September 2009 Archives

[Edit: Was just notified by the inimitable Christopher Mitchell of Muninetworks.org that BroadbandUSA.gov has revised an error in their database that used to sort states based on where the applicants were located rather than the project service areas. There are some additional projects to be considered, which I will do over the weekend to supplement this post next week.]

Building upon my earlier explorations of the BTOP/BIP database of applications, I wanted to take on the challenge of an examining an entire state's worth of projects and determining which deserves funding the most.

As I'm a one-man review crew, I picked a state with a manageable number of applications, namely Vermont, which only has nine.

I don't have access to any more information than is available in the executive summaries, but that should presumably be enough to at least make some initial judgments about a project's significance and whether or not successful outcomes are plausible.

My unscientific approach to reviewing and ranking projects is to look at the short-term and long-term benefits of a project, both on the communities they serve and on informing future federal investment decisions, and also which projects look like they're going to maximize the impact of government dollars.

While I know only one project per state is guaranteed to get funded, I'm going to recommend one access and one adoption/use project as hopefully there'll be enough money and good projects to warrant doing at least this much for every state.

To start with Vermont has two sustainable adoption applications and two for public computing centers:

Adoption
Vermont Council on Rural Development, ~$2.5 million - They're going to create 24 eVermont communities focused on increasing broadband adoption, especially in communities where broadband has just been made available. On the surface this sounds like something all states should be doing, but at least in the executive summary there's no meat to this project, nothing to indicate how what they're doing is special. It all sounds a little generic. I also have to admit that part of me worries that this is a ploy to use public money to increase takerates and therefore profits for a private provider. I'm all for private providers making money, but unless there's a lot more detail about how what they're doing goes beyond just getting people online, then I'm not sure if this is the best use of government dollars.

Health Care & Rehabilitation Services of Southeastern VT, $743,822 - They're going to use this money to purchase and setup videoconferencing technology to connect rural mental health centers so that they can better share resources and save travel times for specialists. I'm 100% supportive of a project like this getting funded, one way or another. Yet I do wonder if it's the best use of BTOP money as it won't directly increase adoption and it doesn't necessarily create any jobs, which is the point of the overall stimulus. That said, if they could eventually extend the ability to communicate via video into homes and/or they're able to inspire other healthcare entities to start using two-way video technologies to improve efficiencies, then this could be an intriguing option.

Public Computing Centers
Vermont Department of Libraries, ~$600k - With this money they're going to enhance four existing computing centers, create four mobile computing labs, and facilitate some computer training. I like that they have a lot of local colleges engaged in this application, and they do have the training element which means this is about more than just buying computers. But if I'm being totally honest, this application's a little ho-hum for me. Not to say the money wouldn't be well spent or that it isn't needed, but instead that I'm wondering what larger benefits we're going to get from this. What lessons are we going to learn to establish best practices that can be used elsewhere. I also have some reservations about the effectiveness of mobile computing labs relative to fixed computing centers, especially since it seems likely that you could establish multiple computing centers for the cost of one mobile lab. This isn't a bad application; it just isn't one that gets me excited.

Southern Vermont Health & Recreation Center Foundation, Inc., ~$4 million - This one didn't have a link to a more extended executive summary so I have very little to go on. The gist is that they want to create a rural society of wellness that can serve as a national model. While I love the idea in theory, and it seems like it's something that should be done somewhere, I wonder if this is the best place to do it. The Recreation Center that is the named applicant looks like a nice facility, but I didn't see anything on their site that suggested they have any expertise in using broadband to encourage better health. The same challenge is true with Springfield Hospital, who they cite as a partner but when I looked at their website there was no mention of them having any special expertise. I do believe that we should be creating health centers that can serve as national models, but I'm not sure this is the one to do this, because based on the paragraph description in the database, I can't help but worry that this is nothing more than building new computing centers with links to health resources, in which case $4 million sounds like a lot of money.

Recommended Project
If I knew more about the eVermont initiative, I might lean towards that one, but as it currently stands I have to go with the one from Healthcare & Rehabilitation Services of Southeastern VT. They're not the strongest project for BTOP's adoption grants as they're not dealing directly with the issue of adoption, but what they are doing is using broadband to drive new efficiencies and doing so in such a way that could help further prove the model about the benefits of using two-way video to increase efficiencies. So if I could fund one adoption/computing center in Vermont, it would be this one.

Infrastructure
Vermont Telephone Company, $56 million grant for last-mile non-remote BIP/BTOP - The basics of this project are simple: VTel wants to overbuild its existing footprint with fiber and extend their reach to unserved surrounding areas with wireless. I do like this idea on one level since they're talking about building fiber, and VTel makes a compelling case that they can be trusted with government dollars and that they're fully capable of building quality networks. But I also have some reservations. For one, is wireless really the best solution for these unserved areas? I know that much of Vermont is hilly and heavily treed, two characteristics that make wireless signals more difficult to deliver. Also, I thought this money was intended to help connect the unserved, which the bulk of this grant won't go towards, as well as the underserved, which VTel's basically saying is what its customers are. Additionally, there is language in the stimulus that suggests these dollars are meant to spur the deployment of networks that wouldn't be deployed by other means, and yet VTel admits that they're likely to make these upgrades eventually and that stimulus funding would simply accelerate their timetable. Finally, I still have serious reservations about giving a grant to a private entity. I worry that doing this makes it hard to insure that these public dollars are used to further the public good rather than just to increase private profitability. I'm not saying this is a bad project, or that VTel was mistaken for applying, just that this doesn't seem like the ideal project to fund.

ECF, ~$69 million loan for last-mile non-remote BIP - I need to admit at the outset of this analysis that I know both Tim and Leslie Nulty personally and consider them both friends. They're also founding members of the Rural Fiber Alliance, which I'm spearheading. And I've been a fan of what they're attempting to do since before the stimulus. With those biases on the table, let me share my thoughts on their project. First off, compared to the VTel project, I'm immediately inclined to favor ECF's by the simple fact that they're a public project, which the original stimulus language suggested should get priority, and they're looking for a loan rather than a grant, and I think so long as a project will be self-sustaining, it's always better to loan money that you'll get back some day than to just give handouts of free money. I also prefer ECF's project because they're going to be bringing fiber to every home in their service area. They're not going to leave anyone behind, creating second-class digital citizens. Finally, I think that ECF's project has a greater chance of establishing a model that the rest of the country can learn from, proving both that fiber can be economical in rural areas and that open multi-service networks can be financially viable. The only things working against them are that fiber is more expensive per home to connect upfront than wireless, and that they don't have an established network deployment/operations infrastructure in place. But I strongly believe that while fiber may cost more upfront, that it's also by far the best long-term investment. Plus ECF's management team does have significant experience building viable networks.

Teljet Longhaul, ~$25 million middle mile grant BIP/BTOP - This is another project I know less about as they didn't include their executive summary, but I can say that on the surface I like the idea: to build new and interconnect existing fiber networks to create a regional network connecting educational, medical, and municipal facilities across VT, NH, NY, and ME. But again I have some reservations. For one, this is another private company that wants a grant, and if there's a public entity that's capable and is looking for a loan instead, I think you have to give them priority. Secondly, their site claims they have a FTTP network, yet they don't list any specifics and a quick Google search didn't turn anything up, which makes me a little suspicious. I'm also concerned about what safeguards would be put in place on a project like this to insure that this private company maintains a fair pricing structure on into the future. I'd hate to see us give out free money only to end up creating a private monopoly without any constraints on their ability to jack up prices. This is especially true with a fiber network, as if public money's paying for most of the deployment, then the cost of bandwidth should be really low, especially in-network as the incremental cost of delivering that is minuscule. So while I like this project's goals in theory, I have some concerns about the details of how it's going to be accomplished.

Northern Community Investment Corporation, two grants totaling ~$20 million across VT and NH for last-mile remote BIP - The gist of this project is that they want to build a big wireless network over the northern parts of VT and NH. NCIC is a non-profit entity, which is good, but they're also asking for a grant instead of a loan so we can't expect to get this money back to help fund other projects in the future elsewhere. I do like projects with a large scale so we can get a big impact from this money, but at the same time I'm still really wary of wireless projects, especially in troublesome terrain like you find in VT and NH. In fact, when I searched through their executive summary, they didn't use the word "fiber" once, which is very concerning as fiber should serve a key roll in any broadband deployment, even if it's not all the way to the home you at least need it running to wireless towers if you want robust wireless access. Also, they talk about serving community anchor institutions with wireless, but I'm always going to favor projects that connect these buildings with fiber as you need a lot of reliable capacity to support the usage of large numbers of simultaneous users like you'd find in a school or hospital. I know that wireless can do in a pinch, but we should prioritize fiber whenever possible. For these reasons I put this project in the good-but-not-great category.

Recommended Project
With all this thinking in mind, if I'm in the position of deciding which of these projects make the most sense to fund, I have to go with ECFiber. While I do have a bias there are a lot of logical, unbiased reasons for this recommendation:

1. They're the only ones asking for a loan instead of a grant, meaning they're the only project that will give money back that can be used to fund additional projects in the future.

2. They're the only ones bringing true broadband to the unserved, which means we won't have to worry about subsidizing these communities again in a few years.

3. They're the only ones that seem to have the potential to establish a model that, if successful, the rest of the country can learn from both for rural fiber and open networks.

None of the other applications feel as significant. That doesn't mean they don't deserve funding, just that I think ECF's will be the best use of taxpayer dollars, both in terms of helping rural Vermont and providing lessons that the rest of the country can learn from.

So there you have it. My thoughts on who should get broadband stimulus dollars in Vermont.

This was a really interesting exercise to embark on. It forced me to clarify my ideas about what types of projects should get funded, and Vermont provided a perfect microcosm of the kinds of projects that are seeking support across the country.

But even though Vermont didn't have that many projects and I didn't have that much information I needed to pour through, it still took quite a bit of time and critical thinking to come to these conclusions. As a result I have a greater appreciation for the challenge facing states, especially the bigger ones, when it comes to trying to whittle their lists down to just a handful of recommendations. Take California, they've got nearly 200 applications to sift through. Needless to say, I don't envy them.

But I do hope that the lines of thinking I introduced in this post will help guide states as well as the decisionmakers at NTIA and RUS as they go through their respective vetting processes and make their recommendations/decisions. Because as I've said before and will continue to say again and again: getting the broadband stimulus right is vitally important to America's broadband future. If we aren't good stewards of this round of funding, there likely won't ever be another.

"FCC reform" has become a buzzword in broadband policy circles recently, with new Chairman Genachowski committed to bringing the agency into the 21st century and everyone acknowledging that something needs to be done to improve its efficiency and effectiveness.

But so far, most of what I've been hearing about how to reform the FCC deals with how to improve specific programs, like USF reform, or specific functionality, like improving their website.

Yet I can't help but wonder: are incremental improvements sufficient to get the FCC where it needs to be?

I ask this because we have to be realistic about the current state of affairs. For starters, the FCC has grown into this massively complex beast over the years because every time a new communications technology came into existence a new set of rules had to be put in place to regulate it. And over time these rules became more detailed and convoluted as the FCC tried to keep pace with technological evolution.

The FCC has spent decades building up these stove-piped regulations that apply certain rules to certain technologies.

And yet the core challenge the FCC faces in this day and age is the fact that these communications technologies are now merging. The distinctions between phone and TV providers has already disappeared, and increasingly the technologies themselves are combining into new forms that don't really exist in any one silo.

The FCC is operating in a world now that's completely different from that of the 20th century. But so far it has not adapted to this new paradigm other than to open up a catchall category of "information services" that has fewer regulations and therefore is the category every service provider wants to fall under. The problem with this is that means the regulations that were in other silos to protect the public's interests are now becoming marginalized.

What this all leads me to is wondering if it's possible for the FCC to become relevant to the 21st century communications paradigm through incremental changes to its existing stovepipes. And on that front, my gut tells me no.

I liken this to a story I heard from a developer friend of mine who was hired onto a project that he spent years trying to incrementally improve. Eventually he realized that he was spending more time fixing problems than on making progress to improve the functionality. So he decided to stop wasting time fixing a leaky ship and instead focus on building a new ship from scratch. Now of course it's not easy to do this. It takes a lot of time, money, and energy. But as a result he now has an application that runs way better than the old one and that stands ready to be expanded in exciting new ways.

I think we have to strongly consider taking the same approach to FCC reform. We don't just need the agency to be a little bit better; we need to have them fundamentally reimagine their role in 21st century communications policymaking.

Yet this doesn't have to be an insurmountable feat. The key is to start by establishing a core premise and building out from there. And the most obvious building block of our 21st century communications infrastructure is that of bandwidth.

Bandwidth is the common element that unites 21st century communications services. It doesn't matter what service is being delivered via IP, it's all using bandwidth.

Also, enabling the availability of more bandwidth is fundamentally what we're talking about when discussing creating a national broadband plan.

Basically, bandwidth is the thing that cuts across all the silos of 20th century technologies within the 21st century paradigm, so I believe that it should be the focus for the FCC moving forward.

With this in mind, I see the national broadband plan as the perfect opportunity for the FCC to stick a stake in the ground and claim ownership over this issue. Over making sure that plenty of high quality, reliable, and affordable bandwidth is available to all Americans. To get everyone online consuming bandwidth. And to encourage the incorporation of using bandwidth to improve all facets of society.

Taking this approach can also help move us towards a unified communications policy framework. For example, instead of taking different money from different services to fund different programs, with a bandwidth-centric mindset we can pursue a bitstream approach to raising funds for things like USF and public media.

What if instead of charging for USF just on phone service and public access channels just on TV service, we combined all communications services under a single bandwidth umbrella and charged a unified fee across all of them in order to fund all of our public interest obligations?

This would stop the practice of providers trying to game the system to avoid having to pay into either of these programs by getting reclassified as an information service. It would also simplify changes moving forward.

I'm not saying that we should abandon all rules associated with specific services like voice or video, but instead that in order to craft the best possible policies for the 21st century communications paradigm that we need our regulatory mindset to match the evolution of technology. We need to acknowledge that just as the industry is making radical changes, the FCC needs to do the same, that in the face of a communications industry already well on its way to fundamentally shifting its paradigm that incremental change to existing FCC policies won't be sufficient.

So I implore the FCC and those trying to influence them: let's not settle for incremental improvements to an outdated paradigm. We're long overdue to approach this reform from a more foundational level. Because that's the only way I see the FCC being an enabling force in the 21st century. And I can think of no better way to reset the FCC than to focus them on the core challenge of bandwidth as the unifying force for communications policy.

For everyone who's ever admired Lafayette from afar and who cares about the future of the Internet, or anyone who just enjoys watching a good time being had, I encourage you to tune in to Lafayette, LA's OneWebDay celebration tonight from 6-7pm Central at www.aocinc.org. (The video will be live later today.)

For starters, OneWebDay is an international celebration of the Internet and how it brings us together as one people. There are events happening all over the world. Go check out their site to see if there's one near you.

But if there isn't or if you'd rather stay at home, then I strongly encourage you to check out what's going on down in Lafayette tonight.

There's a bang-up list of speakers scheduled, including Mayor Joey Durel, LUS Director Terry Huval (they're the ones building the fiber), University of Louisiana-Lafayette President Dr. Savoie, and a whole lot more, all talking about what they're doing with broadband and what they're excited about for the future. It's a celebration of their community, culture, and commitment to pursuing their innovative spirit.

Plus there's going to be a live Cajun band playing throughout!

What better way to spend an early Tuesday evening then tuning in to see what's happening in one of the most wired and inspired communities in the country.

And if you happen to live in or near Lafayette, then get to the LITE Center on Cajundome Blvd by 5:30 for a reception with free beer and win. Then enjoy the show live and be able to cheer on your fellow citizens.

Don't miss out on the opportunity to join in on the fun!

Last Monday I wrote about how I'd heard that NTIA had dumped all the unreviewed BTOP applications on the states.

I backed off from those comments somewhat in my post last Tuesday as I'd tried getting this bit of news confirmed and was having some trouble doing so, plus I got some other intel suggesting that progress was being made.

But today I got that confirmation from this San Francisco Business Times article:

"California technology officials are scrambling to rank 178 applications for broadband stimulus money that have been submitted to the federal government by businesses, nonprofits and government agencies statewide.

Originally, the federal departments of agriculture and commerce were going to determine which applications were viable and then forward them to the state for ranking, but last week federal officials said the state would have to do an initial review on its own, said Joe Camicia, chief of staff in the Office of the State Chief Information Officer.

"We're scrambling," Camicia said."

So it's official, NTIA has thrown states under the BTOP bus.

To some degree I can understand why they've done this. They've set deadlines for getting feedback from the states and they want to give the states as much time as possible to review the applications and make recommendations.

But let's think through this a bit further.

First off, if NTIA truly didn't conduct any initial filtering before passing the applications through then they've created a lot more work for the states by forcing them to review everything, which means they'll be wasting time considering those applications that have no chance of making it to the next round of consideration.

Secondly, if NTIA wanted states to be able to make the best possible recommendations, then why not wait until they're able to see the scores from the initial round of reviews? For the most part, states don't know how the NOFA works therefore their recommendations will be totally divorced from how NTIA will be scoring them.

With these two thoughts in mind, what happens if a state recommends a low scoring application? Will their opinion be immediately disregarded? If so, then what's the point of having them review all the applications?

I actually feel really bad for the states. Take California, for example. They've got 178 applications they now have to review, vet, and weight the relative merits of. In fact, what they really need to do is determine which one project deserves the money most as that's all they're guaranteed to get. But where are they supposed to find the time and unbiased expertise to do this?

It's going to take at least hundreds of hours to do this right, and states only have a few weeks to finalize their recommendations. So not only is their decision-making going to be ill-informed and more work than it needs to be, it's also going to have to be a rush job.

On top of this, from what I hear states have the ability to request whatever information they want from applicants. This is potentially going to create a lot of work for applicants, not to mention the time it'll take states to process and review whatever information comes in. And yet there's no guarantees that the information requested will be relevant to the decisions ultimately being made or to improving applicants' chances of getting picked.

Of course, none of this will be a problem if you're in a state that's submitted their own application. In fact, if I were one of those, I wouldn't waste time conducting any review at all. I'd just recommend NTIA fund my project and be done with it. But that wouldn't be so easy to do if all the applications in my state had already been scored and mine wasn't at the top.

And that leads us to the next part of this analysis, which is to show how states are being setup for failure.

Let's take the example of a state with their own application. What happens if they recommend their own project without the cover of an initial review verifying that it's a viable, worthwhile project? Even if the state does conduct a true review process of its own, if they pick their own project it's going to look like favoritism. This could lower the public's perception of the project's legitimacy even if it's a great project, which isn't exactly the best way to get what should be a community effort underway.

What if a state's recommendations are ignored because they didn't pick a high scoring application? It'll simultaneously make the state look silly in the public eye while demoralizing them at the exact moment we need all levels of government to feel energized and appreciated, especially since the stimulus isn't a one-time initiative, it's (hopefully) the beginning of an ongoing mandate to better coordinate public projects.

While it's likely most projects in a state won't get funded leaving lots of disappointed constituents, NTIA has left the states out to dry by again not giving them any cover for their recommendations. When they say who they think should get the money, they'll automatically become a hated target for a lot of people. This will likely then lead to a lot of inference and speculation if the state decisionmakers have any perceived conflicts of interest, which could lead some worthwhile projects getting marginalized due to these decisionmakers not wanting to deal with the scrutiny.

My point is that NTIA could've done the states a huge favor by holding true to their original plans to have the initial review completed before getting states' recommendations as that would've mitigated much of the negative outcomes listed above, both by helping states make more informed decisions, by saving them from wasting time on projects that aren't worthwhile, and by giving the public greater confidence that this review and selection process is ultimately picking the best projects to fund. Instead NTIA has chosen to prioritize deadlines over effectiveness, to worry more about the clock than the outcomes.

But what's arguably even more troubling is the lack of transparency about what NTIA's doing. They have not said one word about the fact that they've changed course and won't be providing the states with any initial guidance on which applications will make the first cut. They didn't even mention it when Larry Strickling was testifying in front of Congress on Sept 10, despite the fact that they had either just sent the application dump out or were right in the midst of preparing to do so as he spoke.

In fact, when reading Strickling's comments, I realized that he specifically avoided mentioning that they were doing this. Check this out:

"...The expert reviewers' scores for each application will be averaged and those applications considered the most highly qualified in the initial review phase will advance for further consideration.

Each State and territory will be given the opportunity to prioritize and comment on the applications relevant to its jurisdiction. The Act recognizes that State and territorial officials have a unique perspective on broadband needs within their jurisdictions and we look forward to their input.

During the second review phase, NTIA also will engage in additional "due diligence..."

Notice how the state's role is ambiguously positioned in between the initial expert reviews and the second review phase, but no mention is made for how their recommendations fit within this process.

Perhaps I've been misreading things and what this actually means is that states' opinions won't count for much and therefore it doesn't matter how informed they are. But even then this is a rude way to handle things, and not the best first impression this new NTIA could be leaving on the states.

In the end, I see nothing but negatives from dumping unreviewed applications on the states. They're going to have more work, make worse recommendations, take more heat from their constituents, and potentially either influence the final decisions too much by recommending the wrong projects get funded or not enough because they picked projects that have no hope of getting picked.

Yet it doesn't have to be this way. We don't have to keep moving forward under a flawed system. I hate to say we should slow things down, but at the same time I definitely do feel that it's better we get this done right rather than get this done quickly.

So I implore NTIA to reconsider their course of action. Give the states more time to review and provide them with your initial reviews and scores as soon as they're conducted. Because if you don't empower states in this way then I can't help but feel like you're throwing them under the bus.

Hopefully the states don't just turn into another bump on BTOP's fast trip into the ditch.

So over the last couple of days curiosity has gotten the better of me and I've started perusing the BTOP application database available here.

In it I've found a whole range of projects, from those requesting tens of thousands or even less to tens of millions and even more, from those that look just right to those that look all wrong, from those that seem to have the public interest foremost in mind to those that stink of profiteering.

To help frame my initial reactions, let's break things down into the tried and true categories of the Good, the Bad, and the Ugly.

The Good
One very good thing is that there's a wealth of innovative models represented in these applications. They're not all innovative, but there are enough good projects in there that I'm confident at least some of this BTOP money will have a positive impact that pushes our country forward.

Another great thing is that there's a ton of fiber projects, 181 in total requesting $3.7 billion, according to this FierceBroadbandWireless.com article. As a big believer in fiber, I was ecstatic to see that it outnumbered all other wireline technologies by a factor of four or five. This shows that most people realize that fiber's the only technological answer to building networks that can withstand the test of time and grow to match our needs.

Given the initial intent of the stimulus to prioritize public networks, it was reassuring to see all the applications from public entities. I'd heard some buzz a few months ago that maybe there weren't enough good public projects to fund and that we're better off just giving the money to private providers, but this list of projects proves that sentiment to be wrong. There are plenty of worthwhile public projects ready to turn funds into action.

On another positive note, while I'd feared that this program would be stricken with greed through lots of applications more worried about profiteering than the public good, the general sense I got is that there isn't too much of that. It's still there, but not overwhelmingly so. Or at least they're just really good at hiding behind the language of their executive summaries.

Finally, there definitely seems to be enough worthwhile projects to use up all of the budget that's available for this round of funding. I never had concerns that there'd be enough requests, but it's reassuring to know that there are plenty of good applications that deserve to have a chance at these grants and loans.

The Bad
To start this section with, let me say that while reading through this I became increasingly wary of using public grants to fund private projects. I just have a hard time getting my head around taxpayers subsidizing somebody else's profitability when there are worthwhile public projects to be funded. That doesn't mean I think private projects don't deserve funding, just that I think we might need to rethink how that works. For example, why not require any private firms looking for grants to give up part of their company to the government in exchange for the money? That way if they become wildly profitable the American people can share in that success. Alternatively, perhaps what's really needed is an angel/VC mechanism that could fund socially conscious private companies. I'm not saying that all the private companies that applied for grants are bad, just that I think we should treat them a bit differently if we're handing them a check with few strings attached.

In both the public computing center and adoption sections, I think there's too much of an emphasis on buying computers. I completely respect the fact that not having access to a computer is a hugely limiting factor to people adopting broadband, but just because you have computers available doesn't mean that anyone will use them. And there are technological opportunities that may be better than simply buying computers, like pursuing thin client terminals that leverage big bandwidth to host applications on central servers thereby reducing the cost and time associated with keeping computers up and running, since these terminals have fewer moving parts. Alternatively, would it be better to get mobile devices into more peoples' hands than desktop computers since that's the way usage patterns are trending? I'm not saying we shouldn't be buying computers, just that I'd like to see more emphasis on more sophisticated initiatives that step beyond that basic approach of just buying computers and setting them up in a room. Yet this seemed to be the model for most public computing center applications.

On a related note, a bunch of the public computing center applications do nothing more than upgrade the machines at existing computing centers. Is this really the best use of these dollars? I'm actually not totally against this idea, but I think there needs to be some additional level of screening to make sure that only those computing centers that are already successful and that have more demand than supply receive these funds. Because if we end up upgrading computing centers that aren't already in demand, that seems likely to result in wasted resources.

I do need to acknowledge that there are a lot of applications talking about going beyond just buying computers to take a multi-layered approach, especially in the broadband adoption side of things, to combine connectivity, computers, applications, and training. While I'm hugely supportive of this in theory, I can't help but wonder, which of these will work? Which will make better use of these funds than others? Have any of them worked really well yet? Because on paper, the answers to these questions aren't entirely clear. And for the most part I'm not sure if anyone has totally cracked the nut on this yet, so anyone claiming that their model's proven makes me wary. That said, I'm fully supportive of the idea in theory, so let's just make sure we fund the right ones.

The final bad thing I'll mention is that there are a lot of applications in the wrong categories. Requests for funds to build computer centers under adoption. Plans to use money for connectivity projects under public computer centers and adoption. Adoption requests applying for public computer center money. On the one hand, I don't necessarily blame the applicants for doing this as the best projects often don't fit neatly within one definition. And I think this shows that the distinctions between different types of projects are largely arbitrary, suggesting that we should be taking a more holistic approach to funding innovative projects. But I also can't shake the feeling that some of these projects were intentionally put into different categories in the hopes of increasing their chances of receiving funding. In other words, a project to bring last mile connectivity thinks it has a better chance of beating out other adoption projects than other last mile projects. And to me, someone who's willing to do that probably won't be a good steward of taxpayer dollars.

The Ugly
The first ugly trend in these applications is the audacious amount of money requested for satellite "broadband". A $130 million grant and $400 million loan to someday deploy a satellite that will hopefully deliver the speeds they promise but rarely deliver on. Plus two applications of $15+ million a piece that basically goes to business development for the satellite companies helping them get customers. First off, I don't consider satellite service to be broadband. Its upload speeds suck, it has really high latency rendering apps like VoIP unusable, it has really low bandwidth caps and high overage charges, the service is hugely expensive, the new satellite won't be ready to get people connected for at least a few years, and despite their claims of reaching all of rural America there will still be a ton of homes not able to connect because of their geography. Making this even more troubling is that if they get money to serve an area, then that area might not be able to get any more money, so anyone not able to connect to this crappy satellite service will be left without any options. I could go on, but I think this is an incredible waste of money, and I will be extremely disappointed if NTIA deems it worthy of funding, especially since I know of much better projects that are much more deserving, plus I'm having a hard time stomaching giving a private company half a billion dollars to fund its R&D; and help it increase its profitability.

The only group of projects that almost make me more upset are the requests for funds for BPL (or broadband over powerlines). Let's not beat around the bush: BPL is not a proven technology. It's never been deployed on a large scale in the US, and it's never been proven to work all that well anywhere. Plus it doesn't deliver much in the way of bandwidth today, and it has no clear path to be able to easily upgrade that capacity over time. And giving BPL projects money could lead to the same issues as satellite, namely ruling that area out from ever getting any more government money in the future to bring true broadband to their constituents. Not to mention that we're again subsidizing the profitability of a private company.

Somewhere in between surprising and not were the huge number of WiMAX applications, more than any other technology. While this wasn't surprising given that wireless guys have been touting their ability to get more people connected for less money than any other technology, and WiMAX is the new kid in town offering long-range wireless access, it still was a bit surprising as WiMAX is not an overly proven technology either. It's only just starting to be deployed in the US, and the initial reactions to the quality of service being realized in urban areas, where the higher densities make this easier to deploy, have been far from positive. Unlike satellite and BPL, I'm not saying we shouldn't give any money to WiMAX, but I do think that it'd be a mistake to invest too much in an unproven technology. Better we just fund a few projects to see how they work, and then we can look at funding more in the future.

The ugliest grant request I saw connectivity-wise, though, was for a public computer center in San Francisco that wants money for T-1 lines. While this may be their only option for reliable bandwidth, I think it's rather telling that there were only one or two applications out of 2,200 that thought T-1s were worth investing in. We've got to make sure we're only putting money into forward-looking technologies, and T-1s are so 20th century.

On another note, I'm not a big fan of the applications that want to subsidize service. I know that price is a big barrier to many of the people who have yet to adopt broadband, but what happens when the time or money runs out? Will prices just jump back up and leave them out again? Even with these subsidies, how do we know they will be enough to get everyone online? And how do we know that private providers aren't padding their pricing with extra profit subsidized by taxpayer dollars? This wouldn't be the first time this has happened when government's handing out free money. While I'm not totally against this idea, I have some serious reservations about its effectiveness and efficiency.

Another overarching concern I have is that it seems like some of these applications were slapped together just for the stimulus, in other words they didn't exist before February. Unless these projects have some really great people behind them with tons of community support, I don't see how taking the risk with these new ventures is worth it. I'd rather see projects that have been working on their initiatives for a while get funded first. Though the flipside to this is that we also don't want to fund projects that may have existed for a while but haven't made any progress or had any success. It's going to be a tricky balancing act to find the middle ground between these, but I think it's an important consideration to make as free government money always brings out people with dollar signs in their eyes.

Another very ugly aspect of these applications is the database they're displayed in. I know I should probably be grateful for any transparency, but I can't help but wonder why can't we do simple things like search for projects based on dollar amount requested? Why isn't there an easy way to which applicants are non-profit or for-profit? Why can't we have a map that plots out where the various projects are located? Why aren't there any ways for the public to rate, rank, and/or comment on these applications? This last piece is especially important as I think we're missing a ton of opportunity to crowdsource some of the review process.

The final ugly thing I'm a bit worried about is that some of these applications look like they've got the right ideas but they may not be fully fleshed out yet. What support structure do we have for them? Are the choices to either give them money that they may not be ready for, or to not give them funding and watch them fade away? Why don't we have a support system in place that can help advise these projects on how to improve their applications for the next round? I know there's been some talk of having some flexibility to give advise to applicants on what they're missing, but I'm thinking about taking this a step further in order to help increase our chances for success.

Unfortunately, I know that NTIA and RUS have just a little bit on their plates right now, and setting up this support structure would likely take a lot of work. But I think it's important that we all keep the dialog going about what the right way to administer a program like this is, because I'm a believer that this is just the beginning of greater government support of broadband.

So there you have it, my initial thoughts on the good, the bad, and the ugly of the first round of stimulus applications. Let's hope the good becomes great, the bad becomes good, and the ugly just fades away.

Yesterday I called out America for its do-nothing attitude towards broadband policy, criticizing both those that'd rather see little done and may fight against progress, as well as those that aspire to achieve great progress but often don't have specific plans for reaching their goals.

My criticism of public interest broadband advocates was swiftly denounced and refuted by a series of comments, which forced me to reconsider what I'd wrote and thereby realize that I'd made a big mistake.

Namely, I forgot to acknowledge the tremendous amount of great things being done by community broadband activists across this country today on a whole range of issues, from protecting consumers, to spurring adoption and use, to getting the networks we need built. Not to mention the many good ideas that have fallen by the wayside over the years as America failed to realize the importance of having a national broadband strategy.

I cannot state strongly enough how much I appreciate, admire, and aspire to emulate the many public interest broadband advocates that have been working tirelessly for years on these issues that I'll admit to being a relative neophyte on.

I've been fortunate enough to meet, work with, and get to know many of these advocates, so I absolutely know how strong and productive the public interest community can be.

And yet because I do consider myself a member of the public interest community and am someone who believes in making strong considerations to protect the public interest in broadband policymaking, I feel obligated to speak out when something's askew.

The point I was trying to make in my last post is that even though great, actionable work has been done for years by advocates for the preservation of the public interest in broadband policies, there is a rampant perception that those wanting to set more aspirational goals for broadband policy rarely have the data to justify those goals nor the plans for how to achieve them.

I'm not just talking about incumbents, nor just politicians predisposed to favor corporate over community interests. I've heard this from government officials who intuitively think that what we're asking for is right, but now need help coming up with a specific plan for how to achieve them. Because a national broadband plan can't just be a bunch of aspirational goals; it needs to be a spur to get Congress and other government agencies to take specific action to get us moving forward faster into a better broadband tomorrow.

On the one hand, this is really screwy and scary. Even our friends think they can't work with us, and that we're too divorced from reality.

But on the other hand this is a really exciting and tantalizing state of affairs as the public interest community is finally in a position of strength after years of neglect.

The key now is that we don't get stuck espousing the need to do big things and overlook the need to lay out how we can achieve those big goals. Because if we can come together around a data-driven, well-thought-out plan and unite our voices behind it, I do believe that we can accomplish our common goals, namely that the public's interests be not just protected but celebrated in our national broadband plan.

So I hope now with this explanation of the intent of my post yesterday public interest broadband advocates can see that its purpose wasn't wasn't to call out but to call to action, wasn't to tear down but to constructively criticize.

And to anyone who read my last post and took offense as a member of or on behalf of the public interest community, please accept my sincerest apologies. I've learned from this experience and will never again discount the great work being done by public interest broadband advocates across this country.

While germinating for a while, it recently dawned on me what the central challenge to crafting effective broadband policies is: the do-nothing attitudes of most of America's broadband players.

This line of thinking was set off by reading Blair Levin's truly tremendous speech that he gave recently to the Free State Foundation calling for more robust and reasoned debates surrounding broadband policies. Essentially he was lamenting the prevalence of past dogma limiting new lines of thinking in broadband policy discussions.

That struck right at the heart of this core challenge I alluded to above.

On one side you have incumbents, private operators with existing network assets that for the most part are hugely profitable in today's broadband paradigm. Their do-nothing attitude stems logically from the perspective of not wanting to disrupt the good thing that they've got going. The only changes they seek are those that improve their bottom line, and they'll fight anything that they perceive as potentially harming their profitability.

On the other side you have public interest groups, organizations dedicated to making sure America's broadband infrastructure supports the needs of its citizens. These entities tend to not be satisfied with the state of today's broadband, instead wanting bold, aspirational goals to be set, the kind that can help America recapture its position among the world's broadband leaders. But while they want to see lots of action happen, their do-nothing attitude stems from the fact that the big goals they espouse rarely come with specific plans for how to achieve them. Also, they resist any changes that are perceived to increase the profitability of incumbent providers since they consider them at fault of America's current broadband plight.

Then of course you do have some people like myself in the middle, who see that there's truth to both sides, and that are focused on trying to make sure something tangible is getting accomplished.

The challenge is how can we make real progress when the two cornerstones of broadband policy discussions are taking do-nothing stances?

Making these do-nothing mindsets all the more frustrating is that they're preventing the two sides for recognizing that by taking actions that while on the surface may seem objectionable can in reality help everyone realize a better future.

For example, incumbents are totally against government subsidizing any network buildouts that might introduce competition to legacy, private networks. While there are legitimate questions to be answered about the appropriateness of government competing with private enterprise, what incumbents fail to realize is that the building of open fiber networks could be a boon for their businesses. Imagine not having to spend any more money having to upgrade your physical infrastructure in the field. Imagine being able to reach all new customers without having to pay to put another wire in the ground. That's what open fiber networks allow for. But the problem is incumbents perceive these networks as nothing more than government-sponsored competitors, and as a result they can't accept that tacking action to deploy these networks will produce benefits for them.

On the other side, it's hard to talk about any measures that would increase incumbent profitability without getting upbraided by the public interest community. Take net neutrality as an example. No one will argue with the fact that network operators shouldn't be allowed to intentionally slow down some traffic to favor others. But when incumbents talk about wanting to offer opportunities to speed up traffic, they're decried for wanting to squeeze more profit from their networks and for wanting to destroy the openness of the Internet. While I'm not trying to claim that net neutrality is as simple as this, what's troubling is that those who support the public interest's agenda can't seem to open their eyes to possibilities like rules that would give operators free rein to at least try out offering prioritized access lanes before setting in stone rules around how that would work, so long as they pledge to reinvest a certain portion of those profits into upgrading the open capacity of their networks.

Taking this discussion back to a high level, I think it's important for everyone to understand that the time for do-nothing broadband policies has passed. The FCC's in the process of writing a national broadband plan that Blair Levin clearly wants to be aimed at doing something, at producing tangible results. What's in flux is what needs to be done and how we should do it.

So I'd suggest to incumbents to stop assuming that the only good action is inaction, because otherwise they risk having no direct impact on this process of crafting a national broadband plan other than being seen as obstructionists.

And to the public interest community, it's time to get our act together and to turn our big ideas into concrete, actionable plans. We don't need more rhetoric, we need to have specific suggestions for the steps government should be taking to move our country's broadband future forward.

The opportunity's wide open for all players to directly influence the shaping of a national broadband plan that America can be proud of, but the only way to achieve true progress is to put aside the do-nothing mindset and start working towards building an action-oriented plan.

I'm officially fed up with how NTIA's handling the public relations of BTOP.

For starters, I don't see any compelling reasons for why this process can't be a whole lot more transparent.

Why can't we know who the reviewers are? I understand why we might not want to make public who's reviewing what application as that opens up lines to lobby and influence the review process, but why not make public the list of approved reviewers so the public can vet them for conflicts of interest and competency?

Why can't we know what's going on and where things are at in the process? Officially we have no idea how many reviewers have been vetted, nor if they've even started the initial vetting of applications. But I just learned some insight through the comments to this post by BTOP volunteer hopeful Mike O'Connor, namely that 600 reviewers have made it past the initial vetting and that 400 applications have been paneled so far. Why is it I have to learn this from a comment to a blog post?

The thing they seem to not be realizing from a PR perspective is that by not saying anything all of us out in the public that have concerns about how things are going will assume the worst. Without NTIA supplying a narrative about their progress, they leave open their actions to interpretation. And yet even the smallest amount of information can totally change that, like the stats I just shared above, which when I heard actually made me breath a little sigh of relief. Also, it's important for NTIA to realize that it's not like the world imploded because this information made it out into the public.

On a related note, why not announce whenever a project makes it through the initial panel review process? Assuming they're confident that their initial vetting process is working, I see no reason not to let the world know with a big public list which projects are ready to move onto the next stage. This then would give the public a chance to know that progress is being made, and to have a chance to comment on the projects that made it through the first round. The only reasons not to do this is if you're not confident in your review process, or if you're waiting to announce the finalists in one big chunk, but by waiting you lose the opportunity establish this narrative that progress is being made.

One other thing on this topic of transparency that's really irking me is the lack of communication going on between NTIA and their volunteer applicants. These people who have applied to be volunteers are doing their country a great service by offering up their time and expertise to help make BTOP a success. Yet many of them are receiving zero communication from NTIA about what's happening and what timelines look like moving forward. Quite frankly I find NTIA's treatment of these volunteers to be incredibly rude. Why can't they at least send out a mass email to all the volunteers with an update every week or two, if not in detail on the process at least with some news on what's these volunteers should expect will happen next?

Not only is this rude, but it also doesn't lend itself to an effective review process as it wouldn't surprise me if many volunteers decide to drop out because of this treatment, and even those that stay in will become increasingly less likely to be able help out and accommodate NTIA's schedule if they can't know how they should be scheduling their availability to help review applications. Are we expecting these volunteers to put their lives on hold while they wait for word from NTIA?

This new administration has touted that it's committed to bringing about a new era of transparency in how government works for the people. Yet I can't help but feel like NTIA's handling of the PR around BTOP so far has been following the old playbook. Making this even more frustrating is that they have the opportunity to totally upend the old way of doing things by making as much of the review process as public as possible. Just take a look at my post from yesterday for a few ideas on how that could be accomplished.

My guess is the reason they're keeping quiet is that they don't want to invite criticism when they make mistakes, and yet the thing they don't seem to realize is that I think the public is willing to forgive mistakes so long as we all think that NTIA's making an honest effort to do right by the country. And even more frustrating is that the impression I get from everyone I talk to who knows the people over at NTIA is that they are all good, honest, hard-working individuals who are trying to make the best of a bad situation. And yet because of the narrative void about what's happening behind closed doors at NTIA, the public's left to imagine the worst.

Because of all this, I'd like to suggest that NTIA consider changing course in how it's revealing information to the public. Stop trying to keep things hidden and quiet, and start trying to engage the public with the truth about what's going on. If there are bumps in the road, we'd rather know about them now than learn about them later as that's going to make us much more amenable to forgiveness. And maybe by being more public NTIA can garner more ideas and support from the public on how to make this process better, which is vitally important if the NTIA intends as it has stated to revisit its rules and review process for the next round of funding.

The time for silence in government was supposed to be coming to an end. NTIA, it's time for you to step up and show what a more transparent government can accomplish, and in so doing improve the odds that BTOP will be a success, both in reality and perception.

Over the weekend I learned something about NTIA's handling of BTOP that shook me to the core: last week they dumped all of their applications onto states without conducting any initial review to weed out ineligible projects or including any guidelines to help frame how states should go about making their recommendations.

While there's a chance they're going to announce an initial round of cuts today, I'm not optimistic given that the volunteer reviewers I know haven't been asked to do anything yet.

And while they're supposed to give guidelines to states this week, I'm not sure how those guidelines can overcome the many problems with relying on states to play a primary role in deciding who gets what. For one, most states don't have any formal decision-making process or the in-house tech or business expertise to enable them to pick the right projects. For two, few if any states have thoroughly read and tried to understand the NOFA, so they're not ready to pick the best projects relative to the original rules that were set out. Three, there's no end to the potential conflicts of interest that could negatively influence a state's recommendations, including the fact that some states have put in their own applications.

If I'm being brutally honest then I can't help but admit feeling like NTIA dumping these applications on states is a sign that they're punting, that they'd rather someone else make the tough decisions, and that they're positioning themselves to be able to deflect blame to the states if any bad projects end up getting funded.

At the same time, part of me can't blame them for trying to do this. In many ways, NTIA has been set up for failure. When they were given their billions they simply didn't have the infrastructure in place to distribute those funds efficiently and effectively. They then had to craft rules in an extremely polarized broadband policy environment. And they didn't even get their leader in place until the process was already underway.

But that doesn't mean we should be satisfied sitting on our hands watching as BTOP heads into the ditch. Now is not the time to point fingers; now is the time to figure out how to save this process. Because it's not too late to do things right, to find new ways to make sure our tax dollars are going to support the best possible broadband projects. To that end, I'd like to propose a new review process for BTOP.

To start with, I want to suggest that it's a mistake to rank projects based on purely quantitative measures. Yes we need to know how much projects cost, yes we need to make sure they're not overpriced, and yes we need quantitative measures of how self sustaining a project is, how many jobs it creates, and how well it secures a community's broadband future, but there are qualitative elements associated with all of these things that shouldn't be ignored, especially since questions like how much bandwidth is needed, how open networks should be, and who should own networks are fairly subjective.

Plus quantitative scoring systems can often be too rigid. The question shouldn't be, "Is this project 45 or 50 miles from the nearest city?" Instead we should be focusing on, "Is this the right project for the right community with the right people leading it that offers the best avenue for spending taxpayer dollars?"

Additionally, I think it's a big mistake to have this review and decision-making process occur behind closed doors. One big positive outcome of the stimulus is how it's stimulated interest in broadband and broadband policy. But the fastest way to dissuade that interest is to make the public feel like secret people are making secret decisions that they can't guarantee are being made in the public's best interests.

With all of this in mind, I'd like to suggest a three-step process for the public vetting and review of BTOP applications.

The first two steps can happen concurrently.

One step is to conduct that initial review, but instead of doing so behind closed doors with three reviewers reading and ranking the applications separately, I think we should create review panels. These panels would include three reviewers that applicants must sit in front of to present, discuss, and defend their projects. By doing this reviewers can ask questions of applicants directly and get immediate answers. These panel reviews should also be recorded, and some or all of it should be made available for public review. This content can also be used to inform final decision-making further down the line.

The other initial step is to hold an event or series of events in every state capitol where everyone who's applied for money in a state would come together to give a 5-10 minute presentation on why their project deserves the money. There could also be a discussion facilitated between applicants to debate how the rules should be interpreted. These events should also be recorded and even webcast live so the public can tune in. The point of doing all of this is that if we put all the projects on the same stage together next to each other it should help states and NTIA compare projects directly and to get a sense for which applicants are the most prepared. In states with lots of projects, multiple events could be arranged focused on the different types of applications.

Then once states make their recommendations based on this process and incumbents have a chance to flag projects that may not qualify because of existing broadband service, the final step would be to have a core NTIA, and possibly RUS, team lock themselves in a room for a couple of weeks to review the materials and to pick the best possible project for each state. In addition to the paper applications, they'd also have video from the panel reviews and public events to consider, as well as the recommendations of the panel reviewers. When needed, they could call in applicants for states that they're having trouble picking one winner. After they pick the best first project for each state, then they could see how much money's left and fund other projects based purely on merit.

By pursuing this new process, NTIA could be more open to the public while conducting a more thorough vetting process that provides more opportunities to gauge the seriousness and relative value of projects. By thinking just a little bit outside of the box and recognizing that it's not too late to do this right, we can take this process out of the backrooms and put it firmly in the public eye, which will only help further stimulate public interest in the best way to solve our country's broadband problems.

Going a step further, let's consider the timeline for implementing this model.

Given that there were 1,000 volunteers who applied to help review, I'm assuming that at least 300 of them are qualified and not tainted by conflicts of interest, hopefully more. That means we'd have at least 100 panels of three reviewers each. That would leave each team with about 20 applications to go through. Let's say they take half a day to review each on average, that means it'd require two weeks of full-time work, or four weeks of half-time work to get through everything.

For the state events it'd just be a matter of picking a time, finding a venue, and getting everyone there. While there'd be some logistics to deal with in terms of getting the events webcast, and making sure all of the right people are there, these are not insurmountable challenges. Plus anyone that really wants funding should be able to make time for this. So there's no reason these events couldn't all be conducted in the month of October.

What this would all lead to is that by November 1st NTIA (and RUS if they're included in this process) would have everything they'd need to start the final review and selection process.

As they're going through that process, I'd suggest they plan on announcing awards as they make their decisions, either a state or group of states at a time.

It may take them a whole month to get through everything, but that's OK. While we don't want to slow this process down more than needed, the truth is that at least when it comes to infrastructure projects in northern states, most of them will have to wait until spring to start deployment any way. So one easy way to deal with this is to focus on making decisions about warmer states first.

So there we have it. An alternative way to handle the BTOP review process. It's based on the principles of the original process, but with an added emphasis on transparency and collaboration, and a greater acknowledgment of the need to understand the qualitative benefits of these projects, which can't necessarily be captured on paper.

My hope is that NTIA will seriously consider this proposal as a way to save the integrity of their review process, because otherwise I've moved beyond mere concern to full-on panic about the fate of BTOP. And as I've said before and will say again, we can't afford to waste these billions if we want to continue receiving resources to push forward our country's broadband future. So let's remember that it's never too late to do things the right way, and that it's time for us all to work together to make sure we do this right.

So let's start by admitting that I've been worried about NTIA's BTOP stimulus program for a while now.

It began with the disappointing NOFA, which focused too much on the unserved and set inadequate bandwidth thresholds. But even more troubling was how divorced it was from the realities of building networks, which should be done contiguously, whereas the NOFA encouraged slicing communities up so that only those slivers that were un/underserved could apply.

I then got a bit more worried when NTIA's site crashed at the submission deadline. Sure there were a lot of applications, but there couldn't have been more than 2000 people uploading at the same time, which doesn't sound like a crazy number, and therefore leaves me worried that this is indicative of NTIA not being prepared in general to handle this volume of applications.

But these were minor issues compared to what's happening now with the review process, or perhaps more accurately said, what's not happening.

Many of these concerns stem from my following along with the experiences of Mike O'Connor as he writes about life as a BTOP volunteer reviewer on his site.

As a quick frame of reference, I think it's likely you can't expect to find a better volunteer reviewer than Mike. He's been appointed as a member to the MN Ultrahighspeed Broadband Taskforce. He helped start one of MN's first high-speed ISPs in gofast.net in the 90s. And he worked as an AVP in charge of finance at the University of Minnesota. So in other words he understand the technology and business of broadband. Plus I can attest to the fact that he's a really good and honest guy who just wants to see his country become greater through broadband.

My first concern about this review process doesn't stem from a blog post of Mike's but something he told me during a face-to-face meeting, namely how they're vetting reviewers to avoid conflicts of interest. Apparently all that Mike knows they've done so far is have him sign a piece of paper claiming he has no conflicts. There doesn't appear to be any other serious vetting going on of him.

Even if there is, I can't help be concerned that a reviewer would be totally unaware that it's going on, plus there's the matter of thoroughly vetting the thousand people who signed up to volunteer taking some significant time, and yet it appears as though they're either not doing anything or haven't started doing anything, both of which are troubling.

Many have been critical of using an all-volunteer army from the get go as it seems wide open to attempts to game the system, plus it can be a challenge to make sure that not only do the volunteers not have conflicts of interest, but also that they're competent.

But there are other issues with using volunteers that Mike brings up. Like how many hours in how short of a window of time are volunteers expected to invest in this process? He's heard 30-40 hours, but will he have a month to put that time in or a week? I don't think we can expect volunteers to devote full-time work to this, and yet stretching it out means the review process will drag on. Also, what support will reviewers have during odd hours like nights and weekends, which is likely when many of the will be working through these applications?

But none of this is what has me worried the most. What worries me more than anything is that after Mike went through an introductory orientation webinar on Aug 28th, he has not heard from NTIA since then. He has no idea if the review process has started yet. If he's made the final cut of reviewers. If a pile of applications is in the mail on its way to him as I type this. Nothing.

And yet a quick glance at the calendar shows that NTIA's supposed to have some initial recommendations to pass on to states for their input on Monday. That's four days from now.

Making matters worse for the chances of BTOP's success is that it's going to be such a complex equation to determine who deserves what.

Should NTIA go with the cheapest broadband or the best broadband?

Should NTIA invest in networks that only deliver the baseline of bandwidth and that don't have a clear path to upgrade to higher capacities, or should they prioritize networks that are future proof and that can upgrade easily as needed?

Should they favor non-profits and community initiatives like the original stimulus language suggests, or should private companies be favored since some think that municipal broadband's actually a bad idea?

How can they be sure they're funding projects that will be financially self sustaining?

Even more worrisome is that I've heard from some reputable people like David Burstein of BroadbandReports.com that many of the applications he's seen are horribly overpriced, oftentimes trying to get a grant that's two or three times what a network should actually cost to build. This isn't entirely surprising given that government's handing out free money, but how does NTIA make sure it's not wasting that money on inflated projects?

And all of these are concerns relate just to this initial review process. We haven't even gotten to the point of giving the states a chance to have their say, which is likely to be a mess. Some governors don't understand broadband. Some don't want to make the decision themselves and pass the buck to some other entity that might be corrupt or incompetent. And others have conflicts of interest themselves. Plus we have to deal with the fact that some states have put in their own applications, which they'll undoubtedly favor over anyone else's.

Then these projects are going to have to run the gauntlet of incumbents getting a chance to have their say, which is another opportunity to game the system as all they have to do is show advertised speeds and not actual service to disqualify projects from receiving funding.

And these are all issues just with the infrastructure grants. I have a whole other set of concerns about the broadband adoption and public computing center grants, namely that I'm not sure it's such a good idea to just buy a bunch of computers and have a few training classes, which seems to be the bulk of what money's been requested for.

Oh yeah, and I almost forgot about the mess that is the mapping program. Ugh...

I don't want this post to come off as me calling out the hard-working individuals at NTIA as I know there are good people over there trying their best. But I can't help but be dissatisfied with the process so far, and I'm extremely concerned about what the ultimate fate and impact of the BTOP program will be given all the complexities I've listed above.

My main point in all this is that we can't accept failure from BTOP. If we don't do BTOP right, that will hurt our chances for ever getting any more money out of Congress for broadband. Yet I kind of feel like I'm watching a trainwreck in slow motion, and that while I want to help I'm not sure what I can do to stop this from being a disaster.

I'm going to be working through this dilemma over the weekend, and I hope all of you will as well. If you have any thoughts on how we can help support NTIA's efforts and rescue this project from heading into the ditch, add them in as a comment below. I'll then work on coming up with some suggestions and share them in posts next week.

But until then or until we get more word out of NTIA about what's going on, you can color me officially concerned about BTOP.

While there's little consensus as to whether every home and business will someday require a fiber pipe, there should be no debate that every school in America needs fiber.

The reasoning is simple: only fiber can support the demands for simultaneous capacity that the classrooms of today and tomorrow require.

Let's show why with some simple math.

Say you've got one classroom with ten computers in it. One of the many applications these computers can access is an online repository of HD video that's available for a teacher to incorporate into his or her curriculum.

(It should be noted here that such a repository is under construction today and would likely already be widely available if not for the lack of sufficient bandwidth to deliver HD video reliably to most classrooms.)

Next we must acknowledge that an H.264 (a standard for video compression) HD video requires 8Mbps to deliver one stream to one user.

So the classroom described above would require at least 80Mbps of simultaneous bandwidth if each student is to be able to watch their own video at the same time or the same video starting at different times. (If everyone's watching the same video at the same time, multicast technology can be used to broadcast the video digitally to reduce bandwidth demands.)

But this example of a classroom woefully underestimates how much bandwidth a school really needs to support the simultaneous delivery of HD video to multiple students. Many classrooms have 20 computers or more, and hopefully every school has more than one room equipped with computers.

Even if we keep the number of computers at ten and simply bump up the number of classrooms to five, all of a sudden a single school requires 400Mbps to support the delivery of HD video apps.

And that's just the downstream requirements. If we want teachers to be able to lead classes remotely, to conduct virtual field trips, and to foster collaboration between geographically distant classrooms, then there must also be enough upstream capacity to support at least one HD video stream uploading per classroom. In the conservative model laid out above, that would mean a minimum of 40Mbps being required for every five networked classrooms in a school.

Now let's compare these demands against the sad state of many schools' connectivity, in particular K-12 and community colleges as most colleges and universities already have fiber. There are countless schools today that are still stuck paying thousands of dollars a month to bundle together multiple T1 lines, which only deliver 1.5Mbps symmetrical each. In other words, they're paying too much for access to inadequate networks.

And yet I know that many of my fiber-laying friends are able to go into communities and offer schools 100Mbps connections for the same cost as those bundled T1s. Plus they also provide the opportunity for schools to scale their bandwidth up indefinitely, something no other broadband technology can do.

It's also important to note, though, that the benefits of fiber aren't just about faster Internet access. Many applications, like the HD video repository mentioned above, work even better when that fiber's being used as a community, regional, or statewide LAN. In this way, schools are able to get even more bandwidth for in-network delivery between schools, districts, etc.

There's just no getting around the fact that when it comes to the connectivity needs of our educational system, we have to set the standard of a fiber pipe to every school.

Anything less than fiber means teachers will be handcuffed in terms of how much they can incorporate online experiences into their lesson plans. Schools won't be able to realize all the efficiencies and opportunities of their counterparts in other countries that have made a commitment to fiber. And ultimately our students will suffer from having limited access to a truly 21st century education.

With all this in mind, our national broadband plan must acknowledge this basic reality of America's broadband demands. The plan can't afford to allow the debate over residential broadband's future and the sacred cow of maintaining strict technological neutrality to obfuscate what our schools truly need. And the simple truth is that our schools need fiber.

But that's just one component of the national fiber plan that should be at the core of any national broadband plan. Many more details on what that national fiber plan should include and how we can go about accomplishing these goals to come in future posts.

For now, though, let's push everything else aside, and come to agreement on the straightforward, justifiable, and achievable goal that every school in America needs and deserves fiber. The future of 21st century education in America depends on it.

As I recently wrote, most people don't understand even the basics of broadband, including many of our policymakers. Because of this, the discussions surrounding broadband policy-making often must resort to the use of analogies to simplify the explanation of complex concepts and to take tech talk out of the equation.

Some people lament this tendency as analogies are invariably inadequate at describing and explaining all the complexities and dynamics of the issues surrounding broadband. Yet at the same time, storytelling can be a great tool for establishing a baseline of common understanding about the most important core principles. And the reality is that for most people, analogies are the only way to help them make sense of what can be very technical discussions.

That's why I'm going to start collecting and sharing my favorite broadband analogies in order to help equip broadband believers like myself and my readers with better ways of talking about broadband that can help the broadest audience better understand what they need to know.

To that end, this week I heard one of my favorite new analogies from Sean McLaughlin, a community media pioneer and executive director of Access Humboldt, an entity working to bring broadband to and foster local community media in Humboldt County, CA. He's an incredibly thoughtful guy who's able to look at the world through the eyes of a poet, the mind of an engineer, and the heart of a long-time community activist.

Among the many things Access Humboldt does is a project called Digital Redwoods, which is their primary effort to organize local leaders around the goal of bringing better broadband to Humboldt County. I'll be describing this project in greater detail at a later date, but for now let's stay on the topic of analogies.

In talking with Sean he shared that the "Digital Redwoods" was more than just a nice name, it described a specific analogy that they're using to help describe the intent of the project.

The core of this analogy is that we need to think about broadband as an ecosystem that, just like a redwood forest, requires all of its components working together to survive and thrive.

In this analogy, the roots of the redwood trees are like fiber optic cables forming the bedrock of modern communications systems, linking everyone together with reliable, robust connectivity. The leaves then form a canopy akin to wireless access that covers every inch of ground and creates an ecosystem of its own of high-flying critters (or apps). The trees then represent the community anchor institutions around which communities establish themselves and grow.

What I love most about this analogy is the need for interconnectedness that it implies. Without their roots, trees will be less steady and are more likely to fall over. Without their leaves, coverage can't reach everywhere plus there will be less energy (bandwidth) running through the roots. And without the trees you miss out on the ability to foster strong communities and to help tie together wireless and wireline broadband.

I can even how we can take this analogy even further. Perhaps sunshine equates to electricity as the engine that powers broadband, and water to bandwidth as the common element that flows throughout the ecosystem. And, of course, all the little critters then represent us, enjoying life in a connected, interdependent, fully realized broadband ecosystem.

More than anything else, the reason I like this analogy so much is because of how it embodies the importance of thinking about broadband as an interconnected ecosystem and how it establishes the dynamic between wireless, wireline, and communities.

Like all analogies, it starts to break down once you start getting too specific (like where does middle mile, net neutrality, and bandwidth caps fit within this scenario?), but that doesn't lessen it's impact as a tool to help explain the need to look at broadband as an intergrated whole rather than a series of pieces.

You can look forward to more analogies like this in the future. If this article inspires thoughts within you of either how to extend this analogy further or if you want to share analogies of your own, feel encouraged to do so in the comments below!

Because the other great thing about analogies is that they're essentially stories, and stories become stronger the more we share them with others, and the more we share the stronger our community becomes.

Thanks to the Benton Foundation's terrific Headlines newsletter, I found this Ars Technica article that poses the question: "Can 'flexible broadband pricing' fix the digital divide?"

It's primarily a recap of a press conference held on Tuesday announcing the release of this study.

The study's central thesis is that by spreading the costs of network upgrades equally among all users we risk suppressing broadband adoption by raising prices for everyone, whereas if providers can charge more of those who use more we can keep broadband prices for others lower, which should help to bridge the digital divide since cost is the primary reason those who aren't online today don't subscribe to broadband.

While I agree with the notion that the days of all-you-can-eat broadband pricing may be coming to an end and that it makes sense to spread the load equitably so that the heaviest users pay the most, I have a number of significant issues with their assumptions, which also then calls into question their results.

In particular, the fact that they assumed that flexible broadband pricing would only result in more expensive tiers of service being introduced but not any less expensive tiers.

For one, if a core part of their argument is that lower prices enable higher adoption rates as a way of bridging the digital divide naturally, then it would seem to make sense especially if this is an academic report (it was released through the Georgetown Center for Business & Public Policy) to model what would happen if cheaper tiers were introduced just to see how big of an impact that would have.

That kind of data could then lead to a greater emphasis on subsidizing services to low-income households or mandating that services be offered to them at cost so as to overcome any pricing related barriers.

Also troubling about this assumption of evermore-expensive broadband is it implies that market dynamics alone aren't sufficient to keep prices down. In a truly competitive market a provider would not necessarily be able to raise their rates as it would have to take into consideration what their competitors are doing.

Another dangerous assumption of this report is that all operators are investing heavily in their networks and therefore need to be able to charge their customers more to recoup that money. While some operators are investing heavily, many others are not, either because they can't, aren't willing to, or their investments don't cost all that much to make.

The reason I bring this up is that I think we need to be careful about not putting in place a system that encourages providers to suppress what they invest and inflate what they charge. Some of this dynamic is unavoidable given the profit-maximizing nature of a private marketplace, but we shouldn't be rewarding inaction with opportunities to squeeze more money from captive customers. I'd imagine this would likely lead to lower adoption rates over time from decreased customer satisfaction.

What's also troubling about this assumption that broadband's price is only goes up is that the study doesn't reference the fact that there are many entities deploying full fiber networks today that are often offering lower prices than their competitors or are at a minimum delivering a lot more bandwidth for the buck. Put another way, I think it's likely that if the public saw operators delivering less and charging more that that would suppress broadband adoption rates, regardless of how equitably the load was shared.

I say all this not as an argument against the concept of flexible pricing, but instead against the way this study went about trying to prove what good can happen when operators are able to charge whatever they want to whoever they want.

What makes even less sense is that if this study was attempting to frame the benefits of flexible pricing relative to bridging the digital divide, then why not include the theoretical possibility of lower tiers? I can't help but feel like because of their faulty assumption that broadband's only going to get more expensive, they actually missed a huge opportunity to bolster arguments in favor of flexible pricing.

At this point I should say that I do know that price isn't the only hurdle that needs to be overcome in bridging the digital divide, and that it can be easier said than done to dramatically lower broadband prices as there is cost involved in installing a customer, especially for fiber deployers, that there must be sufficient revenue to recoup.

But that being said, I still think we're play a dangerous game with our country's future competitiveness in the global digital economy if we're simply accept the assumption that broadband will only get more expensive.

During this process of building a national broadband plan I'd hope that we're also thinking about what we can be doing to put in place a system that encourages bandwidth that's evermore abundant and affordable.

As bandwidth is the lifeblood of the 21st century economy we can't afford to be stuck in a future where it's getting more expensive and not less.