Monday, May 11, 2020

Kewaunee County Broadband Expansion -- Continued investigation of Bug Tussel Documentation

The memo below starting with the date May 11, 2020 was sent to each Kewaunee County Board Member yesterday.  

Tonight at 6:30 PM the Executive Committee will be discussing contracting with Bug Tussel for Kewaunee County Broadband Expansion.  What I am trying to point out to every member of the board are inconsistencies of the entire process of this venture.  Bug Tussel has misrepresented information to the PSC in this application that spends $1,960,000 of our taxpayer money, and they will never deliver the service that was clearly stated in the Request for Proposal that the County had put out for bid.

This is a complicated subject, and if you have not read my initial blog on this subject, I would highly recommend you do that.  It will help to clarify the entire issue.  Heuer, April 18th Blog on this Subject

May 11, 2020

 Supervisor --------, District --, Kewaunee County Board of Supervisors

Lies last only a moment, but the truth lasts forever

Hello ------,

Your County Administrator Scott Feldt continues to push the Broadband expansion plan for the County by placing this item on the Executive Committee Meeting for May 11th, 2020: “Item 7. Discussion: PSC Broadband Expansion Grant – Contract”  (click here to see the County's RFP) 

If the County is to go forward with this, certain to be, ill-fated plan and proceed to contracting with Bug Tussel, the contract must specifically state the requirements and goals to be met for compliance. It must contain definitions of what constitutes contract completion. There must be provisions in the contract to ensure that Bug Tussel indeed delivers all requirements of the Contract. There must be criterion established to determine if the contract has been fulfilled by Bug Tussel.

This is key to the entire project.  Kewaunee County Broadband Committee’s Request for Proposal, under the Proposal Scope section has this sentence; Provide broadband (high speed internet) of at least 25 down and 10 up for all rural residents within Kewaunee County, preferably higher than 100mbps down and 25mbps up.

That sentence is the essence of the entire RFP, and Bug Tussel must guarantee they will produce that result for this project to be a success. 

Taking that into consideration a thorough review of the Broadband Expansion Grant Application (Click Here to see the Actual Grant Application) submitted to the PSC by Bug Tussel Wireless, Inc. at no time, in the document, refers to that type of service delivery.  In fact, throughout the document there appears to be mistruths and inconsistencies.  These following items and issues need to be clearly addressed by Bug Tussel and must be incorporated into any contract between Bug Tussel and Kewaunee County.

Inconsistencies and mistruths directly from the Grant Application in relation to the Kewaunee County Broadband Committee Request for Proposal.

·        In their presentation to the Broadband Committee they represent “Rapid Bug” service as 2mbps down and 1mbps upload at $49.99. 

o   Yet, in the grant request they represent “Rapid Bug” as 25mbps down and 5mbps upload at $49.99.  Which is correct?  

o   Neither one of these meets the RFP requirements of 25mbps and 10mbps! 

o   What is there proposed charge for the RFP requirement?

·       Provide broadband (high speed internet) of at least 25 down and 10 up for all rural residents within Kewaunee County, preferably higher than 100mbps down and 25mbps up.

o   All means all, not some. 

o   In the Grant Application, they list the Townnships covered as; Red River, Carlton, West Kewaunee, Franklin, Casco and Mischicot. 

o   What about the the townships of Montpelier, Pierce, Lincoln, Ahnapee, and Luxemburg Township?  In as much as they are not mentioned, do they get service?

·       Again, in the Grant Application they are to list existing broadband providers, they list two, TDS and Centurylink. 

o   What about Bertram,, Door County Broadband, Hughes Net, AT&T, Spectrum, Verizon, ViaSat, Cellcom, all of whom are providing service in the County at this time? 

o   Why the obfuscation, the omission and dishonesty?

·       In the Grant Application, page 1, they claim they will serve 199 Businesses and 12,115 Residential Locations, that is interesting when on page 5 they represent there are a total of 9,462 Housing Units in Kewaunee County according to the Census 2018. 

o   Once again, a misrepresentation of facts.  When people or organizations misrepresent facts, it should send a warning to whomever is dealing with them. 

·       Placement of 7 towers with 4 of the seven in the bottom 1/3rd of the County is suspect at best.  It appears by the tower placement that Bug Tussel is choosing to place these AT&T equipped towers to more facilitate their Cell tower building business for AT&T.  Rather than benefiting the broadband effort.

·       Note on page 7 of the Grant Application under c.  There is mention of two types of broadband service 25mbps/5mbps and 100mbps/20mbps within the range of the proposed towers.  They go on to list the names of the tower locations to be; Bay View, Bolt, East Krok, Gregorville, Norman, Ryans Corner, and Tisch Mills.  This further confirms no commitment to the balance or the County.

·       On page 2 of the application Bug Tussel claims 12,115 residential locations will have access to the service.  Then on page 13 of the application (table 1) Bug Tussel represents 7,886 people will have service.  When that number is divided by 2.45, the average number per household, the actual households reached would be 3,218.  That is 26.5% of the total households represented on page 1 of the application.  This is total misrepresentation of the facts by Bug Tussel. 

·       On page 14, (table 2), the total population of Kewaunee County is 20,434, yet they say they will service 29,960 people.  Take out the total of 4,011 from the Tisch Mills (table 1, page 13), site assuming they are Manitowoc County and you still are representing a number served of 5,200 people more than in the County.  Keep in mind, also, there are somewhere between 15% and 20% of the total population who don’t even want internet service.

·        Page 15, Business map claims they will reach and provide service to 199 businesses.  Most, if not all, of the larger businesses have already solved their internet needs by cutting deals with various vendors.

·        Page 16, they talk about “last mile service,” and they introduce AT&T Mobility.  That service is already available in the service area and is also offered by Verizon, Cellcom and others.

·        Page 17, fourth paragraph, very important, this is where they admit they will not be servicing “all” customers in Kewaunee County.  It is carefully worded and says, “We will provide broadband internet services of 25mbps download and 5mbps upload for $49.99 per month rate in the proposed coverage areas illustrated in Figures 4 – 11.  If you carefully scrutinize those maps, you see various colored bans around the proposed towers.  Typically, a tower is engineered to cover an area 3 – 5 miles around that specific tower. Beyond that, typically there is no service.   

o   Remember, line of sight, if a home is in a valley or covered in its surrounds by trees, there will be no service.

·        Page 19, a. Matching funds indicates the Kewaunee County Board approved a resolution on 12/17/2019 which memorialized the county’s financial support for the project and the possibilities the broadband expansion will provide for the county’s constituents.  Note it doesn’t say “part of the constituents or a few of the constituents, it simply says constituents.  Which again means all!

·        Page 20, c. Existing Broadband Service, once again here, Bug Tussel misrepresents the number of broadband operators in Kewaunee County indicating there are two, when in fact, there are about 10 providers.  Why the dishonesty?

All these issues, and more need to be addressed.  But in addition, these items should be considered and added to any contract Kewaunee County would enter with any broadband supplier.

·        First, and most important, service for all is All, not some.  So, the contract must clearly spell out how Bug Tussel will reach all the residents in the County.  As part of that description, there has to be plans to reach those underserved pockets (people surrounded by trees or in a valley) and those plans must include pricing for any special circumstances.  A special circumstance would be if a customer does not have line of sight to a tower, and a secondary pole or tower would be required.  Who pays for that, what is the timeline for Bug Tussel to respond to that type of request and what is the penalty to Bug Tussel if they fail to provide that service?.

·        What is the reporting requirement to the County as to the progress of Bug Tussel actually providing service to customers?  How many customers, when signed, what type of service are they receiving, etc.

·        How is success in this project determined?  What factors are considered?  Number of customers?  Speed Tests? 

·        Who has the responsibility in the County to ensure the project is being completed on schedule and that ALL residents are being served?  How is that even determined.

·        What is the incentive to Bug Tussel, if any, to sign up customers?  What incentive, if any, is Bug Tussel providing to the end user to move them to Bug Tussel?

·        Broadband Technology is changing rapidly, in fact, about every 3 to 4 years all the equipment needs to be changed out and upgraded.  Is that covered in the contract?

·        What if Bug Tussel fails to meet timelines or customer signups?  What is the penalty, how does the County get its money back?


Respectfully submitted by

Ron Heuer
E3530 Townline Road
Kewaunee, WI 54216
920-255-4260  /

 I have officially requested that Chairman Olson, be cited at the citizen input part of tonight's meeting and that the letter be made part of the official minutes of the meeting.

 If you haven’t had the chance to read what I have already written on this subject, I have attached it hereto.  This information was posted April 18th, 2020 on my blog Heuer, April 18th Blog on this


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