signatureFact of the matter is, Geocoding an address to a set of coordinates
has always been an inaccurate process. As Matt stated, in areas where they
have not done 911 Addressing, there is no real way to place an address in
the proper spot. Even with 911 address data it will only plot the location
to the proper section of road frontage, not on the actual structure. Then
you have the issues of garbage 911 data or garbage Census data in the Tiger
files. Don't get me started on how the tracts in many cases are even larger
areas than the zip code ZCTA polygons for rural markets.

It's very difficult when there are policy decisions made for mapping and GIS
processes by people who really don't understand the full ramifications and
limitations of the systems.

Matt and others reading this post. I would not spend a great deal of time
worrying about the accuracy of the tract data. The polygons are so much
larger in most areas of the rural markets, you aren't going to give the FCC
and other data crunchers any better information than they had with zip codes
in the first place.

The real flaw in what they are doing is the all or nothing approach to
showing a Zip or Tract served. Rather than allowing just one reported
subscriber to show it served, they should be showing a percentage of the
area served. They have the number of households served in each polygon
(either by Zip or Tract). They also can total the number of households by
zip or tract. A simple division of the total subscribers by total households
can show the percentage served. THAT would be a much better data set than
all other methods they are trying today. While it won't show exactly where
the service is, they would have a better idea of how to set a percentage
served threshold for which to fund the grant applications.

They can do this TODAY and move forward. It amazes me how sometimes things
like simple math can't be applied to solve problems :-)



Thank You,
Brian Webster
www.wirelessmapping.com
  -----Original Message-----
  From: motorola-boun...@wispa.org [mailto:motorola-boun...@wispa.org]on
Behalf Of Martha Huizenga
  Sent: Wednesday, May 06, 2009 12:59 PM
  To: WISPA General List
  Cc: w...@part-15.org; Motorola Canopy User Group
  Subject: Re: [Motorola II] [WISPA] Response to the FCC Regarding Form 477


  Hi Matt,

  This was a great note to the FCC! Well done. This doesn't help me, since I
am an urban WISP, but my guess is that as you stated a lot of rural WISPs
either had this problem and knew it and just decided to file inaccurate data
or didn't know the data was inaccurate.

  It certainly should help the FCC to know that they chose a parameter that
wasn't as easy as they stated (here is a list of vendors for Geocoding info
: ). I know I had to do mine by hand and contemplated just picking a few
tracts to enter for all my customers, which would have been very inaccurate.

  Martha

  Martha Huizenga
  DC Access, LLC
  202-546-5898
  Friendly, Local, Affordable, Internet!
  Connecting the Capitol Hill Community





  Matt Larsen - Lists wrote:
I thought I would share this email that I just sent to the FCC regarding
the Form 477 report. I am late filing this report because we don't have
accurate data and thought that my reasons why were worth sharing with my
colleagues. I support what the FCC is trying to do with Form477, but was
not able to in good conscience turn in our data by the report deadline.

I hope that this is valuable to some of you out there.

Matt Larsen
vistabeam.com

---

Hi Suzanne,

I am not really in a position where I can give a projected date to have
this information completed for you. However, I do feel it would be
valuable to explain why and provide you and your management some more
information as to why I am unable to give you a better date on when we
intend to have it completed.

For background, Vistabeam (Inventive Wireless of Nebraska) is a wireless
ISP that covers about 40,000 square miles in Nebraska and Wyoming. We
have around 2000 customers spread out across this very thinly populated
area. Even though we are quite small in customer number compared to
other ISPs, we have a very good billing and provisioning system and
quite a bit of detail on our customers. However, we did not have census
tract information for our customers as there had never been a need for
it until the latest Form477 notice came out earlier this year.

Once we received the Form477 notice, we made plans to modify our billing
system to add the census tract information, which we were successful in
doing. We also studied how to obtain geocoding information from multiple
sources and how to integrate this into our database so that we could
complete the report. Our initial integration seemed to be successful
until we started to look at the geocoding data that we received and
realized that over 50% of the census tract information was invalid.

After going through this data, we found that many of the addresses we
have for customers are simply not being processed and located correctly.
The majority of our customers are in rural areas with references to “CR”
and “Road xxx” and other rural address forms that the geocoding engines
simply cannot process. Many of these rural counties do not have GIS
departments with the ability to provide the geocoding information for
these addresses. In the event that the address doesn’t code, the
geocoding engine returns the census tract information for the nearest
Post Office, which is not in the correct census tract.

To get the correct information, we basically have two options.

Option #1 is to drive out to every customer with a GPS unit and record
the information into our system. Since we have approximately 1100
customers with inaccurate information, this is going to be a time
consuming process and would cost us several thousand dollars to collect
– not to mention the lost man hours.

Option #2 is to go through each customer record and use Google Earth and
the driving directions to each customer location to determine the census
tract. This takes about five minutes per customer record, so we are
looking at about 92 man hours to get that data assembled and inserted
into our customer database.

We have chosen to go with Option #2 to collect the invalid census tract
data. However, I do not have the manpower to devote dedicated time to
this data collection so we have distributed this project among several
employees and are making as much progress as we can when our workflow
allows for it. After a month, we are about 10% of the way through it. We
are now entering our slower time of the year, so hopefully we will make
a little bit better progress on it going forward, but I cannot make any
guarantees on when we will get the data completed.

This leaves me with a quandary – I can either provide you with timely,
but inaccurate information that is going to skew your data, or I can
take the time to get the information right. Unfortunately, 99% of the
completed Form477 reports that you have received probably have a
substantial amount of inaccurate data in them.

II can send the inaccurate data that we have, and then you can check us
off the list. That is probably what we will end up doing. In reality, we
probably won’t have a truly accurate report until the next one is due.

I would be happy to provide a computer, Internet connection and a quiet
room for an FCC intern if you would like to send someone out to
participate in the data collection process. I realize that this is not a
likely possibility, but I figured it doesn’t hurt to make the offer.

I really do appreciate the thought process behind collecting this
information. I am one of the founding members and past president of
WISPA, the Wireless ISP trade association, and we have actively
encouraged our members to complete this report and comply with FCC
regulations regarding our industry. I want to comply with the data
reporting requirements of the Form477 report and will commit as much of
my available resources as I can to get the data requested and make sure
that it is as accurate as possible.

Thank you for your time and consideration,

Matt Larsen

Vistabeam.com




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