The BroadbandCensus.com List of NTIA Comments

Editor’s Note (5/22) – The BroadbandCensus.com List of NTIA Comments is being updated. Check back frequently to view additional summaries of the substantive comments filed in this broadband proceeding.

If you have a question about, or suggestion for, the BroadbandCensus.com List of NTIA Comments, please e-mail Cody Williams, williams@broadbandcensus.com.

WASHINGTON, April 19, 2009 – Building on its prior lists of comments filed with the Commerce Department’s National Telecommunications and Information Administration on April 13, 14 and 15, on Sunday BroadbandCensus.com published a collective list of 222 substantive comments regarding the $7.2 billion federal broadband stimulus program.

The BroadbandCensus.com List of NTIA Comments is below, listed in alphabetical order by organization. The date of the filing is included, as well as a link to the filing on the NTIA’s web site. For a growing number of comments, BroadbandCensus.com has provided a brief summary of the contents of the comment.

Comments for the NTIA/Rural Utilities Service broadband grants program were accepted beginning March 10. The official final filing date was Monday, April 13.

All told, nearly 1,700 individuals and organizations submitted questions or comments in the rule-making. The public NTIA web page where the comments are listed is http://www.ntia.doc.gov/broadbandgrants/comments.cfm.

Individuals with questions about the BroadbandCensus.com List of NTIA Comments should e-mail Cody Williams, williams@broadbandcensus.com

The BroadbandCensus.com List of NTIA Comments

71 Concerned Economists, Using Procurement Auctions to Allocate Broadband Stimulus Grants, organized by Paul Milgrom, Stanford University; Gregory Rosston, Stanford Institute for Economic Policy Research; Andrzej Skrzypacz, Stanford; and Scott Wallsten, Technology Policy Institute | April 13 | Comment

Access Delray | April 1 | Comment | Brad Bowman of Access Delray, based in Gulfstream, Florida, championed municipal Wi-Max, specifically in the 3.65 GigaHertz (GHz) band. Bowman states that America should cut the cord and go wireless as much as possible, and go straight to municipalities. He said, “It is a fact that there is no room for a middle man in the offering of core network access and services as evidenced by Earthlink’s and AT&T’s retreat from the Muni-Wireless marketplace.”

Access Delray | April 13 | Comment |  (Updated filing) filed to emphasize the importance of wireless networks – specifically those created and run by municipalities.  Matching funds should be used as much as possible, since the leverage they create will allow more Americans to become connected to the internet.

Access Delray | April 6 | Comment | Access Delray filed a petition to examine competitive practices in the 2.5Ghz band. Access Delray noted that Sprint/Clearwire have gained access to much of this spectrum, and hopes that the new Federal Communications Commission should examine the details of these dealings.

Ad Hoc Telecom Manufacturers Coalition | April 1 | Comment | The coalition, including AC Photonics, ACD Telecom, FiberControl, Minerva Networks, Sandvine, Sunrise Telecom and Vermeer Corp., answered the joint request for information questions directly, suggesting exact criteria for many parameters, such as the percentage of funds that should go to unserved and underserved communities. ACD recommended that funds be split as follows: 15percent to unserved, 5 percent to underserved, 15 percent to education, 25 percent to public safety, and 15 percent to demand stimulation. ACD and the ad-hoc coalition believe that projects should meet multiple needs. States should not be able to approve/disapprove grants, but should have some role in the program. Program criteria should include: Minority-owned businesses, technical approach and depth of research to the project, and the qualifications and capabilities of the person applying. The coalition said that broadband mapping should be at the city level.

Advanced Emergency Communications Coalition | April 13 | Comment | Lemko states that unserved should be defined as an area where mobile broadband service covers less than 20% of the geographic area, and underserved as an area where fewer than 3 mobile broadband providers deliver service in at least 80% of an area.  Considerations should be the ability to provide service to the maximum number of people, the long-term sustainability of the project, with speed a minor factor. Priority should be given to “shovel ready” projects, and ones that leverage other Stimulus funds.  Beyond rural projects, applications should be ranked in the following order of priority:  creating a choice of providers; any fully funded “shovel ready” projects; and previous RUS borrowers.

Alabama | April 13 | Comment | Alabama comments that NTIA should focus on creating objective criteria, and defer to the states as much as possible.  In unserved areas, applicants should be required to show that the proposal requires federal grant assistance.  Having a USDA loan in the same geographic area should not pre-empt an NTIA grant in the same area – as long as the NTIA grant is for a different service.  Each State broadband map should show wireline and wireless coverage, and any federal funds the state receives for broadband activities.

Alaska | April 13 | Comment | The Regulatory Commission of Alaska supports NARUC’s proposal, which allow the states to conduct an initial review of applications, before final NTIA approval.  Grants to for-profit entities should be allowed, provided that the grant will not result in unjust enrichment to the entity or its shareholders.  Grant applicants should agree to the public release and public use of mapping data that is consistent with the confidentiality standards established.  The NTIA should clarify whether a 20% contribution is required for eligible entities applying for broadband mapping grants under the DBIA.  An unserved area is an area where there are “no facilities-based Internet access other than dial-up and satellite based access.”

Alcatel Lucent | April 13 | Comment | Alcatel Lucent believes that the NTIA should issue grants to state and local public safety officials for deployment of broadband networks in the 700 MHz band.  For-profit service providers should be allowed to participate in the program, in order to maximize the ability of BTOP to provide for broadband deployment in unserved and underserved markets.  Unserved area means “no broadband available.”  Both NTIA and RUS should waive application of ARRA’s Buy American provision to broadband equipment.

Allied Fiber | April 13 | Comment | Allied Fiber states that NTIA and RUS should give funding priority to middle mile and backhaul projects on the basis of capacity and neutral connectivity. Access points to middle mile facilities, backhaul facilities, and the Internet backbone should be open to all carriers, regardless of technology.

AlphaStar | April 2 or April 3 | Comment | AlphaStar requested that the Federal Communications Commission be actively involved in the proceedings, specifically with the FCC’s expertise with small cap and minority owned businesses. AlphaStar proposed a hybrid model involving terrestrial broadband and satellite backhaul. Broadband funds would allow AlphaStar, who first rolled out this network in 2000, to roll out this network in unserved and underserved areas as sought by the fiscal stimulus measure.

Alvaron, Inc. | April 14 or April 15 | Comment | Alvaron requests that NTIA and RUS engage in a comparison of appropriate technologies and determine the most cost efficient and future-proofed technology that can be deployed in today’s unserved, underserved, and rural markets.requests that NTIA and RUS engage in a comparison of appropriate technologies and determine the most cost efficient and future-proofed technology that can be deployed in today’s unserved, underserved, and rural markets.

American Cable Association | April 14 or April 15 | Comment | American Cable Association requests that NTIA and RUS apportion funds equally to “unserved” and “underserved” areas, and to any entity that has provided reliable service in the U.S. or its territories within the last three years.  ACA defines “unserved” and “underserved” areas as Census Tracts in which at least 50% of the households do not have access to reliable broadband of 1.5 Mbps downstream and 128 Kbps upstream, and 5.0 Mbps and 500 Kbps, respectively.  High capacity “middle mile” infrastructure deserves priority over “last mile” infrastructure in underserved areas.   Give equal weight to grant proposals that seek to invest in bringing both high capacity “middle mile” and “last mile” infrastructure to an “unserved” area, and finally, mandate that all applicants have 20% in matching funds and the resources and expertise to operate the facilities.

American Farm Bureau | April 13 | Comment | AFB comments that states seeking to connect unserved and underserved rural communities should be given priority.  “Unserved area” is as an area without access to broadband networks that can accommodate state-of-the-art telemedicine, education and business applications.  “Underserved area” is an area with access to broadband networks that can accommodate these applications, but has a low percentage of subscribers.

American Fiber Systems | April 13 | Comment | American Fiber Systems suggested that all certified carriers by should be deemed eligible grant recipients.  Each grant recipient must have 2% or less of the subscriber lines nationally to be eligible.  Municipally owned utilities should be subject to 47 U.S.C. §224 as a condition for receiving stimulus funds.  “Broadband” should be defined as not less than 100 megabits.  “Underserved” should be defined as any area where 90% or less of the population has access to broadband from one provider.  “Unserved” is an area receiving no service or a service lower than 10 megabits from one or two providers.  Priority should go to projects that involve a public/private partnership, have an open network being deployed, and satisfy local needs as identified by such entities.  The FCC should ensure competitive deployment of “open-network” broadband facilities, and prohibit the concentration of any broadband market share in any geographical area, in addition to enforcing any violations of conditions imposed upon stimulus fund grant recipients.  In awarding stimulus funds priority should be given to long-term job creation.

American Legislative Exchange Council | April 13 | Comment | Says the NTIA should not favor private networks over municipal networks.  The NTIA should encourage states to confuse streamline broadband mapping efforts, and should not impose new broadband regulations through non-discrimination or interconnection obligations, but adhere to the FCC’s 2005 Internet Policy Statement.

American Library Association | April 13 | Comment |As “community anchor institutions,” funding should consider libraries’ unique role and special function in the community and should not be discriminated on the unserved or undeserved basis of residential broadband availability.  Private investors should be rewarded for investing in community institutions.  Also, the ARRA should fund hardware and tech support that must be upgraded to support high-speed broadband.  The NTIA should allow multi-state and in-state applications beyond state and national-level applications.  Broadband mapping should be open to community service organizations, including a focus on library broadband coverage, and be open for public view.

American Public Power Association | April 13 | Comment |Smaller communities are lagging in areas of communication, whereas larger American cities are falling behind their European counterparts all the same.  Funding for multipurpose beneficiaries should come from alternate federal funding unless they: (1) meet all BTOP requirements, (2) disclose all supporting federal subsidies, (3) do not “double dip”.  Issues of the states should be considered when distributing BTOP funds.  The NTIA must screen applicants well on intentional use of funds, and not conflict with the applicants’ proposed project. Disproportionate interest should not be given to unserved or underserved broadband areas, but instead the NTIA should reward innovative projects.  The NTIA should avoid targeting specific technologies.  Speed, quality, and affordability should be considered in an applicant’s proposal.  The RUS should offer loan guarantee options without targeting unserved areas only.  RUS need not consider the applicant’s loan status as a previous borrower except in the cases of a “tie-breaker” with another borrower, in unserved areas.

American Tower | April 13 | Comment | says that infrastructure projects should be able to seek direct funding from the NTIA. Recipients need not be penalized for delays on behalf of the government and “shovel ready” infrastructure projects should be rewarded. Projects adequately funded after February 17, 2009 should not be considered for NTIA financing. The NTIA should not require projects to submit multiple purposes in order to gain funding.

ApexCoVantage, which focuses on broadband mapping | April 13 | Comment | Believes that the initial use of the map should be to identify unserved and underserved areas, and must be based on a flexible and dynamic database, based on similar standards as the OECD data.  The map should be able to identify specific user groups, and should be able to determine the available speed tiers, number of providers, and rates for service in an area.  The map should be a tool to track the construction progress as the recipient organizations extend broadband availability into unserved and underserved areas, and have the ability to track the affordability of broadband access.

Apple, Inc. | April 13 | Comment | suggested that projects should be forward looking, technology neutral, and are able to provide affordable broadband when completed, irregardless of the technology used.  Apple believes a minimum speed threshold for wireline projects should be at least 50 Mbps, and at least 14 Mbps for wireless projects.  Proposals should specify both maximum/aggregate speeds as well as average speeds per user.  Proposals should include a way for the government and consumers to find out what bandwidth is actually being provided at any given time.

Arizona | April 13 | Commentpriority should be given to proposals that leverage other Recovery Act projects and that address multiple purposes.  At a minimum, the map should be multi-layered, detailed to the census block level, and show community boundaries, such as categories of public owned land, fire districts, legislative districts, congressional districts, tribal lands, etc.  Consideration should be given to grants that require less than 80% funding.  “Unserved” areas is any area where there is less than a 1Mbps symmetrical connection.

Association of Public Safety Officials | April 13 | Comment | grant applicants should be required to prove that their systems can meet the mobility, security and reliability needs of first responders.  Grant applicants should demonstrate partnership with local, state and non-profit organizations in order to coordinate the deployment of broadband networks. “Underserved” is as an area where mobile broadband services cannot meet mission-critical needs of first responders, typically a speed of at least 1.5 mbps. The NTIA, RUS, and FCC need to set the standards for broadband at the minimum sustainable speed and not the maximum capable speed.  NTIA and RUS should require that public safety agencies would have priority access.

Association of Public TV Stations | April 13 | Comment | NTIA should recognize the capabilities of local public television stations to educate the public about broadband and stimulate demand for broadband, which would enable public television stations to participate in the BTOP.  NTIA should prioritize applicants that demonstrate non-profit status and show a history of public-private partnerships, and should not impose a 20% matching requirement on non-profit entities with educational missions that can certify to financial need.  Applicants should not be required to serve more than one purpose of the Recovery Act.

Association of Public-Safety Communications Officials | April 14 or April 15 | Comment | commented that grant applicants should be required to demonstrate how their systems can meet the mobility, security and reliability needs of first responders.  Systems need to be interoperable to ensure connectivity during large-scale incidents that require coordination.  NTIA and RUS should ensure that grant applicants demonstrate partnership with local organizations.  Areas that are not able to meet the majority of the criteria for well-served areas are “underserved” and areas that meet none of the criteria are “unserved.”  Any area that is not able to provide high-speed mobile broadband services to meet mission-critical needs of first responders is “underserved.”  Broadband must be at least 1.5 mbps to 3.0 mbps.  NTIA and RUS should require that public safety agencies have priority access on the networks.

AT&T | April 13 | Comment |AT&T comments that the most efficient way to disburse funding would be to direct grants to public and non-profit anchor institutions so that they can buy the services and equipment they need to fulfill their missions.  Direct grants focus the public benefits of the broadband programs on the areas most in need when considering direct funding for service providers, and fund programs that remove barriers to broadband adoption, particularly for low-income users.

Atkins Telephone, a rural local exchange carrier in Iowa | April 13 | Comment |Atkins Telephone believes that the states should only play an advisory role in the selection process.  Funding requests should rarely exceed 80% of the total grant request.  “Unserved” should be defined as speeds less than 768Kbps; “underserved” should be defined as speeds at least 768Kbps but less than 12Mbps.  RUS should divide the funds in the following manner – at least 60% for grants and the remaining 40% for loans.  RUS’s “High speed broadband service” should be the same as NTIA’s.  The definition of “Rural” should be consistent with the new definition in the 2008 Farm Bill.  Current and former RUS borrowers should receive top priority.  The selection criteria for RUS funded projects should be similar to the criteria for NTIA projects.

ATSI, a provider of voice-over-internet-protocol service | April 13 | Comment |ATSI encourages NTIA and RUS to adhere to the Recovery Act’s statutory command to provide BTOP grant funding first and foremost to “unserved” and “underserved” areas of the nation, and give priority weighting to project applications submitted by entities that can leverage existing infrastructure and experience to bring optimal speed to the market.

Barling Bay, LLC and Caption Colorado | April 13 | Comment |riteria for grants. “Unserved” or “underserved” areas, such as rural and disabled sub-populations, should be given precedent.

Benton Foundation | April 1 | Comment | Charles Benton, of the Benton Foundation said that the Broadband Technology Opportunities Program should focus on projects that will enhance long term economic opportunity, and not just short-term jobs. Multi-purpose projects can help leverage available funds and should be prioritized, he said. The program should also enhance opportunities for indigent communities. Synergies between the Agriculture Department’s RUS and NTIA should be taken advantage, leveraging RUS’ experience in infrastructure by using NTIA to focus on outreach.

Benton Foundation | March 20 | Comment | Universal broadband coverage is out of the reach of the ARRA funds in itself, but future areas of improvement should be designated.  NTIA ought to establish a “virtuous circle” that promotes supply and demand of broadband, which will extend to improve social conditions and stimulate a greater economic recovery. NTIA should remain sole distributor of ARRA funds, but should work with the state to set broadband priority standards and explore an applicant’s past. Whether public or private, grantees should be ultimately aligned with the public interest and those already obligated to provide broadband in its service area need not be eligible.

Benton Foundation/ University of Illinois | April 13 | Comment |

Beverly Hills, Calif. | April 9 | Comment | Beverly Hill also requested that no hard percentage of grants should be apportioned to any category. Projects should meet multiple goals, when possible, and should be given to those with “a proven record of successful implementation projects on budget and on-time,” said the city. The national broadband map should be at the county level, at a minimum, and ideally at the municipal level.

Big Think Strategies/Open Networks, with a correspondence address in Australia. | April 13 | Comment | Open networks ought to be the aim of NTIA policy. A contemporary definition of Open Networks would shield consumers from excess fees and eliminate negative incentives for network operators. The federal government should require network communications companies to comply with open network policy.

Bill and Melinda Gates Foundation | April 10 | Comment |

Boston, Massachusetts | April 13 | Comment | Boston plans on cooperating with NTIA broadband initiatives in order to produce the most beneficial results. NTIA should appropriately define unserved and underserved so applicants may fully know who is eligible, and where to focus. The underserved definition should not render urban centers like Boston, where the issue is more about affordability than availability, ineligible for ARRA funds. NTIA should define BROADBAND to include infrastructure for making wireless more available for all.

Bresnan Communications, Cequel Comm, Suddenlink, MediaCom, MidContinent, a group of mid-sized cable operators | April 13 | Comment | Collectively, the commenters designate four issues of concern. 1. Eligibility for grants and loans should not favor certain technologies or service providers. 2. Respecting differences between broadband and wireless, minimum data speeds for broadband should be defined as 1.5 Mbps downstream/256 kbps upstream for unserved areas and twice that speed for underserved areas. 3. The application process ought to be two-stage, with a preliminary minimum quality screening test. 4. NTIA and RUS should work together to distribute funds.

Broadband Development Corporation | April 13 | Comment | A flexible approach that uses broadband infrastructure to fit local needs must be used. In order for developments to be cost-effective, a “general contractor” should be placed locally. USDA and NTIA should work with other government agencies in order to initiate the most production. NTIA should establish a prime contractor to review all expansion projects. The prime contractor should partner with non-profit organizations to improve education and distance learning, computer ownership, and literacy, public emergency broadband communications, healthcare and veterinary care delivery, and career education.

Broadband Diversity Supporters | April 13 | Comment | Unserved and underserved low income minority consumers should take priority in broadband reform efforts. The definition of unserved must include physical access and affordability. Underserved must also account for the physical access of low-income populations that cannot afford the services currently provided.  The agencies should not delegate ARRA funding allocation to the states. Socially and Economically Disadvantaged Small Businesses (SDBs) should be given precedence to states seeking stimulus. Bundling of projects should be discouraged and not be awarded. Grant or loan payments should be paid up front in order for programs to begin development as opposed to incremental payment method. NTIA should require multifunctional mapping efforts including social, economic, and ethnic metrics to ensure the correct dispersion of funds occurs. Final contributions from an applicant should not have to equal twenty-percent of the project as this discourages market entry. NTIA should establish National Minority and Broadband Training and Technical Council to evaluate success of such improvements.

Broadpoint, a supplier to offshore oil and gas rigs | April 13 | Comment | encourages the NTIA to recognize the Gulf of Mexico offshore region as separate area. This should be done in order to improve economic stability in the region, and promote the public interest generally:  “NTIA cannot rely on an entity’s mere inability to attract capital to support a claim of financial need. Rather, NTIA should fund projects that would offer broadband services and serve the public interest but are otherwise not economically justifiable.”

California | April 13 | Comment

Center for Technology and Democracy | April 13 | Comment | NTIA must adopt a nondiscrimination requirement for all networks built with BTOP funds, no BTOP money should fund networks that would discriminate its users through limited to pre-determined or operator-selected uses, but should fund networks that connect all users to the entirety of the Internet.

Chase 3000, ISP | March 18 | Comment

Cheetah Wireless, a small wireless service provider | April 13 | Comment | Recommends that the NTIA takes into account companies serving public safety interests.  Small, local wireless providers will have a harder time applying for federal grant money and suggests that first, the NTIA be “as specific as possible as to the planned allocation of funding for each of the Act’s stated purposes,” and that states should play a larger role in determining grant recipients.  Finally, they request that the NTIA facilitates access to broadband infrastructure by providing a centralized, searchable database of backhaul options in its national broadband map.

Chicago, Illinois | April 13 | Comment | Broadband should be defined as 45 mbps downstream and 15 mbps upstream, at a minimum.  Urban areas can be as disconnected as rural areas, and the definitions of “unserved” and “underserved” should take this into account.  The NTIA should favor applicants with comprehensive strategies to increase broadband development, and states should assist the NTIA in filtering (though not ranking) applications.  Also, the NTIA must evaluate whether a for-profit entity is acting “in the public interest” carefully.

Cisco | April 13 | Comment | The company has six recommendations.  The Recovery Act should focus primarily on the deployment of network infrastructure, and should adopt broad eligibility criteria for the BTOP program.  “Unserved” and “underserved” must be defined from a purely technological perspective, and Cisco urges the NTIA to monitor efforts to improve service in both.  In addition, the NTIA must evaluate competing applications on case specific analysis, and should not impose interconnection or nondiscrimination requirements beyond those in the FCC’s Internet Policy Statement.  Finally, the Recovery Act’s “Buy American” provisions do not apply to broadband projects.

Coalition of Organizations for Accessible Technology (COAT) | April 9 | Comment | COAT highlighted the problems that disabled Americans face. Broadband adoption among disabled populations is significantly below average The NTIA should take this into consideration when ranking projects, the group said. COAT “expects applicants for the funds to involve people with disabilities through collaborations and partnerships.”

Community Connect network | April 13 | Comment | The Communities Connect Network offered six suggestions: 1. NTIA and RUS should focus on programs that stimulate demand., 2. The $450 million allocated to public computing and the “innovative adoption programs” should be considered the minimum available for these purposes., 3. Definitions and proposals focused on speed alone do not address the adoption needs of vulnerable populations in urban and rural areas., 4. Local and regional programs that re-grant to deliver services should be eligible., 5. NTIA and RUS should support capacity building networks which promote best practices and strategic coordination., 6. Affordability in broadband must also be addressed- for residents, non-profit community service providers, and small businesses.

Connected Nation | April 13 | Comment | Connected Nation notes that adopting a national policy to stimulate subscription where it is already available, and deployment where it is not, could have dramatic and far-reaching economic impacts.  A recent Connected Nation study estimated that the U.S. would generate $134 Billion in benefits by accelerating the adoption and deployment of broadband.

Connected Nation | April 14 or April 15 | Comment | Connected Nation raises three points:  1. Effective broadband mapping must take place through a collaborative, public private partnership approach., 2. The $350 million provided in the ARRA for implementation of the Broadband Data Improvement Act is not just about mapping, since the physical map is just a small part of the Broadband Data Improvement Act (BDIA)., 3. The BDIA should empower new statewide public-private partnerships, while ensuring continued funding for existing statewide programs.

ConnectKentucky | April 14 or April 15 | Comment | Emphasizes the importance of public-private partnerships, but argues that the demand-side components of the Broadband Initiative Act be linked with broadband mapping initiatives.  A successful broadband program, however, will not work without computer distribution programs for disenfranchised families and communities.

ConnectOhio | April 14 or April 15 | Comment

ConnectTennessee | April 14 or April 15 | Comment

Conxx | April 13 | Comment

Corpus Christi, Texas | April 13 | Comment

CostQuest, a providing of broadband mapping | April 13 | Comment

Coverage Co., a wireless roaming carrier | April 13 | Comment

Cox Communications | April 13 | Comment

Cricket Communications | April 13 | Comment

CTIA- The wireless Association | April 13 | Comment

Delta Regional Authority | April 13 | Comment

Discovery Communications | April 13 | Comment

District of Columbia Government | April 13 | Comment

DSSA Associates, by Don Samuelson | April 13 | Comment

EarthLink | April 13 | Comment

East Central Vermont Community Fiber | April 13 | Comment

EchoStar | April 13 | Comment

Educause | April 13 | Comment

Embarq | April 13 | Comment

Enhanced Telecommunications Corp. | April 13 | Comment

Extension Foundation | April 7 | Comment | The foundation stressed the importance of outreach using education tools to enhance the money spent on broadband connections. Helping rural businesses and entrepreneurs is an important part of connecting rural communities. Extension states that criteria for selection should include a proven track record, proof of sustainability once stimulus funds disappear, and cooperation with existing education centers should be considered.

Fairpoint, which provides telecommunications service in the Verizon network in Maine and New Hampshire | April 13 | Comment

Farmers Mutual Telephone Co. | April 13 | Comment

Fiber To The Home Council | April 13 | Comment

Fiber to the Home Council | March 26 | Comment

Fiber Tower, middle mile focus | April 13 | Comment

FiberTech Networks | March 13 | Comment

Florida | April 13 | Comment

Free Press | April 13 | Comment

Free State Foundation | March 20 | Comment

Frontier Communications | April 13 | Comment

G4 – rural local exchange carriers in New Hampshire and Massachusetts | April 14 or April 15 | Comment

G4 Communications | April 14 or April 15 | Comment

Gardonville Cooperative Telephone Association | April 13 | Comment

Garrett County, Maryland | April 13 | Comment

General Communication, an Alaskan local exchange carrier | April 13 | Comment

Georgia | April 13 | Comment

Global Crossing | April 8 | Comment | Global Crossing emphasized the importance of so-called “middle-mile” facilities. The company specifically urged NTIA to partner middle-mile providers, such as Global Crossing, with last-mile providers – those offering service to customers – so as to avoid duplicate networks. Global Crossing stated that it faces a “chicken and egg” problem: it is unable to speculatively roll out middle-mile facilities to unserved areas. It hopes that last-mile providers in unserved areas will become apparent as the application process moves forward, allowing them to provide middle-mile facilities to these new carriers.

Granite Broadband | April 9 | Comment | Granite said that no hard and fast percentage of funds should be apportioned to each category, since each state will have different priorities. The track record and existing relationship between an applicant and the community they will serve should be part of the application weighting process. Projects that leverage existing public and private assets should be given priority, and projects should be viable and sustainable after stimulus funds disappear. NTIA should not contract with one group to create the national broadband map, said Granite Broadband. Rather, this should be done on a state level, either by NTIA or by a contractor.

Great Plains | April 13 | Comment

Harris Corporation | April 13 | Comment

HeirComm | March 17 | Comment

Hispanic Information and Telecommunications Network | April 13 | Comment

Home Town Cable, a small fiber-to-the-premises provider | April 13 | Comment

IEEE, a technical standards body | April 13 | Comment

ILSR | April 13 | Comment

Independent Telephone and Telecommunications Alliance | April 13 | Comment

Independent Telephone and Telecommunications Alliance | March 18 | Comment

Infinera | April 13 | Comment

InLine | April 6 | Comment | InLine wrote to emphasize three points: (1) funding priority should be given to small- and medium-sized businesses with established records of providing quality broadband services to suburban and rural areas, (2) many areas outside of urban centers have very limited or no access to broadband, and (3) review of grant applications should have input from the state level, but not necessarily directly from state governments.

Intel | April 13 | Comment

International Broadband Electric Communications, Inc. | April 10 | Comment

Intrado Inc. | April 10 | Comment

Iowa Health System | April 13 | Comment

Iowa Health Care | April 13 | Comment

Iowa Utility Board | April 13 | Comment

JAB Wireless | April 9 | Comment | JAB defined an unserved area as one in which service of at least 3 Megabits per second (Mbps) download speeds are not available. An underserved area is an area where there are not two or more providers who can provide 3 Mbps downloads. Projects that can provide short turnaround, and those that provide a least cost solution should be prioritized in the scoring process, the group said.

Jaguar Communications | April 13 | Comment

Juan Eugenio Rodríguez de Hostos, chief information officer of the territory of Puerto Rico | April 9 | Comment | Hostos requested that NTIA take a holistic approach to the stimulus. When establishing priority for funds, NTIA should look to state’s broadband plans, to ensure the best solution.

Kansas Corporation Commission | April 2 or April 3 | Comment | Kansas fully supports NARUC’s position. Kansas specifically points out NARUC’s proposal to allow states to “opt-in” and receive funds to create two to four full-time job equivalents to review applications as a way to quickly allow states and the federal government to partner.

Kentucky Municipal Utilities Association | April 13 | Comment

Kodiak Kenai Cable Company, LLC | April 13 | Comment

Lake County Board of Commissioners, Minnesota | April 8 | Comment | Paul Bergman, a member of the board of commissioners, wrote to emphasize the plight of rural counties. Bergman said he understood that counties such as his have a low return on investment for carriers. However, he said he hoped that program funds would help “level the playing field for underserved counties,” with more jobs and education opportunities for children

Lariat, a wireless internet service provider focusing on the “middle mile” issue | April 13 | Comment

LEMKO Corp., next gen wireless | April 13 | Comment

Level 3 | April 14 or April 15 | Comment

Loudon, Virginia | April 13 | Comment

Maine Public Utility Commission | April 13 | Comment

Massachusetts Department of Telecommunications and Cable, Vermont Department of Public Service, and the Massachusetts Broadband Institute | April 13 | Comment

Media &-Democracy Coalition (amended filing) | April 14 or April 15 | Comment

Media and Democracy Coalition, the point person for a coalition of non-profit organizations | April 13 | Comment

Michael Swack, of the University of New Hampshire | April 13 | Comment

Michigan | April 13 | Comment

Michigan Public Service Commission | April 13 | Comment

Microsoft | April 14 | Comment

Minneapolis, Minnesota | April 13 | Comment

Missouri | April 14 or April 15 | Comment

Montana Independent Telecommunications Systems | April 13 | Comment

Montana Telecommunications Association | April 13 | Comment

Motorola | April 13 | Comment

MSS and ATC Coalition | April 13 | Comment

National Association of State Utility Consumer Advocates (NASUCA) | April 13 | Comment

National Association of Telecommunications Officers and Advisors (NATOA) | April 10 | Comment

National Cable and Telecommunications Association | April 13 | Comment

National EBS Association | April 7 | Comment | The National EBS Association wrote to champion the 2.5 GHz educational band of wireless frequencies, and point NTIA to the advantages this band could have in un and underserved areas. Also, the speeds of wireless networks and wireline networks should conform to different benchmarks. Current WiMax speeds of 3.0 Megabits per second (Mbps) download and 768 Mbps upload should be the wireless standard. Multiple goals should be addressed by applicants, and EBS holders should be eligible for funds.

National Emergency Number Association | April 13 | Comment

National Exchange Carrier Association | April 13 | Comment

National Exchange Carrier Association, second filing | April 13 | Comment

National Rural Electric Cooperative | April 13 | Comment

National Rural Telecommunications Cooperative | April 13 | Comment

National Rural Telecommunications Cooperative, DigitalBridge Communications Corp. | April 13 | Comment

National Telecommunications Cooperative Association | April 13 | Comment

National Tribal Telecommunications Association | April 13 | Comment

National Tribal Telecommunications Association | March 22 | Comment

Native Federation, an organization of Native Americans | April 13 | Comment

Native Public Media, promotes access and ownership of media by Native communities | March 25 | Comment

Nebraska | April 14 or April 15 | Comment

Nebraska Rural Independent Companies | April 13 | Comment

Nevada System of Higher Education | March 23 | Comment

New York State | April 14 or April 15 | Comment

New York, New York | April 13 | Comment

Next G Networks, a wireless company | April 13 | Comment

North Dakota | April 13 | Comment

Northern Valley Communications | April 13 | Comment

NWT Enterprises, which urges wireless backed by fiber | April 13 | Comment

Oakland County, Michigan | April 13 | Comment

Ohio | April 13 | Comment

Ohio Public Utilities Commission | April 2 or April 3 | Comment | The Ohio PUC pointed out the challenges facing both Commerce Department’s National Telecommunications and Information Administration and Agriculture Department’s Rural Utilities Service. In late March NARUC laid out a detailed proposal for guaranteeing a state role. NTIA must continue to oversee the DTV transition and RUS has existing programs in place that they must manage. With these existing commitments in place, the states must play a key role in the stimulus, the state said, as did NARUC. Ohio requested that the states be able to use their first-hand experience within their borders to rank the project applications, with criteria specified by RUS and NTIA as guidance. By allowing the states an active part of the process, resources for both states and the federal government will be saved.

One Economy Corp. (Updated) | April 13 | Comment

One Economy Corp., a non-profit group | April 13 | Comment

OPASTCO, the Organization for the Promotion and Advancement of Small Telecommunications Cooperative (second filing) | April 13 | Comment

OPASTCO, the Organization for the Promotion and Advancement of Small Telecommunications Cooperatives | April 13 | Comment

Open Cape Corporation | March 16 | Comment

Open Range Communications | April 13 | Comment

PACCAR Medical Educational Center | April 8 | Comment | John Gabis, executive director of PACCAR, stated, “in Appalachia, the next highway is the broadband highway.” Broadband could help PACCAR provide live and recorded healthcare to rural healthcare professionals, he said.

PAETEC Communications, Inc., and McLeodUSA Telecommunications Services, Inc. | April 14 or April 15 | Comment

Palo Alto, California | April 13 | Comment

Pan Asian Chamber of Commerce | April 2 or April 3 | Comment | The Pan Asian chamber encourages NTIA to “quickly, efficiently, and transparently disburse the stimulus funding to states” and to be careful to not create “bureaucratic stipulations and barriers that will make it difficult for states to acquire these much needed funds.”

PCIA – The Wireless Infrastructure Association | April 2 or April 3 | Comment | PCIA and the DAS Forum, a membership section of PCIA, said they have “a significant interest in the framework of broadband stimulus grant programs” since wireless broadband service is currently being provided by four or five carriers, with more on the way. Each carrier requires “approximately 35,000 wireless facilities to deploy a nationwide broadband service.” Broadband grants would “transform…unsustainable business models into positive business cases for wireless infrastructure,” allowing a higher level of roll-out than previously possible. PCIA defines “underserved” as an area “in which there is only one provider of ubiquitous wireless broadband service,” and “unserved” as any area where “no wireless broadband service is available.”

Pend Oreille County Public Utility District Number 1, Washington | April 13 | Comment

Pennsylvania | April 13 | Comment

Pennsylvania | April 14 or April 15 | Comment

Pennsylvania Governor’s Office | April 13 | Comment

Plymouth, Indiana, Chamber of Commerce | April 6 | Comment | The chamber of commerce outlined several guidelines they believe the program should follow. An emphasis on dark fiber projects, areas that have high unemployment, greater than 2 percent of national average, and an emphasis on areas classified as rural by the Agriculture Department should get priority in funding. Plymouth also defines underserved as an area that has broadband available to 60 percent or less of the population.

Public Interest Spectrum Coalition | April 7 | Comment | The Public Interest Spectrum Coalition pointed out several criteria they believe NTIA should follow. PISC said that the role of the states should be limited, and a $25 million “small entities” fund should be created. In addition, participants should operate open, interconnected, and nondiscriminatory networks. NTIA or the FCC should consider pre-empting state laws that would serve as boundaries to potential participants.

Public Knowledge, Report on Connected Nation by Art Brodsky | March 24 | Comment

Public Safety Spectrum Trust Corporation. This comment focuses on the 700 MegaHertz swatch of wireless frequencies, and its use by public officials. | April 13 | Comment

Puerto Rico Telephone Co. | April 13 | Comment

Qualcomm | April 13 | Comment

Rabbit Internet Services | April 1 | Comment | Gene Stone of Rabbit states that he “would prefer that NTIA grants not require 20% funding by those receiving grants.”

RapidDSL and Wireless | April 14 or April 15 | Comment

RCN Corporation | April 14 or April 15 | Comment

Regional Fiber Consortium | April 9 | Comment | The Regional Fiber Consortium said that it will be counterproductive to divide the funds for different purposes. Funds should be awarded on a competitive basis. They also said: states should not create their own criteria, but follow those set by Congress; broadband mapping must be done below the census tract level. Mapping at the census tract level – which is only slightly less granular than the ZIP code level – would skew actual broadband availability

Ridgeview Tel | April 13 | Comment

Rural Carriers | April 13 | Comment

Rural Cellular Association | April 13 | Comment

Rural Cellular Association | April 13 | Comment

Rural Fiber Alliance | April 13 | Comment

Rural Independent Competitive Alliance | April 13 | Comment

Rural Mobile Broadband Alliance | April 14 or April 15 | Comment

Rural Telecom Group | April 13 | Comment

Rural Telephone Service, Co. | April 13 | Comment

Sacred Wind Enterprises, carrier serving the New Mexico portion of the Navajos | March 24 | Comment

San Antonio Public Library, San Antonio, Texas | April 9 | Comment | The library wrote to emphasize the importance of libraries and the public computing centers they house. The definition of underserved should contain a library component, where rural areas without a public library within 10 miles, or an urban area where there is not a library within four miles are considered underserved

San Francisco, California | April 13 | Comment

SDF Consortium, a wireless network contractor | April 13 | Comment

Seattle, Washington | April 13 | Comment

SEDA- Council of Governments- local development district in Pennsylvania | March 24 | Comment

Shafter, Calif. | April 13 | Comment

Siemens Enterprise Communications | April 10 | Comment

SkyTerra, which urges 20 percent to satellite services | April 13 | Comment

Small Business Administration | April 13 | Comment

Smith Bagley | April 13 | Comment

Southern Linc Wireless | April 13 | Comment

Southern Ohio Health Care Network | April 8 | Comment | Marcus Bost, of the health care network, urged policymakers to examine the metrics available. For example, 94 percent of households have a broadband connection, but 41 percent of Ohio’s surface area does not have a broadband connection. This represents nearly 500,000 people in the 34 counties covered by Connect Appalachia.

Spacenet, a satellite provider | April 9 | Comment | Spacenet recommended that NTIA offer a coupon program, such as they did with DTV, in order to overcome startup costs with satellite broadband. Spacenet pointed out that satellite broadband service is already available in rural areas

Sprint/Nextel Corporation | April 10 | Comment

Spot On | April 13 | Comment

Stayton Cooperative Telephone Company | April 13 | Comment

StepHouse Networks | April 14 or April 15 | Comment

Stratum Broadband | March 31 | Comment

Sunesys, LLC | April 13 | Comment

Tele Pulse Technology | April 13 | Comment

Telecommunications Industry Association | April 14 or April 15 | Comment

TelePacific, which focuses on underserved areas. | April 13 | Comment

Texas Statewide Telephone Coop | April 13 | Comment

T-Mobile USA, Inc. | April 13 | Comment

Trace Center, University of Wisconsin | April 13 | Comment

TracFone | April 13 | Comment

Triangle J Cable Broadband Consortium, a group of North Carolina government providers of cable broadband service | April 13 | Comment

Tunica, Mississippi | April 7 | Comment | Rodney Gilcrist, Technology Director of Tunica, said he wanted to use stimulus funds to roll out existing fiber to local residents that currently do not have broadband. Excess capacity was rolled out to Tunica’s municipal buildings, and this fiber backbone could be put to use with residential connections.

Tyco Telecom | April 13 | Comment

U.S. Chamber of Commerce | April 13 | Comment

Universal Service for America Coalition | April 13 | Comment

University of Texas law students, a comprehensive filing. | April 13 | Comment| The University of Texas recommends creating an alternative dispute resolution mechanism, a best practices center, a mandatory “model terms of service,” and proceed in a technology neutral manner.

US Cellular | April 13 | Comment | US Cellular believes that the state’s opinions should be noted, but they should not be given final say.  Any entity holding a license to provide telecommunication service from a state or from a federal agency should automatically be eligible for ARRA funds.  The NTIA must look for the best bang for the buck – for example, if 100 people could be served by fiber for the same price that 1000 people could be served by a wireless connection with a max speed of 2Mbps, NTIA should choose the latter.

US Telecom | March 18 | Comment |USTelecom urges the NTIA to focus on projects that will provide broadband and jobs as soon as possible, central part of the stimulus bills.   Companies that already provide broadband service should be eligible for grants, since these entities can create jobs and broadband connects quickly.

US Telecom Association, the trade association of incumbent telecommunications carriers. | April 13 | Comment | USTelecom believes that states should be involved in the grant process, but should not have the final decision.  Several determining factors include: Providing service to unserved and underserved areas, the sustainability of the project, the timeline of construction, the speed that it will provide, affordability of the service, the impact on job creation, public cost, and if it is a public interest project.

Utopian Wireless | April 13 | Comment | Utopian Wireless believes that wireless and wireline broadband should be defined separately, with wireless having a speed of at leas 3Mbps, and wireline being above 20Mbps.  For-profit entities should be eligible for funding, and states should have a role in identifying projects, but their decisions should not be a determining factor.  Unserved areas should be given priority, but in unserved areas where there are multiple project proposals, the following criteria should be used:  1. Applicant has committed to offering a free service.  2. Applicant is a small or start-up business, 3. Applicant can quickly deploy their network, 4. Applicant has a FCC wireless license or access to spectrum.

Van Horne Cooperative Telephone Company | April 13 | Comment | Believes that states should be involved, but only with an advisory role.  A demonstrated history of providing broadband, and a community focus should be a plus for applicants.  The 20% matching funds provision should be enforced, and those able to exceed the 20% should be given a higher score.

Verizon Communications | April 13 | Comment | Projects should focus on “unserved” areas first, and if there are funds remaining after these projects, demand stimulation should be addressed.  The NTIA should continue to use the FCC’s Internet Policy Statement.

Vermont Center for Geographic Information | April 7 | Comment | The center outlined what they believe to be the best criteria for the nationwide broadband map. The map should include DSL, fiber, cable, WISP, and wireless voice and data coverage. Those available should be mapped down to street level. Vermont also states that there is little reason for carriers to claim that releasing the information would put them at a competitive disadvantage.

ViaSat | April 13 | Comment | believes that broadband should be defined differently for “unserved” and “underserved” areas.  Broadband in “unserved” areas should be at least 768kbps down and 256kbps up.  “Underserved” areas should be at least 4Mbps down and 1Mbps up.

Virginia | April 13 | Comment | NTIA and RUS should allow other leveraged funds, such as municipal resources allocated to the project, to meet the 20% matching requirement.  Money for broadband mapping should be allocated directly to the states.  Any publicly owned entity, designated as a community center, not just community colleges and libraries, should be eligible for the $200M set aside to fund community computer centers.

VOIP Logic | March 12 | Comment | The $250M set aside for innovation in broadband should go to a wide variety of projects.  Due to the large growth in wireless broadband, particular attention should be paid to these projects.

Vonage | April 13 | Comment | believes that NTIA and RUS should articulate what constitutes “reasonable network management,” since, in their opinion, the Comcast Order showed that the FCC’s Internet Policy Statement is not specific enough.  Any standards articulated should be for the life of the BTOP grant.

Washington | April 13 | Comment | States should have a meaningful role in the process, and NTIA should aim to be as flexible as possible.  State broadband maps are not necessary, local officials may have the insight necessary to understand where broadband is needed.

Washington Public Utility Districts Association | April 8 | Comment | requested that high standards should be set, and that competition should be encouraged, since competition means “lower price, more choice, and better service.”

WCAI, additional filing | April 9 | Comment | The group also submitted its comments a second time in the Adobe PDF format.  WCAI wants the NTIA to consider wireless and wireline networks seperately.  “served” should be an area without wireless broadband, and should not require symettric speeds for wireless networks.  “Middle mile” projects hould be considered when appropriate, and projects that aim to connect both “un” and “underserved” areas should be considered concurrently, instead of considering “unserved” projects first.

Western Iowa Networks | April 13 | Comment | States can play a role, but only an advisory role.  Six criteria should be examined when ranking projects:  1. Ability to proivde infrastructure, 2. Provide service to Commuity Anchor Institutions, 3. Applicant’s experince, 4. feasability, 5. Sustainability, 6. Ability to complete in a timely manner.

Western Telecommunications Alliance | April 10 | Comment | The NTIA should use the current FCC definition for broadband – 768kbps or greater.  “unserved” is an area that does not have a non-satellite provider that meets this 768kbps threshold.  “underserved” areas are ares that do not have a non-satellite provider that offers speeds in the 10 to 15 Mpbs range.

WGBH in Boston, a public television station, with a comment focusing on people with disabilities. | April 13 | Comment |Accessability must play a role, with accessability requirements in all grants.  Some portion of funds should be set aside for long-term cooperative agreements to ensure cost-effective and technology-neutral ways to impliment this technology.

WiMax Forum | April 13 | Comment | Competition, both at the consumer level, and in “middle mile” facilities, should be encouraged.  Also, officials should be cognizant of the difference in networks, since only wireless networks can provide service to first responders and others.

WindStream | April 14 or April 15 | Comment | NTIA should offer stimulus funds in solely in grants.  This would allow Windstream, and similarly situated carriers, to deploy broadband to those areas of their wireline network where rolling out broadband is unfeasable.  Any network built with Stimulus funds should conform to the FCC’s Internet Policy Statement for at least two years.

Wirefree Partners | April 14 or April 15 | Comment | Priority should be given to those that have a proven track record, and currently have “shovel ready” projects.  Middle mile facilities and wireless projects should not be forgotten, and credit should be given for recent investments in broadband.

Wireless Communication Alliance International | April 8 | Comment | WCAI stated that now is the time to experiment with new technologies, since our networks are transitioning from copper to fiber. Experience should play a part in selection criteria, as well as projects that expand public computer centers.

Wireless Communications Association International | April 9 | Comment | WCAI agreed with previous commenters’ suggestion that wireless networks should be built out in unserved and underserved areas. WCAI said that “unlike fixed services, mobile wireless broadband provides mobility.” Mobile broadband has the potential to produce both good mobile and good broadband. NTIA should give “substantial consideration” to the states, but not delegate all power to them. Finally, mobile wireless and fixed wireless should also constitute separate product markets.

Wireless Internet Service Providers Association | April 10 | Comment | WISPA, a trade organization that is composed of many small wireless providers, specifically answered the NTIA’s questions in their comments.  Some of these answers include proscribing at least 50% of funds to “unserved” areas, and at least 25% to “underserved” areas.States should not play a role in the process – NTIA should rank all projects independent of the states.  Overall, NTIA should focus on proposals that will provide broadband to unserved and underserved areas.

Wireless Philadelphia | April 6 | Comment | Wireless Philadelphia wrote to emphasize the on-the-ground expertise that many commenters have. They wrote that “a comprehensive package of technology services is essential, and is best delivered through established community-based organizations to which economically disadvantaged populations are already connected.” Wireless Philadelphia, and organizations like them, have the experience to maximize the impact of stimulus funds.

Wisconsin Department of Commerce | April 8 | Comment | The department of commerce suggested that NTIA focus on communities defined as “low income communities,” as defined by the Treasury Department’s Community Development Financial Institutions Fund. These communities could be further limited by targeting those defined as rural communities. Unserved should be defined as an area where less than 50 percent of households have access to a digital subscriber line (DSL) or cable connection. An underserved area should be one where less than 50 percent of houses subscribe to a DSL or cable connection, regardless of availability.

Wyoming | April 14 or April 15 | Comment |Wyoming would like for NTIA to focus the process – preferring fewer proposals to more.  Wyoming would like to be involved in the selection process, but would prefer not to be a grantee.  Backbone facilities are critical, and should be given priority.  The matching funds requirement should also be dropped.

XO Communications | April 13 | Comment | The five factors articulated in the ARRA should carry equal weight – projects that attempt to skew the five factors in favor of one should be rejected.  “Broadband” should be defined as 5Mbps down, and 1Mbps up.  Any scoring criteria should take the stimulus effect of the ARRA first, and after this factor is considered, the specifics of the BTOP program, such as speed or availability, should be considered.

Zero Divide | April 6 | Comment | Zero Divide stated several criteria it wished NTIA to follow. These included awarding grants to those that are already experienced in their field, and leveraging stimulus funds should be encouraged, but not required. Likewise, those with 20 percent matching funds on hand should be given greater weight when evaluating applications. Some weighting criteria proposed includes replicable models and proven methods that create public/private partnerships.

Zero Divide, a comprehensive filing by a non-profit organization. | April 13 | Comment | NTIA should award grants to experienced entities, and encourage for-profit companies to partner with non-profits.  More than one purpose of the BTOP grant should be encouraged, but not required.  An 8 factor criteria is also articulated.

Zhone Technologies | April 2 or April 3 | Comment | Zhone said it wanted the program to focus on job creation, and requests that the goals for the program can only be met by “careful and appropriate consideration of the actual American labor content.” Zhone noted that infrastructure is labor and equipment intensive, with as much as 60% of project costs going to equipment elements. With “American content” of equipment varying widely, a close look must be taken in order to meet the overarching goals of the stimulus plan.