I have replied.
Your Confirmation Number is: '2005929437138 '
Date Received: Sep 29 2005
Docket: 04-186
Number of Files Transmitted: 1

As a WISP serving rural Indiana, our biggest problem with providing 100% coverage to our potential customers is trees.  We are currently turning down about 55% of our requests due to inadequate signal to provide reliable high speed Internet.  Since the lower frequencies penetrate foliage better than the higher frequencies, I believe we would be able to reach as many as 90% of those that request service, were we to deploy lower frequencies, such as in the 700MHz area.


We also have problems with the current 2.4Ghz band we use being very crowded.  The signal to noise ratio gets to the point of making the band unusable in some areas.  Having a frequency band allocated just to wireless Internet would alleviate this problems, not just for us, but also for the general consumer who is also trying to use devices in this range.  By letting us get out of the range, there would be less congestion for others.


As a “mom & pop” business, we cannot afford to purchase spectrum at auction.  What we can do, just as small businesses all around our great country do, is offer services to those areas that no one else services.  None of our current customers has any ground-based Broadband Internet service available to them other then NewWays.  Their gratitude is part of what makes our business grow.  Please provide us (the WISP industry) with some dedicated spectrum that is available based on the services we provide rather than the money we have.

Scott Reed
Wireless Networking
Network Design, Installation and Administration

---------- Original Message -----------
From: John Scrivner <[EMAIL PROTECTED]>
To: wireless@wispa.org
Sent: Thu, 29 Sep 2005 00:01:09 -0500
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.
> http://gullfoss2.fcc.gov/prod/ecfs/upload_v2.cgi
> 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:
> [WINDOWS-1252?]*The FCC Acknowledges Receipt of Comments From …
> John Scrivner - Mt. Vernon. Net, Inc.
> [WINDOWS-1252?]…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
> spectrum.
> 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.
> --
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