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-----Original Message-----
Behalf Of Rick Herrmann
Sent: Thursday, September 29, 2005 10:26 AM
To: 'WISPA General List'
Subject: RE: [WISPA] I need 100% participation RIGHT NOW! This means


-----Original Message-----
Behalf Of John Scrivner
Sent: Thursday, September 29, 2005 12:01 AM
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.
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