These comments are also available in
PDF format.

The NTIA has been presented with an extraordinary opportunity to improve
access to, encourage competition among and increase the speed,
affordability and openness of broadband services. Recognizing the
transformative effect that broadband services can have in communities and
the potential for such services to promote economic activity, civic
discourse and innovation, Congress crafted a set of broadband initiatives
that would promote the use of broadband while ensuring, though a set of
public interest conditions, that taxpayers would receive a long-term
return on their investment. PISC urges the NTIA to ensure that these
conditions are met and enforced and to utilize the funds allocated by the
Stimulus Act to make a meaningful impact in the lives of Americans in
unserved and underserved areas. As such, PISC proposes the following:

DEPARTMENT OF COMMERCE
National Telecommunications and Information
Administration

DEPARTMENT OF AGRICULTURE
Rural Utilities Service

FEDERAL COMMUNICATIONS COMMISSION

Joint request for information: American Recovery and
Reinvestment Act of 2009 Broadband Initiatives

NTIA Docket No. 090309298-9299-01
FCC GN Docket No. 09-40

COMMENTS OF THE PUBLIC INTEREST SPECTRUM COALITION
ON GRANT CRITERIA

April 7, 2009

Executive Summary

The NTIA has been presented with an extraordinary opportunity to improve
access to, encourage competition among and increase the speed,
affordability and openness of broadband services. Recognizing the
transformative effect that broadband services can have in communities and
the potential for such services to promote economic activity, civic
discourse and innovation, Congress crafted a set of broadband initiatives
that would promote the use of broadband while ensuring, though a set of
public interest conditions, that taxpayers would receive a long-term
return on their investment. PISC urges the NTIA to ensure that these
conditions are met and enforced and to utilize the funds allocated by the
Stimulus Act to make a meaningful impact in the lives of Americans in
unserved and underserved areas. As such, PISC proposes the following:

• That the role of states in the grant and loan selection process be
  limited, so as to preserve transparency and reduce delay in the grant
  allocation process.

• That the grant selection criteria echo the guiding principles of the
  BTOP program, by prioritizing projects that hold the greatest potential
  to meaningfully affect the impact of broadband in unserved and
  underserved communities, projects that promote the deployment of
  infrastructure that will remain viable in the long-term and projects
  proposed by entities that serve the public interest.

• That the NTIA establish a $25 million "small entities" fund to provide
  small entities with grants and loans for programs that are consistent
  with the goals of BTOP and should reach out to these entities so as to
  encourage their participation.

• That investments in broadband mapping promote a more sophisticated and
  nuanced understanding of the state, current deployment and potential of
  broadband services in the United States, by collecting and displaying
  data regarding the speed, price and availability of wired and wireless
  broadband services, as well as information about the availability and
  use of public spectrum and broadband infrastructure and the success and
  impact of the BTOP broadband initiatives.

• That the NTIA enforce conditions that require grantees to operate
  networks that are open, interconnected and nondiscriminatory, so as to
  ensure the long-term viability of taxpayer-funded networks.

• That the NTIA or the FCC consider invoking a rulemaking to pre-empt
  non-physical impediments (State laws, acceptable use policies,
  contracts, local agreements, etc.) that may preclude entities from
  applying for grants and loans in order to provide a service consistent
  with the purposes of BTOP.

By following the above suggestions, the NTIA can ensure that taxpayer
money is wisely spent, that the public interest is well served and that
broadband connectivity has a meaningful, positive impact in the lives of
Americans.

Introduction

The CUWiN Foundation, Common Cause, Consumer Federation of America,
Consumers Union, Free Press, Media Access Project, New America
Foundation, Public Knowledge, the Open Source Wireless Coalition and U.S.
PIRG (collectively referred to here as the “Public Interest
Spectrum Coalition” or “PISC”), file these comments in
response to the National Telecommunications and Information
Administration (NTIA) and the Broadband Technology Opportunities
Program's (BTOP) joint request for information regarding the American
Recovery and Reinvestment Act of 2009 Broadband Technology Opportunities
Program.

The American Recovery and Reinvestment Act grants the NTIA and the Rural
Utilities Service (RUS) the authority to administer grants and loans for
the deployment and construction of broadband systems that are open,
interconnected and which respect principles of nondiscrimination. In
establishing these requirements, Congress asserted that open networks
hold the greatest potential to realize the core goals of the stimulus
act: job creation, economic empowerment and the fostering of innovation.

PISC commends Congress for writing these requirements into the act and
urges both the NTIA and the BTOP to strictly enforce these principles as
it implements the broadband initiatives prescribed by the stimulus act.
In exchange for the grants and loans administered by the NTIA and the
RUS, grantees should be required to demonstrate that their networks
provide taxpayers with concrete benefits and a long-term return on
investment. Furthermore, the NTIA and BTOP should seize this opportunity
to encourage competition among service providers, increase the
affordability of broadband services and provide the public with
meaningful information and training, so as to maximize the benefits of
connectivity for the American public. With this in mind, PISC makes the
following recommendations to the NTIA and the BTOP:

I. States Should Play a Limited Role so as to Preserve Transparency and
Reduce Delay

2. b. What is the appropriate role for the States in selecting projects
for funding?

With regard to the role of the States in the grant and loan evaluation
process, the NTIA should not delegate authority to the States and should
not allow States to rank projects for consideration, as doing so would
induce delay and confusion and would move part of the decision-making
process outside of the clear boundaries of transparency established by
the American Recovery and Reinvestment Act of 2009^[1], Title VI (heretofore referred to as
"the Statute").

Recognizing that the NTIA has already met the statutory requirements
regarding the consultation of the States and that, furthermore, the
Statute does not require that the NTIA undertake a formal consultation
process with the States, the States should play a limited role in the
process of selecting and evaluating projects.

Instead of inviting the States to submit ranked lists of projects for
consideration, the NTIA might choose to seek input from the States on
definitional issues as well as the criteria on which the awarding of
grants and loans will be based, pursuant to S. 6001 of the Statute. The
NTIA might also choose to have State Governors detail personnel to the
NTIA to assist the Administration in this matter.

Finally, the NTIA should formulate a strategy for addressing projects
that supersede State boundaries, that affect non-State entities or that
serve multiple States. The NTIA should consider that the condition in the
Statue that all 50 States are granted funds could be fulfilled by a
project or projects that affect the deployment of broadband in multiple
States.

II. The Grant Selection Criteria Should Echo and Reinforce the Aims of
the BTOP Program

4. f. What factors should be given priority in determining whether
proposals will encourage sustainable adoption of broadband service?

As was detailed in the testimony of Ben Scott before the NTIA
(3/23/09)^[2],
proposals should be judged, in part, based on their long-term business
feasibility and the network's scalability, so as to ensure that taxpayers
receive a long-term return on their investment. Projects should be
prioritized based on their ability to meaningfully affect the impact of
broadband in underserved and unserved communities. Criteria that should
be considered include a service's affordability and openness and a
project's potential impact on competition in local markets.

As was stated in the testimony of Gigi Sohn before the NTIA (3/23/09,
page 1)^[3], grantees
will receive an "extraordinary government benefit" as a result of the
BTOP program. As such, the NTIA should prioritize those entities detailed
in S. 6001 (e)(1)(A) and (e)(1)(B). In the event that the applicant is a
private entity, the NTIA should consider if the applicant is involved in
a partnership with an entity of the type described in S. 6001 (e)(1)(A)
and (e)(1)(B). If the applicant is not involved in such a partnership,
the applicant should be required to affirmatively demonstrate a
commitment to furthering the public interest, pursuant to S. 6001
(e)(1)(C). Compliance with this requirement should be evaluated based on
a service's affordability and openness as well as its potential impact on
competition.

Additionally, it should be noted that the terms "unserved" and
"underserved" appear only in S. 6001 (b)(1) and S. 6001 (b)(2), in
reference to "consumers residing" in unserved and underserved areas. As
such, the terms "unserved" and "underserved" should not be applied to the
entities listed in S. 6001 (b)(3) through S. 6001 (b)(5), which include
"schools, libraries, healthcare providers, community colleges, and other
institutions of higher education, and other community support
organizations and entities," as well as public safety agencies,
job-creating strategic facilities located within a State-designated
economic zone and organizations that aim to facilitate greater use of
broadband service by vulnerable populations. Recognizing the importance
of connectivity to these entities and the value that these entities
produce in their communities, it was Congress' intent that applications
from these entities not be limited by the terms "unserved" and
"underserved". As such, applications from all entities listed under S.
6001 (b)(3) through S. 6001 (b)(5) should be considered on their merits,
exclusive of the applicability of the terms "unserved" and "underserved,"
which are meant to regulate applications pertaining to residential
services.

Finally, S.6002(h)(3) requires the NTIA to consider whether a grant
applicant is an “economically disadvantaged small business concern
as defined under section 8(a) of the Small Business Act (15 U.S.C. §
637).” In addition, the act stresses the need to place projects
within communities and economic development zones, and to provide
opportunities for non-profits to apply (S.6001(b)(3)). All of these point
to a desire by Congress to ensure that small entities have a meaningful
opportunity to participate in the BTOP program. At the same time,
however, Congress mandated that the NTIA implement the program
expeditiously, ensure that the money is spent wisely and require rigorous
tracking and reporting requirements.

PISC recommends that the NTIA set aside $25 million for a designated
“small entities” fund. Using this approach, the NTIA could
provide numerous small grants on a rolling basis for any of the purposes
permitted by BTOP. In addition, consistent with the OMB Guidance of
February 18, 2009, the NTIA should allocate a portion of the funds
authorized for administration of the BTOP program to meaningful outreach
and training for small entities that would be eligible for grants and
loans provided by this fund. In structuring the fund, the NTIA should
consider how it can streamline both the application process and the
subsequent accountability process.

III. Broadband Mapping Should Provide a Roadmap for the BTOP as Well as
Data Regarding the Success of BTOP Initiatives

8. a. What uses should such a map be capable of serving?

The fundamental purpose of the broadband map described by S. 6001 (l)
should be to outline and inform the Broadband Technology Opportunities
Program (BTOP), the aim of which is to provide all Americans with
meaningful access to broadband Internet connectivity. As such, the map
should not simply illustrate the location of last-mile infrastructure but
rather, should further a more sophisticated understanding of the
distribution, use and effect of broadband services throughout the nation,
pursuant to the goals of the BTOP.

As is described by S. 6001 (l) of the Statute, the primary goal of the
map should be to depict the availability of broadband services and
highlight areas where there is a need for the increased deployment of
broadband services. The map could also serve to help monitor the progress
of broadband deployment projects funded by taxpayer money and enforce the
conditions of those grants and loans, allow federal agencies to produce
statistics regarding the availability and adoption of broadband services
and provide the public with an easily-accessible, searchable,
user-friendly database of information regarding the availability, price
and speed of broadband services on a national scale.

With regard to infrastructure, the map should detail the location of both
commercial and residential services, as well as the larger network
infrastructure (backbone, middle-mile transport, etc.). In so doing, the
map will facilitate and assist in the sharing of facilities by network
operators, which would, in turn, increase both competition among
providers and the affordability of broadband services. The map should
also highlight areas where physical infrastructure is available but where
increased deployment and competition are constrained by non-physical
limitations (local or State laws or agreements, acceptable use policies,
etc.).

Finally, the NTIA should fund programs that develop and implement
qualitative metrics that measure the impact that the availability of
broadband services has on individuals and communities. In developing such
metrics, these programs might collect data regarding the affordability,
speed and uptake of broadband services and the availability of training
and tools to facilitate the use of the Internet the creation of content.
Metrics could include the number of people in a local community who
telecommute or use the Internet for educational purposes, fluctuations in
online economic activity or increases in computer ownership, voter
registration and civic involvement.

8. b. What specific information should the broadband map contain, and
should the map provide different types of information to different users
(e.g., consumers versus governmental entities)?

The map should contain data regarding the availability, speed and price
of all wired and wireless broadband services available in all communities
throughout the nation. As was detailed in the testimony of Art Brodsky
before the NTIA (3/23/09, page 1)^[4], the map should also take into account the backbone
and middle-mile transport and should fit into existing mapping data
sharing standards and protocols. Furthermore, the NTIA should fund
studies to determine what additional data is required in order to design
broadband programs that further the aims of the BTOP.

As the creation and maintenance of this map will be a taxpayer-funded
activity, consumers should have full access to all of the information
contained in the database, in the interest of ensuring transparency and
accountability.

8.c. At what level of geographic or other granularity should the
broadband map provide information on broadband service?

As wired broadband services are typically deployed on a block-by-block
basis, the map should provide information on at least a block-by-block
level, if not a residence-by-residence level. The more granular the data,
the greater the benefit will be to citizens wishing to research the
availability, price and speed of services in their area.

8. d. What other factors should NTIA take into consideration in
fulfilling the requirements of the Broadband Data Improvement Act, Public
Law 110-385 (2008)?

As was detailed in the testimony of Art Brodsky before the NTIA (3/23/09,
page 2)^[5], the
collection and mapping of broadband data should be done by a public
agency, on behalf of the public interest, by a neutral body with no
industry conflicts of interest, using uniform standards and should
produce a comprehensive map containing transparent and verifiable data.

8. i. What information, other than statewide inventory information,
should populate the comprehensive nationwide map?

Broadband service providers should be required to provide the NTIA with
accurate, verifiable and appropriately granular data regarding the
geographic availability, adoption, price and speed (advertised and actual
speed as well as bandwidth/speed limitations) of services already
deployed. In the interest of transparency, the use of this data should
not be restricted by nondisclosure agreements.

In addition, PISC recommends that the NTIA, in a joint effort with the
FCC, compile and make public online an inventory of the public
airwavesthat maps how public spectrum resources are being utilized or
underutilized in various bands. Just as fiber is the essential conduit
for advanced wired connectivity, spectrum is the publicly owned conduit
for wireless broadband. The American Recovery and Reinvestment Act
authorizes funds for developing and maintaining “a comprehensive
nationwide inventory map of existing broadband service
capability [emphasis added].”^[6] Spectrum is at the core of wireless broadband
service capability and we believe it would be in the public interest to
have a clear and transparent mapping of those capabilities between 30 MHz
and at least 6 GHz.

Providing such a map of the airwaves would greatly facilitate expanded
wireless broadband access, speeds and innovation, as the NTIA and the
FCC, as well as Congress, affected industries and the public would have a
more complete, comprehensive inventory of what frequencies are
actually in use, for what purpose, with what technology and at
what locations, frequencies and times. Both government and private sector
assignments and uses should be included in the map, with the NTIA and the
entire administration an active partner in this effort. With ARRA or
other funding, actual spectrum use measurements in a large and regionally
diverse sampling of markets should be part of the Commission’s
broadband mapping exercise. As Dale Hatfield, former NTIA director and
chairman of the President’s Spectrum Advisory Commission, has often
observed, “the government cannot efficiently manage a resource it
doesn’t measure.”

Wireless remains the most cost-effective and rapid means by which to
bring broadband access to rural residents in particular. Already,
thousands of locally-grown Wireless Internet Service Providers (WISPs),
Rural ILECs, public utilities, NGOs and local governments are utilizing
wireless technology in conjunction with unlicensed spectrum to bring
wireless broadband to unserved and underserved rural areas across the
country. A substantial obstacle these small and local providers face in
attempting to expand and scale-up their networks is access to additional
spectrum.

While rural provider access to licensed spectrum is scarce, unused
spectrum capacity in rural and most other areas is abundant. At any given
time and in any given location, the vast majority of our nation’s
radio frequency spectrum is unused or substantially underutilized,
particularly in rural areas. Recent spectrum occupancy studies by the
Shared Spectrum Company and funded by the National Science Foundation,
have demonstrated in a mix of urban, suburban and exurban areas that
large swaths of valuable spectrum are vacant or unused for the majority
of the time.^[7] For
example, the average spectrum use in rural Limestone, Maine was just 1.7
percent.^[8] The
highest occupancy rate on the prime beachfront spectrum below 3 GHz was
just 13 percent in New York City, while the average across locations
studied was just 6 percent^[9]. Across the country, this underutilized spectrum
represents an enormous untapped capacity for rural broadband.

Mapping our nation’s spectrum capabilities would help facilitate
wireless broadband deployments in at least three ways:

• First, more complete and transparent frequency-by-location data
  available online will improve the functioning of secondary markets for
  spectrum license transfers and leasing.

• Second, it will provide information on what will be required to fully
  clear some heavily underutilized bands, so that they can be reassigned
  for commercial use.

• Third, it will reveal the far greater number of frequency bands that
  could be made available for opportunistic access in discrete geographic
  areas, at certain times of day or year, or at certain altitudes or
  directions of arrival (azimuth, elevation).

We believe that unserved and underserved rural areas will be the greatest
and most immediate beneficiaries of a mapping of U.S. spectrum
capabilities. It will quickly become clear that particular frequency
bands are either completely unused or grossly underutilized in certain
rural markets. This could provide the Commission or Congress with the
information that it needs to reallocate or at least to open these
frequencies for non-interfering use by rural broadband providers. One
promising mechanism for this will be the TV Bands Database, which the
Commission’s Office of Engineering and Technology will certify as
reliable as a geo-location lookup service, allowing devices on the vacant
TV channels to do real-time checks of channel availability in discrete
geographic locations. Additional frequency bands could be added over time
to the database, enriching the spectrum infrastructure for rural
broadband providers and consumers alike.

Finally, rural broadband deployment, competition and affordability would
also benefit enormously from a mapping of the public sector fiber
networks used by federal, state and local public agencies nationwide.
Dark fiber and/or excess capacity in public sector fiber networks is
broadband capability that is owned by the public and should be mapped
along with other broadband service capabilities as provided in the
Stimulus Act.^[10]
The lack of middle-mile infrastructure is a considerable problem for
existing rural ISPs and a formidable obstacle to building sustainable
rural broadband networks. The typical rural ISP is 91 miles from its
primary backbone Internet connection and faces considerable costs to
transport traffic to and from the backbone.^[11] Dark fiber and/or excess capacity on
the public sector’s own fiber line infrastructure, opened for
wholesale access to any provider--commercial or non-commercial--including
non-vertically-integrated cell phone carriers, ISPs, Rural LECs and
municipal or community WiFi networks, could help to substantially
increase middle-mile options.

IV. Grantees Should be Required to Operate Networks That Are Open,
Interconnected and Nondiscriminatory, so as to Ensure The Long-Term
Viability of Taxpayer-Funded Networks

13. (5) c. How should the BTOP define the nondiscrimination and network
interconnection obligations that will be contractual conditions of grants
awarded under Section 6001?

Pursuant to the statutory requirement that grantees serve the public
interest (S. 6001 (e)(1)(C)), any network funded under the BTOP must be
open and nondiscriminatory and must interconnect with other networks, in
order to ensure that the goals of BTOP are being met. Furthermore, open
networks will prove more viable in the long-term than closed networks
based on proprietary technology, thereby ensuring a greater return on
investment for taxpayers. Most importantly, only open, nondiscriminatory
networks will ensure that free speech, the creation of content and full
participation in civic society and the economy will remain unhindered.

As was recommended in the testimony of Gigi Sohn (3/23/09, page
1)^[12] and Ben
Scott (3/23/09)^[13] before the NTIA, recipients of the grants and
loans must not degrade, prioritize or discriminate against any lawful
content, application or service transmitted over the recipients’
network or service, subject to a rule of reasonable network management,
must allow users to attach any device or application to the network, so
long as that device or application does not harm the network and must
provide interconnection at any technically feasible point within the
network on a reasonable, non-discriminatory basis.

13. (5) c. (1) In defining nondiscrimination obligations, what elements
of network management techniques to be used by grantees, if any, should
be described and permitted as a condition of any grant?

Given that the FCC's four principles have proven insufficient in ensuring
that networks operate on a non-discriminatory basis (the principles do
not explicitly address cases where a network provider prioritizes or
favors certain content, applications and services over others), grantees
must publicly disclose in full any and all practices used for the
purposes of network management and PISC urges the NTIA to pre-approve
these practices before a grant or loan is awarded. In the event that a
grantee wishes to modify these practices after a grant or loan has been
awarded, NTIA pre-approval should again be required and all impacted
parties should be notified and have the opportunity to comment or object.
Additionally, service providers that offer residential or enterprise
services should be required to provide their customers with meaningful
notification of the terms of service and network management practices in
use, as a precondition for receiving a grant or loan from the NTIA.

13. (5) c. (2) Should the network interconnection obligation be based on
existing statutory schemes? If not, what should the interconnection
obligation be?

As was recommended in the testimony of Gigi Sohn before the NTIA
(3/23/09, page 2)^[14], the NTIA should craft a requirement that is
consistent with Section 251(c) of the Communications Act. Such a
requirement would require a grantee to provide interconnection at any
technically feasible point within the requesting provider’s network
that is at least equal in quality to that provided to any party, on
non-discriminatory rates, terms and conditions. Additionally, the grantee
should be required to either provide unbundled access to the network or
permit line sharing for competitors. Finally, the NTIA should grant
priority to multi-use networks, so as to maximize the impact of the funds
granted.

13. (5) c. (3) Should there be different nondiscrimination and network
interconnection standards for different technology platforms?

Wireline and wireless networks should be required to meet the same
openness and interconnection requirements. Additionally, wireless service
providers should be required to provide competitors with roaming rights
at commercially reasonable rates.

13. (5) c. (4) Should failure to abide by whatever obligations are
established result in de-obligation of fund awards?

13. (5) c. (5) In the case of infrastructure paid for in whole or part by
grant funds, should the obligations extend beyond the life of the grant
and attach for the useable life of the infrastructure?

To ensure the long-term viability of the network infrastructure that it
invests in, the NTIA should revoke grants or loans made to any grantees
that fail to abide by the conditions outlined by the Administration.
Additionally, to ensure a lasting return on investment for taxpayers, the
NTIA should condition the grants and loans such that network operators
are required to abide by the conditions for the lifetime of any
infrastructure built using taxpayer money.

V. The NTIA Should Convene Rulemakings in Order to Preempt Non-Physical
Impediments to BTOP Requirements

Pursuant to its authority under S. 6001 (m) of the Statute, the NTIA
should convene a rulemaking or a series of rulemakings, in order to
preempt any non-physical impediments that may preclude entities from
applying for grants and loans in order to provide a service consistent
with the purposes of BTOP. To the extent that such non-physical
impediments (State laws, acceptable use policies, contracts, local
agreements, etc.) prevent entities from applying for grants and loans,
the NTIA should consider initiating a rulemaking to ensure that all
entities enjoy an equal opportunity during the applications process.
Alternately, the Federal Communications Commission (FCC) might choose to
undertake a similar rulemaking pursuant to its own authority.

Conclusion

The NTIA and BTOP have been presented with an extraordinary opportunity
to promote the deployment and use of broadband services nationwide and to
subsequently encourage job growth, education, economic advancement,
access to knowledge and civic participation. In so doing, the NTIA and
the BTOP should ensure that the public interest is served, that taxpayers
receive a long-term return on their investment and that underserved and
unserved areas receive the greatest possible benefit from these services.

Respectfully submitted,

CUWiN FOUNDATION
COMMON CAUSE
CONSUMER FEDERATION OF AMERICA
CONSUMERS UNION
FREE PRESS
MEDIA ACCESS PROJECT
NEW AMERICA FOUNDATION
PUBLIC KNOWLEDGE
THE OPEN SOURCE WIRELESS COALITION
U.S. PIRG

Harold Feld
Legal Director
PUBLIC KNOWLEDGE
1875 Connecticut Avenue, NW
Suite 650
Washington, DC 20009
Tel: 202-986-9453

[1]
http://frwebgate.access.gpo.gov/cgi-bin/getdoc.cgi?dbname=111_cong_bills&docid=f:h1enr.pdf

[2] http://www.freepress.net/node/49070

[3] http://www.publicknowledge.org/pdf/gbsohn-statement-20090323.pdf

[4] http://www.publicknowledge.org/pdf/abrodsky-statement-20090323.pdf

[5] http://www.publicknowledge.org/pdf/abrodsky-statement-20090323.pdf

[6] See Sec. 6001, The
American Recovery and Reinvestment Act of 2009, Pub. L. No. 111-5, 123
Stat. 115 (2009).

[7] See
“Spectrum Occupancy Measurements,” Shared Spectrum
Company, available at.

http://www.sharedspectrum.com/measurements/

[8] See Tugba Erpek,
Mark Lofquist, and Ken Patton, “Spectrum Occupancy Measurements
Loring Commerce Centre Limestone, Maine September 18-20, 2007”
Shared Spectrum Company (2006), available at
http://www.sharedspectrum.com/measurements/download/Loring_Spectrum_Occupancy_Measurements_v2_3.pdf

[9]See id.

[10] See "Ex Parte
Comments of New America Foundation,” GN Docket No. 09-29, Federal
Communications Commission, March 25, 2009, available at
http://fjallfoss.fcc.gov/prod/ecfs/retrieve.cgi?native_or_pdf=pdf&id_document=6520203629

[11] See
"Encouraging Broadband Deployment," National Telecommunication
Cooperative Association, available at
http://www.ntca.org/images/stories/Documents/Advocacy/PositionPapers/encouragingbroadbanddeployment_ntca2008.pdf.

[12] http://www.publicknowledge.org/pdf/gbsohn-statement-20090323.pdf

[13] http://www.freepress.net/node/49070

[14] http://www.publicknowledge.org/pdf/gbsohn-statement-20090323.pdf