The Honorable Ajit Pai, Chairman 
The Honorable Mignon Clyburn, Commissioner  
The Honorable Michael O’Rielly 
Federal Communications Commission 
445 12th St, SW 
Washington, DC 20554 

Re: RM-11791 

New Wave Net Corp, (NWNC) operates a fixed wireless Internet service covering 10 counties in Central IL.
serving Residential and Commercial customers. NWNC utilizes spectrum in the 5 Ghz unlicensed bands,
as well as 20 Mhz of licensed 2.5 Ghz EBS spectrum in a limited 35 mile subset of our coveage area for
nlos coverage,and 3650 NN spectrum in areas outside our EBS license area. NWNC currently offers Advanced
Broadband speeds of up to 25/3 Mbps with unlimited usage to Line-of-site (LOS) customers on our 5 Ghz
spectrum but are limited to only offering up to 10/1 Mbps service on our sparce EBS and 3650-3700 NN
licensed spectrum.

Our customers usage and bandwidth demands continue to increase. In the rural areras we serve we desparetly
need access to more mid-band spectrum to provide the increase speeds demanded by today's customers. 
NWNC has made good use of the bands available to us today but the demands of growing broadband usage
require larger channel sizes and additional spectrum.  The 3700-4200Mhz spectrum is very well suited
for this purpose and is uniquely positioned to meet the broadband demands of consumers without requiring
an expensive and lengthy band clearing process that based on past auctions takes 5-10 years.
   
This spectrum should be made available on a coordination basis and not auctioned.  Coordination 
allows many users in the spectrum, not just a single provider who must spend a significant 
amount of capital on licensing fees instead of building networks.  Auctioning the spectrum will 
only result in delaying the deployment of broadband to American consumers. 

The Broadband Access Coalition proposal should be adopted by the FCC for all of the reasons listed in the Proposal.


Garth Nicholas
CFO
New Wave Net Corp
Bloomington, IL 61702