 My name is Clay Purvis, I'm the Director for Telecommunications and Connectivity with the Department of Public Service. We're here tonight to discuss the Vermont Ten-Year Telecommunications Plan. We are now at the final draft of that plan and this is the second draft that we've issued. I have with me tonight Matt Dunn from Rural Innovation Strategies Incorporated and CTC Technology and Energy. They are the groups that the Department of Public Service hired to complete the Ten-Year Telecommunications Plan. Tonight we're here to get comment from members of the public, such as yourselves, on this draft of the plan and any changes that you might recommend we make. We are scheduled to issue the final adopted plan on June 30th. This is the third of four meetings, excuse me, the third of five meetings we're having. The first meeting was last week, last Thursday in Montpelier. We had a meeting with the legislature yesterday afternoon and today we're here in Springfield. Tomorrow we'll be in Craftsbury at the Craftsbury Town Hall. That meeting will also be online and then finally we'll have a meeting on Monday June 28th at the Dorset Town offices, which should hopefully be online, please stay tuned for that. We have the physical space designated, we're still strategizing how we can have an online meeting as well. But we will post that call and information once we have that established. So for the hearing tonight, we're going to start with a very brief overview of the plan from Matt Dunn. And then we are going to move to your comments and we'll start with folks who are joining us online. And then we'll take comments from folks on the phone and then we'll move to anyone who might be joining us in person down in Springfield. So with that, Matt, turn it over to you. Great. Thank you, Clay, and delighted to be here in Windsor County in Springfield at the Black River Innovation Campus, which is a, for those who haven't made it here yet, it's a beautiful space with 10 gigabit connectivity, which is relevant to this conversation of the potential that can happen when a fiber of the home is built out. This is a co-working space and innovation hub. And anyway, it's just super exciting to be here and to be here in an unmasked situation now that the state is opening up. We are delighted to share this very summarized overview of the 10-year telecommunications plan. We are anticipating that people have had a chance to take a look at it in its entirety. This is not meant to cover all of the elements of the 300-plus page document, but want to just highlight some pieces for folks and provide some additional context. So this is the overview of what we're going to be reviewing today, and we'll talk about the opportunity, the core values that informed this plan that came from the statute. We'll talk about terrestrial broadband, parts of the plan, mobile broadband, public safety, and then PEG television. So what we want to say at the outset is that the creation of this 10-year plan came at a unique moment in history in Vermont, where the urgency that came out of COVID put us in a position of actually having the motivation and the resources to finally ensure that all individuals in Vermont had access to broadband. And our focus is on the 51,000 premises that currently do not have even cable speeds of broadband service. And this is a group of places that it's clear the market just isn't going to serve on its own. We see these as the places where the emphasis of the investment should take place, and that the investment that happens should ensure future-proof broadband, 100 over 100 fiber to the home. Because what that does is not only leapfrog these locations from having very poor broadband service to excellent service, but it also is the kind of investment that is going to be able to scale over time. Because once you put in fiber to the home, you can actually do equipment upgrades and allow it to go from 100 over 100 to 500 over 500 gigabit over a gigabit or even 10 gigabit symmetrical service. And the cost of that, we've spent a significant amount of time in this plan to refine those numbers. That estimate is between $360 million and $440 million. The difference, by the way, between those two numbers is whether or not we connect premises that are designated as camps. This is kind of a unique Vermont situation, and there's a range of views as to whether premises that are considered camps should be connected. As you can imagine, they tend to be in more remote locations where the cost of actually getting broadband service to them is more expensive. But that gives you a pretty accurate sense of what that cost would be. And with the ARPA money, that has been currently allocated by the legislature and then is available to be allocated, plus the resources that are likely to come through an infrastructure package, this is dual. This is something that can happen over the next several years. And became the focus of this plan was how to achieve this infrastructure goal that we have had for 20 years, and allow that to support the state moving forward. The core values that went into this 10-year telecom plan came from the legislation itself, and we looked at it through the framework of what is going to be the most efficient strategy for bringing high-speed internet, what is going to allow for the long term support of telecommunication needs. We also understand that the state, through its legislation, has made local control or working through CUDs as a priority. And then finally, to make sure that there is equity, that individuals throughout Vermont will have access to high-speed internet, regardless of geography, but also income race or any other factor. So in the pursuit of high-speed internet and the 100 over 100 goal that was set by the legislature has been complicated by some factors that we think are important to acknowledge. One is that the reverse auction that the STC undertook this last year provided subsidy to a variety of different broadband providers, but not in a coordinated fashion. It allowed for some of the broadband providers to secure funding to build fiber to the home to the densely populated areas of a broader region, but not those other locations. So it made the communication union district planning process that much more difficult because if you're going to try to build a network, and suddenly the core of that network is going to be subsidized for someone else to be able to provide to, it makes that planning difficult. Second is that the stimulus money did not just come to Vermont. It's coming to the entire country, which is causing intense labor and materials demand, which is going to make the construction timeline and probably the cost as well not as predictable as it may have been in the past. And the final thing is that CUDs are not all created equally in their current state. Some of them are very sophisticated and have been running an ISP for some time. Others have just recently formed and are all volunteer. So with the decision to utilize CUDs as a major conduit for the resources to be able to build out broadband, there is going to need to be greater support for those CUDs to make sure they're going into that process with the right tools and expertise to be successful. The H360 framework, the legislation that passed this year certainly was front of mind as we were doing the plan and in fact is very much aligned with where we had arrived independently as the best strategy for the state moving forward. There are a number of specifics that we got into that went beyond what was immediately recommended in the legislation, but completely aligned. So there are some things that we do believe absolutely need to be requirements as well as items that we think are best positioned as priorities as they were in the statute and we articulate that in the plan itself. There are some questions that in acting 360 are going to have to be confronted. These are not necessarily easy questions like how do you make sure that there is precision in the award of funding process as well as meeting the desire to have CUDs universal service plans be the focus and how to adjudicate whether or not there is a conflict with another provider's investment. All the way through to how to think about circumstances where a CUD's effort doesn't actually work out and we know that these are complicated business operations with a number of unknowns and so understanding that scenario is going to be important to make sure that we don't end up in situations where areas that should be served are unserved because of business model not working. There are some technical standards that we believe are critical to make sure that there is interoperability as well as a design that will avoid host remote isolation and other kinds of challenges that would be a problem in the future. We outline those specifically along with the type of design that's going to be necessary to ensure at least symmetrical gigabit and beyond speeds in these locations. There is as I mentioned before some needs for the CUDs to have both expertise and support because we're asking a lot of these largely volunteer organizations and you want to make sure that they're going in to be able to do public private partnerships that are understanding the long term and if they're going to be negotiating with large incumbent telecoms there's going to have to be a certain amount of sophistication and ongoing support in those processes and the same if they're going to be doing a lot of the building and planning themselves because these are complex projects with a lot of design that's necessary to be able to do them right. In the longer term once we get past this infrastructure push we believe that CUDs have a role to play in making sure that everyone is then able to actually avail themselves of the broadband that has been deployed. It's one thing to make sure that there is infrastructure it's another to make sure that it's affordable and accessible. So we have a number of recommendations of the role that CUDs can play in collaboration with other institutions that have this as part of their core missions including library schools and peg television stations and so we bucket it under affordability access to devices themselves without devices broadband doesn't actually give you much value and then the digital skills to be able to make the best use of those tools and either for making life more affordable to be able to avail oneself of careers that can be facilitated online all the way through telehealth. Beyond the terrestrial broadband infrastructure that's necessary there's also mobile broadband and when we did our survey this came up over and over again as a high priority for Vermonters and so the plan does include recommendations on expanding mobile broadband throughout the state but what it also started with is an analysis of where there is broadband today breaking it out by indoor and outdoor mobile service as you can see from this map you know there are large large amounts of the state that are not in our very densely populated areas that that do not have service we do think that indoor as I mentioned later will be supported by bringing fiber to the home because people can use voiceover IP wireless capacity but there is there is lots of outdoor areas that still need coverage and there is just there is a 23 percent of the addresses are covered are only 23 percent are covered at an outdoor capacity in a way that would be predictable. This is a look at the road miles that are covered and this is particularly important in terms of public safety and when you look at our class one roads which is largely interstate there's actually quite good coverage it's not perfect but it's at about 91 percent as you get to class two and class three roads however it goes down quite dramatically and so this is definitely an area of concern for public safety and to be able to make a call for help as well as a general sense of where the coverage is in the state. In the plan we have put out some recommendations that if funding is available either through stimulus or other infrastructure dollars that there are ways to do an RFP process that would both leverage the creativity of the public sector or sorry of the private sector to be able to come to the table with plans for that build out of the infrastructure but also points that would be awarded to make sure that there are incentives in that process to support multiple providers and to make sure that the likelihood of success is high as we all know for monitors feel strongly about towers and so we would want to make sure that the actual solutions that would receive this funding could be actionable in the current environment. Public safety is obviously an important part of the telecom system and we have we received actually a lot of feedback from the first draft and was able to reach out to local safety organizations to get their take on where things stand and I mean the good news is that the state has taken steps to migrate to next generation 911 systems but there is still a need for land mobile radio in the state because other options like using FirstNet or other kinds of wireless is just not robust and in the meantime the MLR LMR systems are aging and they need upgrades. There is funding available we articulate where that those funding sources at a federal level could come from in the plan as well. There is a discussion as well about the issues of voice over IP systems and the reliance on grid power for 911 access. This comes down to the availability of battery backup and allowing or frankly encouraging the telephone and telephony providers to be able to provide consumers with a variety of alternatives for power supplies including additional batteries. Things may seem simple but are absolutely critical and we did receive some feedback on that and have incorporated those kinds of recommendations into the plan. Finally we did address as was asked in the plan the importance of peg television stations but also some of the precariousness of the funding. There was a study that was completed by the Berkshire Consulting Report and we heard it loud and clear that peg channels are really important to Vermonters. That was particularly true during the pandemic where their public mission was on display in a wide variety of ways including making sure that public meetings were continuing to be shared through other kinds of platforms rather than in-person meetings as well as helping individuals and businesses to be able to use technology to continue to connect during our period of time where we were not going to be having in-person communication. The funding sources for peg television are declined as more and more individuals are using over-the-top types of services rather than going through a traditional cable mechanism and there are some interesting recommendations that were in the Berkshire Report. Each of them have some complexities to them. We did not get into the full legal analysis of each of those because we felt that that was not entirely in scope of the work that we were doing but we do believe that there is going to be some decisions made in other states that should give an indication to Vermon as to what paths forward would be considered legally viable but we absolutely believe the legislature should look to general fund support in the interim until a long-term funding source is found in order to make sure that there is continuity of service from these important institutions in our state. So that's an overview of the plan and happy to turn it back over to you Clay. Great. Thank you very much, Matt. I appreciate it. I think we will now start with public comment. All right. Just making my screen big. Apologize there. Matt, could you take us off the presentation? There you are. All right. So now we'll move to the public comment portion of tonight's presentation or tonight's hearing. We'll start with folks who joined us online using the Microsoft Teams meeting application or the web browser and then we'll move to folks on the phone followed by anyone who's joined in person if there are any. So if you'd like to give a comment, I'd appreciate it if you use the raise hand feature that is located in the top right hand corner of the screen and we'll just go down the line. So the first person who's raised his hand, her hand is Rob Perry 823. I'd appreciate if you put yourself on video if you can. If not, that's okay. But do please state your name and yeah, state your name and if you want you can state the town you're from. Okay. Yes, can you hear me? I can hear you. Okay. I would put on video but some upgrade that came to my Windows machine disabled my camera and I've been trying for the last few days to get it back on again. So my name is Robert Perry. I'm the executive director of the Mad River Valley TV station, the PEG channel that supports Waitsville, Warren, Faston. We reached Duxbury, Moretown and that general area in the Mad River Valley. And I appreciate the comments at the end about the importance of PEG. I think through the 20 years we've been a PEG channel in the valley. We've grown in importance and the pandemic really showed how important PEG channels are. The legislature agrees and the Berkshire report that was commissioned is an important step in trying to find out how we can continue to fund our services. Because as noted, our major source of funding is cable subscriptions, a piece of that revenue, and that is declining with court cutting and the over the top players that we all use. So we are moving towards a streaming model. We're going to stream the channel. We need to find a way to see if we can raise money through that, but it will be launched as a free service for our community. So we do need to find a funding source. Our concern is that the study mentions and goes through these conclusions, but doesn't really deal with the issues raised here that you need to do due diligence on the recommendations, really dig into the legality of it. The legislature required that the additional due diligence be done and understanding of these recommendations. So we can move forward together with broadband, expanding broadband access, not in a way that's counter to it or conflicting with it. Because we really want to partner with broadband expansion. It's critical to our future that we can connect to our constituents through broadband because our cable audience is declining constantly. So we need to reach our community through broadband access. And so we're looking for a way to partner, not in conflict with broadband expansion. We view that as very important. I view it as important as I have DSL at home and I would like to get more than the 11.7 megabit upload that I might get. So that's kind of my point. We like to move forward and in partnership with broadband. We don't feel it in conflict. We feel the report somehow sets us up as a kind of an ancillary topic to be sort of a checklist thing. And we think we're a very important part of the overall telecommunications plan going forward. All right. Thank you very much. Great. Thank you for your comment. We'll move next to Will Dodge. Good evening, Will. Hello, everyone. Nice to be here. Great work that you guys have done on this telecommunications plan. So my name is Will Dodge. I'm an attorney at Downs Rockland Martin. I chair the regulated entities group at the law firm. And that includes what we call the Environment, Energy, and Telecommunications Group. And I do a lot of work in the siting field. I'm not here tonight to represent any particular client of ours and will deny trying to speak for any of them particularly. But I'm more speaking just as a practitioner who understands some of what the department's role is and some of the challenges for telecommunications in the state. And also just as a citizen consumer who wants to make sure that all of my equipment works well, especially during a once-in-a-century pandemic. So one, I'm going to focus my comment specifically on wireless. And one thing that I will note generally about the telecommunications plan, figure six, the wireless coverage map, I very much respect the need to show or to try to depict where there is and is not coverage in the state. But I also think that there's been a lot of work done just probably in the short period between the time that this map was created and now, and that it's probably worth doing some updates on it so that there's more focus on some of those underserved areas. So for instance, up in the Northeast Kingdom, driving along the border basically between Canaan to Norton, Norton Down, I can attest both as a consumer and as somebody involved in siting that there's great coverage along those main roads now that there wasn't even a year ago. And I know that there's some other places. So all by way of saying, worth it to probably try as best you can to update that before going to final print on the telecom plan, or else providing some kind of a disclaimer somewhere that says, you know, this map is constantly changing, something to that effect. The second comment I have more concerns, section 248a, which is the wireless siting statute. That statute was put into place back, well, has a long history, but in its current iteration, it basically started in about 2009 and has been continually extended round about every three years since that time. And what I would say is as imperfect as wireless coverage is in the state as represented by that figure number six, it would be substantially worse had we not had that statute in place. And I also think that we're at the point with it because basically 11 years have gone by that there are more communities that would rather that 248a continue to exist than not exist, both because it helps in many instances, in most instances, to expedite those projects that are non controversial and make it much easier to upgrade facilities to basically put antennas and get more competition on existing towers that have been built than if we didn't have it and everything was run through local zoning and act 250. And what I'll just say as a practitioner is I've had instances in the past, I would say four to five years, where we'll tell a municipality, we need to seek permits from you for putting antennas on an existing tower where we're not there today on behalf of a carrier client. And we'll have the zoning administrators or the town planners tell us, please don't bother us with this. Can you please go through 248a? It's much easier. We like it better that way. The other thing that I think that 248a has shown to be more successful in doing is allowing doesn't always work this way, but when it does work, it works really well for new projects that tend to be more controversial and have more process. It allows for better flexibility in terms of the carrier or the tower to developer and the community. And a couple of examples that I can show specifically include Grand Isle, Thetford, and Menden, where there were very controversial projects that ultimately through the course of the process resulted in an approval of a site that was much more to which the community, the host community, was much more amenable than when we started out. By contrast, the one time in the past decade or I would say the past five years where I've been involved where you've got a new tower that's run through Act 250 and that ultimately gets appealed by a party that is against it and that has to be run to superior court to ultimately run a full de novo trial, it ends up being much more expensive and taking much, much longer, really more expensive for everyone than the alternative. It had been run through the Public Utility Commission. The last iteration of the draft telecommunications plan at least talked a little bit about should 248A be renewed. And I would just encourage the department to at least think about some type of advocacy or positive statements or at least an acknowledgement that looking through the course of history, it's proven to be better than the alternative. The last thing that I will say is at the federal level there's been a lot of guidance and two specific regulations that have been put out to try to expedite further those non-controversial projects. The PUC has not really taken any types of steps to harmonize how it administers 248A with those new federal rules. And where I think that that's headed is an easy way to address it would be to hold workshops or to even make further changes to the statutes to recognize those federal regulations. The alternative is that if that doesn't happen eventually someone, this is not meant to be a threat. I'm just saying as a matter of fact someone's going to end up bringing a lawsuit somewhere and that's going to end up costing someone funds and it'll probably be the state of Vermont i.e. the taxpayers or the rate payers depending on which way you look at it. So it would be great regardless of what happens to try to make sure that Vermont's laws and rules are harmonized with those new federal requirements that came out of the FCC. And I'd be happy Clay to provide a citation to those two regulations separately to you to at least take a look at. Yes, thank you. Please do that. And certainly this is an area where the plan could maybe reference a little more the history of 248A. So thank you for your comment. I appreciate it. We'll move next to Mike Abadi. I don't know. Sorry if I mispronounced your name. You got it. I got it. Okay, great. That's cultural confidence right there. Hello, I'm Michael Abadi. Well said there. Chair of work immediate. Just want to thank Vermont State Government for historically protecting and supporting public access TV. I produced a show on the Georgia Center runoff and engaged with public access world down there. And I learned it had been decimated by state law chains. Atlanta's Public Access Center charges for everything. The Cal county station is just a drop off. No studio, minimal staff. This is how you make immediate tips. And Vermont is like you have a strong public access TV set up healthy community radio infrastructure and community minded commercial outlets like the community. But state law can start such outlets and then citizens are subjected to manipulation and misinformation. So I hope you think about not just the technical questions but also ensuring that we have local public cultural infrastructure. And I propose you take the funding study and set up a trigger point. Cable revenues go goes down by a certain percent and or 25 percent. You take it. He would kick in and the cable revenues continue to fall that he was designed a mechanism to get your foot in the door and send it off to them. People have determined tech stations are essential and also may be determining at the same time that their table bill isn't. And our funding is tied to table revenue. So hope you can put together a package to operationalize these funding. These findings of the tech funding study. Thank you. And any thoughts on a trigger point? Great. Thank you. We'll take it under advisement and we'll consider it for the final plan. If we could move to Tammy Riley. Tammy you're on mute. Should be a top left hand corner. Next to the leave button. Unmute. How are we doing? There you go. There we go. Okay. Thank you so much. Thank you again for all the work on this plan. It's impressive. And thank you for taking the time to take my comments. I am Tammy Riley. I'm the executive director for Greater Northshire Access Television also known as Jeanette TV. And we operate three peg channels on the Comcast system in the Manchester region and we serve a regional community of 11 towns in that area. As you know we provide essential media services for individuals, towns and schools and community organizations. And I want to talk a little bit about in addition to traditional peg services, we also meet the cable needs of our communities by providing local news and information programming. And the news programming is really essential in this day and age. It exposes the local stories and provides local information that's not otherwise being covered through traditional commercial media outlets. Especially in our region we're sort of sandwiched in between Burlington and Albany. So there's really no television coverage. So we have a real opportunity to serve our community in that way with those information services. As we're looking to the future as we've all discussed it's apparent that our traditional cable subscriber funding is declining. One of the biggest challenges is to find the solutions to continue serving the communities and to meet their expectations as the landscape changes so fast. And more and more people are consuming this local, this essential local information that you can't find anywhere else through our system. But their expectations are that it be available everywhere, online, on cable, digitally and that the technical standards match the commercial entities. So as small peg centers we struggle to keep up with these demands as our funding declines. So I wanted to talk a little bit about that and then just state that we were disappointed that the telecom plant didn't take a deeper dive into the PEG study recommendations because it did provide some creative solutions and described authority of the state and provided solutions for funding for the public benefit sector in terms of PEG, E911 and Universal Service. So we're disappointed in that. So I want to state that. And finally to echo what Rob was saying I feel strongly that we can really be a partner in finding solutions and that funding solutions for PEG don't have to be in conflict with rate payers and CUDs and that we really need to think hard about how we can work better together and that we're really vital in this. Access stations reflect the needs of the community, the pulse of the community, we're embedded in the fabric of our schools and our towns and the people, individuals and organizations from all walks of life, all population sectors engage with us on a daily basis. So we're really embedded and I think we really need to be a part of the solution and be part of the process to coming up with solutions for the future. And that's really my final thought. Thank you again for all the work and for allowing me to speak today. Thank you. Thank you, Tammy. I appreciate it. We'll go next to CJ. Hi, CJ. Hey, good afternoon clients. Nice to see you again. You too. Why don't you take it away? All right. So I actually am going to be directing my comments to two areas. So first of all, thank you all for the excellent work on a really large and comprehensive plan. I have some idea of the amount of effort that's gone into it. And so thank you, Matt. Thank you, Clay, for a great preso. I am here particularly as I'm on the Board of Directors of Orca Media. I'm also on the governing board for EC Fiber, which was the first, what was it, TUD? Because it was under some different legislation than the CUDs, but it's the CUD. And I was three years on its executive committee. And I think I met you and Matt Dunn working on some of the enabling legislation for rural broadband with EC Fever's vice chair at the time, Paul Haskell. My background is technology and broadband. I'm the former CIO for a series of telecoms via mergers culminating in Verizon's Global Fiber Optic Network and the former CTO for Cable and Wireless, which is now level three, one of the big providers of fiber optic services worldwide, VP of business operations for a startup called On Fiber, which did mid-sized metropolitan fiber networks and the director of business development for GT, the alternative to AT&T way back when where I led the launch of Enterprise Solutions. So I did a lot of technology fiber and figuring out how money needed to work. The main things that I wanted to address have to do a little bit with, as you all know, work media is the access center for the Montpelier Vermont area, it serves central Vermont. Community media is widely recognized as by the legislature is an important aspect of information and telecom services. And I feel like Rob Perry and Tami and others have really done a great job of addressing that. Just want to call attention to the fact that our coverage of meetings held under open meeting law from select board meetings and town meetings and school board meetings and graduations and of course, you know, state house content and legislative committees came out to be recognized as increasingly important during the pandemic and will likely continue to do so as technology more and more and remote communications run our culture. So these give Vermont the opportunity to have unsurpassed community engagement and transparency because we uniquely have town meetings and an open legislature. In fact, these hearings themselves are being streamed by orca via the statewide TV channel, Vermont Community TV and the statewide access channel is now HD, which I think is the only access channel in the state so far. So Matt recognized in this excellent presentation the situation with declining revenues from cable television channel subscriptions and their impact on the peg channels. Community broadband access is funded by cable entertainment revenues and as its importance and community value is growing. Seeing during the pandemic, the funding is going to be decreasing with the projections of decreasing cable revenues. So in short, my key point here is that it's going to be, I think, important to look at shifting the financing from cable entertainment revenues to financing from streaming revenues. We now have Amazon Prime, Hulu, Netflix, AT&T as well as a host of other streaming avenues and so we don't actually need to impact the CUDs. We should probably just be looking to the other monetization channel for entertainment revenues, which is streaming and the advantage of that is rather than creating a whole new model, you're simply going to the same source and saying as your revenue shift from cable connections and coax to streaming monetization, we would like to continue to support the community access, which more and more will be using the same media via the same avenue. So you're just switching from the coax and cable subscriptions to the streaming. The metering will need to be a little bit different, but the helpful thing is that the justification and rationalization is the same. Does that make sense? Are there any questions or thoughts just on how that could be done? There's some technology behind it, but it's eminently doable. My second comment then would simply be to look at the fiber networks. Fiber optic networks support the economy in two significant ways and there's the obvious one that we've all been pounding the table for, which is education, business development, jobs, telehealth, agriculture, more and more requires it oddly enough social engagement and internet of things from remote driving to talking posters. You also don't have cell services without backhaul, which means you have to have broadband. So good cell services, healthy businesses, healthy students, healthy people with telehealth. There's another huge economic impact that I don't see discussed too often that I wanted to bring up and that is interest payments. What are interest payments have to do with fiber optic services in the economy and that the interest payments have to do with the rule of seven, which is often cited when people are being taught about investing and the rule of seven is that if you invest seven dollars or seven years at seven percent, your money will double. But this also applies to borrowing money and one of the things that happens when you're building fiber optic networks anywhere is that you have to borrow a lot of money because they're expensive and so if you borrow say 50 million dollars at seven percent for 14 years, you're going to pay back not just 50 million, you're going to pay back a hundred million dollars in interest plus your original 50 million dollars in principle. And the reason I bring this up is that if your source of money is an out of state lender, then all of that interest money goes out of state. But if you want to support your local community, it helps a great deal if your lending source can be an in-state lender because then all that interest money goes back in state and for some reason I seldom see this addressed. It's very well established in the big telecoms that the source of money and the interest payments are a critical part of the economic equation of these fiber networks. And in addition, the people that control your debt tend to control a little bit your resource. So there's a huge opportunity here and I'd love to see a little bit more of that opportunity being addressed in the telecom plan because it's potentially hundreds of millions of dollars and for Vermont that's a lot of money. That really concludes my commentary. I just want to thank you again for giving me the opportunity and for doing such fine work. Please support the PEG channels. They're a great resource for all of us and they make Vermont a special place and consider looking at the financing model. Thank you. Great. Thank you CJ. All right. Do we have anyone else online? Otherwise we'll move to the phone. Do you just want to speak up and let us know you want to talk? All right. Let's go to the phone. We have one person on the phone. I guess hit star six and state your name. Justine Whitaker from up there. Thank you, Steve. Go ahead. I want to raise a number of things. Some of them you may have heard some before. The this is not a plan that meets statutory requirements by any stretch. The statutory requirements require addressing each of the goals of 202c with strategic objectives and measurable progress and funding sources needed for each of those goals. Those goals include mobile wireless, competitive choice, open access, etc. In many ways this proposal or this report that the contractor has put together attempts to end around those statutory goals by suggesting that the CUDs should be empowered to negotiate those away with private corporations. That is a patently absurd notion and it eviscerates the legitimacy of this as a planning document. So I think it would be wise for the department to admit the failures of the public participation process, admit the failures of the AMO financial analysis element which you've heard a lot about, admit the failures of not addressing the goals in accordance with statute and not adopt this plan. Start this process anew with possible legislative changes next January to have this built telecom plan built on top of the statewide fiber design that's authorized and funded through the community broadband board. The recommendations that we set up the CUDs to take care of tech support and assume responsibility for the high cost areas where consolidated doesn't want to build themselves and even suggest that these CUDs might end up being the carrier of last resort basically looks suspiciously like a private equity scheme where you privatize the profits and you socialize the costs. That's a political agenda being inserted into our telecommunications planning process. It has no business here. This is supposed to be a 10-year telecommunications plan that can be fine-tuned between administrations but not whiplashed between administrations. Also I read the contract with CTC. For some reason somebody intentionally shouldered the department with the assembly of the final draft and not the contractor. The point of inserting the language allowing for a private engineering firm to do the plan was to get reputationally backstopped credibility and objectivity from an engineering point of view and to have the department brush off and trivialize most of the public comment that was inserted into Appendix G is not only an insult to the folks that went through a lot of work to put that public comment into the record but it basically undermines the entire credibility of the process. The public participation process was supposed to be coordinated with AMOs necessitated you know orientation workshops because the plan has been failed the department has failed to do a plan for 14 years now or 16 and so the capacity of the public to engage and discuss with confidence the issues this is not just an internet plan either as much as some would like to hope this is a telecommunications plan which will rely on self-service and public safety uh high capacity you know bulletproof circuits public safety grade circuits that are going to make sure a dispatch gets to a radio tower to get to the portable radio in the ambulance and this that reliability is not in in this plan anywhere that interface that interoperability with state systems is not in this document at all so I'm just raising a huge red flag but this really think this is a hollow with flagrant disregard of the statutory requirements uh in the discussions I've heard these last two days about voiceover IP it's it's a fallacy to suggest that you know consumer education in better batteries or bigger batteries in the homes are the solution when you know darn well I'll say damn well that the all the cable amplifiers when they lose power no one's getting a 911 call or a voice call out no matter how big your batteries are at home so the the existence of the consolidated remote terminals those have about eight hours of runtime and the the green version of the cable amplifier pole mounted cable amplifiers have about four hours of runtime so the newer grayer ones might have eight hours of runtime but you're you're leading people at higher risk than ever before by this disregarding these vulnerabilities in the network and not fully digging into those from an engineering point of view I feel like you know resee use ctc to win the contract and then dumb the plan down to reese's capabilities instead of utilizing our ctc's engineering expertise uh and I look forward to seeing where all the money went for this to document which is not a plan but the two documents together that have cost nearly three quarters of a million dollars is is uh is grounds for the auditor and the attorney general to take over uh small cells we recently modified the pole attachment rules and it was too late by the time people realized what was in there but the pole attachment rules now consider small cells nothing but a pole attachment whereas I find a new horizon small cell on the village green you know less than a hundred feet from where you know friends and kids that you know have their picnics and yes we are preempted on safety issues but that's sure we sure do have citing uh criteria and opportunity so I have to respectfully disagree with will dives that 248 a is working for everybody it's working for those who have you know four hundred dollar an hour you know corporate legal budgets to gain the system uh the epuc system is a is a tragic farce of public participation and the costs for mended at that for uh to litigate those cases are enormous so 248 a is not the panacea that it looks like from somebody who represents you know atc but the small cell on vermont colleges green is one that uh should be a prime example in how we need to reconsider how we cite these I heard bragging about uh tainan highway coverage uh cell coverage along that is that more than one carrier is that one carrier only we discovered that atc and t after taking the you know 50 60 million dollars in subsidies uh at the behest of the governor's opt-in decision promised to have coverage in many areas said they had coverage in areas but when we paid a contractor to go out and measure it there wasn't coverage there and atc and t as much as told us to go pound sand so any publicly subsidized uh cell coverage infill of dead zones should definitely be mandatory all carriers coverage necessitating a neutral host the neutral host analysis the open access analysis are miserable failures of uh intellectual honesty and thorough due diligence in this document so I the ammo analysis funding analysis should have dug deep into the telephone personal property tax it suggests that in uh appendix g that the right away fee we're we don't really understand who's talking about collecting the right away fee that's patently observed and and ill informed we currently have a right away fee in statute in 19 vsa 26a and it's not being enforced and the department is party to that with the trans so to for the department's knowledge of that broadband fee statutory mandate and then to have the whoever's responding to the public comments in appendix g say that we don't know understand what any of this means it's just it's it's just absurd it's a fallacy uh there was one of the key public comments filed through the survey monkey was about a fundamental and prerequisite uh network architecture decision of active fiber versus passive fiber we have one we have multiple examples of passive fiber in vermont we have one example of active fiber but the ability to upgrade one of statutory goals is to make sure that all of our investments are upgradeable to future technology and don't foreclose options and opportunities for future technology upgrades and active fiber network whereas a dedicated glass strand is delivered to each serve location rather than through 32 at 32 times splitters uh allows for that upgrade path whereas the splitters preclude that upgrade path if somebody needs a higher speed or a you know 100 gigabit or a 800 gigabit service you have to go build a new fiber cable to that end you can't do that through passive splitters so that comment was not responded to in appendix g seems to be missing it was not included in in appendix uh yeah the first part of collected public comments and then it was you know trivially said oh well we incorporated it into the plan everywhere else the public comments were incorporated into the plan they were included the appendix with a note saying we incorporated this on these pages that was not done so um with the issue of the funding uh the attachment fee the streaming tax the right-of-way fee the telephone personal property tax to hear a contractor say that it's not entirely in scope is really it is in the statute and it's in the contract so to you know try to dodge that at this point uh is a further cause to not adopt this plan and admit you have failed and address uh public uh just a point of clarification uh act 154 from last year uh didn't modify the um the aspect of the the telecom plan on on peg based on the fact that the the Berkshire report was coming out it the AMO funding analysis is still in the statute and it's in the country in the ctc contract so i don't i don't i'm not familiar with the okay that's all right i just wanted to you you may be correct but it's still in the set it's still in the uh statutory uh it's in the ctc contract as one of the uh deliverables the propagation analysis uh seems to be from from my reading of the description of how that was gone about it didn't factor in uh segment segmented antennas it appears to have been done on a omnidirectional antenna basis disregarding tilt and uh azimuth of segmented antennas uh but it's it's grossly different than the maps that atn t promised to have by now uh just on one carrier i as you may know i'm not a supporter we do not want to become known as a state you want to visit only if you're an atn t customer or only if you're a Verizon customer the in rural areas where it's not cost effective for these carriers to build everywhere the neutral host model where one set of infrastructure is managed by a neutral host operator and through roaming agreements all carriers are uh able to deliver and receive calls and broadband services over that infrastructure is the money we should be pursuing for all of the dead zones that we currently have and engaging the CUDs in owning those small cells and deploying them as a priority uh is is important um the public participation to not have published paper plans to not have uh i mean i eventually got a paper plan but it was almost like a punishment joke a single sided black and white so none of the graphs mean anything in the appendix in in black and white and uh you know a three-inch stack of paper uh loose bounds no three-hole punch nothing it was just uh if you're going to do effective public participation which is the phrase in the statute the workshops there's a proposal that was sent to chris rechia back by charlie arkin and i several years ago in the around the 2014 or 17 time frame uh the AMOs were to be engaged in bringing people up to speed on the dimensions and the capabilities and the the served and unserved areas ahead of time so people could engage in a meaningful discussion that is that it was all skipped here uh and the AMOs were not engaged the there was some trivial email back and forth between whether uh you know a rici employee was going to do it and it basically fell off the table and that to me that is a fundamental piece of a public participation process in this plan is it the undergirding of what this plan is supposed to be about so that failure alone should disqualify this plan for being adopted so i'm basically asking to you appeal to y'all's integrity uh as a department if if there's any left in the upper echelons there to not adopt this plan and force this into a a new strategy to get it done it's not okay to have the group responsible for developing the plan also adopting the plan with not so much as an approval by any uh body oversight body so i'm recommending that if if the department is to continue to develop the plan uh or continue to be done by contract that the community broadband board have final adoption authority but only after making an affirmative finding that it hits every one of the statute order requirements and it is complete and thorough according to statue and otherwise it's not adopted and it's set back for further view but this idea we have a very rapidly closing one-year window before we uh have to measure this tell this telecom plan against the incentive reg plan for consolidated uh that reminds me that the incentive reg the treatment of the incentive reg plan in the draft the final draft by the cons consultant contractor is a fallacy it is absolutely inaccurate it says that it's only about basic rate telephone service but when you go and read the incentive reg statute 30 vs a 226 b it shall be approved only if it is consistent with all the goals of 202 c and promotes competition so those things alone in 226 b would argue for us uh insisting on access to consolidated fiber uh interoffice fiber maybe maybe maybe not the local loop uh it's a passive architecture anyway so it may not be as useful and more it may be impossible to share other than on a wholesale uh basis um i'm trying not to get too into weeds for some of the other folks listening um um well steven we do have uh two more meetings if you want to break it up okay that yeah that's over time our race i'll stop there yep all right thank you steven how do we have anyone else who'd like to give a quick comment uh before we uh bring this hearing to a close click can i respond to a couple points real quick sure keep it to two minutes though so we're go with respect to route 114 in the northeast kingdom that there are multiple carriers there and i can attest as a user that uh those sites are online and working it's not simply a predictive map but those are sites that work and if if mr wittaker would like to go to those and test them themselves he really should with respect to 248 a and small cells i could tell you with a certainty that without 248 a there is a complete hodgepodge of regulation all through the state about whether you would ever even need a permit to put up a small cell anyway so if anything strengthening 248 a would create more notice for those types of projects not less we recently did a project involving nine small cells uh going up route 108 in stowe and all the joiners in the area all got notified as did the town we had plenty of back and forth everyone was comfortable with it and we ultimately um we ultimately address some concerns that are going to have much better coverage in stowe with respect to litigation risk what i would tell the dps is that however much litigation if you want to call it that that we had for contentious sites under 248 a that is nothing compared to the process that you would see if in every single case you would end up with a suit in federal district court and if you want to check that just to start asking your counterparts over in main massachusetts and new hampshire where that's how things are run doesn't make a difference uh if you ultimately um don't care about costs but the way that 248 a issues are resolved end up being much more collaborative and finally what i would say uh with respect to the neutral host idea part of the reason that 248 a is successful is because tower infrastructure developers the ones who are entrepreneurial can find those spaces lease up lease up land and try to be ultimately marketing um space to multiple carriers which is how they benefit and we would benefit as having competition on you know those uncovered spaces so we're not as mr. Whitaker said just a Verizon state or an AT&T state um it is one of those things that 248 a handles better than is true with act 250 so that's all simply in defense of saying that 248 a really does work well and we hope that the uh the agency or the department will consider advocating for it uh in the final version of the plan thanks great thank you all right well we'll bring this hearing to a close thank you all for your comments and uh i really appreciate it um we'll have another hearing tomorrow uh at 6 p.m. in Craftsbury uh that will be online as well and like i said next Monday the 28th we'll have a hearing in uh Dorset at the town clerk's office um in town and that information is on our website but thank you again i appreciate your um participation and uh coming out uh and um sitting in a hearing on uh on a beautiful day so all right have a good evening and we'll see you tomorrow clay before you shut down the meeting completely um may i put in just a very brief comment it was one of the stumps again yep um so will mention the wireless coverage map and was it your effort that of driving around and around the development i was partly informed by that we'd certainly like to do it again um we have the resources to do it that is my recommendation uh is to establish a rolling fund to keep that and a and a and a job to keep that constantly updated my only other 30 second comment is to consider that um when we have limited fiber which we will always have in low density states we're essentially creating microscopic semi monopolies just as we did with AT&T and GTE and uh you can recognize those by looking at the churn rates so they're easy to determine um when in working as an executive in an industry where five nines reliability was a requirement for um reliability of coverage and where there were big teeth if we failed to achieve those the state might want to consider using that uh that tool it's proven it works it uh fosters good quality of service and good behavior and you can use the fines to support things this is not a popular position but since i'm not having to report to any board you can use those fines to finance things thank you very much great thank you very much all right everyone have a good night thank you