Well done, Forbes.

Forbes Mercy wrote:
Ouch did I really say "embarrassed" instead of embraced" I really should proof this thing better, a few hanging sentences and other grammar goofs. Oh well I did with what time I had so everyone else please don't suggest my need for English 101.

I kind of gutted your letter and changed it to one that acts a little more like 
it's from an organization then a person.  Please don't take offense and feel 
free to change it.  As you have explained to me, stepping back and looking at 
it from another person's eyes sometimes gets the same effect with a little 
calmer face.

Forbes Mercy

President - Washington Broadband, Inc.

Dear Sirs,

I represent the Wireless Internet Service Providers Association (WISPA) an 
organization which has worked closely with the Federal Communications 
Commission (FCC) for many years.  As you know we consist purely of WISP owners 
and have been pleased with the open ear provided by the FCC in our numerous 
opportunities for testimony and individual meetings.  These meetings have 
resulted in a very fair and generous application of unlicensed frequencies.  We 
feel that not only our industry has benefitted but many other applications have 
been invented providing American consumers new services, competition and 
pricing that helps keep inflation in check and advanced services accessible to 
all income levels.

One of our agenda issues has been active inclusion in the use of the 700 MHZ frequencies 
known as "TV White Space".  The ability to have a product that actually covers 
distance through vegetation is very exciting.   We have battled the upper frequencies 
short range and low power but also have provided innovative services to the most rural 
areas.  This is a testiment to the vision of the FCC with your successful experiment 
giving Americans unlicensed space just to see if we can succeed, we did and because of it 
are very grateful.

We have considered the 700 MHZ space as the ultimate application for rural development and wish to convey some concerns over the preliminary specifications submitted. Our examples of this would be: 33' minimum antenna heights, pre-programmed exclusion zones, with no accounting for LOCAL terrain or foliage. As you know provision of Wireless has little similarity with Radio Station methods of engineering and implementation. The specifications become even more focused with the suggested geolocation of every Customer Premise Equipment (CPE) device. These proposeals could eliminate 90% of the customers and easily as many WISP's from using this band.
Very few people will be able to justify the  $500 (probably closer to $1000) 
installation costs of these systems.  We had hoped for an in-house antenna 
system that does not require outdoor antennas which are confusing to renting 
land owners and asthestically challanging to homeowners.  It redirects costs 
from a 'take home and plug in' service to a much higher model of 'a truck run 
for every install' scenario.   Most of our operators have been pleased with the 
prospect of eliminating roll-up antennas, the high cost and hazard of roof-top 
work and the difficulty of employing installers, it triples the costs of 
operation and those funds, which could be used for more deployments, instead 
goes to unnecessary infrastructure and is passed on as higher costs to all 
income level Americans.

WISPA feels there is no need for the outdoor only, or minimum antenna height 
requirement.   We feel that the local interference issues have been dealt with 
professionally in our existing bands and the minimal abuse has been well 
documented by the FCC.  Low signal strength have been built into your standard 
for the incumbent detection mechanism.

Of course we acknowledge the pressure from the TV Broadcasting organizations to 
have more stringent standards due to the proximity to their systems therefore a 
beacon system in which any cpe would be acceptible to identify the owner of the 
ap for faster recitification of problems should one occur.  This uses the 
innovation we have embrassed and the costs will assure that any problem, albiet 
unlikely, can be quickly qwelled locally.  This resolves our need for GPS units 
and other expensive testing equipment not available to all providers.  It also 
eliminates the need for dual antennas and GPS's for each customer CPE, another 
expensive requirement not required of any other commercial or unlicensed 

Because of the need for some control to satisfy broadcasters the spectrum needs 
to be unlicensed with registration required with the FCC.   Again we reiterate 
the need for inexpensive access to deploy thus hope any registration would be 
within reason.   The innovation we have provided meets the President's goal of 
rural deployment without need for public funds and provides local 
responsiveness and competition that forces National providers to keep costs 

As we have been in the past, the Wireless Internet Service Provider's 
Association will be happy to help with how this new standard will 'meet the 
road' as we have since the inception of the unlicensed process.  Our emphasis 
has always been on economical deployment and exclusion in favor of high profit 
driven corporations continue to hurt deployment.  the individual owners of our 
companies use the time honored American tradition of 'a good product at a 
reasonable price' with emphasis on local ownership.  This is far from the 
motivation from stock owned large corporations where service and selection is 
based on rapid return of investment and not on innovation or rural (sparce) 
area deployment.

Our industry has plenty of high margin products to choose from already.  
Backhaul products are stable and plentiful.
Everything from wireless, to copper to fiber is an option in the right conditions. Our industry's only real gap is in medium speed cheap products that will go through walls and trees etc., and the 700 MHZ meets that goal. We continue to value our close relationship with the FCC and are pleased that public service organizations still think of the public first. As an organization of small business owners we look forward to proper deployment of this frequency and recognition of the responsible manner we have deployed more restrictive bands to expand and serve the public.
Thank you for you time,

Marlon K. Schafer
WISPA FCC committee chairman
(509) 982-2181                                   Equipment sales
(408) 907-6910 (Vonage)                    Consulting services
42846865 (icq)                                    And I run my own wisp!

WISPA Wireless List: wireless@wispa.org


Archives: http://lists.wispa.org/pipermail/wireless/

Scott Reed
Wireless Networking
Network Design, Installation and Administration

WISPA Wireless List: wireless@wispa.org


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