WISPs are Delivering Broadband to the Rural Unserved – the Last 25 Million

1. WISPs primarily use unlicensed frequencies because building a broadband network with unlicensed frequencies allow WISPs to provide affordable service quickly.1. Low barrier to entry2. Low cost 3. Equipment readily available and produced in mass quantities4. Existing knowledge base exists and is often shared with newbies5. No regulatory lag6. Few if any other broadband options exist in their communities7. Deployment choices made by local operators to solve local

broadband problems instead of depending on decisions made by corporate bureaucracy aimed at maximizing investor returns.

Using unlicensed frequencies do have limitations:

1. There is not enough spectrum to deliver high-bandwidth service to everyone who wants service.

2. Trees, hills and other obstructions prevent Wisps from serving customers who do not have line-of-sight to the access point/base station.

3. TVWS unlicensed spectrum will help solve the first two points.4. ALL radio frequencies have limitations, whether unlicensed or licensed.

Each frequency has it’s own “propagation characteristics”. The propagation characteristics of TV spectrum are better than the propagation characteristics of the currently available unlicensed spectrum options. Therefore, Wisps use of TVWS spectrum will allow many people to receive broadband service who can not receive service today.

Generalities:

1. As spectrum frequencies decrease, bandwidth capacity also decreases.2. As spectrum frequencies decrease, penetration and coverage increases.3. As spectrum frequencies decrease, antenna systems become larger.4. As spectrum frequencies decrease, signal travels farther.

Wisp use of TVWS frequencies will NOT cause any interference with licensed television broadcasters. The rules have been carefully tailored to assure that no interference will occur.

WISPA has worked diligently with other industries, trade associations and manufacturers to help create a set of rules that everyone can live with and will promote rapid and affordable deployment of TVWS networks to stimulate ubiquitous broadband options to the vast majority of consumers.

WISPA and Wisps continue to work with the FCC and with the entire TVWS ecosystem (manufacturers, broadcasters, etc.) to fine tune the rules so that everyone’s needs and concerns are addressed. Wisp use of the TVWS frequencies can be a win-win-win outcome for everyone, especially the consumers.

Congressional action to auction all spectrum lacks some intelligence1. Unlicensed frequency allocations stimulate ingenuity and technology

advancement.2. Unlicensed frequency allocations lead to “consumer comfort” and easy

to use technology.3. Unlicensed frequencies are the most efficiently used spectrum

allocations available today.4. Auctioning all spectrum (as has been recommended in several bills) is a

poor choice for our nation’s future.1. Keep the license purchasers honest2. Create competition3. Allow small business to rapidly deploy unserved areas

Congressional action to auction all spectrum lacks some intelligence5. Supply and Demand Principle

1. If a portion of the TVWS spectrum is maintained for unlicensed use, the supply of available auctioned spectrum will decrease and cause the price per megahertz pop to increase. Therefore, the revenue generated from such an auction would be nearly the same as if all TVWS spectrum were auctioned.

2. Auctioning all spectrum will further polarize industry participants and will create a stronger monopoly/duopoly in the telecommunications industry. Fewer choices (supply) will result in higher consumer prices.

3. The principal belief that auction proceeds will help pay down the national debt lacks the long term outlook of stimulating the economy with small business, job creation and increased income tax revenues from massive industries created by unlicensed spectrum. “Selling our Soul for a quick fix”