I have little need of more microwave spectrum. I need spectrum in the
low UHF or high VHF bands to get thru these trees.
I think many, if not most, rural WISP's would agree with me.
AOL IM Screen Name -- Theory240
West Michigan Wireless ISP
A division of:
Camp Communication Services, INC
Marlon K. Schafer (509) 982-2181 wrote:
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
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.
Marlon K. Schafer John Scrivner
FCC Committee Chairman President
(509) 982-2181 618-237-2387 cell
(509) 988-0260 cell
Founding Board Members
(509) 982-2181 Equipment sales
(408) 907-6910 (Vonage) Consulting services
42846865 (icq) And I run my own wisp!
220.127.116.11 (net meeting)
----- 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
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