Politics

The WISPs Respond

WISPs across the nation have filed comments with the FCC defending the interests of entrepreneurs.

[October 4, 2005]

Louisiana [.pdf]
Ladies and Gentlemen of the FCC,

I am inclined to believe that the TV spectrum that is slated to be abandoned could be of serious value to all WISPs across the U.S.A. I live in a super rural part of N. Louisiana and there are no TV stations for 100 miles (Jackson, Ms.) to my East, 40 miles (Monroe, La.) to my West, 100+ miles to the North (Little Rock, Ar.) and 100 miles to my (Alexandria, La.) South. This spectrum help WISPs like myself that serve a very rural and super under served area of the country. I have towers all over this area of N. Louisiana and still have hundreds of people who cannot receieve the signal that I am broadcasting in the 2.4 GHz and 900 MHz spectrum.

I feel it is a shame that such a promising spectrum could go up for auction and some individual with billions of dollars would come in and buy it up and then just sit on it like what is taking place now in the 700 MHz spectrum all across the country. The ability to hang gear and broadcast in a sub 700 MHz frequency would give everyone in N. Louisiana the ability to connect to high speed Internet whereas today the tremendous beautiful 90 foot oak trees soak up all signal we broadcast in the spectrum we are currently trapped in.

This TV spectrum would actually give many many small business owners like myself the opportunity to serve our markets with more positive results and more people served than ever in all history. The areas that I currently serve are about 90 percent no broadband available except my service, although I currently can't reach 60 percent of the residents where I do have towers due to foliage. This TV spectrum would make all the difference in the world to the majority of the citizens in all of N. Louisiana and across this great nation. There can be no other benefit as great as the results that would be accomplished within the first year of allowing WISPs' access to this under used and great spectrum. Please allow us to show you how we could utilize this spectrum and serve the greater good of all Americans. It is imperative that we are allowed use of this spectrum to serve millions of under served citizens today.

Sincerely, Mac Dearman
www.inetsouth.com
www.radioresponse.org (Katrina relief)
Rayville, La. 71269

Texas [.pdf]
I am part of the WISP community and am excited to see the FCC considering giving some of the Television frequencies to the wisp providers. In my area trees are causing a major obstacle to wisps. The frequencies that we are currently allowed to use are not enough to saturate the area. If the wisp community is allowed these new frequencies, they would be put to good use providing a much larger coverage area in the areas that are currently under served.

Thank you for your time,

Bryan Ponder, totalnet.us

Oregon [.pdf]
Applegate Broadband LLC 9522 Thompson Creek Road
Applegate, Ore. 97530

We serve the rural areas of Southern Oregon, with no broadband access other than satellite. Our service area terrain is rugged with lots of trees. Our main problem is LOS issues to communities that cannot get access from our WIPOPs. We have an large area (4000 square miles) right now that has a significant population with many residents contacting us over the last couple of years begging us to offer service. I cannot see how to make it work with the current frequencies available. There is no over the air TV coverage of any kind in this area, yet we do not have access to the same wasted white noise spectrum that would make it possible to offer broadband access in this rural community. If we had access to some 700 MHz spectrum with enough power, I'm confident that we could bring reliable and inexpensive broadband access to this community among others in our service area. As it stands, because of the limited LOS offered by other frequencies available, the cost of covering this area is not even close to economic, and all these people go without broadband service...meanwhile the 700 MHz band in this area goes on hosting nothing but background white noise, just like it has for decades. Please offer up some 700 MHz unlicensed spectrum for rural communities!

New York [.pdf]
Dear Sirs:

I wish to add my voice to the other WISP that have expressed a need for the use of spectrum in the 700 MHz range. I have all the usual problems deploying broadband service utilizing the available cluttered frequencies with all their challenges complicated by local zoning rules for antenna placement and everyday competition. I am sure you are aware of these existing conditions in the WISP community so I will leave those points to others to elaborate on.

My personal concern here the great North-East is the relationship of the laws of RF propagation, physics and trees. They are the greatest barriers to signal penetration and quality service in my area. Often the amount of equipment needed to obtain even marginal results is just not financially feasible, either for the customer or the provider. Often these are the little towns and villages that need our service the most.

To that point, I offer an example: This past month I have been involved in quoting and engineering a broadband connection to a small village of 440 low cost apartments, controlled by a Village Housing Authority. They have a program of "computers for kids" that goes out into the community and obtains computers for children in the complexes. The next step in this program is to make low cost broadband available to every one of those computers. All of the housing units are surrounded by trees and it is non line of sight between the groups of buildings. The combination of limited power allowed, spectrum available and project funding will give marginal coverage at best. There just isn't enough money for an access point on every building.

If I had a 700 MHz range frequency, I could cover a whole block with just a few transceivers and insure in-building penetration to the end users all at the same service layer. The broadband funds would go three times farther thus making services available to more people. It would be "more bang for the buck" and that is what we all need right about now. It would also eliminate the need for a intermediate linking layer to tie everything together that is an additional waste of spectrum and funds.

I offer this opinion weighted with 45 years of radio communications and RF experience. It amazes me to see the tenaciousness of this new breed of communications frontiersperson. They will "dumpster dive" for the tiniest bit of useable spectrum to serve their customers and do whatever engineering it takes at all hours to build their networks.

These young Wireless Pioneers are "chafing at the bit" to provide the services this country needs. Just give them the land (spectrum) they need and watch them innovate, build networks and build a stronger nation just as their forefathers did. I am sure you will do your part by being fair with allocations and I trust you will provide the needed tools. Respectfully,

David L. Vrablic
BlueBox Wireless "A LogicalNet Connection"
Albany, NY, 12205

Digital TV industry
For the opposition, see IEEE 802.22's submission [.pdf], a jargon laden document that says in part:

more order is required than "traditional Part 15 environment"—especially in bands where licensed incumbents exist

and claims that digital TV would require two channels of clear space on each side of every digital TV channel, if we're reading the statement accurately.

Our take
We believe that the long term benefit of public spectrum outweighs the short term budget boost gained through spectrum auction. If, however, the government is committed to auctioning the spectrum, we would advocate planning for the future by auctioning a term lease, of perhaps 20 years, rather than a permanent sale.

Although prospective buyers will argue that they will invest money to build a business in the spectrum, the buyers' fee, amortized annually, would be virtually zero in a permanent auction. If the total amount of money gained by the government is $20 billion, and the lease is for 20 years, then the entire digital TV broadcast industry would pay about $1 billion per year, about what the industry pays today for broadcasting a single major sport.

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