JetWeb, Inc.
PO Box 744
Brushton, New York 12916
Phone# (800) 700-0279
Fax# (518) 529-0100
sales@JetWeb.us
Visit is online at JetWeb.us
Via ECFS
Marlene H. Dortch, Secretary
Federal Communications Commission
445 12th Street, S.W.
Washington, D.C. 20554
Re: Written Ex Parte Presentation
ET Docket Nos. 09-191 and WC Docket No. 07-52
Dear Ms. Dortch:
My company, JetWeb, Inc., provides Fixed Wireless broadband service in [area]. We rely
primarily on unlicensed spectrum to deliver broadband services to consumers that have no [or few]
broadband choices. We built our network from scratch using devices authorized under Part 15 rules the
FCC adopted to open up 900 MHz, 2.4 GHz, 3.65 GHz and 5 GHz spectrum for unlicensed or light
licensed broadband devices. Thanks to the Commission?s initiatives; consumers, businesses, and
government services in the Brushton, Moira, Dickinson, Malone, Bangor, Constable areas can now get
broadband service
JetWeb, Inc. is concerned that certain Network Neutrality rules, if adopted, would severely and
adversely affect our ability to continue to provide our customers with affordable Fixed Wireless
broadband services. It is our understanding that although mobile broadband will have a special set of
rules, Fixed Wireless broadband will be lumped in with traditional wired services and be subject to a
stricter set of rules. We feel that the Network Neutrality rules imposed on Fixed Wireless broadband
should be no more rigid than the rules that will apply to mobile wireless broadband providers. The
physics of wireless technology and delivery necessitate a relaxed set of rules for all wireless technologies.
Many of the proposed rules will destroy our industry, our business and our customers? Internet
experience. We believe wireless networks, either Fixed or mobile, will be unable to operate effectively if
the definition of what constitutes ?reasonable? network management practices does not account for the
unique obstacles faced by small businesses with congested networks, bandwidth constraints, tower and
middle-mile access limitations and a lack of investment capital. For many households in rural
America, this will mean the loss of broadband services entirely at a time when the country is
seeking to accomplish ubiquitous coverage.
We need to face the reality that content delivery and demand is outpacing the technology and
spectrum available to meet consumer demands, especially for Fixed Wireless networks that have limited
spectrum, capacity and throughput. Many regions of our country do not have the wireline broadband
infrastructure available to meet this demand. The past has proven that often times it is economically
unfeasible to build new wireline infrastructure in rural areas; thus Fixed Wireless broadband is often the
only economical delivery mechanism to deliver quality broadband services to those households that have
been overlooked or bypassed by traditional wireline Internet providers.
JetWeb, Inc.
PO Box 744
Brushton, New York 12916
Phone# (800) 700-0279
Fax# (518) 529-0100
sales@JetWeb.us
Visit is online at JetWeb.us
It should not be taken lightly that the FCC was charged by the ARRA to write a National
Broadband Plan so that all Americans could receive affordable broadband service. If the proposed rules
are approved, this one action alone would cripple this goal. Why would the FCC protect one method of
wireless broadband delivery and not apply the same good fortune to a similar technology that is in place
and actively servicing many people and businesses today? As Fixed Wireless technology improves, and
more spectrum is opened to the Fixed Wireless industry, then a more relaxed set of Network Neutrality
rules may be revisited in the future, but now is not the proper time.
In nearly every industry in the world, flow is managed, whether it is sewer systems, hydraulic
fluid, natural gas, air traffic, the highway system, or countless other systems. Flow management is
essential for orderly delivery of a medium in a safe and effective process. Data is no different than
anything mentioned above. Without proper management, systems will fail and the data highways will be
disrupted, leaving millions of businesses and residents without service.
Companies that are building and maintaining the data highways should be able to control and
manage the traffic coming in and out of their network as they see fit, in order to effectively deliver the
high levels of sustained traffic that are starting to clog the Internet.
The majority of Fixed Wireless networks have been completely funded with private funds and
organic growth. As Internet traffic grows exponentially, Fixed Wireless broadband providers are
seeing not only their middle mile transport costs increasing but last mile transport costs increasing
exponentially as well. Given the state of our current economy, we do not feel that we can pass these
increased costs on to our customers. This is not a time to increase regulation in order to satisfy the
consumer thirst for more content delivered to their doorstep for the same cost that they are currently
paying.. The economics just do not justify it.
Our company supports the positions taken by WISPA, the Wireless Internet Service Providers
Association in their Ex Parte presentation filed on December 10, 2010.
Sincerely,
Nicholas J. Brockway
Vice President