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Auctioning off the TV channels is not acceptable to us.

We are a rural WISP supplying 20,000 homes with ABSOLUTLY no other option.
These frequency are vital in the non line of site issues facing WISP today.
900MHz is simply not as effective as once thought.   Our biggest hurdle is
the natural, beautiful landscape that makes living in the country so
attractive. Our options to solve the problems are to put up towers. Trying
to put in more towers makes no sense as there could never be enough of them
to properly penetrate these vibrant green hillsides. We need the TV
frequency. The physics of the frequencies making up the over the air
television bands make them ideal for broadband deployment.

The goal in America is Fiber to the home. Weather it is physical fiber or
wireless fiber makes no difference, just put us on the same playing field.

WISP have proven their salt.  Most recently with the hurricane disasters
relief efforts, and having the ability to bring in, in some places, the
absolute only services (VOIP & Internet)to help locate and reunite the
devastated victims in the most trying of situations.
We are experienced, we are determined, we are professional. We are what make
up rural Americas connectivity. Hardworking entrepreneurial men and women
willing to do what big business would say does not make economic sense. 
We went into rural areas deemed unprofitable by the RBOC's. 
Are rural Americans just to sit back and let technology pass them by just
because of the location they choose live. We have shown it can be
accomplished effectively, efficiently and at a cost all can afford. 

Do not ties our hands, Help us help Rural America. Give WISPs these unused
television channels and we will get broadband access to every American near
and far.

Respectfully submitted,

Chuck Moses
High Desert Wireless Broadband communication LLC
Mojave CA

Chuck Moses
High Desert Wireless Broadband Communication
16922 Airport Blvd # 3
Mojave CA 93501
661 824 3431  office
818 406 6818  cell

-----Original Message-----
Behalf Of John Scrivner
Sent: Wednesday, September 28, 2005 10:01 PM
To: wireless@wispa.org
Subject: [WISPA] I need 100% participation RIGHT NOW! This means YOU!

If you are on other lists please forward this message to every 
unlicensed list you know of so we get 100% of this industry to do this 
PLEASE! This will take about 5 minutes of your time and it may make 
history for our industry.

The FCC has had an open Notice of Proposed Rulemaking" called 04-186 - 
Unlicensed Operation in the TV Broadcast Bands. They have tried to stall 
this proceeding out because the NAB - National Association of 
Broadcasters does not want anyone to use TV channels but them. In fact 
the NAB has even stooped to putting out propaganda in the form of a 
video docu-drama portrayal of a Grandma who cannot watch TV because the 
evil unlicensed operators were messing up her TV reception with their 
demonic unlicensed broadband operations (ok I embellished a bit).

Here is the deal. If we lose this fight it is not going to be over a 
lame video showing a grandma losing her TV stations from our efforts. I 
am gonna kick some NAB ass before I let that happen.


A from will appear magically in your web browser. Fill in the blanks 
with your contact information. Use the guide below for specific lines to 
help you with items you may not know how to fill in correctly.

1) Where it says "Proceeding" type in 04-186
2) For the "Mail Correspondence to" line click on "Name".
4) and 5) Leave Blank
11) Check "Late Filed" check box.
12) Select the drop down for "Statement for the Record"

The other lines not listed above are things like your name which I will 
assume you guys have covered. :-)

Then type your comments about why you need those TV channels for 
broadband. Give good reasons and do not argue with the FCC. Just tell 
them why you need the channels. Use good grammar, use correct spelling, 
be as good a writer as you can even if it is only one sentence. I want 
to see 500 comments from the WISP industry on this NPRM over the next 5 
days. Let's bury them in so many comments in support of this NPRM that 
the FCC cannot deny us this ruling.

Here are some thoughts that may help motivate you to do this right now:

How would you like to serve up broadband that operates in 100% of the 
proposed theoretical coverage area around your AP with no significant 
line of sight issues? How would you like to use common off the shelf 
cable modem type devices with minor modifications as CPE for these new 
magical APs? Then pay attention and do what I ask right now and do not 
try to micro-manage this effort. Just speak up right now! Today! Not 
tomorrow! We need solidarity on this one. Let's get it right and get the 
message out loud and clear right now.

Be prepared to hear negative comments about what I am proposing from 
WiMAX interests because they do not support all of what I am asking. We 
are not WiMAX radio builders. We are WISPs and we need TV channels right 
away before Uncle Sam pays billions to the RBOCs to circumvent what we 
are doing. This is the FCC plan if you do not act fast. The 120 day VOIP 
911 order was a clear message that WISPs are not going to have a level 
playing field in this current FCC administration in many cases. It is 
time for us to demand what we need to build our industry.

Auctioning off the TV channels is not acceptable to us. The FCC needs to 
hear it many many times if we are to have a chance at this effort. We 
need those TV channels offered up under the FCC 04-186 NPRM. Support it 
and let the FCC know why you support it. Tell them about your people who 
cannot get signal. Tell them about the unacceptable number of towers it 
takes to cover a few blocks in a heavily treed area using higher 
frequencies. Tell them how we could maintain higher density modulation 
schemes without fallback if the signal to noise ratios were more stable 
as we will have with TV channels. Tell them how spectrum is getting 
tight because of the massive growth of wireless broadband in your 
markets and about how unlicensed use of unused television channels will 
help this. Tell them we will prove that Grandma will never lose her TV 
signal with our systems regardless of the NAB "Sky is falling" 
mentality. Tell them this NOW!.

We are going to get 04-186 passed right now or we are going to force the 
FCC to go ahead and rule against us now while we are the people who 
brought communications online in gulf affected areas. We have the 
highest level of political equity we have ever had and I plan to use it 
while we can. It may well be our only chance to get this spectrum and we 
disparately need THIS SPECTRUM NOW.

When you submit your FCC "Statement for the Record" you will be the 
proud owner of an official web page confirmation ID which shows you have 
actually made a difference for your industry and you will feel like 
singing "America the Beautiful" while dancing around wearing nothing but 
a flat panel antenna like a fig leaf. You will also have good luck if 
you send a copy of your FCC comment confirmation to the lists to show 
others you have done your part. (Please do not send any photos of 
yourself wearing a flat panel antenna).

Here is my confirmation:

*The FCC Acknowledges Receipt of Comments From .
John Scrivner - Mt. Vernon. Net, Inc.
.and Thank You for Your Comments*

* Your Confirmation Number is: * '2005928723564 ' **

*Date Received:*        *Sep 28 2005 *
*Docket:*       *04-186 *
*Number of Files Transmitted: *         *1*

*This confirmation verifies that ECFS has received and accepted your 
filing. However, your filing will be rejected by ECFS if it contains 
macros, passwords, redlining, read-only formatting, a virus or automated 
links to source documents that is not included with your filing.
Filers are encouraged to retrieve and view their filing within 24 hours 
of receipt of this confirmation. For any problems contact the Help Desk at*

Here is my "Statement for the Record":

The role of telecommunications in the relief efforts after hurricane 
Katrina and Rita were critical and volunteer WISPs were the first 
responders to bring services online in many of the affected areas. There 
was such widespread devastation of critical communications 
infrastructure that many people did not have a means of communications 
at all. WISPs and related technology efforts worked feverishly to help 
bring VOIP telephone service, computers and Internet access to those in 
shelters and even aid workers and FEMA staff. This critical link to 
federal online resources, registration to online search databases and 
phone calls to loved ones, insurance companies, aid agencies and 
government resources helped thousands of people on the road to putting 
their lives back together. This work was done largely as volunteer 
efforts using donated equipment operating in unlicensed frequencies.

The 04-186 proceeding is important to this story because of one clear 
shortcoming that WISPs have to deal with every single day. WISPs do not 
have adequate spectrum to operate their networks as effectively as they 
could with television channel space. The bandspaces that have been set 
aside for unlicensed use until now have begun a frenzy of activity in 
telecommunications never before matched. Services, products and 
technologies have blossomed from the availability of unlicensed spectrum 
adding billions into the U.S. economy but the bands we have are not 
enough and the ability to penetrate through foliage or other obstruction 
at higher frequencies with lower power make these bands hard to operate 
in as effectively as we could with proper spectrum for broadband 
deployment. The physics of the frequencies making up the over the air 
television bands make them ideal for broadband deployment.

The end result of the WISP lack of access to usable bands with better 
propagation is that many who could have been served in gulf affected 
areas were not served at all, by anyone. Heavily treed areas or areas 
simply beyond the radio line of sight of the unlicensed bands we use 
made access to those who needed help difficult if not impossible in some 
cases. Sometimes those who were served took longer to get service 
because of the need to run extra equipment to overcome line of sight 
issues which led to delays.

The story is simple. If WISPs have access to unused unlicensed 
television bands the explosion of broadband alternatives will make 
efforts to bring communications into disaster relief areas a simple 
matter to address. There are thousands of small WISP operators who 
strive to be the broadband operator of choice for their small part of 
the country. These generally middle-class entrepreneur operators thrive 
in any environment, especially rural areas. We had several operators 
involved in the Katrina and Rita affected areas who were local WISP 
operators within the affected area they helped serve. They were some of 
the first people to help bring the telecommunications infrastructure 
back to life. WISPs are a good neighbor to have in disaster situations 
and they need unused television channel space to help.

Your average WISP operator could easily be thought of as an equivalent 
business to a new millennium family farmer. They just need a little 
ground (spectrum) to grow on. Selling off agricultural ground in large 
chunks to a mere handful of highest bidders instead of supporting the 
thousands of family farmers in the U.S. would be considered a foolish 
path but that is what is being contemplated with the unused television 

Middle-class backed operations cannot play in the auction game. We do 
not need a telecommunications industry made up of spectrum "haves" and 
"have nots". We need middle class spectrum policy. Making good spectrum 
available to unlicensed broadband operations is a good start and I 
support 04-186 as a step toward a spectrum middle-class that America so 
disparately needs to thrive and become the number one broadband adopting 
country in the world.

Give WISPs these unused television channels and we will get broadband 
access to every American in two years. I am confident we can accomplish 
this challenge in our industry.

John Scrivner
Mt. Vernon. Net, Inc.
WISPA Wireless List: wireless@wispa.org


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