There is a clear difference in what CL professes to be true, than what is

I am glad to jump on any bandwagon to disprove these hubris statements.

And I, personally, will be happy to support any endeavor to demolish these
accusations that have been laid at the WISPA doorstep.


I thank you for your confidence in my logic.  

I am just an old Missouri gal, and call it as I see it.



Victoria Proffer




From: Fred Goldstein [] 
Sent: Friday, June 29, 2012 8:50 PM
To:; WISPA General List
Subject: Re: [WISPA] Happy Independence Day!


At 6/29/2012 09:36 PM, Victoria Proffer wrote:

For those who may have missed it, the petition is here:
I am sorry if I don't get this right Fred, but I don't believe this is the
petition, rather than it is the complaint.
Is that correct?

It is their "Petition for Waiver".  It is basically a complaint, but since
WISPs are not licensees, and the WISPs haven't actually done anything wrong,
they cannot file a real complaint against them.  Instead they are
petitioning to have WISPs ignored in CAF Phase I.

However, it is accompanied by a number of Exhibits which deserve attention
too.  To see it, go to the FCC's e-filing page, then ECFS, and search for
"CenturyLink" as the filer and "petition for waiver" as the type.  You'll
see that this was filed in a whole bunch of Dockets.  

They pulled a bunch of WISPs' coverage maps off of the NBM and decided that
they were "implausible".  Now a few are sort of sloppy, basically simple
radii.  CL claims that radio coverage never fits a perfect circle due to
terrain and they are close to correct there.  However, some WISP maps may
simply stop at 10 miles even if they can go farther.  They also rule any
WISP implausible if its coverage area is more than 10 miles wide.  They
simply assume that a WISP has exactly one tower, so any bigger coverage must
be a lie!  I note that some of the maps look like they were generated by
RadioMobile.  But they were fed into the state mapping entity as part of the
NBM project. The state maps in turn tend to be normalized to census blocks
or even larger areas.  So the map is not identical to the RadioMobile
coverage prediction or for that matter any real coverage.  This is an
artifact of the NBM, not the WISPs' own doing.  The map exaggerates CL's
coverage too, the same way.  DSL touching a census block makes that whole
block look covered.

And let me state on a side note ... your interjections in WISPA business, in
my opinion, is extremely valued!
There have been several times that you have broken a complex problem down to
common sense.  Thank you.

Thank you! 

Victoria Proffer
From: [
<> ] On Behalf Of Fred Goldstein
Sent: Friday, June 29, 2012 8:21 PM
To: WISPA General List
Subject: Re: [WISPA] Happy Independence Day!
At 6/29/2012 08:45 PM, Victoria Proffer wrote:

In my years in this industry, it is clear that some fail, as well as some
become a sterling example of what I consider my industry is primarily made
of, girt, fortitude, honesty, common sense, gumption, imaginativeness (check
it out, it is a word =), resourcefulness ... oh well, you get the picture =)
With that said, I have to make my comment.  
It is one as an individual and not necessarily representing the views of the
board of directors.
The Century Link FCC filing is a direct attack on our industry and what our,
sometimes small, enterprises stand for.  
The Century Link filing, in my opinion and it has been mentioned, a clear
sign of weakness on their part and shows their dependency on .gov subsidies.
In this aspect is a victory for WISPA!  
Yet it is slanderous document that WISPA and the individuals accused must
As an elected member of the WISPA board of directors, I can assure you that
the board is addressing these issues and considers this a priority.

For those who may have missed it, the petition is here:

Century Telephone Enterprises, by whatever name it's using, has always been
the worst of the worst.  My nickname for them is "The Devil Incarnate".
These are the folks who, facing a modem pool owned by a tiny carrier during
the dial-up years, simply refused to pass calls to that carrier as "local",
even though the rate center was local.  Utterly sleazy. 

Their petition is indeed slanderous, basically claiming that WISPs can't
offer as good a service as they can, and demanding that the FCC treat all
WISPs like satellite providers.  This would let CenturyLink take Phase I CAF
funding of $775/subscriber to overbuild WISPs.

To show how ridiculous this is, just turn it around.  What could you, as a
WISP, do with a gift of $775 in capital per subscriber?  Yeah, a lot more
than they can.  That's a lot of money to a WISP, but bupkis to a subsidy
whore like Century.

I look forward to the Board's response, and if the Petition is open to
Comment from others, it deserves a serious blasting.

 Fred Goldstein    k1io   fgoldstein "at"   
 ionary Consulting       
 +1 617 795 2701
Wireless mailing list

 Fred Goldstein    k1io   fgoldstein "at"   
 ionary Consulting       
 +1 617 795 2701

Wireless mailing list

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