Alvarion, Inc. is listed as a Reply Commenter.
Frank
----- Original Message -----
From: "Marlon K. Schafer" <[EMAIL PROTECTED]>
To: "WISPA General List" <wireless@wispa.org>
Sent: Sunday, February 25, 2007 2:35 PM
Subject: Re: [WISPA] Is it enough ?
Patrick, you've been awfully quiet on this one. What are Alvarion's
thoughts? Have you guys filed on this matter?
Tranzeo, same question....
Any other vendor members care to chime in here?
thanks,
marlon
----- Original Message -----
From: "Frank Muto" <[EMAIL PROTECTED]>
To: "WISPA General List" <wireless@wispa.org>
Sent: Sunday, February 25, 2007 11:25 AM
Subject: Re: [WISPA] Is it enough ?
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'" <wireless@wispa.org>
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.
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