voice service providers accountable for illegal robocallers using their networks.

Many service providers and telecom consultants pore over FCC regulations to try and understand the requirements. Is that sufficient? Are there other things they need to worry about?

FCC regulations are a good starting point and, telecommunications providers should stay abreast of updated regulations and releases. However, FCC regulatory compliance alone may not be enough to defend an action if provider’s face the FTC and state attorneys general’s “known or should have known” standard or the creative, evolving litigation strategy of the plaintiff’s bar.

Marriott filed a lawsuit in federal court against unknown perpetrators, “John Does,” who made illegal robocalls misusing Marriott’s name. Why would Marriott do that? What’s the point?

This is sheer speculation, but as often turns out, the actual perpetrators who harmed Marriott likely will be insolvent or outside the reach of Marriott. By using “John Does,” Marriott preserves its ability to amend its complaint to implead carriers and providers that carried or transported the fraudulent traffic.

Marriott could rely on the FTC’s “known or should have known” standard to show underlying carriers are the “John Does” that profited from bad actors (now insolvent or extra-judicial). It’s unlikely Marriott would commence this litigation without a strategy outside positive public relations for pursuing bad actions; rather, the “John Does” will likely turn out to be carriers of bad traffic who settle Marriott’s claims.

The Call Authentication Trust Anchor Working Group issued Caller ID Authentication Best Practices, which the FCC published and endorsed as voluntary measures. Then the Fourth Report and Order on Robocall Prevention mandated affirmative obligations to prevent service providers from originating robocalls. It seems like momentum is building toward holding service providers responsible for knowing their customers and the nature of their calls.

Based on recent trends, there is certainly momentum in that direction and Know Your Customer will likely continue to grow in importance. Thus, providers should ensure they have a good KYC policy in place, particularly as new risks emerge, and scrutiny grows. However, as discussed above, this appears largely driven by the FTC and state attorney general actions.

Of note, the Industry Traceback Group in July 2021 published a Policies and Procedures booklet with a best practices section. All voice service providers should review the booklet, and particularly the best practices. Accountability will keep mounting and the weakest link—the weakest KYC policy—will be the first to break, and that provider will be accountable and “holding the bag.”

Jonathan Marashlian is Managing Partner of Marashlian & Donahue, PLLC, The CommLaw Group, a full-service telecom law firm located in the Washington, D.C., area catering to businesses operating in and around the dynamic and diverse communications and information technology industries. Their clients include providers of VoIP, wireless and traditional telecommunications services, SaaS-based and cloud computing technologists and Internet-of-Things application and network vendors. The CommLaw Group has formed a Robocall Mitigation Response Team to help clients achieve the level of compliance needed to avoid the emerging threats of litigation and regulatory enforcement. Jonathan S. Marashlian may be reached by email or by phone at 703-714-1313.

A prior version of this piece was published on October 6, 2021, on TransNexus. This lightly-edited Expert Opinion is reprinted with permission. Broadband Breakfast accepts commentary from informed observers of the broadband scene. Please send pieces to commentary@breakfast.media. The views expressed in Expert Opinion pieces do not necessarily reflect the views of Broadband Breakfast and Breakfast Media LLC.

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Mike Harris: Investing in Open Access Fiber Optics is Investing in the Future

Chattanooga’s municipal broadband network has delivered $2.7 billion in social and economic benefits during its first decade.

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The author of this Expert Opinion is Mike Harris, the co-founder of SiFi Networks.

In the United States, most Internet Service Providers are privately owned companies who have established copper network infrastructure exclusively for their own use, forcing customers into often unreliable, unsustainable internet package deals. But in 2010, the small city of Chattanooga, Tennessee invested in an early publicly owned fiber optic network.

As the co-founder of open-access telecom company SiFi Networks, I believe that investments in similar open-access infrastructure will help bridge community divides and futureproof a city’s economic and social prosperity.

According to a study by Bento Lobo, department head of finance and economics at the University of Tennessee, Chattanooga’s municipal broadband has delivered over $2.69 billion worth of social and economic benefits during its first decade. With a population of just 185,000, imagine the potential savings for a city the size of New York.

So, how did Chattanooga achieve this and what were the city’s motivations?

Motives behind the madness

In 1969, Chattanooga was dubbed America’s dirtiest city. A post-industrial wasteland, it entered the late twentieth century with a stagnant economy, declining population and high levels of unemployment following the closure of its large manufacturing factories. It’s not surprising that decades later publicly owned utility company, EPB, chose to invest in its residents’ future.

EPB began replacing the underground copper wiring — originally established to exclusively handle telephone calls — with fiber optic cables feeding connectivity to the entire community. Fiber optic networks are vastly superior to copper because they can transport data using photons travelling at the speed of light. Previous infrastructure uses electrons capable of less than one per cent of that speed.

Where before Chattanooga was perceived as an underdeveloped, low-income area, suddenly businesses were moving in, employment was growing, and more adolescents were graduating from high school. Is it about time for other cities to follow suit?

Why other cities should follow suit

Internet connectivity is a human right much like water, electricity and gas utilities. Yet 21 million U.S. citizens are still living without reliable broadband according to the Pew Charitable Trusts. Research also shows that 40 percent of schools and 60 percent of healthcare facilities outside metropolitan regions lack internet download speeds of at least 25 Megabits per second (Mbps) and upload speeds of at least 3 Mbps. This is the acceptable speed defining a reliable broadband connection.

As the Chattanooga model demonstrates, the solution is the establishment of fiber optic infrastructure. With fiber networks, EPB offers residents and businesses gigabit speeds of up to 1,000 Mbps, or 1 Gigabit per second. In hindsight, with this capacity Hamilton County was well equipped to deal with the 75 percent increase in total volume of bandwidth being used per day during the pandemic, with residents being forced to work and educate from their homes.

These gigabit speeds also allow for a high degree of network responsiveness necessary for establishing a smart grid system. Most US cities use standard grid systems, which rely on consumers informing a service when they have a power outage or system failure.

Smart grids establish a two-way communication network using digital devices and automation so that service providers are notified immediately when problems occur. EPB’s Hamilton County smart grid, for example, can quickly re-route power around storm damage decreasing outages by 40 per cent in minutes, according to Lobo’s study. He estimates Chattanooga’s consumers will save $20.6 million per annum simply from avoiding spoilage and loss of productivity due to power outages.

Saving money, saving livelihoods

EPB has more than proven that fiber networks are a socioeconomic investment benefitting everyone, not just those lucky enough to live in a fiber area. Better, faster connectivity will enable businesses in all neighbourhoods to thrive, creating job opportunities. During the ‘gig decade’ (2011-2020), EPB’s fiber network directly supported the creation or retention of approximately 9,500 jobs in Hamilton County, luring the migration of global corporations like Volkswagen. The U.S. Bureau of Labor Statistics has reflected this, stating Hamilton County’s unemployment rate being 4.7 percent as of November 2020, compared to the U.S. overall percentage of 6.7.

Chattanooga at night

The social benefits don’t stop here. A study by South Australia’s premier, Jay Weatherill, correlated gigabit networks with improved support for police and fire communications, wastewater management, traffic control and medical diagnostics. These are all features of SiFi Networks’ FiberCity and if Chattanooga has demonstrated anything, it is that fiber networks improve residents’ quality of living above all else.

FiberCity — the next step?

Chattanooga has demonstrated the importance of staying connected. To this end, becoming a SiFi Networks FiberCity could be the next step for cities across the US.

Privately financed networks, like SiFi Networks’, are often the best option to guarantee necessary funding for construction, maintenance and expansion of fiber infrastructure. Municipalities wouldn’t have to rely on taxpayer’s dollars, which can instead be diverted to healthcare, education and other social entities. During a period of continuous technological evolution, FiberCities have one simple mission: to combine advantages of Chattanooga’s gigabit speeds with futureproofed smart city services across the U.S.

Mike Harris is a successful entrepreneur and technologist, having previously founded Total Network Solutions Ltd in 1989, which he later sold to UK telecoms giant British Telecom in 2005. He subsequently co-founded SiFi Networks and is a current investor in the company. He is also the chairman and owner of the New Saints Football Club in Wales, UK. This piece is exclusive to Broadband Breakfast.

Broadband Breakfast accepts commentary from informed observers of the broadband scene. Please send pieces to commentary@breakfast.media. The views expressed in Expert Opinion pieces do not necessarily reflect the views of Broadband Breakfast and Breakfast Media LLC.

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