STATE CAPITOL DAVE FREUDENTHAL OF WYOMING CHEYENNE, WY 82002 GOVERNOR ‘THE STATE, Office of the Governor October 14, 2009 The Honorable Lawrence E. Strickling Assistant Secretary for Communications and Information United States Department of Commerce Washington, D.C. 20230 (via E-mail to imartinez.@ntia.doc.gov) Dear Assistant Secretary Strickling: Tam writing to you in response to your invitation to comment on Broadband Technology Opportunity Program (BTOP) applications for grant proposals within Wyoming by October 14, 2009. The American Recovery and Reinvestment Act of 2009 (Recovery Act) authorizes the US. Department of Commerce’s National Telecommunications and Information Administration (NTIA) to consult with states regarding allocation of grants funds to projects affecting each state. Mr. Rob Hurless, my energy and telecommunications policy advisor, has worked with a team of specialists to prepare these comments, Mr. Hurless has been assisted by Mr. Alan B. Minier, Chairman of the Wyoming Public Service Commission, and Mr. Bob von Wolffradt, Wyoming Chief Information Officer. Mr. von Wolffradt is also responsible for Wyoming’s participation in the national mapping project under the Broadband Data improvement Act and the Recovery Act. The team identified all of the BTOP and joint BTOP/Broadband Initiative program applications that propose to serve areas of Wyoming by visiting the Broadband USA Web site and searching the applications database for applications with proposed project areas in Wyoming.’ We have chosen to confine our comments to proposals of particular interest. The team selected six grant/loan applications with qualities in common. The projects: 1, Provide additional investment in backbone infrastructure in Wyoming; 2. Address special Wyoming priorities; * http:/Amww.ntia.doc.gov/broadbandgrants/applications/search.cim TTY: 777-7860 PHONE: (307) 777-7434 FAX: (307) 632-3909The Honorable Lawrence E. Strickling October 14, 2009 Page 2 Stimulate econo ay ee Meet greatest broadband needs in Wyoming; Provide greatest possible sustainable benefits to Wyoming; growth and jobs in Wyoming; and Are “shovel-ready” in Wyoming, taking into account our construction season. The six projects are shown in Table 1 below. pass app oo “a [Paar Rpm cs | Gaa Ragant [Lama 2 | Stersurtekptom Compan: le | Meaitaninernene™ | greproe | sadgente | 5292000 3 | motes compan | Wenetanl "| spnon | hae smoon.ss 4+ |sommettathisirmiseOnaniai} Enerms Deron | Bro | fea | SE25326 s Con yong Coe wyommaras Petal | prop | batt | 52:20 tenn sien ‘ Pethnwatesine | yrop | compe | satnate The first two applications, from Advanced Communications Technology, Inc., (ACT) and Silver Star Telephone Company, Inc. (Silver Stat) provide critical additional investment in backbone infrastructure facilities. A special priority for broadband stimulus in Wyoming is to complete a statewide fiber network with redundant, self-healing network architecture capable of supporting a robust broadband environment. A broadband steering committee identified several physical infrastructure gaps that need to be addressed for the benefit of numerous entities and many of our citizens to provide modern broadband access and enable next generation, IP-enabled 911 and coordination, as well as electronic access to government, education, commerce, health, telework, and safety. This type of focus will encourage scalability and flexibility of projects,The Honorable Lawrence E. Strickling October 14, 2009 Page 3 ACT proposes a middle mile project that "closes the gap" in an existing 960 mile fiber network enabling robust, redundant broadband network opportunities for 11 counties and 26 communities in Wyoming, The project constructs approximately 34 miles of fiber facilities between Togwotee Pass and Moran to connect the eastern portion of a gap with a corresponding project proposed by Silver Star Telephone Company, Inc. connecting the western portion of the project from Jackson to Moran, Silver Star proposes to construct approximately 44 miles of fiber facilities, The ACT/Silver Star middle mile BIP/BTOP project is reasonably expected to cost $5,128,034, and matching funds are proposed to enable maximum possible sustainable economic benefits and meet one of Wyoming’s greatest broadband needs. Sustainable economic benefits include construction of 78 miles of state of the art fiber backbone facilities, and the creation of as many as 83 jobs. Although the project ambitiously crosses some of the most challenging terrain, the information in the applicants’ filings shows credible evidence of their abilities to complete the project in an appropriate manner. We would underscore the fact that the need for completion of the project was discussed 1g the initial announcement with, and within, Wyoming's telecommunications industry follo that ARRA funding might be available for this important infrastructure project. Without ARRA funding, we believe it will be many years before market forces alone will address this need. Wyoming Health Information Organization, Central Wyoming College, and Hot Springs Greater Learning Foundation propose telehealth, educational and public computer center and sustainable broadband adoption opportunities. Adoption is an issue of particular significance in Wyoming where exposure to the possibilities of the Internet often occurs during formal education, but languishes afterward because of the limits of services presently being provided In rural Wyoming, broadband adoption is as much a problem of fostering demand as a problem of supplying access. Each of the three proposals is supported with what we consider to be sophisticated broadband planning strategies and thoughtful academic analysis. Each of the three proposals would fill a necessary space in the efforts of many important Wyoming partnering entities. Each of the three proposals is based on credible project leadership and credible community involvement. The Hot Springs Greater Learning Foundation proposal is unusual in Wyoming in that it has specific legislative support in the form of Engrossed House Bill 0239, Enrolled Act No. 116, passed during the 2009 session. Union Telephone Company (Union Wireless) would meet special Wyoming priorities with its loan proposal. It would significantly expand wireless coverage by doubling the number of cell towers, and in doing so upgrade the statewide availability of wireless broadband to 3G. While we recognize the limits of 3G technology, the reality is that the economies of fiber-based‘The Honorable Lawrence E. Strickling October 14, 2009 Page 4 broadband imply that 3G is the best option for broadband penetration in the more thinly settled reaches of our state. ‘The largest wireless carriers in Wyoming concentrate service in the state’s few population corridors. With some exceptions, rural broadband alternatives have been limited, expensive, or simply non-existent. Union’s project would press 3G into the state’s internal frontiers, and stimulate demand as well as provide supply. The applicant is an experienced provider in Wyoming, albeit one that has experienced some strains with its growth. We believe the estimate of fifty jobs created to be very credible; there is reason for optimism that the long- term benefits of a dramatic extension of 3G service would be more substantial In conclusion, please accept these comments and explanations. If you have any questions LG Dave Freudenthal Governor or concerns, please contact Mr. Hurless. Best regards, DE:pjb ce: Ian Martinez, Senior Adviser and Director of Outreach, NTIA