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It is important that public safety entities fully understand the options that are available to them to better improve their facilities.
I feel that the national broadband plan,if it is to work,needs to be afforadable for everyone in the us. Since it seems evrything is going up but our paychecks. Low coast affordable broadband for all
The National Broadband Plan should adopt the ComCARE E-Safety Program to enhance homeland security by helping bring 21st-century capabilities to emergency response, deploying integrated, interoperable, and interconnected wireline and wireless systems and applications.

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ComCARE (Communications for Coordinated Assistance and Response to Emergencies) is a national nonprofit coalition of over 100 members of the emergency response community dedicated to advancing emergency response, www.comcare.org/ESafetyVision.html
Title: Using Broadband Infrastructure to promote Jobs Creation, Workforce Development and Entrepreneurship Education through the building of Social Entrepreneurship and Asset-Based Community Development modalities.
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The primary outcome expectations of the American Recovery and Reinvestment Act of 2009 (ARRA) include significant jobs creation, promotion of economic recovery and assistance to those most impacted by the recession. Technology will surely play a pivotal role towards attaining these goals and integral to retraining misplaced workers while sustaining the programs that are launched through the massive social investment of the ARRA.

Robust and feature rich broadband wireless networks launched in our communities, cities and counties would provide direct cost savings and increases in productivity for all of our local governments, first responders, colleges and schools, libraries, workforce investment boards, smart grid and all other public/private systems, agencies and non-profits throughout our regions, not to mention providing low cost ubiquitous high speed wireless internet access and communications for our residents and businesses.

New tele-medicine, tele-work, employer outreach, community outreach, digital inclusion for low-income households, distance learning, workforce development programs and smart grid applications are all borne of these cost-effective high speed fixed, nomadic and mobile wireless networks that will also attract corporate investment within our regions and communities and drive economic stimulus and growth.

So how do we make this happen?

Read my full article answering this at http://www.govtech.com/dc/articles/718085.

By definition, Asset-Based Community Development (A-BCD) is a methodology that seeks to uncover and highlight the strengths within communities as a means for sustainable development. The basic tenet is that a capacities-focused approach is more likely to empower the community and therefore mobilize citizens to create positive and meaningful change from within. Instead of focusing on a community's needs, deficiencies and problems, the A-BCD approach helps them become stronger and more self-reliant by discovering, mapping and mobilizing this model using all their local assets. Few people realize how many assets any community has.

Using this definition as the premise and incorporating into this model, the empowerment that our communities unknowingly maintain to create positive and meaningful change from within lies with technology. The layperson or average citizen does not realize that the assets needed to generate revenue that stays within their communities, and would support self-sustainability of these communities where we work and live, are literally right there under our noses.

The asset being referred to is wireless spectrum... particularly WiMAX wireless spectrum using the 2.5GHz Educational Broadband Service (EBS) band and the 3.65GHz band.

Designing and building out a WiMAX network is not rocket science but does require experience and expertise. This also introduces a community wide educational component starting with public awareness to promote the social capital needed to kick start this program. If our schools and colleges acted as the lead agent in this endeavor then we would be off to a good start.

It is these same colleges and schools that have the rights to what is now known as the 2.5GHz Educational Broadband Service band (formerly the ITFS band). Beginning in 2004 the FCC changed the rules on this band that allocated its use for broadband. This basically catapulted this spectrum real estate from swamp land to ocean front property. However, rather than educating these non-profits on the value of the asset they had maintained for decades the FCC allowed Clearwire and Sprint/Nextel to approach these non-profits, checkbooks in hand, and entice Boards of Trustees to lease their spectrum to these incumbents.

These non-profits include state universities and university systems, public community and technical colleges, private universities and colleges, public elementary and secondary school districts, private schools (including Catholic school systems in a number of large metropolitan areas), public television and radio stations, hospitals and hospital associations, and private, non-profit educational entities, all operating in the communities in which we work and live. On Election Day 2008 the outgoing FCC approved a deal that would combine all 2.5GHz EBS leases, and the spectrum, under one brand - CLEAR. As a result of this CLEAR now has the rights to 85+ percent of the 2.5GHz EBS band throughout the United States for the next 15-30 years.

What is being done to utilize this spectrum, specifically related to Asset-Based Community Development methodologies? Nothing -- With that being said let's move on to the next component in this model.

Cable incumbents, including Comcast and Time Warner, need a wireless strategy going forward to compete in the marketplace and keep costs down. In a few markets -- like Portland, OR -- Comcast has begun reselling CLEAR services.

As an incentive to Comcast and Time Warner our cities and communities should begin to build out WiMAX networks using the 3.65GHz band. This band provides for 50MHz of bandwidth that can be used for applications in the fixed and nomadic environment (e.g. households, businesses, smart grid, distance learning/training, delivery of e-newspapers, etc). The infrastructure needed to provide these services could be offered by Comcast or Time Warner or an established 3.65GHz local internet service provider (ISP).

In fact, our schools, community colleges and universities could become the lead agent for the 3.65GHz ISP, partner with cable companies in the offering of multiple service level agreements (SLA's) using both the 2.5GHz and 3.65GHz, with revenue share from the 3.65 side remaining within the communities and cities, in which we work and live, and supporting the large social investment of the ARRA, paid for by the American citizens.

The Plan & the Benefits


•CLEAR, EBS License Holders, Comcast, Time Warner, 3.65 WiMAX providers and our schools, colleges, and libraries need to agree upon concurrent build out of the 2.5GHz and 3.65GHz bands within their respective markets/regions. This will provide our residents, businesses, public systems and non-profits with a robust high speed ubiquitous mobile, fixed and nomadic internet access and communications (e.g. VoIP).


•Newspapers need to partner with these service providers in order to keep their doors open for business. Digital delivery of "e-newspapers" is right around the corner, replacing thetraditional printing press. This will put WiMAX enabled e-readers into the hands of their existing circulation.


•The cable company and newspaper subscribers/circulation also represent an immediate marketing arm and strategy for the offering of extended WiMAX services and applications.


•Approach State and Federal Department of Labor, Employment & Training Administration (ETA), Workforce Innovation or related agency and request funding for the planning (and possible build out) of the network (e.g. RF studies, engineering, tower/building locations to mount equipment, wholesale bandwidth, RFP/RFI to tier one operators/service providers, etc.). ETA is investing more than $260 million in 26 different regions across the United States in support of the WIRED (Workforce Innovation in Regional Economic Development) Initiative. Through WIRED, local leaders design and implement strategic approaches to regional economic development and job growth. WIRED focuses on catalyzing the creation of high skill, high wage opportunities for American workers through an integrated approach to economic and talent development.


•Private sector money needs to step up in conjunction with grants from Department of Commerce NTIA Broadband Technology Opportunities Program (BTOP) and Department of Agriculture RUS Broadband Initiatives Program (BIP). These agencies are responsible for allocating $7.2 billion in broadband stimulus dollars.

An established 3.65GHz service provider will apply for an infrastructure and sustainable adoption grant. (revenue share provides for sustainability of ARRA, BTOP and BIP programs launched in the regions). The colleges/schools/libraries will apply for an increased computer/bandwidth grant. Private sector is required to provide 20% of the total infrastructure grant for BTOP however a minimum of 25% should be sought simply based on the potential ROI within any given region.


•The money from the increased computer center/bandwidth grants will be used to revamp existing or build new public computer/skills training centers (community colleges as lead agent) within the region that will offer specific training on the WiMAX network (e.g. qualified students/applicants can receive on-the-job-training and subsequent employment with either the 3.65 operator, CLEAR or the reseller).

These public computer/skills training centers can also offer training (both distance and on-site) and staffing services for a multitude of other industry sectors in need of labor exchange. Increased integration of community and technical college efforts with business and the public workforce system activities can be implemented to meet the skills training needs of high growth industries.


•All schools, colleges and libraries will be networked and provided the bandwidth needed to migrate to the needs of 21st century education and technology components. This will include virtual private networks, extended parent/teacher interaction and distance/home schooling.


•Power companies need to invest in WiMAX enabled devices that can provide for smart grid applications starting with time-of-day scheduling, demand control and load shedding of major loads in our homes and businesses, in conjunction with smart meters to provide remote meter reading.


•Local governments need to identify specific applications that can provide direct cost savings and increases in productivity for their departmental applications (e.g. permitting, remote water meter reading, parks and recreation, field reporting from hand held devices, etc.)


•Public Safety/First Responders can use the public network to monitor known trouble spots via cameras and DVR's that can be accessed from the station and/or their vehicles. Cameras and DVR's could also be accessed prior to a first responder arriving on the scene.


•Hospitals, Doctors and Veterinarians can provide tele-health services including remote diagnostics, remote monitoring of critical care patients, real time video conferencing and archived case studies/information.

With reference to workforce innovation many of the occupations projected to grow the fastest in the economy are concentrated in the health care industry. For example, from 2004-14, total employment of home health aides-including the self-employed-is projected to increase by 56 percent, medical assistants by 52 percent, physician assistants by 50 percent, and physical therapist assistants by 44 percent.

The industry is currently seeking to increase the available labor pool of health care employees. To attract new employees to the health care industry, industry employers are focusing recruitment from non-traditional labor pools. Increasing the diversity of workers and reducing turnover rates is also of concern.


•Our local employers can take full advantage of the network to identify direct cost savings and increases in productivity by allowing employees to incorporate tele-work or tele-commuting into their schedules.


•These networks will provide for comprehensive youth development services so that all youth, particularly those most disadvantaged, have the academic, technical, and work-readiness skills they need to successfully transition to adulthood, careers and post-secondary education and training


•Mentor/Protégé Programs - Graduate students, higher education students and experienced workforce can be paid to tutor qualified K-12 and Community College students in specific fields of interest. This is directly related to programs surrounding Science, Technology, Engineering and Mathematics (STEM).

What does all this mean? The Social Entrepreneurship Model

By definition, the main aim of a Social Entrepreneurship as well as social enterprise is to further social and environmental goals. Although social entrepreneurs are often non-profits, this need not be incompatible with making a profit. Social enterprises are for 'more-than-profit,' using blended value business models that combine a revenue-generating business with a social-value-generating structure or component.

This model identifies a means to organize, create, and manage a venture to make social change. This is specifically related to jobs creation as the primary outcome while providing sustainable adoption modalities for the ARRA and BTOP in regions throughout the United States. Even more specifically, this model identifies an important trend relative to the role licensed spectrum (2.5GHz, 3.65GHz) will play 1, 2 or 5 years from now in our day-to-day lives. This is not to say that incumbent license holders or lessees have not foreseen this but this model takes a proactive approach to incorporate the operating and business models that WiMAX can introduce through ubiquitous wireless accounts, services and applications as the availability/need for bandwidth increases. It is this proactive approach which can provide operators and service providers the ability to greatly improve their brands and ultimately increase their bottom lines.

This model will also incorporate many underlying programs that can be brought in to eliminate the disparity and co-join programs between labor and education as an integral part of the jobs creation and sustainable adoption modalities being sought through the ARRA and the broadband stimulus.

What about AT&T/Verizon LTE (700MHz Broadband)?

Based upon the above operating model, and the concurrent build out of WiMAX in multiple markets in all U.S. metropolitan service areas (MSAs) over the next two years, by the time LTE (and FiOS) starts to propagate and take hold all businesses and households will have a wireless (WiMAX) pipe. During the initial two year build out, CLEAR and independent operators could maintain an average rate per user (ARPU) of around $35-50 per month. When LTE presents, consumers and businesses will have become acclimated with the ubiquitous access that WiMAX has presented and will be used to the core infrastructure, applications and services that WiMAX offers.

When LTE starts to saturate, WiMAX core infrastructure will drop in price and remain as the low-cost core infrastructure for schools, colleges, local governments, libraries, public safety, energy (smart grid), workforce development and our public/private systems, agencies and non-profits while LTE introduces enhanced consumer based services, which we will want, demand and pay for. This will include three-screens digital media, hosted video platforms, video servers, CDN (content delivery network), publishing platforms, technology platforms for rich media, encoding/transcoding, DRM (Digital Rights Management) and content security, client software, streaming, players, asset management, streaming and delivery platforms, VOD (Video on Demand), hybrid set-top boxes, carrier and over-the-top enabled devices, broadcast and streaming, CE device streaming platforms, software platforms for three-screens services, just to mention a few.

It is also feasible that future WiMAX core infrastructure, services and applications will be billed as part of our water, sewer, and garbage pickup at rates below $10-$15 per month for a 6D/4U MB ubiquitous wireless connection.

As newer technologies are introduced - like LTE -- CLEAR (2.5GHz EBS) and established 3.65GHz WiMAX providers will already have a strong position in the market place, a wireless pipe to most households and businesses, a much stronger brand and the ability to use narrative and verbiage surrounding both Social Entrepreneurship and Asset-Based Community Development as part of their business marketing strategy and community involvement.

Therefore, what WiMAX will become is standards for a collection of technologies which can be deployed today that will directly benefit workforce development, education, the environment and socio-economic issues that plague our local communities and governments daily in today's economy. The introduction of WiMAX technologies will act as a catalyst and pioneer these types of programs and services that will ultimately benefit our communities and drive participation by the large incumbents as newer technologies are introduced in the marketplace.

As the FCC is charged with providing a national broadband plan to Congress and the Obama Administration by February, 2010 (6 months) I would invite our new FCC Chair, Julius Genachowski, to take a look at what is being introduced in this forward thinking model and provide incentives for the large incumbents and smaller operators to participate.
I think the "Contact" button at Broadband. gov should work, but it does not.
I think the button that pops up when you sign up and tells you that you can "re-send your email notificaiton" should be spelled correctly, but it is not. Is this a real site? I see it is beta, but it could still be done correctly.
How come the FCC ONLY will allow comment on broadband, when there are so many other issues it addresses in our society?
I work with public safety on the basic field communications. That is not addressable here, though there are HUGE issues. Apparently we can only work through industry representatives, who have their own agendas, not necessarily congruent with the real needs of public safety. This is a giant flaw in the input capability which the FCC could chose to correct in a forum such as this.

There is a technology that can service communities with BroadBand Service that includes
i) Land Telephone
ii) Internet Service
iii) Television Service
iv) Mobile Phone Service
v) Home network on the go.
vi) Two-way radio with Video and document transfer features.
And all other teleshopping features that could include E-Commerce from home.

This is the near zero interference future compatibility resolution available today in the market.

Regards,
Tinsel_Tunes@hotmail.com
How about adding OpenID (Google, Yahoo, AOL, etc.), Windows LiveID, Twitter, MySpaceID, and Hotmail support for registration and login and activity stream social publishing to allow your users to publish their comments here back to Yahoo, Twitter, Facebook, and MySpace.

This will make it much easier for anyone to participate and will also drive additional traffic back to your site from the social networks. Check out JanRain's RPX http://rpxnow.com for a free offering that provides all this functionality.
As Comcast and Time Warner need a wireless strategy going forward they are starting to resell Clearwire's (CLEAR) WiMAX services( http://blogs.zdnet.com/BTL/?p=24012 ). This represents a stepping stone towards the most immediate available solution to developing and deploying a viable and sustainable national broadband plan. This also can set the precedent for any changes the new FCC will make surrounding the 700MHz band ( http://www.fiercewireless.com/story/fcc-may-auction-more-broadcast-spectrum-wireless/2009-10-28 ) [see subscript below]

The new FCC is all about spectrum (or the lack there of) because of the growing demand for mobile broadband (internet access) and communications. As Comcast and Time Warner have abundant cash reserves they should be locking down wholesale agreements with Clearwire and coordinating with the States to provide a cohesive plan to work with all all the applicants they are now trying to shut down because of concerns that these applicants are stepping on their territory. ( http://www.dailyherald.com/story/?id=331943 ).

Comcast/Time Warner/Clearwire could immediately create thousands of jobs by agreeing on concurrent build out of the 2.5GHz EBS (mobile) and 3.65GHz (fixed) WiMAX bands within their (our) markets. This would provide a robust, interoperable broadband network with ubiquitous wireless accounts for all individuals, households and businesses in all rural, metro, urban and suburban markets.

3.65GHz Fixed WiMAX - local governments, school systems, libraries, colleges/universities, smart grid, public safety, workforce, non-profits, households, businesses.

2.5GHz EBS Mobile WiMAX - mobile overlay for fixed, individuals, households, businesses.

The FCC/NTIA/RUS need to step up and provide incentives for this type of plan as incumbent cable and telcom's are not going to go away and need to maintain ARPUs (average rate/revenue per user) and market share while building towards a national broadband plan.

Please use the remaining $3.2 billion to provide incentives to make this plan happen.

Read more at http://www.digitalcommunitiesblogs.com/broadband_nation/

[Subscript]
In 2004 the past FCC changed the rules on the 2.5GHz Instructional Television Fixed Service (ITFS) band which allowed Sprint & Clearwire to approach non-profits within our communities to lease this very valuable asset. These non-profits include state universities and university systems, public community and technical colleges, private universities and colleges, public elementary and secondary school districts, private schools (including Catholic school systems in a number of large metropolitan areas), public television and radio stations, hospitals and hospital associations, and private, non-profit educational entities.

Ironically, these are the same agencies that now qualify for broadband stimulus funding but have signed away their rights to the asset they have maintained for decades. They must now wait on Clearwire (middle man) to launch within their respective communities/markets.

Clearwire (CLEAR) now has rights to 85+ percent of this spectrum, nationwide. ( http://www.fcc.gov/transaction/sprint-clearwire.html )

Read more at http://www.digitalcommunitiesblogs.com/broadband_nation/

With ARRA and the Broadband grants opportunities now available, and the process to leverage broadband investments advancing consistently, I believe the timetable originally set for the grant & project timelines will be met. There were some challenges in applying for the first round so far (uploading PDF's overloaded so I had to mail in documents), but I was pleased to see the challenges were being met. I was especially pleased to see management at the Government level addressing the problems head-on and responding to the challenges very quickly.

The lights are on, and someone is home. All this leads me to believe that if the grant funds are awarded to people who are as committed to the programs goal as well as the government representatives that I have interacted with thus far; we will indeed see jobs created by the program. The government is providing support - WE WILL HAVE TO PRODUCE RESULTS EFFICIENTLY!

It's easy to write something on a blog, or take a jab at someone if you don't agree with something. But real commitment is evidenced by the private sector BUYING into the progress and putting up their own funds to match government funds. As a businessman, I've always felt more comfortable doing a deal when my partners have 'SKIN IN THE GAME'.

Let's all be accountable to the American people and ALL our stakeholders. Let's keep REAL DOCUMENTS to support the REAL JOBS created by this program, and let's make sure we do our part to PROMOTE OUR PROGRESS as equally as we promote our negative criticisms of our governments efforts to right itself on the road to economic recovery.

Thank you for the opportunity.

Good job!
1. Simplify administrative process by creating a critical pathway that can be applied to 95% or better of the projects. Current program is so adminstratively cumbersome that less than 5% of the funds have been disbursed in the first 2 years of the program.

2. Expand funding to cover all telemedicine peripherals currently covered by USDA grant program. Why should there be different standards?

3. Ease Stark provisions to allow open participation of For-Profit specialist physicians in the program at a discounted rate. Without specialists being linked to primary care and emergency rooms, telehealth is limited and without financial models that ease the costs for specialists to participate, why should they?

4. Take un-disbursed funds that have been allocated to either disbanded or unsuccessful projects and allow current particpants with successful projects to take advantage of additional funds for expanding their proven networks.
There is one ISP thru the electric coops thru the rural America is putting in fixed wireless broadband. It is absorbing all the bandwidth at the major nodes right now to give broadband to rural America. When this ISP finishes it's job rural America will have the best communication and Internet in the US. It will be better than what they get in the cities and suburbs right now. It will make the telecoms and cable network look luke babies in the way the world turns. They can handle bandwidth with no problem and also put in capacity faster than cable and telecoms can do and also at a cheaper cost than they spend. So you would have to ask yourself why don't they learn how to do it right. In the case of Verizon they decide not to compete with this ISP and sold their operation to Frontier because every place they went they lost all the business and had to abandon the equipment in the location. The bottom line it will come out that rural America will have a better Internet and communications then the cities and suburbs and the society will have to force them to come up to the standards that rural America is setting. You maybe shocked at this information but it is happening thru rural America. Furthermore they give constant bandwidth which it doesn't go up or down depending how many are on as they can handle the demand no matter how many are on. They also did growth without Government help and they are doing thru the bootstraps of rural America as they don't trust the Government. President Obama helped by mandating the tier one providers give as much bandwidth to the major nodes that this ISP requires period. The ISP take the bandwidth from the major nodes and does its job. So get it thru you head that there is modern communication going in without Government help as fast as possible and it is state of the art and do it fast. In a year or two it will come out that rural America has the best Internet and communication in the world without Government help and charges the same or less than what is charged in the cities and no caps. Have fun.
Digital Ecology vision must inform the Plan to create sustainable broadband media ecosystems that serve the real needs of communities.

Thanks to leading public interest advocates - here's a draft definition:

Digital Ecology - An interactive, multidisciplinary inquiry of life in an increasingly digitized and technologically mediated environment.

Digital Ecology explores how people interact with, are shaped by, and shape the mechanisms through which we produce, share, receive, archive, and access information, stories, and cultural knowledge.

Digital Ecology is rooted in the belief that a healthy digital ecosystem is community-based, people-centered, and supportive of political, economic, cultural and technological justice.
We need to recognize that mobile computing is now a reality. Rather than allowing schools to buy cell phone jammers we should encourage them to employ smart phones for educational purposes. Imagine if students always have the opportunity to learn wherever they are. A GIS system coupled with locational-aware datasets could make this possible. When they go to the skatepark they could find out how many injuries have occurred here. Or how the graffiti in the city was lowered after the park was built. Their town church or city hall could trigger multimedia about architecture and mathematics or local industry and historical happenings.

Anything that will allow students to follow their passions and learn to learn would be a vast improvement. Thus we could begin to address the shortfalls in education and broadband simultaneously.
After we bought a foreclosure/fixer upper in Memphis,TN, my spouse and I found ourselves in a 2.5 year saga to get decent internet service--within sight of the city. The house had ISDN, but AT&T was reluctant to activate it. They refused to put in a port for DSL, saying they were full in our area (but check back), and left us with dial up that routinely was half the speed of the dial up account we had in central Memphis 5 years previous, and nowhere near as fast as my DSL line had been. They then doubled the price of the abysmal dial up, because they wanted us to switch to DSL, but they would not connect DSL still.

The cable providers would only install if we paid them $5000, saying they would pay the other $1500, and then bill us for monthly service too. Finally I switched to a Wireless EVDO card. The first was fast, but only worked 7 days out of 30 from ATT. I returned it. The second was much slower, but worked reliably until this summer, when Sprint did something to their tower, and I was unable to make it or its replacement work anymore at speeds higher than 20kbps. Which is unacceptable at any price.

Meanwhile quick internet access has become necessity to my architecture practice, whereas just 5 years ago it was not. Therefore, I looked at satellite again, and just signed up last month. It is FAR below cable speeds and DSL, but yet twice the price. However, I am forced to use it even though all my neighbors have cable or DSL. No one suscribes to satellite because they want to. They subscribe because they have no other choice. This puts me at a severe competitive disadvantage with my peers, and as a sole proprietress, I already have enough of that.
Build the physical broadcasting towers and rent space to telecommunications companies so we don't have multiple towers standing next to each other.
The FCC has been tasked with developing a National Broadband Plan by February 17, 2010, and has requested input. Most of the comments filed to date deal with a myriad of technology issues rather than approaching the creation of this plan based on the economic constraints that must be overcome in order to provide broadband to as much of the U.S. population as is practical.



2. The goal of providing broadband services to essentially all of the nation's population who want broadband access is a noble goal and one that can be accomplished fairly quickly and economically. However, it is important to understand that we already have, or will soon have, the technologies in place to deploy broadband beyond its current reach. In actuality, there are two separate issues facing the FCC in completing this report and both are based on economics-not technology.

a. The first issue is how to build out new broadband coverage where there is none today because companies building these systems cannot earn a return on their investments.

b. The second issue is how to support citizens in the urban/suburban areas of the nation that already have a choice of 3-8 broadband service providers but who cannot afford or justify the expense.



3. Therefore, in its report, the FCC should address these two different situations and provide economic solutions to both of them. The solutions will, of course be different. Once the plan is reduced to one of economics instead of one of technology, the options for various solutions will present themselves. This plan should not be a one-size-fits-all plan nor should it try to establish how many competitors should be permitted to compete for business in specific geographic areas. Once the economic issues have been resolved, the number of providers will be determined by market forces and how well each company manages its costs.



4. There is no rationale for moving forward with a separate, nationwide network in today's environment. Most of the urban population has access to DSL, cable, perhaps FIOS, and from four to six wireless broadband service providers as well as Wi-Fi, and now White Space unlicensed spectrum. Most of these areas will see fourth-generation technology built out over the next few years, not only by the existing wireless network operators, but also by Clearwire and a number of cable companies. These same companies are also committed to expanding their networks, where economically feasible, to cover more pops with wireless broadband than ever before.



5. It should be noted that with the possible exception of the Sprint PCS network, the other three nationwide wireless network operators did not start out with nationwide network deployments, rather they built their networks over the years by merging and acquiring other network operators. There is enough competition in most of the populated areas of the United States today to provide broadband services at economical prices. The issue in these areas is not that broadband services are not available, but the fact that some of our population does not want broadband connectivity and others simply cannot afford it.

a. The way to provide broadband in the more populated areas is to find ways to make these services available to people who cannot afford them. This is not simply a matter of supplying broadband, this portion of the population needs access devices as well.

b. This is an area where focus should be changed from providing broadband to providing services that make use of broadband. Working with various community organizations, educational facilities, the medical industry, and device manufacturers will result in a higher uptake of broadband services in the more populated areas of the United States



6. In areas of the nation where there is no access to broadband today, or only a single broadband provider, a number of solutions can be explored. These solutions include partnering, again, with educational and medical communities, power utilities, wired and cable providers, wireless network operators and the broadband satellite industry.

a. Once again, there is no one solution for areas of less dense population. The way to provide broadband connectivity is to first partner with the various organizations and groups mentioned above, then undertake an assessment of existing infrastructure in each area and develop a plan that takes this infrastructure into account in providing services that are less expensive to build out and maintain. One resource available in 47 of the 50 states are the rural power companies that have been providing electricity to the rural areas of the United States for many years. They own right-of-ways, high-tension towers that could be used for cell sites, and they already have service vehicles to take care of the power needs of the residents they serve. I am NOT advocating Broadband over Power Lines (BPL), which has proven to be a failure. I AM advocating the use of these resources. Power companies (many of them co-ops and represented by a national organization) have the desire and need to use broadband connections for their own systems and the planned smart grid, and would like the ability to sell or resell broadband services to customers they already serve. An example of how well this works is the early deployment of DirecTV in these rural areas. For the most part, these systems were sold and installed by power companies and small rural wired and wireless operators. As a result, a very large portion of the rural population has access to affordable, high-definition TV services today.



7. Because broadband services connect to the Internet and are IP-based, from a technology point of view, it does not make a difference if solutions for deployment are different in different areas of the nation. Once the connectivity is in place, regardless of the technology, customers can access the Internet and services. There is no need for the system to be one seamless, nationwide network to accomplish the goal of providing broadband services for all who live and work in the United States.



8. For all of the reasons discussed above, I believe that the FCC's Broadband Plan should not focus on technologies-wired, cable, fiber, and wireless-but rather on the economic models needed to drive the adoption of broadband services. Today we have many different technologies capable of delivering a broadband experience, and in the future these technologies will be enhanced, data speeds will be increased, and new technologies will emerge. The FCC should not limit the future of broadband by stipulating broadband speeds, capacities, or costs, in the same way that the FCC has not dictated specific wireless technologies for specific portions of the spectrum. Market forces will drive these decisions and the research needed to continue to advance the state-of-the-art. Attempting to predict or shape what lies ahead will only serve to hinder technological developments. Therefore, it would be in the best interests of the U.S. population to focus on ways in which more people can become connected, more people can access faster connections and greater capacity, and how we enable those who do not have the financial resources to take advantage of the technologies and systems that are and will be in place to provide these services.



9. It would be easy to become bogged down in the early planning stages by trying to define exactly what broadband service is; what data speeds and what capacity meet the definition of broadband.

a. Today, broadband services, both wired and wireless, run the gamut from a low of roughly 256 Kbps to higher than 50 Mbps, and the technology already exists to increase the high-end of this speed curve. Of course, it also must be decided if to qualify as a broadband service both the up and down links need to be symmetrical in nature or if slower speeds from a customer's device back to the network are permissible and, if so, what the difference should be.

b. Capacity on a per-customer basis is even more difficult to define and plan for. Most of today's systems make use of shared bandwidth, so both the speed and the customer's ability to access higher amounts of data may be affected by the network load.

c. There are two schools of thought regarding the capacity of today's wired Internet. According to many reports, we are already at a point where 40% of today's traffic is made up of video, and Internet infrastructure providers will not be able to keep up with the increased demand over the course of the next five years. The issue of shared bandwidth is exacerbated when the system is wireless. There are more variables that impact data speeds and capacity for wireless networks, including the amount of spectrum available per cell sector, or site, the technology deployed, the capacity of the backhaul system, and the capacity of the network itself. It is, therefore, important to factor all of these variables into the plan for our future broadband needs. However, there are those, including Google, that dismiss limited wireless bandwidth as being irrelevant. Their rationale is that we will simply build more wireless nodes and take wireless from the last mile to the last 500 feet, to the last 200 feet to the last foot. However, that does not take into consideration the fact that wireless IS the last mile or foot and that it takes a wired infrastructure to connect the wireless nodes to the Internet. With data speeds increasing over the next few years, traditional backhaul wired systems will not be able to provide the data capacity that is needed. We will need to build fiber and microwave systems in order to provide the backhaul that will be needed for future broadband deployments.



10. Today, 92% of the U.S. population has at least one provider of broadband service, and 96% of the total population has wired and/or wireless voice access. While there may be some technical impediments preventing further development of broadband services in rural areas, many of these issues will be solved within the next few years with the advancement of both wired and wireless technologies. Further, it is not, in my opinion, practical to choose a single method of providing broadband services to the nation's population. Rather, it will be both more cost effective and more timely if several thrusts are put forward in the report.



11. The first of these would be to narrow the gap between the 92% of the population that already has at least one broadband provider and the additional 4% that do not have access to broadband services but do have access to wired and/or wireless voice services.



12. Next would be to develop economic models to encourage additional providers to build out service areas where the competition is limited to one or only a few service providers.



13. These objectives could best be achieved by completing an inventory of services that are already available, determining how they could be extended to cover more of the population, and what would be required to ensure additional competition in the marketplace.



14. There is a tendency in today's government to believe that more is better, in this case, the more networks providing services, the more competition and, therefore, the cheaper the prices the citizens. In the United States, we already enjoy some of the lowest costs for broadband services in the world. Adding more competitors might cause a slight drop in the price of service for a short period of time, but in the long run, adding competitors will drive many companies out of business, leaving their subscribers stranded with no access or having to scramble to find a new company for their access. Market forces will dictate how many broadband providers can survive.

a. For example, in the San Francisco, Oakland, San Jose, CA area, there are approximately 3.5 million people. Today these 3.5 million people have access to at least eight broadband service providers and within the next five years another four or five providers will be offering service in the same area. It is not possible, even with transient traffic, for this area to sustain ten to twelve broadband suppliers. What is the correct number? The answer will only be known after several company failures and a series of mergers and acquisitions. In the meantime, the citizens have to sort out their choices and make the best decision they can, based on the marketing skills of the various providers.



15. A final point needs to be made here. Providing a plan for nationwide broadband must include ways to continue to provide for additional capacities in both the wired and wireless worlds. Today the demand for content on the Internet is growing faster than the infrastructure needed to service that demand. There is little incentive for wired service providers to build new infrastructure today and this issue needs to be addressed. This nation cannot afford to run out of bandwidth, and based on data I have seen, we are in a position where this could happen by 2012.



Conclusions



Because the FCC is responsible for regulating the public side of our wired and wireless services, the focus of this plan could be technology enhancements or requirements deemed necessary to provide for nationwide broadband services. It is my belief that the technology is available today and will be enhanced, and that new technologies will be introduced in the future to provide for a number of broadband options. I would respectfully ask the Commission to concentrate on the economic issues rather than the technologies. No matter how much technology we have, we will not be able to accomplish our goal of broadband for all Americans unless we find a way to provide services for all and at the same time enable those who invest in the networks to earn a return on their investment.

1Andrew Seybold: Broadband for All Americans, http://http://www.andrewseybold.com/downloads/WPBroadband12-22-08edt.pdfWPBroadband12-22-08edt.pdf

2http://www.internettrafficreport.com/

3http://search.techrepublic.com.com/search/internet+data+traffic.html

4http://www.chetansharma.com/blog/2007/11/21/pbs-commentary-on-the-smartphone-market/

5http://www.searchviews.com/index.php/archives/2007/02/google-warns-about-internet-overload.php


I hope one goal in this National Broadband Plan process is broadband video-capable hand held computers worldwide, so that One Laptop per Child countries, for example, may be able to access the web (and open teaching and learning opportunities, such as at the open World University & School wiki, - like Wikipedia with MIT Open Course Ware - http://worlduniversity.wikia.com/wiki/World_University). I hope the U.S. can integrate its adoption of significantly fast broadband with this worldwide goal, and benefit economically by significantly scaling up broadband access worldwide.

http://scottmacleod.com
Satellite cost/speed offerings currently available do not meet the broadband needs of rural communities. Satellite is still the most cost effective way to reach areas of extremely low population density. Identifying those for whom Satellite is the most effective means of providing broadband (with a reasonable 5m/1m speed and subsidizing it through a revamped Universal Service Fund is one solution. The subsidies would have to assist those in need and restrict those who would like broadband satellite for convenience.
Policy should also make a distinction between those who live in extremely low population density areas for pleasure and those who live in low density areas out of necessity. Farmers, loggers, miners, forestry service employees and the like should be helped.
Working for a company who is actively engaged in selling off rural customers but is also at the forefront of providing cutting edge technology where population densities make economic sense has given me an inside look at the effects subsidizing rural telecommunications have on companies who have to compete against cable companies who only provide service where they want to.
Efforts at blocking the sale of these rural assets have failed in every case and they should. I work in buildings that used to have floors you could eat off of and now they have not been mopped in 10 years. I cannot get a soap dispenser for a restroom and the bushes don’t get trimmed until the local government issues citations for being a public nuisance. Expecting what is left of the Bell Operating Companies to continue doing what they did when there was a monopoly in this competitive environment is an expectation that will never be realized.
A Universal Service Fund that is funded by all of the telecommunication providers (telecommunication providers needs to be redefined to include all entities engaged in selling services to transfer data, regardless of content, for profit) is the only fair way to continue providing universal service.
Most of the time the simple solution normally is the better one. The main problem is to satisfied every player in the Broadband sector Carriers,Providers and consumers. A multifunctional solution should include all this sector involve in a national plan. So we propose a simple one.

Internet3.
Learning from past mistakes and the government taking in mind all sector involves on this matter migrate to a new Digital and broadband era. The Government mentality should be provide services like Broadband, but taking in count the high cost one great idea is to provide like the national highway system provide the long haul and middle mile so Cities, Municipalities and utilities providers can deploy last mile broadband.

These long haul network will be connect to some several aggregations point or marketplaces so multiples service and content providers will compete for subscriber connected. Using this model every sector will find a benefit and a attractive way to increase revenues. for example government will have a new way of income charging per services rate to SP. SP virtually wont have OPEX winch increase profit margins per services and subscriber will have the freedom to select the SP of choice.
The result of this model no unserve or under serve areas.It so difficult to understand the simplicity of having a road in front of my house and that road connected to a highway and that highway connect every state.

I suggest that we settle on one definition of broadband that is technology neutral, i.e. it sets a basic, minimum standard for performance and connectivity to the web and anything below that is NOT considered broadband. This would remove device or user specific issues, and focus on the true broadban plan goal -- basic connectivity for every American
wireless broadband needs to be acessable on all major highways in which ambulances travel in order to better communicate with medical directors and recieving hospitals
Stop confusing Broadband with The Internet so that we can get a connected infrastructure instead of billable paths. http://frankston.com/?N=BI. Speed easy but availability is far more important -- 24×7×X×Y×Z wired and wireless.
I believe, that if a company such as GM or Ford were to invest in mass transit for the US, in the form of bullet train. This would create jobs and increase the economy.
Verizon just increased the cost of mobile wireless broadband and they are making it mandatory on what they call "advanced phones", which will be most of the new phones. Obviously, we have a mono/duopolistic model that doesn't work. See the link http://www.dslreports.com/shownews/Verizons-New-Wireless-Pricing-Is-An-Insult-104386.
I think the broadband plan needs to incorporate--in economic analysis and in its promotion--the notion that pervasive broadband and digitial technologies may fundamentally transform models of economic investment and return through increased coordination and collaboration.

Put simply, the Internet-based "crowd" is changing the way we consume, inform, communicate, and produce.
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