In defense of WISPA and those who have previously filed, I do not think you
can state this as a last minute cause for response. This has been an ongoing
[beneficial] cause for the WISP. The 04-186 NPRM was first filed by the
FCC's OET on 5/13/2004 with a First Order & Report w/Further NPRM filed on
10/18/2006, not discounting the Notice of Inquiry (NOI) listed below.
If you look at the first NPRM and in the first paragraph(¶) towards the end
it states, "...allowing unlicensed operation in the TV bands could benefit
wireless internet service providers (WISPS) by improving the service range
of their existing operations, thereby allowing WISPS to reach new
customers."
My gosh, this is directly aimed at WISP's!
In addition to a Notice of Inquiry on 12/11/2002 - From footnote from the
1st NPRM - "See Notice of Inquiry in ET Docket No. 02-380, 17 FCC Rcd 25632
(2002). The Commission also sought comment on the possibility of allowing
unlicensed devices to operate in the 3650-3700 MHz band with only the
minimum restrictions necessary to prevent interference to authorized users
of the band. However, the matter of unlicensed operation in the 3650-3700
MHz band is now being addressed in a separate proceeding. See Notice of
Proposed Rule Making in ET Docket NO. 04-151, FCC 04-100 (re]. April
23,2004)."
In ¶ 10, of the 1st NPRM, you will notice that the FCC does acknowledge WISP
commenter's; "In addition, a number of WISPS filed comments expressing their
support for making spectrum in the TV bands available for unlicensed use.
These parties generally submit that use of TV frequencies could improve
signal coverage.(23)."
Footnote (23) - See, for example, Cliff LeBoeuf comments at 1, C. Crowley
comments at 1, David Blood comments at 1, A M Techtel Communications
comments at 2, John Hokenson comments at 1, Air Networking comments at 1,
Redline Communications at 5-6, Kevin Rice comments at I, Lakeland
Communication, Inc. comments at 1-2, Old Colorado city Communications at 6,
Mutual Data Services, Inc. comments at 1, New Gen Wireless, Inc. comments at
1, Big Tube Wireless, LLC comments at 1, Keith Schmidt comments at 1, Chase
3000 comments at 2, Jason Hunt comments at 1, R.W. Shepardson comments at 1,
David Lindley comments at 1, Eje Gustafsson comments at 1, Mark Worstall
comments at 1, Netrepid comments at 1, Mother Lode Internet comments at 1,
REC Networks comments at 1, Alvarion, Inc. comments at 1, Roy Preston
comments at 1, David Robertson comments at 1, Kerry Penland comments at 1,
Marlon K. Schafer comments at 1, and ScotI Sniven comments at 1.
Only 75 commenter's are listed as filing Comments to the 1st NPRM and 26
filing Reply Comments, see Appendix A.
Now, the FCC is using data from 1997 under the guidelines of the Regulatory
Flexibility Analysis (RFA), See Appendix C.
The RFA directs agencies to provide a description of, and, where feasible,
an estimate of the number of small entities that may be affected by the
proposed rules, if adopted.m The RFA defines the term "small entity" as
having the same meaning as the terms "small business," "small organization,"
and "small business concern" under Section 3 of the Small Business Act.m
Under the Small Business Act, a "small business concern" is one that: (1) is
independently owned and operated; (2) is not dominant in its field of
operations; and (3) meets may additional criteria established by the Small
Business Administration (SBA).
Appendix C Section A. paragraph 2 of the RFA states in the behalf of WISP's;
"These proposals, if adopted, will prove beneficial to manufacturers and
users of unlicensed technology, including those who provide services to
rural communities. Specifically, we note that a growing number of wireless
internet service providers (WISPS) are using unlicensed devices within
wireless networks to serve the needs of consumers. WISPS around the country
are providing an alternative high-speed connection in areas where cable or
DSL services have been slow to arrive. The additional frequency bands where
operation is proposed will help to foster a viable last mile solution for
delivering Internet services, other data applications, or even video and
voice services to underserved, rural, or isolated communities. In addition,
TV frequencies, which are below 900 MHZ, have less signal attenuation
through foliage and walls than frequencies above 900 MHz currently used by
WISPS, thus affording improved signal coverage."
DO you not think this is this worth the time to state your OWN case and
those of others in the WISP industry? The FCC is giving the WISP industry a
huge OPPORTUNITY to speak their peace and step up to the plate and be heard.
This FCC OET NPRM is asking for your input directly and specifically.
Frank Muto
Co-founder - Washington Bureau for ISP Advocacy - WBIA
----- Original Message -----
From: "Rick Smith" <[EMAIL PROTECTED]>
maybe WISPA needs to be describing these better, in advance as opposed to
the last minute...
if all our comments were the FIRST posted, wouldn't that look better?
What's out there that we should be looking at NOW as opposed to later...
-----Original Message-----
From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED] On
Behalf Of Marlon K. Schafer
Sent: Saturday, February 24, 2007 9:32 PM
To: WISPA General List
Subject: Re: [WISPA] Is it enough ?
The cut and paste is ok, but that's just more junk for people to read.
The
FCC has told me that the association needs to file, but that should also
be
backed up with individual filings. Even if it's just to say that you
agree.
What I wish is that more people knew the issue better so that they could
file on their own in their own words.....
laters,
marlon
----- Original Message -----
From: "Rick Smith" <[EMAIL PROTECTED]>
To: "'WISPA General List'" <[email protected]>
Sent: Saturday, February 24, 2007 1:10 PM
Subject: [WISPA] Is it enough ?
Other people in 04-186 are posting fully written positions.
Other WISPs are just filing "I agree with WISPA..." comments.
I don't think that's enough! I think, AT THE WORST, that you should cut
and
paste WISPA's filing if that's what you agree with.
At the LEAST fully state your position!
We look like easily corralled cows following the leader into the corner.
--
WISPA Wireless List: [email protected]
Subscribe/Unsubscribe:
http://lists.wispa.org/mailman/listinfo/wireless
Archives: http://lists.wispa.org/pipermail/wireless/
