Brian,

I do agree it is regrettable that the majority of WISPs do not report,
and that there is a sort of "reap what you sow" sort of effect. The WISP
industry is too often its own worst enemy. I would disagree about the
comment regarding vendors though. Not only is it not our responsibility
to brow beat WISP customers (and we have no means to compel them anyway)
to fulfill their obligation to file 477, most vendors (Aperto excluded
as a rare exception) are not based in the US. You cannot expect vendors
to monitor the requirements imposed on their customers in all the
regulatory domains around the world. We can and do try to pay attention
to all the regs and rules as they pertain to us, and that burden is
large enough.

In any event, vendors are no more responsible for WISPs filing their
477s than car manufacturers are responsible for drivers keeping their
drivers licenses current. As individuals, some of us have beaten the 477
drum to death though; I know I did years ago when the obligation first
arose and again when it was made mandatory for all broadband providers,
regardless of numbers of customers (a move by the FCC I think intended
to try to capture the cumulative numbers of small WISPs, for WISPs
ultimate benefit and so the FCC could justify creating rules in our
favor).


Patrick Leary
Aperto Networks
813.426.4230 mobile

-----Original Message-----
From: wireless-boun...@wispa.org [mailto:wireless-boun...@wispa.org] On
Behalf Of Brian Webster
Sent: Monday, February 15, 2010 10:37 AM
To: WISPA List; memb...@wispa. org; WISPA Board; Motorla List Beehive
Subject: [WISPA] WISP's are killing themselves!!!! - New FCC form 477
reportis out, not looking good for Fixed Wireless
Importance: High

The latest FCC report on form 477 broadband data is out
(http://hraunfoss.fcc.gov/edocs_public/attachmatch/DOC-296239A1.pdf).
While I don't see a whole lot of useful data in it, I do see where
WISP's are killing themselves and the industry, why?

  a.. In the periods prior to the December 2008 report, fixed wireless
has shown a steady increase in subscribers. The last reporting period
the number of subscribers dropped from 808,000 to 488,000!!! That's a
39.6% drop in the actual data that had been previously reported. Know I
know that most of the problem is the fact they now require census tract
reporting rather than zip codes, but dropping like this does not help
the industry as a whole.
  b.. Because of the low number of reported subscribers, the reporting
by technology portions of the report does not even earn fixed wireless a
spot on the charts in it's own category. It's lumped in with the 1.4%
total of all other technologies compared to the rest of the broadband
industry. Hell Satellite has their own category with .9%.
  c.. The total number of fixed wireless providers reporting is 617.
That means there are a huge number of WISP's not filing form 477 and
those that didn't report must have a large number of subscribers. The
previous period where fixed wireless had 808,000 subscribers had only
505 WISP's report!
Matt Larsen and the WISP directory have around 1,800 WISP's registered.
I've heard other estimates between 2,000 and over 4,000. Only 617 fixed
wireless operators reporting is not helping the cause at all.
  d.. The National broadband plan is being formulated as we speak,
looking at those statistics it appears the WISP industry is in a serious
decline and that as a total percentage of broadband provided to
consumers nationally, they make no significant difference.
If you were a government policy maker, would you even pay attention to
WISP's. I certainly would not. They have to make decisions based on data
and that benefit the majority of the country. WISP's have thumbed their
noses at providing this data for years. I think it is really going to
bite them in the butt now. Fiber to the home is coming liking it or not.
USF reform is coming like it or not. USF reform is going to subsidize
broadband to the very markets wireless serves more economically today.
Removing that advantage is going to put the WISP industry in serious
trouble.

The manufacturers are killing themselves as well. In their quest to just
sell radios, they have missed the importance of keeping the industry
healthy. If the WISP's cannot compete and/or show that they are a
significant option to the overall broadband infrastructure in the US,
how will they continue to sell product. If anyone knows the true number
of WISP's out there it is the manufacturers. They should be leading the
charge with groups like WISPA to make sure ALL WISP's stand up and get
counted. How hard would it be to stuff each shipment with educational
material on the importance of filing form 477?

The current FCC is very open minded but the results of this type of
report force them to make decisions that benefit the most people.
488,000 is a very small portion of over 129 million homes.

All I can say is ouch........


Thank You,
Brian Webster




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