Wednesday, July 29, 2009

The Competitive Telecom Agenda: FCC Chairman Genachowski Announces Further Staff Appointments 07/29/09 Federal Communications Commission (FCC) Chairman Julius Genachowski today announced the appointment of senior staff in the Media, Enforcement, and Wireline Competition Bureaus of the Commission; and in the Office of Communications Business Opportunities (OCBO), and Office of the General Counsel (OGC).

As seen in both the appointment by President Obama of Chairman Genachowski himself, and in many of the Chairman's staff, if today's FCC senior staff appointees have anything in common in their careers in government, law, and academia, it is the pursuit of policy agendas generally favoring increased competition in the American telecom industry.

William Lake will serve as Media Bureau Chief, while Sharon E. Gillett will become the new Chief of the Wireline Competition Bureau. Appointments were also announced for Media Bureau Deputy Chiefs Robert Ratcliffe and Kris Monteith, and Enforcement Bureau Deputy Chief Suzanne Tetreault.

“This extraordinarily talented senior staff has extensive experience in the private sector, the academy, and the public sector, including here at the FCC and in state government,” said Chairman Genachowski, in a press release (download .PDF) issued by FCC today.

“With their help, the agency will pursue policies that advance a vibrant media sector, unleash innovation and job creation, protect consumers, and promote competition," concluded the Commission Chairman.

In a separate press statement of today (download .PDF), Genachowski also announced appointments in the Commission's OCBO, and the OGC. These positions include: OCBO Director Thomas Reed, OCBO Senior Deputy Director Carolyn Fleming Williams, and Associate General Counsel and Chief Diversity Officer Mark Lloyd.

While each of the appointments announced today is to a senior staff position at the Commission, none require Senate confirmation.

Observers of state broadband programs and policies, and readers of, will recognize that Ms. Sharon E. Gillett has been serving as Executive Director of the state broadband program of the Commonwealth of Massachusetts, the Massachusetts Broadband Institute (MBI). As we reported at the time, she was appointed by Governor Deval Patrick (D-MA) to the position on April 29, having previously served as Patrick's chief communications industry regulator as Commissioner of the Massachusetts Department of Telecommunications and Cable (DTC).

The Governor and Director Gillett keynoted a press event in the broadband unserved / udnerserved area of Western Massachusetts yesterday, which announced the inter-agency launch of the State's middle mile network project developed by MBI and MassHighway, the Commonwealth's surface transportation agency.

Early this evening the Patrick Administration released a statement on the Gillett federal appointment by State Assistant Secretary for Housing and Economic Development C. Stanley McGee, “It is with a mix of sadness and pride that I am writing to let you know that Massachusetts Broadband Institute (MBI) director Sharon Gillett has accepted an appointment from the White House as Bureau Chief of the Federal Communications Commission’s (FCC) Wireline Competition Bureau. Sharon’s expertise in broadband and other telecommunications issues makes her a valuable asset for the FCC in this significant national leadership position; our loss is America’s gain.”

From the Commission's press releases of today, the professional biographies of the appointees announced, links and (text) added:

Enforcement Bureau

Deputy Chief, Enforcement Bureau, Suzanne Tetreault: Ms. Tetreault is currently serving as Acting Deputy Chief of the Consumer & Governmental Affairs Bureau, overseeing the work of the Disabilities Rights Office and Consumer Policy Division. Since 1991, Ms. Tetreault has held a variety of positions at the Commission, including Chief of Staff of the Enforcement Bureau, Acting Chief of the Wireline Competition Bureau, and Deputy Associate General Counsel. Prior to joining the Commission, Ms. Tetreault worked at the Federal Trade Commission, and practiced antitrust and communications law with Jones, Day, Reavis & Pogue. Ms. Tetreault will serve as Acting Chief beginning August 10, 2009.

Media Bureau

Chief, Media Bureau, William Lake: Mr. Lake most recently served as the head of the DTV task force at the FCC. Previously, Mr. Lake was a partner at WilmerHale in Washington, D.C., where he led the communications regulatory practice for many years. In government, Mr. Lake has previously held positions at the Department of State, EPA, and the Council on Environmental Quality. He began his legal career as a law clerk to the Honorable John M. Harlan of the U.S Supreme Court and the Honorable Henry J. Friendly of the U.S. Court of Appeals for the Second Circuit.

Deputy Chief, Media Bureau, Robert Ratcliffe: Mr. Ratcliffe most recently served as the Acting Chief of the Media Bureau. Previously, he was a Deputy Chief of the Enforcement Bureau, where he was responsible for media enforcement matters. Prior to his assignment to the Enforcement Bureau, Mr. Ratcliffe spent more than 20 years in various positions in the Media Bureau and its predecessors, including Deputy Chief of the Bureau, senior legal advisor to the Bureau Chief and Assistant Chief of the Video Services Division and the Policy and Rules Division. He also served as interim legal advisor on media issues to former Chairman Alfred Sikes in 1989. Mr. Ratcliffe began his career at the FCC in the original Cable Television Bureau, where he served as Chief of the Policy Review and Development Division and the Research Division before the bureau was combined with the Broadcast Bureau in the early 1980s.

Deputy Chief, Media Bureau, Kris Monteith: Ms. Monteith has been at the FCC for 12 years, most recently as Chief of the Enforcement Bureau and Deputy Bureau Chief for Outreach and Intergovernmental Affairs in the Consumer and Governmental Affairs Bureau. Ms. Monteith previously served as Chief of the Policy Division of the Wireless Telecommunications Bureau, Deputy Chief of the former Common Carrier Bureau's Competitive Pricing Division, the Designated Federal Official to the North American Numbering Council, and as a Senior Attorney in the then-Common Carrier Bureau's Network Services Division. Before joining the Commission in 1997, Ms. Monteith was in private practice with the law firms of McDermott, Will & Emery and Keller and Heckman. Ms. Monteith’s appointment will become effective August 10, 2009.

Wireline Competition Bureau

Chief of Wireline Competition Bureau, Sharon Gillett: Ms. Gillett is the Director of the Massachusetts Broadband Institute and previously served as the head of the Massachusetts Department of Telecommunications and Cable. Ms. Gillett was at the Massachusetts Institute of Technology from 1995-2006, where she engaged in academic research, program management, and teaching focused on Internet and telecommunications policy and technology, with a particular focus on broadband. Before joining MIT, Ms. Gillett was a software engineer and manager at Thinking Machines Corp. and BBN Communications Corp. (now BBN Technologies), where she worked on ARPANET computer networking technology. Ms. Gillett will become Chief of the Wireline Competition Bureau on August 28, 2009.

Office of Communications Business Opportunities

Director, Office of Communications Business Opportunities, Thomas Reed: Mr. Reed most recently was Of Counsel at K&L Gates LLP in Washington, DC, where his practice focused on a broad range of issues including commercial litigation, corporate governance, investment management, and civil rights. At K&L, Mr. Reed specialized in regulatory issues affecting women and minority-owned businesses. He has worked extensively with some of the nation's largest organizations that advocate for women and minority-owned business and is a regular commentator on disadvantaged business enterprise certification procedures. He has also served as Legal Counsel to the National Coalition on Black Civic Participation. Before joining K&L, Mr. Reed was a Senior Trial Attorney in the Civil Rights Division of the U.S. Department of Justice.

Senior Deputy Director, Office of Communications Business Opportunities, Carolyn Fleming Williams: Carolyn Fleming-Williams most recently served as Director of the Office of Communications Business Opportunities, FCC. During her 15-year tenure with the Commission, she has also served as a Senior Attorney-Advisor with the Media Bureau. Prior to joining the Commission, Ms. Fleming-Williams served as corporate counsel with the Communications Satellite Corporation (COMSAT). She was also an associate attorney with the law firm Kirkpatrick & Lockhart, now K&L Gates LLP. Prior to joining K&L, she was an Honors Attorney with the U.S. Department of the Treasury. She has also served as President of DC Habitat for Humanity and as a Fairfax County Commissioner for Civil Service.

Office of General Counsel

Associate General Counsel and Chief Diversity Officer, Mark Lloyd: Mr. Lloyd was most recently the Vice President for Strategic Initiatives at the Leadership Conference on Civil Rights/ Education Fund, where he oversaw media and telecom initiatives. Mr. Lloyd also has been an adjunct professor of public policy at the Georgetown University Public Policy Institute and a visiting scholar at MIT, teaching communications policy. Previously Mr. Lloyd has been a senior fellow at the Center for American Progress, the General Counsel of the Benton Foundation, and an attorney at Dow, Lohnes & Albertson. Before becoming a communications lawyer, Mr. Lloyd had a distinguished career as a broadcast journalist, including work at NBC and CNN.

Texas Broadband: Texas Partners with Connected Nation to Map Broadband Availability

(Vocus/PRWEB ) via 07/29/09 Yesterday, Texas Agriculture Commissioner Todd Staples announced a partnership between the Texas Department of Agriculture and Connected Nation, a national nonprofit, to create a broadband initiative called Connected Texas and to develop a detailed broadband inventory map to better position Texas for competitive funding from the American Recovery and Reinvestment Act of 2009 (ARRA).

The map, which will feature the information of participating broadband providers large and small, is expected to serve as a key asset for the state as it prepares for federal stimulus funding to support broadband investment.

"We are excited about this new partnership," Commissioner Staples said. "Connected Nation will help Texas close the digital divide between urban and rural communities in our state. By creating a broadband map, we will learn which areas are unserved and underserved. This critical knowledge will lead to developing projects that bring high-speed Internet to all Texans, which will enhance economic development, expand educational opportunities, and improve health care."

The Texas broadband map, which will be a function of Connected Texas, will feature a collaborative, public-private approach to broadband mapping, as Congress prescribed in the Broadband Data Improvement Act (BDIA) of 2008. The map will illustrate broadband service availability at the street level, based on information from all types of providers across Texas, including cable, telephone, wireless Internet service providers, rural cooperatives, and municipalities. Most importantly, the broadband map will illustrate the service gaps that remain in rural and other remote locations. This information will best prepare Texas for a sound, yet aggressive approach to improving broadband adoption.

The Texas map will be developed under the leadership of the Texas Department of Agriculture. Through a rigorous system of broadband data collection, GIS analysis, and data verification, Connected Texas’s mapping project will determine where broadband service is currently available to Texas households statewide and, more importantly, the gaps in coverage where households are not served by any broadband provider.

Currently, more than $7 billion is available through the ARRA for broadband projects nationwide. In the ARRA, $350 million fund the BDIA. These grant funds are available for states to develop public-private partnerships for grassroots-driven expansion of broadband and computer use, particularly among unserved and underserved populations.

Connected Nation conducted a recent study of the impact of public-private broadband expansion programs funded through the BDIA and the ARRA. The study found that a comprehensive, grassroots-driven program for increased broadband access and use in Texas could result in a total economic impact of $9.4 billion through the creation of more than 173,000 jobs and cost savings in areas such as health care and the environment and through activities such as telecommuting.

"The federal government has set the expectation that states must be able to illustrate the extent of broadband coverage in order to prioritize broadband stimulus investments for unserved and underserved areas," said Brian R. Mefford, Connected Nation’s CEO. "Our partnership and the creation of a broadband map will provide Texas the opportunity to address the areas of Texas where broadband is not readily available. This will better position Texas for the broadband opportunities provided by the ARRA."

Monday, July 27, 2009

MarketSYS USA: NTIA and USDA Unserved and Underserved Reports Simplified

(PRWEB) via July 27, 2009 (Editor's Note: Ms. Liz Zucco, CEO of MarketSYS of Canton, GA is a frequent commentator and contributor to She has provided many of the key insights we have been credited with in our analysis and reporting since our launch on March 10. MarketSYS is a partner of our corporate parent, PrattNetworks LLC of Boston, MA.)

MarketSYS provides easy solution for applicants to get accurate, high-quality and proven reporting for NTIA and RUS Broadband Grant and Loan Applications.

Canton, GA -- Broadband Grant and Loan applications for NITA and USDA Funding require a new type of reporting called the "Unserved and Underserved Reports". These are causing operators and applicants heartburn as they try and figure out what is needed in order to complete millions of dollars of funding requests by the August 14 deadline.

These are some of the most difficult components to develop for Broadband Loan and Grant Applications under the new guidelines. MarketSYS USA has been developing Underserved reports for RUS funding since the broadband program began in early 2002.

"We are seeing a number of concerns about these reports from our clients," stated MarketSYS President, Liz Zucco. "We have increased our capacity to help companies and consultants handle these reporting requirements. I have personally developed these reports for millions of dollars in RUS funding for clients over the years and have trained a large staff to execute accurate reports quickly so that operators can finalize their funding requests without delay."

The reports that the BTOP and BIP Applications require are very specific. They have to be carefully developed with a specific methodology. MarketSYS has developed proven processes and methods to give operators and applicants accurate reports within just a few days of their request.

"Our services in this area ensure that the applicant gets accurate reporting for their grant, and we can get these reports out in time for Round One Proposals which have to be completed by August 14, 2009," stated Zucco.

Interested applicants can contact Ms. Zucco at 404-454-5477.

MarketSYS also provides much of their research that they have compiled for their grant clients on their main website by joining as a member at

Friday, July 24, 2009

Broadband Stimulus: NTIA & RUS Post First Wave of Grant - Loan Application FAQs 07/24/09 The two federal agencies responsible for administering the $7.2 billion broadband stimulus programs funded by the Recovery Act, have now posted their first wave of answers to frequently asked procedural questions about the programs.

The 2 agencies, the National Telecommunications and Information Administration (NTIA) of the Department of Commerce, and the Rural Utilities Service (RUS) of the Department of Agriculture are today conducting their last of 10 regional Workshops held around the nation since July 7.

The Workshops, held from National Harbor, Maryland on July 7, to Los Angeles, California today, were attended by several thousand audience members in total, many of whom issued scores of verbal and written questions.

The majority of the 43 answers to questions posted yesterday, 07/23, about the programs were asked by audience members at the Workshops. Earlier this week, the 2 agencies posted an additional set of 81 answers relating to the highly detailed issues of online eAuthentication and Contractor Registration.

All posted questions and answers are available via the FAQ Section of the joint agency site.

Thursday, July 23, 2009

Broadband Stimulus Public Private Partnerships: OpenCape & RCN Metro

RCN Metro Press Release via 07/23/09 HERNDON, VA, July 23, 2009 – RCN Metro Optical Networks, a division of RCN Corporation (NASDAQ: (RCNI) and a premier provider of fiber optic-based network solutions, announced today that it was selected by OpenCape Corporation as its network partner to build and operate a 300-mile fiber network across Southeastern Massachusetts, Cape Cod, and the Islands.

RCN Metro Optical Networks was chosen after OpenCape’s exhaustive due diligence and from a long list of competitors. The OpenCape Corporation, a non-profit 501(c)(3), intends to apply in August for a $40 million grant under the federal Broadband Technology Opportunity Grant (BTOP) program of the American Recovery and Reinvestment Act to build the network.

“OpenCape is excited and pleased to have a partner with the experience and footprint of RCN Metro. The technical knowledge they bring to the table is a great fit, but more importantly they offer the business skills that will ensure the success and sustainability of this regional initiative,” said Dan Gallagher, President of OpenCape.

CN Metro will build and manage operations for the regional open access network. Municipal, public safety, and private last mile providers will be able to connect to the OpenCape network for data transport throughout the region and to the Internet backbone in Boston and Providence.

The added capacity will help the region develop economically and offer increased competitive opportunities for businesses, residents, non-profits, and public service organizations across the region.

“RCN Metro is pleased with the opportunity to work with OpenCape Corporation on this important initiative serving private and public sectors in Southeastern Massachusetts and on the Cape and Islands,” said Felipe Alvarez, President of RCN Metro Optical Networks. “RCN Metro has long supported underserved markets, and we are dedicated to offering communities in this region a meaningful choice in telecommunication services through our high quality service offerings.”

The relationship is an example of the public-private partnership that the federal stimulus funds hope to encourage, combining public and private investment, and regional and business know-how to develop needed digital infrastructure to support the region in this digital century. Adds Gallagher, “This is a once in a generation opportunity to build the telecommunications infrastructure that will serve southeast Massachusetts for the next 50 years.” notes that RCN Metro Optical Networks was
was selected by OpenCape, following a public Request For Information (RFI) process launched on May 15 (download: .PDF).

About OpenCape
The OpenCape Corporation ( is a non-profit 501(c)(3) corporation. OpenCape Corporation’s purpose is to fulfill the need for a regional communications network on Cape Cod and the Islands to enhance education, research, and economic development, AND provide for an emergency communications network in times of crisis.

About RCN Metro Optical Networks
RCN Metro,, is a premier provider of high-capacity transport services for carriers as well as large and medium-sized businesses. RCN Metro offers a comprehensive suite of services including: Ethernet, SONET, Wavelength, Video Transport, Internet and more. With a network leveraging unique rights-of-way, spanning from Maine to Virginia and out to Chicago, RCN Metro deploys custom solutions to service providers as well as companies in the finance, hospitality, media, government, health care and education industries. RCN Metro is a wholly owned division of RCN Corporation.

About RCN Corporation
RCN Corporation, (NASDAQ: (RCNI), is a competitive broadband services provider delivering all-digital and high definition video, high-speed internet and premium voice services to residential and small-medium business customers under the brand names of RCN and RCN Business Services, respectively.

In addition, through its RCN Metro Optical Networks business unit, RCN delivers fiber-based high-capacity data transport services to large commercial customers, primarily large enterprises and carriers, targeting the metropolitan central business districts in the company's geographic markets. RCN's primary service areas include Washington, D.C., Philadelphia, Lehigh Valley (PA), New York City, Boston and Chicago.

NTIA Webinar: State Broadband Data and Development Grant Program Online Workshop

Online Statement of NTIA, via 07/23/09 On July 24, 2009, the Department of Commerce's National Telecommunications and Information Administration (NTIA) will host an online workshop on its recently announced grant program to fund collection of state-level broadband data, as well as state-wide broadband mapping and planning. This initiative will provide consumers with better information on the broadband services available to them and inform efforts to increase broadband availability nationwide. The workshop is intended to present information and answer questions about the grant application process for potential applicants.

Online registration link,via GoToMeeting: Here

The State Broadband Data and Development Grant Program is a competitive, merit-based matching grant program that implements the joint purposes of the American Recovery and Reinvestment Act and the Broadband Data Improvement Act (BDIA). The Program will provide up to approximately $240 million in grants to assist states or their designees to develop state-specific data on the deployment levels and adoption rates of broadband services. These data, including publicly available state-wide broadband maps, will also be used to develop the comprehensive, interactive national broadband map that NTIA is required by the Recovery Act to create and make publicly available by February 17, 2011.

The workshop will be recorded and made available online at Grant applications for this program will be accepted through the online system until August 14, 2009.

Pre-registration for the workshop is required and NTIA recommends registering no later than two hours in advance. Potential applicants are invited to email questions about the grant program to in advance of the workshop.

Wednesday, July 15, 2009

New York State Continues Efforts to Maximize Federal Broadband Stimulus Funds

ALBANY, NY, New York State press release via 07/15/09

New York State Broadband Stimulus NOFA Information Session Draws Public and Private Partners

On July 14, 2009, the New York State Chief Information Officer and Director of the Office for Technology, in partnership with Governor David A. Paterson's Economic Recovery and Reinvestment Cabinet Office, the New York State Public Service Commission, and the New York State Foundation for Science, Technology, and Innovation hosted an information session regarding the first Notice of Funding Availability (NOFA) for the American Recovery and Reinvestment Act (ARRA) broadband grants.

On July 1, 2009, National Telecommunications and Information Administration (NTIA) announced the NOFA for broadband Stimulus funding under the ARRA.

Attendees representing communities, libraries, schools, not-for-profits, state agencies, broadband providers and community leaders gathered at the session to review current funding opportunities and discuss the requirements for applying for broadband stimulus funding outlined in the NOFA.

"The Paterson administration recognizes we must take every opportunity to maximize federal stimulus funding opportunities to expand broadband in both urban and rural areas. We are making every effort to ensure applicants understand the guidelines and eligibility requirements, and critical timelines for applying for broadband stimulus funds," said Dr. Mayberry-Stewart, New York State Chief Information Officer, Director of the Office for Technology, member of Governor Paterson's Recovery Cabinet and Chair of the NYS Council for Universal Broadband.

The NOFA signals the first of three rounds of funding for the Broadband Technology Opportunities Program (BTOP), Broadband Initiatives Program (BIP), and the State Broadband Data and Development Grant Program (state mapping initiative). Approximately $4 billion is available during the first round.

The recently released NOFA details the rules to govern grant NYS broadband stimulus eligibility, the types of projects favored, and the broadband definitions that apply. The Information Session was designed to enable applicants interested in applying for broadband federal funding to have a better understanding of the NOFA and training.

Sharon Cates-Williams, NYS Deputy CIO for CIO/OFT and co-chair of the Universal Broadband Council's Infrastructure Action Team, provided an overview of the NOFA, stressing the importance of adhering to guidelines when completing applications for broadband stimulus funds. "I encourage each of you to read the NOFA, monitor the NYS Broadband Stimulus and federal stimulus websites, attend webinars, and most importantly be certain you have a quality assurance program in place so your applications are not delayed or rejected," said Ms. Cates-Williams.

New York State Broadband Map
During the information session, William Johnson, Assistant Deputy Director of Operations for the Office of Cyber Security and Critical Infrastructure Coordination, provided an update on mapping existing broadband infrastructure for rural and urban, unserved and underserved areas throughout New York State.

Mr. Johnson stated a predictive analysis was used to map the state and urged counties and service providers to further validate the map. "Comprehensive mapping is essential in prioritizing stimulus funding. The statewide mapping initiative is a fluid process and we will continue to revise the broadband coverage and availability maps to reflect updates made by county leaders and service providers. We are at the forefront of this initiative."

As part of the New York State Universal Broadband Strategy (download .PDF), the statewide broadband mapping project was initiated to prepare a statewide map of existing wired broadband availability. This helps to understand where the unserved and underserved areas remain across the state.

Edward Reinfurt, Executive Director of the New York State Foundation for Science, Technology, and Innovation, and chair of the NYS Council on Universal Broadband Government Initiatives Action Team, further emphasized the advantages of New York's statewide broadband mapping initiative stating, "New York State's broadband mapping initiative maps unserved and underserved areas throughout New York State. This feature provides a competitive advantage when applying for broadband federal stimulus dollars to show you are serving unserved and underserved areas."

New York Counties: Broadband Enables Economic Development & Public Safety Delivery
Executive Director of the New York State Association of Counties (NYSAC), Stephen Acquario, discussed New York State's approach to maximize federal broadband stimulus funds for public safety. NYSAC and CIO/OFT are working with counties and regions to form partnerships to submit proposals for broadband stimulus funds for public safety purposes. These regional partnerships are intended to maximize stimulus funding to New York State to stimulate the economy while addressing our public safety needs for first responders.

"Using federal stimulus funds for New York State will accelerate our economic recovery. County leaders remain committed to harness the potential of broadband technology. Using these funds for job creation and enhancing law enforcement public safety answering points will help grow local economies and also protect the public," said Mr. Acquario.

In addition, statewide broadband applications were discussed by Dr. Hao Wang, Deputy Commissioner and CIO of the New York State Office of Mental Health; David Walsh, NYS CIO of the State Education Department; Dr. Daniel Chan, CIO of the Office for Temporary and Disability Assistance; and Michael Fancher, Vice President for Business Development and Economic Outreach for the College of Nanoscale Science and Engineering.

"Broadband Infrastructure can advance healthcare delivery in New York State by making critical health information available for patients in a secure fashion, making healthcare providers accessible to broader populations, and by making healthcare information available at citizens homes," said Dr. Wang during his presentation.

"Technology changes the learning environment. Classroom walls no longer apply. With broadband technology, learning can take place from anywhere, anytime," said Mr. Walsh during his presentation. "Through the use of we have demonstrated that broadband technology is a viable channel to deliver the services our customers and citizens deserve and expect," said Dr. Chan during his presentation.

"Targeted investments in broadband can have a tremendous impact on the delivery of services. broadband applications maximize operational efficiency, reduce cost, increase revenue and boost public safety," said Mr. Fancher during his presentation.

The information session was recorded and will be available as a webcast on the New York State Broadband Stimulus website ( for 30 days.

Application packets to apply for broadband stimulus funding under the ARRA are available on the Broadband USA website at The first round of award notices will be announced in November 2009. All three funding rounds are expected to be completed by September 2010.

About CIO/OFTThe State Chief Information Officer and Office for Technology (CIO/OFT) provide statewide IT strategic direction, IT policy and centralized IT services to the state and its governmental entities. CIO/OFT provides IT enterprise services to support the missions of state agencies by operating four mainframe data centers 24 hours a day, 365 days a year, including more than 90,000 telecom users, 50 statewide mission-critical applications, a secure network of over 1,600 miles of fiber, including IT operations, telecommunications, Internet and Intranet services, enterprise email systems and support, IT training, networking, data storage and processing. In addition, the agency has a world renowned project management practice, develops and supports web applications and assists with application development. For more information, visit

Tuesday, July 14, 2009

Harvard’s Berkman Center to Conduct Independent Review of Broadband Studies to Assist FCC

(Editor's Note: We republish today's FCC release in full. We think it signifies the level to which the Obama Administration is taking broadband policy, beyond the current 'broadband stim' grant and loan programs, seriously. The Berkman Center at the Harvard Law School is one of the leading academic research institutes in the world that studies the economic and societal impacts of broadband and Internet access. Fully coincidentally, in the late 1980s when one Barack Obama was our neighbor in the Winter Hill neighborhood of Somerville, Massachusetts, he was a student at a nearby law school. We can't recall which one.)

FCC Press Release via 07/14/09 The Berkman Center for Internet and Society at Harvard University will conduct an independent expert review of existing literature and studies about broadband deployment and usage throughout the world. This project will help inform the FCC’s efforts in developing the National Broadband Plan.
“Advanced communications have the potential to enhance the lives of all Americans, improve public safety, create jobs, and support our economic recovery,” Chairman Julius Genachowski said.

“As the Commission embarks on the important task of crafting a National Broadband Plan, better data will inform and animate the activities of the agency. The Berkman Center’s independent review of existing information will help lay the foundation for enlightened, data-driven decisionmaking. I appreciate the Berkman Center’s invaluable assistance and look forward to seeing the results.”

Yochai Benkler, the Berkman Professor of Entrepreneurial Legal Studies at Harvard, and faculty co-director of the Berkman Center for Internet and Society, said, “I am pleased that the Berkman Center can contribute positively to the process Chairman Genachowski has envisioned for developing a national broadband strategy by providing to the Commission, and thereby the public, the results of our compilation and assessment of the existing literature on this important and timely subject.”

“A comprehensive assessment of these plans will be enormously helpful given our short timetable,” said Blair Levin, who is coordinating the FCC’s National Broadband Plan. “We don’t want to reinvent the wheel. Knowing what has already been learned will improve our ability to deliver the best possible National Broadband Plan.”

Consistent with Chairman Genachowski’s recent public statements regarding an open and transparent National Broadband Plan process, the results of the Berkman Center review will be made publicly available.

Friday, July 10, 2009

California Broadband Stimulus: CPUC Workshop & Live Video 07/10/09 Hosted by California Public Utilities (CPUC) Commissioner Rachell Chong, and California Sate Chief Information Officer Teri Takai (OCIO), today's open meeting of the CPUC gives a detailed look at the planned interrelationship between the state's broadband program and the federal broadband stimulus grant rounds.

The Open meeting and live video feed will be held: July 10, 2009; 10 am - 2:30 pm (PT).

The NTIA-RUS Application Guideline documents displayed by Commissioner Chong during her presentation, are available via our sites here. As Commissioner Chong stated, she was able to download the documents via and, given that the final federal documents have not been posted online to date.

CIO Takai and her agency personnel have been designated by
Governor Arnold Schwarzenegger as the lead state officials to interface with the federal broadband stimulus program. Ms. Takai last week iterated the state Administration's close monitoring of, and coordination with, the federal broadband stimulus effort. In a press statement from the Governor's Office released within hours of the issuance of federal program funding guidelines, she stated, "We are actively reviewing the guidelines and will soon announce a schedule and instructions for those interested in submitting proposals."

Link to Live Video & Archived Video: here (RealPlayer)

Link to Agenda fro the CPUC Site: here, as below:

CPUC Workshop - Application Process for Federal Stimulus Funds for Broadband

Friday, July 10, 2009
10 a.m. - 2:30 p.m. PT

CPUC Auditorium
505 Van Ness Ave.
San Francisco, CA

1. Click here for more workshop details (page 2)


Introduction and Opening Remarks

  • Robert Haga, Chief of Staff to Commissioner Chong
  • Teri Takai, California Chief Information Officer
  • Commissioner Rachelle Chong, CPUC

2. Overview of BTOP/BIP Notice of Funds Availability

  • Commissioner Rachelle Chong, CPUC

3. California Role / Process for Matching Funds

  • Joe Camicia, Chief of Staff to CIO
    • Submitting Applications to State of California Concurrently with Federal ARRA Broadband Applications – site
    • California Process and Schedule for Submitting Recommendations Pursuant to NOFA


  • Commissioner Rachelle Chong
    • Matching Funds for Infrastructure Projects
    • California Advanced Services Fund


  • Susan Walters, California Emerging Technology Fund
    • Process for Matching Funds for Adoption Projects from CETF

6. Public Input Period

7. Overview of Broadband Mapping NOFA and California Process

  • Michael Morris, Video Franchising Director, CPUC

8. Public Input Period

Thursday, July 9, 2009

Volunteer Review Plan for First Broadband Stimulus Applications Ignites Firestorm 07/09/09 A federal agency proposal to use volunteer reviewers to make approval and denial decisions on the first round of approximately $ 1.6 billion in Recovery Act broadband stimulus competitive grant applications has set-off a firestorm of protest.

The program, first announced online on Monday, July 6, is being launched by the National Information and Telecommunications Administration (NTIA), of the US Department of Commerce. A description of the volunteer reviewer solicitation program was posted at: Call for Reviewers Broadband Technology Opportunities Program, part of the joint federal agency site

NTIA states in the Call that the agency " soliciting volunteers to serve as panelists to evaluate grant proposals for the $4.7 billion Broadband Technology Opportunities Program (BTOP), an important part of the American Recovery and Reinvestment Act of 2009."

Criticism from the Floor

The plan was publicly described yesterday at an outreach Workshop held outside Boston by officials of NTIA, the Commerce agency administering $4.7 billion of the federal Recovery Act's total $7.2 billion funding for broadband stimulus programs.

The plan was described, initially in passing, by a NTIA employee during a breakout session on the NTIA's Broadband Technology Opportunity Program (BTOP) as part of the day long Workshop, one of ten such public outreach events scheduled around the nation during July. The NTIA speaker was met with immediate questions about the volunteer effort, negative comments, and outright strong criticism of the plan.

One state broadband administrator posed a direct question to the official, asking "What is to prevent the large telephone companies from just loading the process with their employees?"

Other attendees peppered NTIA representatives with questions and concerns, most exploring the obvious potential for conflict of interest and similar abuse of the volunteer program.

The Workshop was attended by approximately 300 telecom industry representatives, state broadband program officials from several jurisdictions in the Northeast, attorneys and consultants, and broadband community activists. Most of the questions from the the estimated 50 people attending the breakout session were focused on the Call for Reviewers.

Criticism from the Blogoshphere

Ms. Esme Vos, editor of the online publication, informed last evening that she was outright calling for a boycott by experienced telecom industry practitioners of the NTIA volunteer review program.

"I am calling for a boycott or perhaps more strongly, an old-fashioned workers' strike, the way workers used to do in the US many moons ago," stated Ms. Vos in an e-mail.

"I don't see Commerce department employees working for free, do you? Why should they tell us we should work for free? I am beyond appalled. This tells me that the US government is not serious about broadband because if it were, it would pay very good money (of the sort they seem to shower on Halliburton) for experts to assess these networks. By the way, if I see "experts" who I know have a serious conflict of interest acting as volunteer grant reviewers, I will expose them on," concluded Ms. Vos.

Broadband author and consultant Mr. Craig Settles posted criticism today on his site Fighting the Next Good Fight, saying "How skilled are these people really going to be to be able to look at a 100- or 200-page proposal and be able to determine if it should get the 5 points for affordability, or points for having a strong management team, which are all elements of the NOFA? The people who are best qualified to do this work are either working 20 hours a day to keep the job they have, or trying to find a job."

"And from the political side, the vulnerability for tampering and unfair influence is huge. There's talk of these volunteers working from home. Even if they sign a confidentiality statement and swear on a stack to bibles to not have a conflict of interest, who the heck is going to look over their shoulder to ensure this. For that matter, when you get down to it, anyone can look over their shoulder - literally -at home or their office who hasn't signed a pledge of confidentiality or no conflict of interest," said Mr. Settles in a separate communication with

USDA to Use Federal Employees & Retained Contractors for Review
The balance of the total in Recovery Act broadband monies, a budget authorization of $2.5 billion, is being managed by the Rural Utilities Service (RUS) of the US Department of Agriculture (USDA).

USDA officials stated yesterday in a Workshop session attended by that RUS would not be using volunteers in any part of its grant and loan application review process. During a presentation on the Broadband Initiatives Program (BIP) of RUS, a USDA official stated that RUS is now in the process of retaining federal contractors to compliment its agency workforce of over 6,000 federal employees assigned to program management in the field. USDA estimates that an unknown number of these experienced program employees will be temporary reassigned to grant and loan review tasks, including management of the selected federal contractors.

Our Take: We were sincere in expressing our thanks to the managers and employees of NTIA and RUS we met yesterday at the Boston area Workshop. We have done so throughout the past months we have been covering the "broadband stim" story nationally.

We were in the room when a hard working NTIA employee was besieged with questions about the volunteer reviewer program.

Both NTIA and RUS deserve nothing but thanks from all of us that care about the transformative powers of ubiquitous broadband in American society for the yeoman's duty they have performed over the past 5 months.

On this issue however, we think NTIA has made a mistake. The Department of Commerce and NTIA need to go back and issue a call for paid federal contractors to supplement DOC-NTIA employees managing the review process. USDA-RUS is the model in this regard.

House Ag Rural Development Subcommittee Reviews Broadband Stimulus 07/09/09 The House Subcommittee on Rural Development, of the full Committee on Agriculture, this morning is conducting the first review by Congress of the Recovery Act's broadband stimulus program called after the release last week of federal program regulations.

As first reported on, Mr. Walter B. McCormick, CEO of US Telecom, the industry lobby and trade group representing large telephone operating companies will be testifying. We believe US Telecom will use Mr. McCormick's testimony as an avenue to criticize specific aspects of the broadband stimulus regulations, released on July 1 in a Notice of Funds Availability (NOFA).

The Subcommittee on Rural Development, Biotechnology, Specialty Crops, and Foreign Agriculture is chaired by Rep. Mike McIntyre (D-NC), with Rep. Mike Conaway (R-TX) Ranking Member. The full Committee is chaired by Rep. Collin C. Peterson (D-MN), with with Rep. Frank D. Lucas (R-OK) the Ranking Member.

Live audio and video feeds are online at: Live Audio House Committee on Agriculture.

As is the case for all full Committees and Subcommittees of Congress, the Subcommittee goes into recess frequently to take votes on the House floor. When in recess, the live video feed shows a test pattern.

Written testimony will eventually be posted on the Committee site at: Witness Opening Statements.

The Chairmen have issued a witness list comprised of 2 federal officials and 5 cable and telco industry representatives:

Thursday, July 9 – 10:00 a.m.
1300 Longworth House Office Building
Subcommittee on Rural Development, Biotechnology, Specialty Crops, and Foreign Agriculture —Public Hearing.
RE: To review rural broadband programs.

Panel I

  • Ms. Cheryl Cook, Deputy Under Secretary for Rural Development, U.S. Department of Agriculture, Washington, D.C.
    • Accompanied by Mr. David Villano, Assistant Administrator, Telecommunications Programs, Rural Utilities Service, U.S. Department of Agriculture, Washington, D.C.
  • Mr. Mark Seifert, Senior Advisor to the Assistant Secretary, National Telecommunications and Information Administration, U.S. Department of Commerce, Washington, D.C.

Panel II

Wednesday, July 8, 2009

NTIA-RUS Application Guideline Package Now at 6 Documents, Released July 8 07/08/09 As the 2 federal agencies which are administrating the total $7.2 billion in broadband stimulus funds work to post their Application Guideline documents online, we are now hosting all 6 Guideline documents.

Document Download, Go To: Broadband Stimulus Online Library
(see: File Navigation, below for folder location)

We make these documents available as a service to our readers, under the terms of the disclaimer, below.

These documents, and the file location referenced below, include a new scanned version of the single document we posted on July 7.

Each of the 6 documents, comprised of 378 total pages, were handed out at the second national Workshop venue hosted jointly by the National Telecommunications and Information Administration (NTIA) of the Department of Commerce, and the Rural Utilities Service (RUS) of the Department of Agriculture. Federal officials attending the Workshop held in Dedham, Massachusetts today, July 8, told us that all 6 documents "should be posted by the end of this week" at the "Download Application" section of

We believe that this 6 document package comprises, or nearly so, "The application packages for electronic and paper submissions" referenced (line 37, page 2) in the Notice of Funding Availability (NOFA) document released last week, on July 1, jointly by the 2 agencies.

In view of the high interest in the broadband stimulus program, is making the 6 documents available, via free download (registration required), at the site of our corporate parent, PrattNetworks LLC.

Disclaimer:, and its corporate parent PrattNetworks LLC, make no claim as to the accuracy of the referenced six (6) electronic documents, as such documents exist as reprographic copies of federal publications in the public domain. We caution readers that these scanned electronic copies of paper materials distributed by federal employees at a joint agency Workshop may contain copy errors, scanning and reprographic errors, and may not otherwise be the final posted documents referenced in the NOFA. Said final documents, to be posted on the site, an Internet site of the United States Government, may have a different form, finish, and meaning from these documents. makes these documents available as a courtesy to our readers only. We make no claim as to the accuracy of these documents, nor any statement or suggestion these materials should be used in the filing of an actual application. The NOFA makes clear that only the electronic documents to be posted at may be used for formal application purposes.

File Navigation:
Document Download, Go To: Broadband Stimulus Online Library

Following a brief registration, you will be passed to a secure document library. The 6 Application Guide documents are in File #2, entitled "BIP (RUS) & BTOP (NTIA) Application Guidelines"

Tuesday, July 7, 2009

NTIA-RUS Application Guide for Broadband Stimulus Program Now Online via

(Editor's Note of 07/09/09: The single Application Guide document posted on Tuesday, July 7, has now been augmented with the posting of a total Application Guideline package comprised of 6 documents, inclusive of the first posted Guideline. The first document was distributed at the federal broadband stimulus Workshop in National Harbor, Maryland on July 7. The full 6 document package was distributed yesterday, July 8, at the Workshop in Dedham, Massachusetts. See our story, with fully updated links to the new online document file: here.) 07/07/09
The 2 federal agencies
administering the $7.2 billion broadband stimulus program funded by the Recovery Act today released a 54 page application guide form for applicants under the program.

The document, formally titled "Broadband Infrastructure Application Submission to RUS (BIP) and NTIA (BTOP)," was handed out by the agencies at the first program workshop, held today in National Harbor, Maryland. The document has not been posted electronically at the joint agency site, as of the time of this posting.

Document Download, Go To: Broadband Stimulus Online Library
(see: File Navigation, below for folder location)

The document is referenced (line 37, page 2) in the Notice of Funding Availability (NOFA) document released last week, on July 1, jointly by the 2 agencies, the National Telecommunications and Information Administration (NTIA) of the Department of Commerce, and the Rural Utilities Service (RUS) of the Department of Agriculture.

"This is simply the most comprehensive grant application guideline I have ever seen in years of federal grant work," commented Ms. Liz Zucco of Canton, GA based grant management firm MarketSYS USA. "
The multiple choice check-off system is user friendly, and clearly worded, unlike many essay based formats of the past," concluded Ms. Zucco.

In view of the high interest in the broadband stimulus program, is making the 54 page application guideline document available for free download (registration required), via our the site of our corporate parent, PrattNetworks LLC.

Disclaimer:, and its corporate parent PrattNetworks LLC make no claim as to the accuracy of the referenced document, a copy of a federal publication in the public domain. We caution readers that this is a scanned copy of a hard copy document handed out today at the workshop in Maryland. It may have copy errors. It may not be the final document to be posted on the site. makes the document available as a courtesy to our readers only. We make no claim that this document should be used in the filing of an actual application. The NOFA makes clear that only the electronic document to be posted at can be used for formal application purposes.

File Navigation:
Document Download, Go To: Broadband Stimulus Online Library

Following a brief registration, you will be passed to a secure document library. The Application Guide is in File #1, entitled "Featured Documents and Reports". The document is named "Application Guidelines for RUS (BIP) and NTIA (BTOP)".

Monday, July 6, 2009

US Telecom's McCormick to Testify to House Ag Subcommittee Hearing on Broadband Stimulus 07/06/09 Walter B. McCormick Jr., President and CEO of the United States Telecom Association (US Telecom), will be a witness before the House Agriculture Subcommittee on Rural Development's hearing to be held Thursday of this week, July 9, on the Obama Administration's broadband stimulus program.

McCormick's testimony will mark the first opportunity that the lobbying arm of the large incumbent telcos will have to tell Congress what it thinks of the Administration's broadband stimulus funding regulations released last week, on July 1.

The Association's CEO will also be testifying 3 days after the Wall Street Journal today broke the story (registration required) that the Obama Justice Department is opening an antitrust investigation into the business practices of the "big telcos," the Regional Bell Operating Companies (RBOCs) .

US Telecom spokesman Tom Amontree stated to, in an e-mail of this afternoon, that Mr. McCormick "is scheduled to testify" at Thursday's Subcommittee hearing.

As of our posting time, the full House Agriculture Committee has not released its witness list for the hearing. The Subcommittee on Rural Development, Biotechnology, Specialty Crops, and Foreign Agriculture is chaired by Rep. Mike McIntyre (D-NC). The full Committee is chaired by Rep. Collin C. Peterson (D-MN).

As of our posting, Committee press staff and Congressman McIntyre's office staff had not returned our calls for confirmation of the Subcommittee witness list.

USTelecom, formerly called the US Telephone Association and the largest US trade and lobbying group representing incumbent telephone operating companies, last week expressed its 'concern' with unspecified policies of the broadband stimulus guidelines jointly released last week by the US Departments of Agriculture and Commerce. In federal parlance the guidelines are called a Notice of Funding Availability, or NOFA (download: .PDF).

In a press statement of July 2 Mr. McCormick stated that US Telecom is "..concerned that some of the new mandates seem to go beyond current laws and FCC rules." Mr. Amontree was responding to's request for specific citations from the NOFA which were of concern to the trade group. The US Telecom spokesman stated that "...we are still reviewing the nofa and won’t go beyond the statement at this time," but suggested that interested observers should watch the Subcommittee testimony for Mr. McCormick's statements.

Friday, July 3, 2009

Communications Workers of America: Buy American Waiver is "Symptom of Decline of US Manufacturing" 07/03/09 The Communications Workers of America (CWA), the national industrial union representing 740,000 organized members within the telecom sector, stated today its displeasure with the the recent waivers, issued by the Departments of Agriculture and Commerce, of the Buy American provisions of the Recovery Act.

CWA, a delegate organization of the AFL-CIO, was the only arm of the American labor movement to have lobbied the Obama Administration in favor of a strict enforcement and interpretation policy regarding the applicability of the Buy American clause to the "broadband stimulus" provisions of the overall $787 billion American Recovery and Reinvestment Act of 2009 (ARRA).

In an e-mail of this afternoon, responding to inquires of earlier this week by, CWA Spokeswoman Ms. Candice Johnston stated, "This is a symptom of the decline in US manufacturing. Most companies now also outsource some tech work and (the) overall impact isn't good. I believe the intent of Congress in this program was to stimulate the US economy and US jobs. We need to do more to keep and grow quality US jobs."

CWA endorsed then Senator Barack Obama for the presidency on June 23, 2008.

Late last Friday afternoon, June 26, the National Telecommunications and Information Administration (NTIA), a division of the US Commerce Department, and the Rural Utilities Service of the US Department of Agriculture (RUS) both issued nearly identical "limited waiver" notices for the Buy American provision.

NTIA and RUS are the 2 federal agencies designated by Congress to disperse the total of $7.2 billion in Recovery Act funds to spur broadband deployments in "unserved" and "underserved" areas of the US. Each notice was separately based on a "finding" previously issued on June 19 by the Secretaries of Agriculture and Commerce, Tom Vilsack and Gary Locke, respectively. Both waivers are referenced in the federal guidelines, called a Notice of Funds Availability (NOFA), issued July 1 to launch the first competitive broadband stimulus application round (download: . PDF).

The waivers are applicable to certain specified network and telecom equipment purchases to be funded by the broadband stimulus appropriations of the Act. Actual expenditures on network and telecom equipment covered by the waivers will be spent by successful applicants competing for the federal funds under competitive grants, loans, and grant / loan combinations. Both waivers were published in the Federal Register on July 1 (download: PDF).

The waiver issuance marks a clear victory for network and telecom gear makers Alcatel-Lucent (NYSE: ALU) and Cisco Systems (NASDAQ: CSCO), and the Washington-based trade group the Telecommunications Industry Association (TIA). All 3 entities had lobbied NTIA and other federal agencies in favor of a permissive interpretation of the Act's Buy American language, and had requested the waiver issuance.

“We are encouraged by the RUS and NTIA decisions to waive the Buy American requirements for certain broadband network equipment", said TIA President Grant Seiffert in an e-mailed statement sent to

"These announcements recognize that technology is manufactured on a global scale and that American consumers should have access to the best available technologies, regardless of origin. TIA continues to support open markets and free trade", concluded the trade group president.

Alcatel-Lucent and Cisco are TIA members, together with some 300 other gear makers, system integrators, and associated industry groups and vendors.

As we had previously reported, first on April 16th, Cisco has been conducting a series ex parte discussions with decision makers at NTIA.

We also speculated that what Cisco and other major players in the American technology sector saw at stake in the Buy American controversy could be far more significant that the equipment portions of the $7.2 billion in broadband stimulus funding. We believe that American tech firms having substantial foreign manufacturing operations feared being frozen out of the much larger information technology (IT) purchasing opportunity represented by ARRA. We have always concurred with analysis, like that of the Baller Herbst Law Group (download: PDF), that the Act's total IT-centric appropriations can be seen as reaching as high as $100 billion.

If Cisco, Alcatel-Lucent, and TIA are the equipment sector industry lobbying Goliaths of the Buy American debate that has simmered in industry journals, and on tech blogs over the past 60 days, surely scrappy Zhone Technologies, Inc. (NASDAQ: ZHNE) has been the industry's David.

Zhone, a telecom equipment manufacturer headquartered in Oakland, California, having its primary manufacturing facility in Largo Florida, has been the leading industry voice for a strict interpretation of the Buy American clause. In public comments filed as part of the NTIA-RUS rulemaking process that lead up to the NOFA release of this week, Zhone argued the essential point that the ARRA was first and foremost about creating American jobs. As a domestic manufacturer, Zhone sought competitive advantage via its lobby effort.

S spoke with Steve Glapa, Vice President of Product Management and Marketing at Zhone within hours of the release of the NTIA and RUS documents.

"While we still believe the Administration could have found a reasonable way to guide the broadband stimulus funds more explicitly toward creating and sustaining American jobs -- as was the ARRA's original intention -- we respect their decision to place more emphasis on speed in the process and just move on from what had become a surprisingly contentious issue," said Glapa.

"We have many customers who are anxious to get started with the formal grant proposal process, as soon as NTIA and RUS can release their guidelines. We expect to have ample opportunities to help turn these funds into America jobs nonetheless, and we're eager to get started as well," concluded the Zhone spokesman.

The Obama Administration's disclosure regulations for lobbying activities directed at federal agencies involved in the dispersal of federal stimulus funds mandate that lobbying contacts be made a matter of public record.

Our Take: The betting was on Cisco, Alcatel-Lucent, and TIA to win this lobbying round. As we said back in April, whatever the politics and merits of the arguments, the simple fact that a sizable portion of the value, in particular semiconductor arrays, of networking gear is fabricated abroad will make a strict interpretation of the Buy American section of ARRA difficult.

Joining Cisco and Alcatel-Lucent as the big industry winners in the waiver decision is Corning Incorporated (NYSE: GLW), for just the opposite reasons.

Foreign made optical fiber received no waiver. Is Corning ramping-up more capacity, as in the halcyon days of the telecom boom, days in which some of us couldn't spend Wall Street's money fast enough to put glass in the ground?

The NOFA released on July 1 has an obvious tilt toward middle mile projects financed with NTIA grants. Service providers are now building FTTx and HFC plans into their RUS loan applications. The waivers specifically state that they do not waive the Buy American clause in ARRA for "fiber optic cables." We think industry analysts will be ringing-up a certain American manufacturer headquartered in Corning, NY to ask the same question we pose.

Kudos to CWA and Zhone for putting up the good fight, and helping to articulate an important issue.

As we have said repeatedly before -- and iterated in our 8 Points analysis published Wednesday morning prior to the NOFA release -- the waivers for Buy American were fully expected, but the Made in America and technical certification programs of RUS will remain untouched.
CWA's past filed comments on Buy American and today's statement of respectful yet obvious disappointment with the Obama Administration on this issue, by the labor movement's largest organization in the technology sector, will very likely be considered a bright line by the Administration going forward vis-a-vis other waiver requests.
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