As many of you know I participated on a panel last week with 2 FCC staffers.
Here is the text of an email I just sent to them:

Paul and John;
    I just reviewed the latest form 477 report. I am dismayed by the results
for the fixed wireless industry. I cannot believe, and I am sure you don't
either that there was a 39.6% decline in subscribers over 6 months when
there were 112 more operators reporting. The only conclusion I can draw is
that fixed wireless operators who reported in the past using the zip code
method, did not file when they were required to report by census tract. Many
of those operators must have had a large customer base.
    As I mentioned on the panel, I have assisted some WISP's file their 477
reports by mapping their customer databases and assigning the proper tract
data to each record. In talking with most of them, it became apparent that
the FCC did not provide an adequate tool to help those people file. While it
is possible to look up a single address and get the tract data, there were
no provisions to allow for a bulk upload and query to assign this
information. Many of the 20 or so WISP's I helped had databases of 1,200 to
1,400 records. That would be a very time consuming process to do one at a
time.
    Most small WISP's do not have the GIS skills or tools to deal with this
issue that major carriers already have on staff. Zip codes were easy because
it was already part of the information they had on hand. If possible there
should be a tool to address this issue which should increase the reporting
numbers from those who had participated in the past.



Thank You,
Brian Webster
214 Eggleston Hill Rd.
Cooperstown, NY 13326
(607) 643-4055 Office
(607) 435-3988 Mobile
(208) 692-1898 Fax
Skype: Radiowebst
www.wirelessmapping.com
  -----Original Message-----
  From: motor...@afmug.com [mailto:motor...@afmug.com]on Behalf Of Peter
Kranz
  Sent: Monday, February 15, 2010 1:50 PM
  To: motor...@afmug.com
  Subject: RE: [Motorola II] WISP's are killing themselves!!!! - New FCC
form 477 report is out, not looking good for Fixed Wireless


  Maybe they can keep making this report harder and harder to fill out so we
all just stop doing it..



  That report is a huge waste of my staffs time. And based on the underlying
edits and validations you can tell their system computes the census tracks
internally to verify it matches the one you provide. The system should
accept data in a way that is simple for a WISP to provide and derive the
census tracks, etc.. maybe then more people would provide the data.



  Peter Kranz
  Founder/CEO - UnwiredLtd
  www.UnwiredLtd.com
  Desk: 510-868-1614 x100
  Mobile: 510-207-0000
  pkr...@unwiredltd.com

  From: motor...@afmug.com [mailto:motor...@afmug.com] On Behalf Of Chuck
McCown
  Sent: Monday, February 15, 2010 10:41 AM
  To: motor...@afmug.com
  Subject: Re: [Motorola II] WISP's are killing themselves!!!! - New FCC
form 477 report is out, not looking good for Fixed Wireless



  Brian,

  Could you find a list of the fixed wireless companies so we can all verify
we are on the list?



  From: Brian Webster

  Sent: Monday, February 15, 2010 11:36 AM

  To: WISPA List ; memb...@wispa. org ; WISPA Board ; Motorla List Beehive

  Subject: [Motorola II] WISP's are killing themselves!!!! - New FCC form
477 report is out, not looking good for Fixed Wireless



  The latest FCC report on form 477 broadband data is out
(http://hraunfoss.fcc.gov/edocs_public/attachmatch/DOC-296239A1.pdf). While
I don't see a whole lot of useful data in it, I do see where WISP's are
killing themselves and the industry, why?



    a.. In the periods prior to the December 2008 report, fixed wireless has
shown a steady increase in subscribers. The last reporting period the number
of subscribers dropped from 808,000 to 488,000!!! That's a 39.6% drop in the
actual data that had been previously reported. Know I know that most of the
problem is the fact they now require census tract reporting rather than zip
codes, but dropping like this does not help the industry as a whole.
    b.. Because of the low number of reported subscribers, the reporting by
technology portions of the report does not even earn fixed wireless a spot
on the charts in it's own category. It's lumped in with the 1.4% total of
all other technologies compared to the rest of the broadband industry. Hell
Satellite has their own category with .9%.
    c.. The total number of fixed wireless providers reporting is 617. That
means there are a huge number of WISP's not filing form 477 and those that
didn't report must have a large number of subscribers. The previous period
where fixed wireless had 808,000 subscribers had only 505 WISP's report!
Matt Larsen and the WISP directory have around 1,800 WISP's registered. I've
heard other estimates between 2,000 and over 4,000. Only 617 fixed wireless
operators reporting is not helping the cause at all.
    d.. The National broadband plan is being formulated as we speak, looking
at those statistics it appears the WISP industry is in a serious decline and
that as a total percentage of broadband provided to consumers nationally,
they make no significant difference.
  If you were a government policy maker, would you even pay attention to
WISP's. I certainly would not. They have to make decisions based on data and
that benefit the majority of the country. WISP's have thumbed their noses at
providing this data for years. I think it is really going to bite them in
the butt now. Fiber to the home is coming liking it or not. USF reform is
coming like it or not. USF reform is going to subsidize broadband to the
very markets wireless serves more economically today. Removing that
advantage is going to put the WISP industry in serious trouble.



  The manufacturers are killing themselves as well. In their quest to just
sell radios, they have missed the importance of keeping the industry
healthy. If the WISP's cannot compete and/or show that they are a
significant option to the overall broadband infrastructure in the US, how
will they continue to sell product. If anyone knows the true number of
WISP's out there it is the manufacturers. They should be leading the charge
with groups like WISPA to make sure ALL WISP's stand up and get counted. How
hard would it be to stuff each shipment with educational material on the
importance of filing form 477?



  The current FCC is very open minded but the results of this type of report
force them to make decisions that benefit the most people. 488,000 is a very
small portion of over 129 million homes.



  All I can say is ouch........



  Thank You,

  Brian Webster








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