Larry Yunker wrote:

John,

I'm certainly not arguing against WISP compliance with the reporting
requirement. Rather, I'm trying to clarify WISPA's interest in identifying
WISPs across the nation.

Where have we asked to "identify" WISPs at all? I am not looking to "identify" WISPs. I do get asked all the time by regulators, legislators, press, investors, etc. how many WISPs there are and how much of the US we serve. I cannot give a qualified answer. Nobody can because many WISPs won't file their 477s. How can I answer this question when people will not stand and be counted?


It sounds to me that you are looking at this from
the prospective of a lobbying effort. If we can show more WISPs then we can
show more need and thus can obtain more ... (spectrum, assistance,
allowances, etc.)  These are seem to be legitimate reasons

It is 100% why I am pushing for WISPs to comply. That and it is the law of the land for US WISPs.



If WISPA can identify WISPs across the nation, then how can WISPA convince
WISPs to self-report?

All we can do is try to promote the importance of filling out these reports. After that it is up to the WISP themselves to decide. It is out of my hands beyond that.

  Is WISPA planning to use strong-arm tactics (report
or we'll report you) or is WISPA hoping to just inform WISPs of their
federal obligations and hope for the best?

I have never pushed for strong-arm anything and will not start now. This would be a serious step over the line of trying to build the large representative scale we want to see in WISPA. We are not the police. We are a group of operators and others who want to help promote and improve the industry. That is straight from the by-laws.

The FCC can use a spectrum analyzer and drive around for one hour and find a WISP who wants to hide his head in the sand. It is not like they are invisible. As one of the FCC reps said in our last meeting, "We could bust a couple of them and the rest will fall in line" (paraphrasing a bit). I do not think WISPA will be any more effective than what the FCC could be with a couple of site visits. That is really up to them. They certainly have the resources to do that. They have several thousand times more resources and power at their disposal than WISPA does to handle this issue. If it is important enough to them then they can get WISPs to fall in line. The ironic thing is that WISPs are truly only hurting themselves if they think they can ignore this requirement. I doubt the FCC will push for compliance and then WISPs will become less and less represented in future legislation and policy because of their own lack of interest in letting the government know what impact they are making in delivering broadband. I am open for suggestions for ways to get the word out. Strong arm is not really an option though. I still see this as a free country and strong-arm anything is not really part of my makeup.

  Is there some other method that
would lead to greater compliance without making WISPA look a private
attorney-general?

We can only act as leaders by example in my opinion. I like to think that most of the time that people in this industry look to WISPA and our members as those who represent the best interests of our industry. We want to see our customers numbers represented more accurately in order to gain more justification for spectrum and policy reform for our industry. If we cannot prove we are serving the public interest then we cannot expect the public to represent our interests. FCC Form 477 is the most important tool we have in proving we are serving the public good.

If you have an idea then please share it. I think we have been very vocal that this form is important to the future representation of our interests in D.C. If WISPs do not act on this they are hurting themselves. I do not think anything else could be presented to a WISP which would make this point any more clear.
Scriv


Larry Yunker




----- Original Message ----- From: "John Scrivner" <[EMAIL PROTECTED]>
To: "WISPA General List" <[email protected]>
Sent: Sunday, February 18, 2007 3:14 PM
Subject: Re: [WISPA] wisp survey


The FCC has given some unlicensed spectrum, in part, to help make lower cost access and more access to broadband available in the US. Future access to more of this unlicensed spectrum will require some accountability by the FCC that unlicensed spectrum is helping to serve that purpose. By not filing we show less impact toward filling the "digital divide" and we are indirectly helping to justify criticism by others that unlicensed spectrum is not effectively serving the public interest in regard to broadband availability. Filling out the forms would help us to ask for and receive more spectrum and policy relief when needed in order to continue to advance the public interests of more access and lower cost access to broadband in the US. As of now Form 477 results show WISPs as serving less than 1% of the public with broadband. This is artificially low due to non-compliance by WISPs to fill out their forms.

How can the FCC justify helping WISP interests if we cannot even show what we are doing to deliver broadband using the spectrum we have been given? How would the FCC helping us, in turn, help the public interest if there is no accountability that we are helping to serve the public interest? They (the FCC) are absolutely justified in their desire to see more WISPs fill out these forms and we should be complying with this. It is not a "big brother" issue at all. Form 477 is there to justify our representation in policy initiatives that we need to survive.

One other issue is that it is a matter of the law. We are required to comply.
Scriv


Larry Yunker wrote:

Marlon,

I understand that the vast majority of WISPs have chosen not to file the 477 form (or in the alternative they just don't know that they are supposed to file).

Just out of curiousity, what do you hope to accomplish by locating the thousands of non-compliant WISPs? Are you hoping to use this as-of-yet unidentified mass to evidence the difficulty of meeting the standard, or are you hoping to convince those non-compliant WISPs to join WISPA in its efforts to develop a workable standard? or are you just hoping to prove out the estimates that you have already provided to the FCC? Or is there some other driving force?

Larry Yunker


----- Original Message ----- From: "Marlon K. Schafer" <[EMAIL PROTECTED]>
To: "Principal WISPA Member List" <[EMAIL PROTECTED]>
Cc: "WISPA General List" <[email protected]>
Sent: Sunday, February 18, 2007 10:43 AM
Subject: [WISPA] wisp survey


Hi All,

OK, we're not going to get most wisps to fill out the 477 any time soon. At least it's historically looking that way.

2 years ago I brow beat the major vendors and manufacturers into giving me the number of wisps that they show on the books and/or radios sold into the US market in the last 4 years.

That effort lead to the belief that there are a genuine uncontestable 3000 wisps in this country with a minimum of 1,000,000 subscribers. Numbers that the FCC folks still use today as being more accurate than the 477.

Does anyone know of a research group that we could hire to repeat my efforts in the past. Something that might be more effective yet? There has to be a better way to do this than the 477.

Any ideas on the costs to do this project? Should we even put any effort into it?

Could this be done by a group of scholars at a college?

Looking back on the data that I'd gotten at the time and how I calculated things, I think that the real number of wisps was likely closer to 6000. Today my gut tells me that that number is up by 25ish % and that the customers serviced is likely at least double what it was back in late 2004. I know MY customer base has more than doubled since that time.

thoughts?
marlon

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