Subject: [NEXTEL-1] Extend America- The Story Then-

From: [email-masked]
Date: Wed, 09 Jul 2003 19:03:10 -0400

December 19, 2001

The Honorable Nancy Victory
Assistant Secretary of Commerce for Communications and Information
1401 Constitution Avenue, NW
Room 4898
Washington, DC   20230

Dear Madam Secretary:

Extend America, a new commercial wireless company offering advanced mobile
telecommunications and information
services, submits the following comments related to Docket No. 011109273-1273-01,
the National Telecommunications and
Information Administration Request for Comments on Deployment of Broadband
Networks and Advanced Telecommunications.
Please include these comments in the record.

Sincerely,

Edward T.  Schafer
CEO
Extend America

RE:       Comments from Extend America on the National Telecommunications and
Information Administration Request for
Comments on Deployment of Broadband Networks and Advanced Telecommunications
[Docket No.
011109273-1273-01].

Extend America
Extend America is a new commercial wireless company, headquartered in Bismarck,
North Dakota, offering advanced
mobile telecommunications and information services in 5 states: North Dakota,
South Dakota, Montana, Wyoming, and
Nebraska.  It is the goal of Extend America to close the “digital divide” that
increasingly separates rural America from the
economic dynamism of the rest of the nation.   We believe the survival of the
rural quality of life depends on delivering quality
communications to a mobile public and to enable education, medical care, and
commerce.  Extend America is uniquely devoted
to the rural customer and will provide the most modern wireless voice and digital
broadband communications to underserved
rural markets.
Extend America intends to offer quality mobile voice services and greatly enhance
Internet access and high-speed data
transmission. Extend America is an integral part of the all-digital Nextel
Communications national and international networks,
thereby connecting rural communities with the rest of the nation and the world
with advanced telecommunications and data services.  The mobile wireless
transmission speeds offered by Extend America will enable rural consumers to
access higher bandwidth services than the infrastructure currently allows.   Since
Extend America will be utilizing cutting edge wireless technologies, the services
provided to its rural consumers will be constantly evolving, multiplying voice,
data, video, and multimedia applications through ever increasing bandwidth
technologies.
One particular area of emphasis that Extend America will have in the range of
mobile high-speed data offerings will be
the delivery of public safety applications.  We believe that there is an
ever-increasing need for mobile broadband public safety
applications and these services will be a major focus of our company’s business
plan.  In order to meet the public safety needs
of rural Americans in today’s environment, mobile broadband data applications are
necessary and Extend America intends to
offer such services throughout its service territory
Comments
Extend America appreciates the opportunity to provide comments related to
broadband policy in the United States.
As a company based in North Dakota, one of the most rural states in the Union, we
are focused on delivering broadband
services to rural consumers.  Thus, our comments will focus on issues related to
stimulating broadband deployment in rural
areas.  Our service territory includes areas with some of the lowest population
densities within the United States.  In addition to
our general commitment to rural consumers, we intend to enhance telecommunications
services in many under-served areas such as Indian Tribal lands were broadband
services can stimulate much needed economic development.
NTIA can play a key role in advancing broadband deployment in rural and
under-served areas through its policy
development authority and its advocacy of grant and loan financing programs and
regulatory policy.  Specifically, NTIA can
lead the Administration in supporting legislative initiatives and urge the
adoption of policies that will help advance a variety of
broadband technologies.
We note that there are currently several legislative initiatives that are under
consideration in the U.S. Congress, which
could help to stimulate the deployment of broadband technologies and services in
rural areas, and we encourage the
Administration to consider supporting such efforts.  In addition, the
Administration can play a key role in advocating
technologically neutral regulatory and finance qualification criteria at the
appropriate regulatory and administrative agencies to
help promote broadband deployment.
In general, Extend America believes that there are two primary policy
considerations that NTIA – or any other federal
agency – should use in formulating a broadband policy. The Administration can best
foster entrepreneurship and innovation
through the adoption of a technologically-neutral policy – such as what Congress
adopted under the Telecommunications Act
of 1996 – and providing for stimulation for investment through low-interest loans
and universal service programs.
The first principle we suggest is to encourage the development of a variety of
technologies through technically neutral
criteria with respect to government loans or other support systems, such as
universal service.  Government programs to
stimulate broadband deployment ought to be structured to encourage land line and
wireless technologies alike, not prefer one
over the other.  A second criterion that should drive Administration broadband
policy is a clear recognition that government
does play a critically important role in stimulating investment through
low-interest loans and universal service programs.  Any
effective broadband policy should recognize that entrepreneurship and innovation
often need government credit support and, in
some cases, grant support.  It is important that the Administration advocate and
advance programs that provide low-interest loans and high cost support to rural
carriers.  These essential programs ought to be an important part of any broadband
policy.

Low-Interest Financing for Broadband Deployment in Rural Areas.
One of the most efficient and cost effective ways to stimulate broadband
deployment in rural areas is for the
government to provide low-interest financing to rural carriers.  As a start-up
rural telecommunications carrier, we can attest to
the critical importance that low-interest financing plays in developing a feasible
business plan that can adequately serve rural
consumers.  We encourage the Administration to support not only the existing
broadband pilot program administered by the
Rural Utility Service (RUS), under the United States Department of Agriculture,
but also legislative initiatives to expand the
program which will help spur broadband deployment in rural areas.  This program
provides low-interest loans to qualified
borrowers to finance projects to deploy broadband services in rural areas.  In
fiscal year 2001, about $100 million in
low-interest loans were available.  The FY 2001 program defined a qualified rural
area as non-metropolitan population centers
with no greater than 20,000 people and the definition of broadband services was
determined to be 200 kilobits per second, each way.
In the fiscal year 2002 appropriations bill for the Department of Agriculture,
$49.4 million in appropriations was
provided to the Distance Learning/Telemedicine program, of which $22.5 million in
appropriations was provided for the
broadband pilot program.  Of the $22.5 million, at least $12.5 million will be
made available for grants and the remainder for
loans (or grants at the Administrator's discretion).
In addition to the fiscal year 2002 appropriations bill for the Department of
Agriculture, there are two other significant
efforts – originating in the U.S. Senate – to provide even more funds for the RUS
broadband program.
First, included in the Baucus substitute for the economic stimulus package is a
provision that would provide an additional $5 million for broadband loans.  The
loan authority under this provision is limited to $400 million.  If it were to
become law, this provision would add $400 million in addition to the funds
provided for broadband grants and loans made available under the fiscal year 2002
appropriations bill.
Second, there is a bi-partisan effort to further expand the broadband program in
the Senate version of the Farm Bill.
Lead by Senators Daschle, Dorgan, Stevens, and Burns, the Senate Farm Bill
contains $100 million, per year for five years, in
direct spending for the broadband program.   Further, the broadband program would
be changed from a “pilot program” under
the Distance Learning/Telemedicine program to a freestanding, sustainable
program.  The provisions do not specify how much
of these funds would be available for grants and loans.  It would be up to the
discretion of the Administrator to determine how
much of the $100 million in funding would be dedicated to grants and loans.   The
significance of this particular initiative cannot
be overstated.  The Senate legislation would provide stable funding for the next
five years, providing needed assurance for business planning and long term
deployment schedules.
It is important that the Administration support this bi-partisan legislative
effort to expand the RUS broadband
program.   The Administration’s support for the Senate effort to expand the
broadband program and put it on secure financial
footing for the next five years in the Farm Bill is critical.  Companies like
Extend America that are trying to deploy broadband
services in under-served areas need the assurance that low-interest financing is
going to be available more than just one year at
a time.  The long-term vision of the bi-partisan Senate effort is a model that the
Administration should embrace.

Maximize the Loan Authority of Low-Interest Financing Programs.
In addition to supporting legislative efforts to expand the RUS low-interest
broadband grant and loan programs, there
are some discretionary decisions that the Administrator of the RUS can make that
will either maximize the effectiveness and
reach of the broadband loan program or minimize it.  The need for these loans is
great.  The Administration should provide the
maximum amount of loan authority possible to the RUS to provide broadband loans
through the appropriated amounts
provided by the U.S. Congress.  We urge NTIA, as the principle voice of the
Administration in telecommunications policy, to
encourage the Office of Management and Budget and the RUS Administrator to
authorize a significant increase in the amount of
loans that can be awarded to qualified borrowers under the broadband program.  The
FY 2002 appropriated amounts should be sufficient to provide hundreds of millions
of dollars in loan authority.
The RUS Telecommunications program has a long history of making sound accounting
decisions in awarding only
feasible loans.  We expect this tradition to continue and the Administration can,
with sound justification, translate only a small
amount of appropriated funds into hundreds of millions dollars of broadband loan
authority.  There should really be no reason
why a qualified borrower with a sound business plan meeting RUS standards should
be turned away from low-interest financing
to deploy broadband in rural areas.  A broad interpretation of loan authority
based on the FY 2002 appropriations levels is needed until additional legislation
is passed to ensure a long-term generous program.

Definition of Broadband Services.
With respect to the definition of broadband services as it relates to the RUS
broadband program, it is imperative that
the RUS adopt a flexible definition that will not rule out certain technologies.
Currently, the RUS uses the broadband definition
established by the Federal Communications Commission (FCC) in its annual broadband
report, which is 200 kilobits per
second each way.   Rather than lock into one particular definition, the
Administrator should apply a flexible definition of
broadband services to encourage new broader bandwidth technologies that provide
significant progress towards higher
bandwidth services in rural areas.  The program should foster the development of a
variety of technological applications,
including terrestrial and satellite wireless services.  This can only be achieved
if the RUS adopts a flexible definition.  The
current definition of 200 kilobits per second each way could have the effect of
excluding many wireless technologies which can
provide broadband and "broader-band" technologies which are capable of evolving
over time.
Rather than being limited to a particular definition, the RUS should consider
applications for low-interest loans from
carriers that are deploying technologies that make significant progress towards
broader bandwidth services.  In the wireless
area in particular – satellite and terrestrial – technology is changing at a rapid
pace.  These services should not be excluded
from this important program although they may not always meet the 200 kilobits per
second definition.  The definition should be
flexible enough to permit financing for applications which represent a dramatic,
meaningful and truly bandwidth enhancing technologies in the mobile wireless
context.
The joint report by NTIA and the RUS, Advanced Telecommunications in Rural
America,[1] pointed to the
importance of wireless technologies in closing the digital divide separating many
rural residents from the rest of America.  The
report specifically mentioned that government should encourage the development of
new wireless technologies.   The adoption
of a flexible definition of broadband services by the RUS for its broadband
program is one very important step the
Administration can make to help advance the goal of encouraging the development
and deployment of new wireless broadband
technologies.
Extend America urges NTIA, as the Adminstration’s principle voice in
telecommunications, to urge the RUS to employ
a flexible definition of broadband services under its broadband program.  The
definition should recognize progress towards broader bandwidth, not become fixed
to one particular level.

Universal Service Support and Broadband Grant Programs
In addition to supporting broadband finance programs such as the RUS broadband
program, there are other essential
programs that play a critical role in stimulating broadband deployment.  One
indispensable program is high cost support under
the universal service system.  The Telecommunications Act of 1996 mandated that
the Federal Communications Commission
(FCC) “preserve and enhance” universal service through the adoption of reforms
that not only would allow for the universal
service system to accommodate a new competitive environment but also to ensure
that “consumers is all regions of the Nation,
including low-income consumers and those in rural, insular, and high cost areas,
should have access to telecommunications and
information services, including interexchange services and advanced
telecommunications and information services.” [2]
One of the most important steps that could be taken to simulate broadband
deployment in rural areas is for the FCC to
fulfill the mandate of the Telecommunications Act of 1996 and identify support
mechanisms for advanced services.  In
establishing such support mechanisms, the FCC should ensure that such support is
available to a variety of broadband
technologies and carriers (provided such carriers meet the necessary criteria to
be designated as an eligible telecommunications
carrier under Section 214(e) of the Act).
Extend America urges NTIA to advocate on behalf of the Administration that the FCC
act to identify additional universal service support mechanisms for broadband
services, including services provided by new entrants offering wireless
technologies.
Furthermore, Extend America believes that NTIA’s  Technology Opportunity Program
(TOP) can also help stimulate
broadband deployment.  A focus on new wireless technologies and partnerships
within this program can be very productive.
TOP and other grant programs that provide assistance to end users can help drive
demand for broadband services in rural and
small communities and become the building blocks of a broadband network for a
community.  We encourage the Administration to support the TOP program and make it
part of its broadband policy.
Finally, Extend America believes that mobile wireless data communications can have
a significant public safety benefit in
rural areas where distance is a challenge to traditional wireline and wireless
services.   New carriers like Extend America can
offer new solutions to rural public safety communications needs.  The
Administration should adopt policies and dedicate
resources to efforts which encourage partnerships between the public and private
sector to utilize commercial wireless
technologies in the public safety arena.  The TOP program is one program that has
traditionally supported many public safety
projects and this ought to continue to be a focus of the very important TOP
program.
Again, we appreciate the opportunity to provide comments to NTIA regarding
broadband policy.

Submitted by,

Edward T. Schafer
CEO
Extend America

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