I would strike the "only 50 MHz of spectrum" statement about 3650. The
industry has paid billions for way less. The answer is using spectrally
efficient systems with what we get for free.......





-----Original Message-----
From: Marlon K. Schafer (509) 982-2181 [mailto:[EMAIL PROTECTED]
Sent: Tuesday, March 28, 2006 12:02 PM
To: wireless@wispa.org
Cc: isp-wireless@isp-wireless.com
Subject: [WISPA] Fw: [Board] Television Whitespaces Position Paper -
Version 2


Hi All,

Barring something that you guys see that we've missed this will be sent to 
the commerce committee folks.  For those that don't know there are a couple 
of bills in Congress at this time that deal with this issue.

As I can't send an attachment to the isp list I'll put the text here:





Monday, March 27, 2006




WISPA TV White Spaces Position Paper




WISPA is the WISP industry's only industry owned and operated trade 
association. We're a 501c6 corporation with a 7 person, membership elected 
board.




We believe that the FCC's Broadband Access Task Force had it right in saying

that there should be more unlicensed spectrum made available. The 5.4 GHz 
band is a good start, it's got some severe power level limitations though. 
It also only works in areas where there is clear line of sight which means 
it will not work well to deliver service to customers directly in locations 
where there are trees, buildings or other obstructions between a service 
tower and a potential customer. For these areas we require sub- 1 GHz 
frequencies exactly like that which can be delivered by unused television 
channel space. As of this writing 5.4 GHz is not allowed for use legally in 
the United States. The new 3650 MHz band is also currently in a state of 
limbo. And even when opened up it's got huge exclusion zones and is only 50 
MHz of spectrum. In short the unlicensed broadband industry needs help to be

able to adequately serve the millions of potential broadband customers we 
have to say no to every day because we do not have spectrum that can 
penetrate trees and other obstructions. This is a problem which accounts for

60% or more potential customers being told no when they ask for service in 
areas where unlicensed broadband services are currently being delivered. The

remedy to this is clear. The Senate Commerce Committee can make this 
obstacle go away by simply tasking the FCC with passing their own proposed 
rulemaking number 04-186. This will allow 100% of potential service areas to

be served with high quality broadband in all corners of this country. Even 
the most rural areas can be served cost effectively if we have access to 
unlicensed use of unused television channels. Please help us help America 
regain our technological leadership role in the world by giving us access to

these channels to allow broadband for all citizens today.




At this time there are somewhere in the area of 28,000 licenses relating to 
spectrum use in the USA. In fact, almost all spectrum is licensed today. The

basic licensing of spectrum is mostly unchanged in nearly a century now. 
Certainly there are some changes, the recent ITFS changes are a good 
example, but the basic principal has not changed.




Technology has changed. Spectrum policy rules should reflect what's possible

today, not what was possible 70 years ago.




Today there are already high speed wireless data systems on the market that 
measure their environment and change channels to avoid interference. There 
are also systems that measure the signal needed between two points and 
adjust power levels accordingly. The 04-186 rulemaking we are asking for 
requires these technological features in any system using unused television 
channels to make sure that no harm is done now or in the future to licensed 
users of these channels. Grandma will never miss a television program from 
an unlicensed radio on her channel. It is not going to happen. The standards

in the 04-186 rulemaking stipulate that no device will interfere with any 
licensed use of the television channel space under any circumstances. WISPs 
have every intention of making full use of any of these unused television 
channels as soon as possible for broadband delivery and we will make sure we

do no harm.




The United States of America will have to make use of sub - 1 GHz spectrum 
to make broadband available to all citizens in a cost effective and timely 
fashion. In fact, use of unused television channels is the only logical path

that delivers the promise of ubiquitous low-cost broadband to all Americans.

Without access to this spectrum the United States will continue to fall 
behind the rest of the world. It would be a shame for the country that 
invented Internet to allow themselves to fall behind in bringing this 
miracle of modern communications to every citizen.




Nearly half of all available television channels are left unused even in the

top markets of the United States. In the rural areas the available channels 
are largely unused for any purpose. Even channels that are utilized in a 
given market are usually received by viewers via cable or satellite, 
negating the importance of the use of the spectrum for over the air 
television reception. Over the air television is now little more than a 
glorified licensing database system where licenses are used more to lock a 
market area for an operator than they are to serve viewer's needs. The 
reality is that estimates show that as little as 5% of US households receive

their television through the air. It is becoming apparent that broadband 
will become the number one benefit to the US population regarding the use of

these bands. The right way to make use of these bands is for the Commerce 
Committee to task the FCC to now pass their 04-186 rulemaking without delay.




Waiting for auctions until after the DTV transition will further stymie 
growth and availability of broadband to our citizens. Auctions stifle 
innovation and timeliness of availability of services. Why should we have a 
large minimum purchase price for licenses over a large geography while at 
the same time looking at ways of stimulating broadband deployment with 
grants and other initiatives? This system actually slows the adoption of the

technology by entrepreneurs. Unlicensed use of the bands can happen now and 
stimulates broadband deployment now. The 04-186 rulemaking states that any 
broadband device using unlicensed spectrum in the television bands has to 
change channels in the presence of a licensed user. This means that even 
launching now before the DTV transition is complete has no chance of harming

the license holders. Equipment will be required to avoid interfering with 
these license holders.




It is very common to see cable and DSL deployed in communities once a WISP 
operator launches service. This shows that the competitive pressures from 
unlicensed broadband are good for the customer and that this will inevitably

lead to more choice and better options for broadband even in rural areas. 
The access to unlicensed use of television channels for broadband 
strengthens the competitive access to broadband and will aid the competitive

process for better broadband opportunity for all Americans.




WISPs by the thousands are out there serving rural AND urban America today. 
The explosive growth of unlicensed wireless broadband is leading to a 
shortage of available frequencies. There is a constant drive by the industry

to do more with less. It is time for Congress to tell the FCC to give us 
more and better quality spectrum to be able to more effectively serve the 
broadband needs of all Americans.




Congress should direct the FCC to pass the 04-186 rulemaking now as it is 
written. The rulemaking has completed the entire public process and all 
issues have been addressed with the result being a complete solution for 
access to the spectrum needed to bring broadband to all citizens of this 
country. The 04-186 rulemaking addresses the concerns of the television 
industry adequately and there is no reason to delay this proceeding any 
further. Waiting for the DTV transition dos not alleviate unfounded fears 
perpetuated by the television broadcast industry. The time to make this 
monumental step toward a more viable broadband future for the United States 
is now through passage of a law to enact the 04-186 rulemaking of the 
Federal Communications Commission.




Sincerely,

Marlon K. Schafer John Scrivner

FCC Committee Chairman President

(509) 982-2181 618-237-2387 cell

(509) 988-0260 cell




Founding Board Members

WISPA


laters,
Marlon
(509) 982-2181                                   Equipment sales
(408) 907-6910 (Vonage)                    Consulting services
42846865 (icq)                                    And I run my own wisp!
64.146.146.12 (net meeting)
www.odessaoffice.com/wireless
www.odessaoffice.com/marlon/cam



----- Original Message ----- 
From: "John Scrivner" <[EMAIL PROTECTED]>
To: <[EMAIL PROTECTED]>; <[EMAIL PROTECTED]>
Sent: Monday, March 27, 2006 10:10 PM
Subject: [Board] Television Whitespaces Position Paper - Version 2


>I made a few revisions to this document including some grammatical and
> content changes. Please proof and give feedback if other changes are 
> needed.
> Thanks,
> Scriv
>
>


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