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North Georgia Town Considering Fiber for Business

The City Council of the city of Commerce is considering using its existing fiber resources to offer connectivity to local businesses. At a November 3rd work session, Council members reviewed the plan and, according to the Main Street News, members voiced support for the idea.

“We’ve been actively working on this for months,” [City Manager Pete] Pyrzenski told the council. “We’ve been counseled on, we’ve talked through the options… this is a pretty viable utility for Commerce.” 

“We are ready to pull the fiber,” Pyrzenski declared. “Our role is to supply the fiber. We’re not going to get into cable TV, not going to get into telephone, just high-speed Internet.”

“Businesses have been looking for an alternative,” noted Mayor Clark Hill.

Windstream now serves the community of 6,500 but there have been significant complaints and there are no other options in this north Georgia town.

The city will need to invest $70,000 for equipment and legal fees. The network plan will use an existing line and will run additional fiber to expand the reach to more commercial customers. At this point, the city estimates a 5 - 10 year payback but that period may be reduced if local businesses respond positively. The city will fund the deployment with an interdepartmental loan from their municipal electric utility. Commerce also owns a municipal gas utility.

Multiple Minnesota Projects Submit "Expressions of Interest" to FCC

We reported in February that the FCC sought "expressions of interest" from entities that want a share of Connect America funds. The agency sought feedback on the need and desire for projects across the country from entities that have not traditionally received universal service funds. The FCC received over 1,000 expressions of interest.

Minnesota leads the U.S. in proposed projects. According to a recent MPR News Ground Level article, 62 expressions of interests come from Minnesota. Projects vary in size; some focus on a small number of homes while others plan to bring services to many people.

All of the proposed projects address gaps in rural broadband service. MPR noted that several of the expressions of interest describe community experience with CenturyLink, Frontier, and Mediacom. The RS Fiber cooperative wrote:

“The communities have approached all three providers [CenturyLink, Windstream, and MediaCom] and asked them to work with the communities to build the fiber network. They all refused. Then the communities offered to put up the money to construct the network and the providers could operate and eventually own the network. None of them were interested.”

The MPR article reports the FCC will likely offer approximately $86 million to the three incumbents to bring broadband to unserved and underserved areas. If they refuse, a long line of interested parties are waiting.

Minnesota's desire for broadband caught the attention of state lawmakers. A bill to earmark funds for rural broadband was introduced earlier this session and has received bipartisan support. From the MPR article:

Even if the Minnesota projects go nowhere with the FCC, they already may have had an impact here in the state.

For the first time, lawmakers here are considering whether to spend money on broadband infrastructure, and the idea has backing from Gov. Mark Dayton. But “there was concern from the governor and others there might not be enough interest,” said Christopher Mitchell, analyst with the Institute for Local Self-Reliance. “This answers that.”

Home Security Firm ADT Opposes Kentucky Bill to Eliminate Landlines

In February, we reported on another attempt by AT&T, Windstream, and Cincinnati Bell, to eliminate plain old telephone service (POTS) in Kentucky. According to Mimi Pickering from the Rural Broadband Policy Group, AT&T's SB 99 is quickly moving ahead and may even be up for a full House vote at any time.

Kentucky has fought to save its landlines for three years in a row. Many of us only think of landlines as a way to speak with loved ones, but for the isolated, elderly, and those that face daily health hazards, a landline is also a lifeline.

We recently learned that home security firm ADT submitted a letter opposing the passage of SB 99 because many business and residential customers rely ADT's technology designed for traditional landlines. Even thought the letter is dated March 4th, it only recently came to light. The letter states:

Many of our customers, like the one who alerted ADT to this bill, rely on POTS to carry alarm signals to and from monitoring companies like ADT.  Some also use POTS for their Personal Emergency Response Systems (PERS) and medical alert services.  ADT accepts that the transition from POTS is a natural progression towards new technology, and is actively working to develop best processes and an acceptable timeline where POTS is discontinued; however, the safety of everyday Kentuckians could be jeopardized if this is not done in a pragmatic, thoughtful way.

Kentuckians can weigh in on this bill by calling the toll free message line at 800-372-7181 and tell House leadership and their legislator to oppose SB 99.

Big Incumbents At It Again In Kentucky; Mimi Pickering in the Richmond Register

Yet again, lobbyists from AT&T, Windstream, and Cincinnati Bell are lobbying state elected officials under the false guise of improving communications in Kentucky. In a Richmond Register opinion piece, Mimi Pickering from the Rural Broadband Policy Group revealed the practical consequences of Senate Bill 99.

Republican Senator Paul Hornback is once again the lead sponsor on the bill. As usual, backers contend the legislation moves Kentucky communications forward. Last year, Pickering and her coalition worked to educate Kentuckians on SB 88, that would have eliminated the "carrier of last resort" requirement. We spoke with Pickering about the bill in Episode #44 of the Broadband Bits podcast. They had a similar fight in 2012.

In her opinon piece, Pickering describes the practical effect of this policy change:

It would allow them to abandon their least profitable customers and service areas as well as public protection obligations. But it is a risky and potentially dangerous bet for Kentuckians. Kentucky House members should turn it down.

Everyone agrees that access to affordable high-speed Internet is a good thing for Kentucky. However, despite what AT&T officials and their numerous lobbyists say, SB 99 does nothing to require or guarantee increased broadband investment, especially in areas of most need.

AT&T Kentucky President Hood Harris claims that current Kentucky law prevents the company from investing in new technology. As Pickering points out, AT&T refused to build in unserved areas when offered federal funds. Those funds came with minimum obligations; AT&T was not interested.

The bill appeared to be on the fast track to passage, breezing through the Senate Economic Development, Labor, and Tourism Committee only ten days after being introduced. According to the Kentucky Herald-Leader, AARP, the Kentucky Resources Council, and several smaller cable and Internet service providers expressed opposition to the bill:

"We are not giving up our land lines. We want to hang onto them even as we get our cellphones because we think the land lines are more dependable," said Jim Kimbrough, president of AARP Kentucky.

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Smaller cable companies and Internet providers told senators they worry the bill lacks language to protect them from unfair competitive tactics by AT&T once it's freed of even more PSC regulation, following earlier phone deregulation measures that passed in 2004 and 2006.

Pickering knows quick passage is dangerous. From her opinion piece:

How is this good for Kentucky? There is no good reason for the General Assembly to rush thorough the AT&T-backed legislation and surrender the rights and protections guaranteed to us under our long-standing communications laws.

SB 99 is bad news and big trouble for all of us, unless of course you are one of these telecommunication giants.

Mark Creekmore Takes on Windstream - Community Broadband Bits Podcast #69

Earlier this year, Mark Creekmore transitioned from a frustrated DSL customer to a champion for better Internet access in Georgia. A concerned citizen and tech consultant, Mark joins us for the latest Community Broadband Bits podcast. He discusses his history with Windstream and the steps he went through to improve his Internet access.

Along with this interview, you can read a how-to guide he wrote on DSL Reports.

Mark documented the times his connection speeds fell, his calls to tech support, and their inability to deliver what they promised. Finally, he helped the CBS Atlanta affiliate to cover Windstream's failure to deliver service in this video.

CBS Atlanta News

We became aware of Mark as he became aware of Windstream's efforts to revoke local authority from local governments to build networks that would deliver the services that Windstream would not. Read our coverage of those legislative fights from 2013 and 2012.

We want your feedback and suggestions for the show - please e-mail us or leave a comment below. Also, feel free to suggest other guests, topics, or questions you want us to address.

This show is 22 minutes long and can be played below on this page or via iTunes or via the tool of your choice using this feed.

Listen to previous episodes here. You can can download this Mp3 file directly from here.

Thanks to Mudhoney for the music, licensed using Creative Commons.

Small Minnesota Town, Annandale, Fed up With Slow DSL

Yet another Minnesota town is fed up with slow, unreliable Internet access and is examining what it can do to make sure it has the network it needs to succeed in the modern economy. Annandale is 50 miles northwest of Minneapolis with a population of 3,200 and has Windstream as the telephone company.

Windstream, as with other large firms that primarily serve rural America, offers a DSL more suited to the late 1990's than 2013. It has little capacity to invest in better networks, even if it had the willingness. We've covered Windstream several times in previous stories.

After a flood of complaints from residents to City Hall about slow speeds and frequent outages, the City issued a request for proposals for a feasibility study that will explore alternatives to the present reliance on Windstream.

Local leaders understand that the private sector is not likely to invest significantly in its community due to its density and rural location. But the town needs modern Internet access to retain and attract good jobs. The Annandale Advocate newspaper ran a story on September 17 but it is not available for non-subscribers.

At a chamber of commerce meeting later in the week Gunnarson added that strong broadband is a basic, essential feature of modern commerce.

"New businesses expect good Internet. When you buy a car you expect tires on it. Unfortunately, our car has wooden tires," he said.

logo-annandale-advocate.jpg

The same paper published a guest editorial by City Council members to explain how little power the City has over private providers. Many people falsely believe that towns are actively keeping competition out:

We even had some people angrily ask our staff why are we keeping the competition out. So to set the record straight, the city can't do much about it because it is all private wires, equipment, operations and corporate customer service.

Also, a recent call to the PUC, the Public Utilities Commission, confirms that not much can be done since broadband is not regulated. Sorry folks. As far as letting in competition, we have zero say in that. Any other provider can come in any time. In fact, many of us citizens would throw the welcome party.

If any provider believes it is being denying the right to offer service in Annandale, there is a legal process to rectify the situation. Since 1992, no local government has had the power to offer a cable monopoly and the same is true for telephone or Internet access since the 1996 Telecommunications Act.

The problem is not local governments, it is the extremely high cost of building networks and the difficulty of competing with entrenched incumbents that can lower costs temporarily to deny subscribers to new networks.

Annandale has not committed to any specific course of action; it is gauging what opportunities are available and how a business model might work. And like most towns, they are leaving the door open to working with the incumbent:

Does our current provider still have an opportunity to be rock star in Annandale? They sure do. They just need to upgrade and make the city hall phone stop ringing.

A CBS Atlanta investigation has previously found that Windstream blatantly lies to consumers about their services.

CBS Atlanta News

Given Annandale's size, it is impractical to build a standalone triple-play FTTH network but it may find that an incremental fiber approach could work. Start with municipal facilities and businesses and expand to residents as necessary. Without a strong cable provider, most households probably already have a satellite TV service. This would leave open the possibility of doing an Internet and telephone double-play as Longmont, Colorado is doing. They could also partner with another network that wants to expand.

Regardless, you can expect the same big companies that refuse to invest in Annandale will publicly argue that the town should do nothing. But doing nothing is the best way to ensure nothing changes.

First BTOP Project Connects Rural North Georgia Communities

Back in December, 2009, Vice President Biden travelled to Dawsonville, Georgia, to officially kick off the American Recovery and Reinvestment Act (ARRA) program. The first award, a grant of $33.5 million, went to the North Georgia Network Cooperative. The group combined that grant with local and state funding and in May, 2012, lit the North Georgia Network (NGN).

We spoke with Paul Belk, CEO of NGN, who shared the network's story and described how it is improving economic development while serving schools and government across the region. We also recently published a podcast interview with Paul Belk.

In 2007, Bruce Abraham was the Lumpkin County Development Authority President and could not recruit new business to the region. Atlanta is only 60 miles away but companies and entrepeneurs were not willing to branch out toward north Georgia. Business leaders repeatedly told Abraham they were not interested because of the lack of broadband. DSL was available from Windstream, but businesses kept telling Abraham, "That's not broadband." North Georgia was losing jobs and there was no strategy to replace them.

Abraham found economic development representatives from Forsyth, White, Union, and Dawson counties shared the same problem. With North Georgia College & State University in Dahlonega, the group decided to address the problem together.

In 2008, they received a OneGeorgia Authority BRIDGE grant. They used the $100,000 award to commission a feasibility study that suggested the area had potential as a new tech hub. The study also indicated that the region's traditional manufacturing and agricultural industries would continue to dwindle. The group, determined to pursue the establishment of a new tech economy, knew the first step would be next-generation infrastructure.

In 2009, two local electric cooperatives joined the group and it incorporated to become the nonprofit North Georgia Network Cooperative. With the addition of the Habersham and Blue Ridge Mountain Electric Coops, the organization had access to technical expertise, equipment, and staff that could facilitate construction and operation of the future network.

Recovery Seal

Belk notes that the pieces fell into place for NGN throughout the process. The group applied for a grant during the first round of the Broadband Technology Opportunities Program (BTOP). The NGN Cooperative received a $33.5 million BTOP grant and an additional $2.5 million OneGeorgia Authority BRIDGE grant. Habersham and Blue Ridge Mountain also invested, bringing the final cost to $42 million.

Mostly aerial, the 1,100 mile network went up quickly (PDF of the network map). Construction began in March 2011 and was finished that same fall. On May 2, 2012, the network was officially lit in Lumpkin County where construction had started, completing the ring.

Unlike most other BTOP projects, NGN provides some last mile connectivity for small and medium sized business. Habersham and Blue Ridge Mountain work directly with customers, who can purchase connections between 1-10 gig. The backbone allows 100 gig transport.

Belk notes that NGN changed economic development in several ways. Before the network, local businesses learned to get by with little or no reliance on local connectivity. Tax professionals used to store files and transactions on a laptop and then drive to another community with better connectivity because DSL was not reliable or fast enough to transfer files. He describes their method as a "courier service." The NGN Cooperative continues to reach out to small and medium sized businesses to encourage adoption and show them how the network can expand their reach.

Belk told us about JumpinGoat Coffee Roasters. In the past, this small business relied exclusively on sales through its physical storefront and most sales were during the tourist season. Now the company sells gourmet coffee all over the country all year long beause it has reliable and robust connectivity. JumpinGoat is only one example of how NGN brings more money into the community.

Recently, NGN announced it will provide connectivity to a new data center built by Boston-based Standard Colo, in Lumpkin County. The initial investment in the community will be $10 million and community leaders expect the total investment to be $70-83 million in five years. 

Georgia seal

The investment will create 10-12 high paying positions in a community where average wage is $10 per hour. In addition to increasing the tax base, Belk sees this as a first step in transforming the area into the tech hub envisioned in 2008.

NGN also contributes to the community's efforts to prepare students to fill future tech jobs. Before NGN, Lumpkin County Schools had 3 bonded DSL connections and less than 20 Mbps to the Internet - now the District has 1 gig and access to the 10 gig cloud at no extra charge. Eight school districts and three colleges connect with NGN. The cloud allows schools to scale back on expenses for equipment, such as servers and video encoders, because each district can share across the cloud rather than purchase equipment for each location.

Eventually, the schools hope to eliminate textbooks and use the cloud as depositories for learning materials. Belk sees the schools breaking out of the "island" approach to pool their buying power for better prices on virtual learning material licenses.

Kids are entering college better prepared, says Belk, in part because the University of North Georgia and other local colleges provide credit to high school students via distane learning. The community wants to create an environment where, throughout their school careers, kids learn with technology and acquire skils to take advantage of the booming tech hub. Parents in north Georgia want to keep their kids close to home.

In addition to schools and businesses, seven local governments and five major medical centers use the network for connectivity. Belk notes that most financial institutions in the region also connect to the NGN. Users work directly through the electric coops to connect.

NGN's serves as a backbone for multiple carriers, reducing rates, encouraging choice, and prompting better service in a region that was left behind by large incumbents. The price of DSL has dropped $10 since the network launched. Belk says Windstream, who would not invest in the region in 2007, is "building fiber like crazy."

Belk feels his region is in a good position now, thanks to the network. While he can point to value in enhanced educational opportunities, healthcare advances, and business development, he believes the community gained most by avoiding loss. Belk notes that, like the interstate highway build out that determined what small towns would survive, broadband infrastructure establishes winners and losers. If you don't offer it, some other community will.

Kentuckians Once Again Fighting to Keep Landlines

Last year, we reported on the failed SB 135, which would have eliminated the "carrier of last resort" requirement in the state. The bill, sponsored by Republican Senator Paul Hornback would have let AT&T decide who could receive basic telephone service and would have limited consumer protections.

Last year's bill did not become law, but a progeny, SB 88, has already passed in the Kentucky Senate and was received in the House on February 15th. (We'd like to report what committee will hear it first but the Kentucky Legislative web has not yet published that information.) Senator Hornback is again the chief author of the bill, crafted by AT&T and its ALEC pals.

The Kentucky Resources Council (KRC) provides an analysis of SB 88 and a prognosis on how it would affect Kentuckians. KRC must be feeling deja vu, as are many organizations looking out for rural dwellers who depend on their landlines. These bills continue to be introduced year after year as large telecommunications companies spend millions of lobbying dollars, also year after year.

WMMT, Mountain Community Radio in Whitesburg, Kentucky, recently reported on the legislation. Sylvia Ryerson spoke with Tom Fitzgerald from KRC, who discussed the analysis. From KRC's report on the legislation:

At potential risk is the opportunity for existing and new customers, to obtain stand-along basic telephone services from the incumbent telephone utility, or “Plain Old Telephone Service (POTS)” as it is called. Those most adversely affected by this loss of access to basic, stand-alone, telephone service are those least able to obtain affordable and reliable alternatives – those who live in rural, lower density areas, and the poor in dense, urbanized areas who have no affordable alternative priced as low as POTS.

Kentucky Resources Council

The main concerns with the bill include:

Removal of power from the Public Service Commission to hear and resolve complaints about local exchange service. This would affect voice service, operator assistance, directory assistance, and accurate 911 assistance. Restoring lost service is often a waiting game for rural customers served by AT&T. With no where to go, customers can lose their connection to family and the outside world for even longer periods. As with many other provisions of this bill, the elderly are the biggest casualty. Healthcare matters are  often handled over the phone, including my dad's pacemaker monitoring.

In areas where there are more than 5,000 households, offering basic stand-alone service would be at the provider's discretion. Service could be terminated without prior regulatory approval if there are any other voice services offered to the customer, even if that service was from an affiliate. This lack of competition would likely lead to cost increases for people who cannot afford them. Another scenario would be the company's requirement for customers to bundle services, forcing those least able to afford it to purchase services they do not need or want just to get telephone service.

In communities where there are fewer than 5,000 households, the current providers (AT&T, Windstream, or Cincinnati Bell) could cease to offer stand alone landline service of there was available voice wireless service, even if that service was less effective for 911 purposes. Again, the "forced bundle" would be an issue.

They could also petition to be relieved of the obligation to provide basic telephone service if they meet certain criteria regarding the availability of voice services from other providers in the area. For example, if there is a broadband provider "capable" of providing voice services (contrasted with one that actually "does provide" voice services) the provider could be relieved of the obligation. Again, that "capable" provider does not have to offer the service as a stand alone, but may require bundling.

Providers can use any technology they wish if they decide to continue the "provider of last resort" obligation, which will make that obligation completely deregulated. This tactic is the backbone of the private sector's efforts to deregulate. For more on this strategy, we encourage you to listen to our conversation with Harold Feld on the 23rd episode of the Broadband Bits Podcast.

Telephone

For more detail on the bill, and all its shortcomings, take a few moments to review the detailed analysis by KRC. The full text of the bill, its amendments, and the status, are available on the Kentucky General Assembly website.

So what could be gained for Kentuckians by passage of such a bill?

From a Courier-Journal report by Joseph Gerth:

Proponents of Senate Bill 88 say the bill would allow companies like AT&T, Cincinnati Bell and Windstream to sink more money into expanding wireless broadband communications rather than costly old, outmoded land lines.

History shows us, however, that promises made by regulated companies today often end up as foggy memories tomorrow. We have seen time and time again how dergulation given in exchange for promises results in a breach of the social contract. This is known as Kushnick's Law:

"A regulated company will always renege on promises to provide public benefits tomorrow in exchange for regulatory and financial benefits today."

Rather than wait to be taken advantage of again, we encourge you to call the toll-free legislative message line 1-800-372-7181 and leave a message that will be delivered to all legislators. This is especially critical if you live in Kentucky, but legislation like this will march across all states if it passes here or elsewhere. 

Georgia Bill Aims to Limit Investment In Internet Networks

Stay updated on developments by following this tag.

The Georgia General Assembly is considering another bill to limit investment in telecommunications networks in the state, an odd proposition when just about everyone agrees states need as much investment in these networks as possible.

House Bill 282, the "Municipal Broadband Investment Act," purports to limit the ability of public entities to invest only in "unserved" areas. But as usual, the devil is in the details. This bill will be discussed on Wednesday, Feb 13 at 4:00 EST in the Telecom Subcommittee of the House Energy, Utilities & Telecommunications committee (Committee roster here).

We strongly encourage Georgians to write to members of this committee and explain that these decisions should be made at the local level, not by the state. Communities each face unique circumstances regarding the need for telecommunications investment and they can be trusted to make informed decisions after weighing the available evidence.

Many local governments have invested in modest networks to connect local businesses, but such investments will be prohibited in Georgia if residents in the area are already served with a connection of at least 1.5 Mbps in one direction. This baseline is far lower standard than the FCC's definition of "basic" broadband: 4 Mbps down and 1 Mbps up. Setting a low baseline hurts communities but rewards carriers that have refused to invest in modern networks.

This bill poses a dramatic threat to the ability of local governments to encourage economic development and provide the environment necessary for the private sector to create the jobs every community needs. See our fact sheet on how public broadband investments have created jobs.

Supporters of this bill will claim that it only restricts investment to areas that are most needing it. This argument is not only flat wrong, it comes mostly from those most interested in preventing, not encouraging, investment.

The bill will effectively prohibit any community investment because the cost of collecting the data and making the case that areas are unserved is prohibitive, particularly when the bar for what constitutes being unserved is set unrealistically low. The cost of collecting data at the census block level is high and communities are extremely unlikely to spend the necessary sums when there is no guarantee they will be able to take action on it.

Additionally, requiring a network to operate only in unserved areas is akin to requiring a health insurance plan to only accept terminally ill patients. A network requires a mix of densities and households in order to be sustainable. Should any community build a network under these circumstances, however unlikely, such a network would almost certainly require ongoing subsidization, which would then be used as evidence for why such a network should never have been built. Heads they win, tails we lose.

This bill is much sneakier than last year's broadside attack on community networks. Rather than aggressively challenging community broadband, this approach appears to be more reasonable, even as it creates the same result: greatly limiting the authority of communities to decide for themselves whether an investment is appropriate for encouraging economic development.

Windstream Logo

We understand that Windstream is the main lobbyist pushing this bill forward in an attempt to protect the networks they have refused to upgrade to modern standards. Windstream is just one of several large telecommunications companies that does not have the capacity to invest in the next-generation networks demanded in the 21st century economy. For instance, see this recent story from Missouri about Windstream:

“People feel they are paying for a service they are not getting,” Rep. Fitzwater told Windstream. “I get emails every day, letters, telephone calls. McAllister Software is a major employer, employing around 140 people. They are vital to the local economy, and they need internet service. There were about 45 hours last year that they had to shut their doors because they had no internet. There are other businesses in town that are affected by internet speeds. The other day there was a water main break and school was closed; some of the businesses had to shut down because of reduced internet speeds because the kids were online playing games.”

Even as Windstream cannot provide the necessary speeds, they are pushing a bill to make it harder for others to step in and provide the necessary services. This is why the bill uses a 1.5 Mbps standard, DSL often provides that below-basic level of service but does not support common applications or business needs.

In short, this is a bill that will only hurt the residents and businesses of Georgia, taking away one of the only methods a community can ensure it is ready for the digital economy.

More Evidence for Looming Broadband Monopoly

DSLReports has accurately noted the continued decline of competition between DSL and cable providers. Heck, it seems like no large company wants to invest in the future of broadband in this country. Verizon and AT&T have chosen to focus on wireless technology, resulting in less true competition. Cable (or FTTH if you are lucky to have that option) tends to offer faster, more expensive connections and DSL is the slower, less expensive option for many.

As we noted in an earlier post, Verizon no longer offers stand alone DSL and is voluntarily losing customers to focus on their more profitable (and more expensive) fixed LTE service. Many of the companies providing DSL service simply lack the interest or capacity to invest in modern networks.

Windstream lost broadband subscribers last quarter for the first time ever losing 2,200 subscribers for a 1.36 million total. Verizon added just 2,000 net broadband users last quarter, the worst quarterly result in four years. The AP quotes Verizon as saying that the hit was due to Verizon's decision to stop selling standalone DSL.

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Meanwhile, smaller telcos like Windstream, Frontier, Fairpoint and CenturyLink find themselves unable or unwilling to upgrade their networks to keep pace with faster cable speeds. That's going to result in considerably more bloodshed for the telcos as additional subscribers jump ship (assuming they have the choice), resulting in cable's domination of the U.S. residential broadband market.

Continued reliance on these companies to build the essential infrastructure our economy and citizens need is foolish. The incentives are all wrong for their model and the amount of public money it will take to bribe them into building better infrastructure would offer far higher returns when invested in models that are democratically accountable to the community -- networks owned by local governments, cooperatives, or other nonprofit organizations.