Your Confirmation Number is:  '2005929275258 '
Date Received:  Sep 29 2005
Docket:         04-186
Number of Files Transmitted:    1 

-----Original Message-----
From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED] On Behalf Of info
Sent: Thursday, September 29, 2005 3:43 PM
To: WISPA General List
Cc: Lance Jahnke
Subject: RE: [WISPA] I need 100% participation RIGHT NOW! This means YOU!
Importance: High

Mark Williams
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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 YOU!


-----Original Message-----
From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED] On 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 

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 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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