Subject: [NEXTEL-1] M/A-COM Private Radio Systems, Inc on Public Safety Agency Communications- WT Docket No. 96-86

From: Marcel <[email-masked]>
Date: Fri, 03 Jan 2003 09:59:55 -0500

Please excuse the formatting. The original text can be found at:
http://gullfoss2.fcc.gov/prod/ecfs/retrieve.cgi?native_or_pdf=pdf&id_document=6513398661
==================================================================================
                                        Before the
                            FEDERAL COMMUNICATIONS COMMISSION
                                     Washington, D.C.
                                     In the Matter of
                             The Development of Operational,
                           Technical and Spectrum Requirements
                For Meeting Federal, State and Local ) WT Docket No. 96-86
                            Public Safety Agency Communication
                            Requirements Through the Year 2010

Comments of M/A-COM Private Radio Systems, Inc. to the Sixth Further Notice of
Proposed Rulemaking.

December 9, 2002
M/A-COM Private Radio Systems, Inc.
P.O. Box 2000
3315 Old Forest Road
Lynchburg, VA
(434) 385-2465?ii

TABLE OF CONTENTS
INTRO 1
BACKG 2
DISCUSSION 4
A. ADJACENT CHANNEL COUPLED POWER VALUES - Sec.
90.543..........................................................4
B. MEASUREMENT BANDWIDTH
...................................................................................................................7

SUMMARY/CONCLUSION.....................................................................................................
17?1
                                        Before the
                            FEDERAL COMMUNICATIONS COMMISSION
                                     Washington, D.C.
                                     In the Matter of
                            The Development of Operational, )
                          Technical and Spectrum Requirements )
                For Meeting Federal, State and Local ) WT Docket No. 96-86
                           Public Safety Agency Communication )
                           Requirements Through the Year 2010 )

Comments of M/A-COM Private Radio Systems, Inc. to the Sixth Notice of Proposed
Rulemaking.

To the Commission:

INTRODUCTION

M/A-COM Private Radio Systems, Inc. (M/A-COM) applauds the Commission for its
efforts to assure the Commission rules keep pace with and recognize the diversity of
equipment
that is becoming available and will become available in the future as public safety
agencies enter
full-scale into 700 MHz digital communications. Adopting Adjacent Channel Coupled Power
(ACCP) or Adjacent Channel Power (ACP) emission limits for public safety transmitters
operating in the 764-776 and 794-806 MHz frequency bands is far preferable to establishing

emission “masks” for the various types of communications that public safety will utilize
in the
700 MHz frequency bands.

M/A-COM is pleased to say that it generally supports all of the proposals made by the
Commission in the Sixth Notice of Proposed Rulemaking concerning establishment of ACCP
(or?2
ACP) values and concerning the Terminology Update from ACCP to ACP 1 . However, as will be

explained fully later, M/A-COM wonders whether consensus was ever reached within the
Telecommunications Industry Association (TIA) Private Radio Section, on the measurement
bandwidth to be utilized to evaluate ACCP or ACP in the immediately adjacent 6.25 kHz
channels. M/A-COM is concerned the measurement bandwidth for these the channels does not
properly recognize the receiver characteristics of the 6.25 kHz equipment that will be
used in the
immediately adjacent channels. Our concern increases with the realization that the failure
of the
measurement bandwidth to adequately reflect receiver characteristics could result in
transmitter
modulation changes, which will unnecessarily reduce transmitter range thereby increasing
system complexity and cost. Furthermore, M/A-COM is concerned that use of an inappropriate

measurement bandwidth for the immediately adjacent 6.25 kHz channel could unnecessarily
impede the utilization of future spectrum efficient technologies. M/A-COM believes that
changes
to the measurement bandwidth in very limited cases will facilitate optimal system designs
without raising interference potential or banning future spectrally efficient
technologies.

BACKGROUND

Tyco Electronics, acquired Com-Net Ericsson Critical Communications, Inc. (Com-Net)
in May of 2001, and established M/A-COM Private Radio Systems Inc. as an operating
component of its M/A-COM Wireless Systems Business unit. Com-Net and its predecessors
Ericsson Private Radio Systems and Ericsson GE Mobile Communications had long been
actively involved in the private radio business, particularly the public safety segment of
this
market. The Tyco Electronics acquisition merged the expertise developed by Com-Net and its

predecessors through its Enhanced Digital Access Communications Systems (EDACS ® ) with
the
expertise developed within M/A-COM through its advanced digital OpenSky ® communications
system.

M/A-COM and its predecessors have been active participants in this public safety
proceeding 2 from the very beginning. In 1995, Ericsson personnel were very active members
of
the Public Safety Wireless Advisory Committee (PSWAC) with one Ericsson employee serving
as a member of the PSWAC Steering Committee. More recently, M/A-COM and its
predecessors have been active members of the Public Safety National Coordination Committee

(NCC) again with a current M/A-COM employee serving on the Steering Committee from the
very beginning of the NCC in 1999.

M/A-COM and its predecessors have also been very active participants in the formal
rulemaking activities of this public safety proceeding since the initiation of the
rulemaking in the
fall of 1996. We have supplied numerous comments, replies and petitions throughout the
various
steps in this proceeding and we have participated in numerous presentations and briefings
to
Commission Staff on relevant issues and topics.

Additionally, M/A-COM and its predecessors have participated in the TIA discussions
within the Private Radio Section and the various TR8 Engineering Subcommittees that
developed the TIA recommendations 3 which form the basis for this part of the public
safety
proceeding. We have accompanied TIA members and staff to the Commission for various
presentations and discussions on the topics raised in the instant Notice of Proposed
Rulemaking.

In light of this background, M/A-COM is pleased to offer the Commission these
comments.

DISCUSSION

A. ADJACENT CHANNEL COUPLED POWER VALUES - Sec. 90.543

1. ACCP Values for the 37.5 kHz Frequency Offset.

M/A-COM agrees that the emission limitation requirements for base stations should be
more stringent than the emission limitation requirements for mobile transmitters. In 1998,
as
noted in the Petition for Reconsideration filed by our predecessor company, Ericsson Inc.,
we
have always believed that the –65 dBc value for the 37.5 kHz frequency offset with 12.5
kHz
and 25 kHz transmitters was in error.

We, therefore strongly support the FCC proposal to change the ACCP value for the 37.5
kHz frequency offset with 12.5 kHz and 25 kHz transmitters to –60 dBc.

ACCP Values for the 350 kHz Frequency Offset.

While our predecessor company’s 1998 Petition for Reconsideration 5 did not specifically
recommend the addition of ACCP values for the 350 kHz frequency offset, we believe that
the
addition of an ACCP value for the 350 kHz frequency offset will provide additional clarity
to the
rules. Furthermore, M/A-COM agrees that the proposed ACCP value for this new offset of
–65 dBc with a 100 kHz measurement bandwidth is the appropriate requirement.

 ACCP Values for Base Station Frequency Offsets Greater than 400 kHz.
While our predecessor company, in its previous filings, did not highlight the confusion
factor introduced by the formulaic ACCP approach for offsets greater than 400 kHz up to
the
receive band, M/A-COM recognizes the confusion and potentially contradictory requirements
caused by the current formula in the Commissions rules. We believe that a single set ACCP
value rather than a formula is the best way to implement a clear and enforceable emission
limitation requirement for frequency offsets greater than 400 kHz up to the receive band.
We
agree that the Commission’s proposed value of –80 dBc for offsets greater than 400 kHz up
to
the receive band is reasonable. M/A-COM, however, also wishes to point out that in later
filed
comments, which principally address wideband ACCP recommendations,6 TIA recommended
that the ACP requirement for base station transmissions in the “paired receiver band”
should be
relaxed from –100 dBc to –85 dBc for both wideband and narrowband transmitters. TIA
justified
relaxing the ACCP value on the basis that greater protection than this is routinely
provided by
additional filtering external to the transmitter. M/A-COM agrees wih this TIA
recommendation
and thus recommends this change be included in the tables for 6.25 kHz, 12.5 kHz and 25
kHz
base station transmitters now found in Sections 90.543 and 27.53. These revised numbers
are
shown in the Tables recommended by M/A-COM in subsection B of this Discussion section
hereinafter.

General

Our predecessor company did not address a number of the proposals made by the
Commission in the Sixth Notice of Proposed Rulemaking, but M/A-COM agrees with these
additional Commission proposals. Specifically, M/A-COM agrees with the method
proposed by the Commission.

M/A-COM also believes that compatible changes should be implemented for transmitters
operating in the 700 MHz Guard bands, if the purpose of the guards bands as protectors of
public
safety spectrum is to be fully realized. Thus we agree with the Commission proposal to
adopt
corresponding revisions to Section 27.53(d) of the Commission’s rules.10

. Wideband ACCP requirements.

M/A-COM understands that the TIA comments referenced in the Sixth Notice of
Proposed Rulemaking solely addressed the ACCP requirements associated with narrowband
transmitters, i.e. transmitters with bandwidths less than or equal to 25 kHz. The TIA
comments
referenced in the Sixth Notice of Proposed Rulemaking specifically stated TIA was in the
process of developing ACCP recommendations for 700 MHz wideband transmitters, and that
such recommendations would be submitted to the Commission for action in 2002.
M/A-COM would like to direct the Commission’s attention to comments 11 that have been
filed with the Commission wherein, TIA provided recommendations for ACCP requirements
applicable to wideband transmitters. Current Commission rules are nonexistent as regards
50
kHz and 100 kHz transmitters, and the rules for 150 kHz transmitters are substantially
inconsistent with many of the changes in methodology and policy embodied in the changes
proposed in the Sixth Notice of Proposed Rulemaking for narrowband transmitters.
M/A-COM, therefore, strongly encourages the Commission to expeditiously commence
additional rulemaking proceedings within the WT Docket No. 96-86 in order to implement the

necessary improvements and/or modifications to the wideband ACCP requirements in the
Commission’s rules.

. MEASUREMENT BANDWIDTH

In the First Report and Order 12 in this proceeding the Commission adopted Section
90.543 of the Commission’s rules, which established emission limits for the 700 MHz band
based on ACCP. The limits that the Commission adopted in Section 90.543, also included
adoption of measurement bandwidths for calculation/measurement of the applicable ACCP
limits. Specifically, the rules as adopted indicated that a 6.25 kHz measurement bandwidth

offset 6.25 kHz from center frequency for 6.25 kHz transmitters, and offset 9.375 kHz from

center frequency for 12.5 kHz transmitters, and offset 15.625 kHz from center frequency
for 25
kHz transmitters was to be utilized for ACCP determinations in the 6.25 kHz channel
immediately adjacent to the transmitter channel.

M/A-COM’s predecessor, Ericsson Inc., filed a Petition for Reconsideration,13 which
noted, among other things, that even though Ericsson Inc. generally agreed with the ACCP
concept, the measurement bandwidth for ACCP determinations in the 6.25 kHz channel
immediately adjacent to the transmitter channel should be changed. Ericsson Inc.
recommended
that the measurement bandwidth for ACCP determinations in the 6.25 kHz channel immediately

The Commission did not specifically address the Ericsson Inc. measurement bandwidth
recommendations in the Second Memorandum Opinion and Order.14 Instead, the Commission
noted that there was general industry agreement on the ACCP concept, and the Commission
invited the industry to develop recommendations for ACCP values. This culminated in the
comments that were filed by TIA in August of 2001. 15 M/A-COM agrees consensus was reached

on the ACCP values that were included in the TIA filing. However, M/A-COM questions
whether or not consensus was reached on the specific issue of the measurement bandwidth
that
should be used for ACCP determinations in the 6.25 kHz channel immediately adjacent to the

transmitter channel.

Prior to the August, 2001 meeting of the TIA Private Radio Section and the relevant TR8
Engineering Subcommittees, there was no discussion on the appropriate measurement
bandwidth
for ACCP determinations in the 6.25 kHz channel immediately adjacent to the transmitter
channel. In the initial draft of the recommendations that would become the TIA August,
2001
submission, the measurement bandwidth numbers were simply the numbers that had been
included in Section 90.543. In essence, TIA Private Radio Section and the relevant TR8
Engineering Subcommittees had not appropriately addressed the issues raised by Ericsson
Inc,
and others, regarding the correct measurement bandwidth to be used for ACCP determinations
in
the 6.25 kHz channel immediately adjacent to the transmitter channel.

At the August 2001 meeting of TR8.6, the Transceiver Performance Recommendations
Engineering Subcommittee, a motion was made and seconded that the ACCP measurement range
for the 6.25 kHz channel immediately adjacent to a 12.5 kHz transmitter be from 6.625 kHz
to
12.5 kHz to more closely resemble the band occupied by a receiver centered at 9.375
offset. In
effect this motion was saying that the measurement bandwidth should be 5.875 kHz offset
0.1875 kHz from the center of the receiver channel away from the transmitter. The motion
properly recognized that the effective receiver bandwidth of the receiver occupying the
6.25 kHz
channel immediately adjacent to the transmitter channel is only 5.5 kHz.

When the vote was taken on the motion at the TR8.6 meeting in August of 2001, the total
was 7 in favor of the motion, and 4 against the motion, with two abstentions. In essence,
a
significant majority of those decisively voting believed that the measurement bandwidth
should
be changed from 6.25 kHz to 5.875 kHz for the 6.25 kHz channel immediately adjacent to the

transmitter.16 However, the subcommittee chair, declared that due to the large number of
“no”
votes there was no consensus for the change and thus the measurement bandwidth for the
6.25
kHz channel immediately adjacent to the transmitter would remain at 6.25 kHz. What is very

interesting about this scenario is that fact that consensus was a requirement to change a
number
on which consensus had likely never been achieved. In fact, M/A-COM believes that the 6.25

kHz measurement bandwidth for the 6.25 kHz channel immediately adjacent to the transmitter

would not be supported by even a simple majority of the TIA voting members.

In light of the foregoing, M/A-COM does not believe that either the Commission or the
TIA Private Radio Section have adequately addressed the measurement bandwidth issues that
were raised by Ericsson Inc., and others, in their timely filed Petitions for
Reconsideration.

Specifically, we believe the correct measurement bandwidth for the 6.25 kHz channel
immediately adjacent to the transmitter remains a viable issue requiring Commission
action.
For the reasons expressed partially in the Ericsson Inc. Petition for Reconsideration and
for the reasons expressed herein most notably the need to assure consistency with the
motion
made at the TR8.6 meeting in August of 2001 and assure consistency with receiver
characteristics, M/A-COM believes that the tables in Section 90.543(a) as proposed in the
Sixth
Notice of Proposed Rulemaking 17 should be changed to read as follows: (Changed
measurement
bandwidth values are shown in bold. The 6.25 kHz, 12.5 kHz and 25 kHz base transmitter
tables
shown hereinafter include the recommended change for ACCP in the paired receive band as
discussed in subsection A.3, supra.)
6.25 kHz Mobile Transmitter ACP Requirements
Offset from
Center Frequency (kHz)
Measurement
Bandwidth
(kHz)
Maximum
ACP
(dBc)
6.4375 5.875 -40
12.5 6.25 -60
18.75 6.25 -60
25.00 6.25 -65
37.50 25.00 -65
62.50 25.00 -65
87.50 25.00 -65
150.00 100.00 -65
250.00 100.00 -65
350.00 100.00 -65
>400 kHz to 12 MHz 30 (s) -75
12 MHz to paired
receive band 30 (s) -75
In the paired
receive band 30 (s) -100
17 See Sixth Notice of Proposed Rulemaking, pages A-7, A-8, A-9, and A-10?11
12.5 kHz Mobile Transmitter ACP Requirements
Offset from
Center Frequency (kHz)
Measurement
Bandwidth
(kHz)
Maximum
ACP
(dBc)
9.5625 5.875 -40
15.625 6.25 -60
21.875 6.25 -60
37.50 25.00 -60
62.50 25.00 -65
87.50 25.00 -65
150.00 100 -65
250.00 100 -65
350.00 100 -65
>400 to 12 MHz 30 (s) -75
12 MHz to paired
receive band 30 (s) -75
In the paired
receive band 30 (s) -100
25 kHz Mobile Transmitter ACP Requirements
Offset from
Center Frequency (kHz)
Measurement
Bandwidth
(kHz)
Maximum ACP
(dBc)
15.8125 5.875 -40
21.875 6.25 -60
37.50 25 -60
62.50 25 -65
87.50 25 -65
150.00 100 -65
250.00 100 -65
350.00 100 -65
>400kHz to 12 MHz 30 (s) -75
12 MHz to paired
receive band 30 (s) -75
In the paired
receive band 30 (s) -100
150 kHz Mobile Transmitter ACP Requirements
Offset from
Center Frequency (kHz)
Measurement
Bandwidth
(kHz)
Maximum ACP
Relative
(dBc)
Maximum ACP
Absolute
(dBc)
100 50 -40 Not specified
200 50 -50 -35
300 50 -50 -35
400 50 -50 -35
600-1000 30(s) -60 -45
1000 to receive band 30(s) -70 -55
In the receive band 30(s) -100 -75?12
6.25 kHz Base Transmitter ACP Requirements
Offset from
Center Frequency (kHz)
Measurement
Bandwidth
(kHz)
Maximum ACP
(dBc)
6.4375 5.875 -40
12.50 6.25 -60
18.75 6.25 -60
25.00 6.25 -65
37.50 25 -65
62.50 25 -65
87.50 25 -65
150.00 100 -65
250.00 100 -65
350.00 100 -65
>400 to 12 MHz 30 (s) -80
12 MHz to paired
receive band 30(s) -80
In the paired
receive band 30 (s) -85
12.5 kHz Base Transmitter ACP Requirements
Offset from
Center Frequency (kHz)
Measurement
Bandwidth
(kHz)
Maximum ACP
(dBc)
9.5625 5.875 -40
15.625 6.25 -60
21.875 6.25 -60
37.5 25 -60
62.5 25 -65
87.5 25 -65
150 100 -65
250 100 -65
350.00 100 -65
>400 kHz to 12 MHz 30 (s) -80
12 MHz to paired
receive band 30 (s) -80
In the paired
receive band 30 (s) -85?13
25 kHz Base Transmitter ACP Requirements
Offset from
Center Frequency
(kHz)
Measurement
Bandwidth
(kHz)
Maximum ACP
(dBc)
15.8125 5.875 -40
21.875 6.25 -60
37.5 25 -60
62.5 25 -65
87.5 25 -65
150 100 -65
250 100 -65
350 100.00 -65
>400 kHz to12 MHz 30(s) -80
12 MHz to paired
receive band 30 (s) -80
In the paired
receive band 30 (s) -85
150 kHz Base Transmitter ACP Requirements
Offset from
Center Frequency (kHz)
Measurement
Bandwidth
(kHz)
Maximum ACP
(dBc)
100 50 -40
200 50 -50
300 50 -55
400 50 -60
600-1000 30(s) -65
1000 to receive band 30(s) -75 (continues at
6dB/oct)
In the receive band 30(s) -100

Alternatively, the Commission could select a measurement bandwidth of 5.5 kHz with no
displacement from the center of the 6.25 kHz channel immediately adjacent to the
transmitter
channel. M/A-COM does not believe that using this measurement bandwidth would negatively
impact the interference environment. Use of a 5.5 kHz measurement bandwidth would change
the proposed ACCP tables in Section 90.543(a) as follows. (Changed bandwidth measurement
values are again noted in bold. The 6.25 kHz, 12.5 kHz and 25 kHz base transmitter tables
shown hereinafter include the recommended change for ACCP in the paired receive band as
discussed in subsection A.3, supra.)
6.25 kHz Mobile Transmitter ACP Requirements
Offset from
Center Frequency (kHz)
Measurement
Bandwidth
(kHz)
Maximum
ACP
(dBc)
6.25 5.500 -40
12.5 6.25 -60
18.75 6.25 -60
25.00 6.25 -65
37.50 25.00 -65
62.50 25.00 -65
87.50 25.00 -65
150.00 100.00 -65
250.00 100.00 -65
350.00 100.00 -65
>400 kHz to 12 MHz 30 (s) -75
12 MHz to paired
receive band 30 (s) -75
In the paired
receive band 30 (s) -100
12.5 kHz Mobile Transmitter ACP Requirements
Offset from
Center Frequency (kHz)
Measurement
Bandwidth
(kHz)
Maximum
ACP
(dBc)
9.375 5.500 -40
15.625 6.25 -60
21.875 6.25 -60
37.50 25.00 -60
62.50 25.00 -65
87.50 25.00 -65
150.00 100 -65
250.00 100 -65
350.00 100 -65
>400 to 12 MHz 30 (s) -75
12 MHz to paired
receive band 30 (s) -75
In the paired
receive band 30 (s) -100?15
25 kHz Mobile Transmitter ACP Requirements
Offset from
Center Frequency (kHz)
Measurement
Bandwidth
(kHz)
Maximum ACP
(dBc)
15.625 5.500 -40
21.875 6.25 -60
37.50 25 -60
62.50 25 -65
87.50 25 -65
150.00 100 -65
250.00 100 -65
350.00 100 -65
>400kHz to 12 MHz 30 (s) -75
12 MHz to paired
receive band 30 (s) -75
In the paired
receive band 30 (s) -100
150 kHz Mobile Transmitter ACP Requirements
Offset from
Center Frequency (kHz)
Measurement
Bandwidth
(kHz)
Maximum ACP
Relative
(dBc)
Maximum ACP
Absolute
(dBc)
100 50 -40 Not specified
200 50 -50 -35
300 50 -50 -35
400 50 -50 -35
600-1000 30(s) -60 -45
1000 to receive band 30(s) -70 -55
In the receive band 30(s) -100 -75
6.25 kHz Base Transmitter ACP Requirements
Offset from
Center Frequency (kHz)
Measurement
Bandwidth
(kHz)
Maximum ACP
(dBc)
6.25 5.500 -40
12.50 6.25 -60
18.75 6.25 -60
25.00 6.25 -65
37.50 25 -65
62.50 25 -65
87.50 25 -65
150.00 100 -65
250.00 100 -65
350.00 100 -65
>400 to 12 MHz 30 (s) -80
12 MHz to paired
receive band 30(s) -80
In the paired
receive band 30 (s) -85?16
12.5 kHz Base Transmitter ACP Requirements
Offset from
Center Frequency (kHz)
Measurement
Bandwidth
(kHz)
Maximum ACP
(dBc)
9.375 5.500 -40
15.625 6.25 -60
21.875 6.25 -60
37.5 25 -60
62.5 25 -65
87.5 25 -65
150 100 -65
250 100 -65
350.00 100 -65
>400 kHz to 12 MHz 30 (s) -80
12 MHz to paired
receive band 30 (s) -80
In the paired
receive band 30 (s) -85
25 kHz Base Transmitter ACP Requirements
Offset from
Center Frequency
(kHz)
Measurement
Bandwidth
(kHz)
Maximum ACP
(dBc)
15.625 5.500 -40
21.875 6.25 -60
37.5 25 -60
62.5 25 -65
87.5 25 -65
150 100 -65
250 100 -65
350 100.00 -65
>400 kHz to12 MHz 30(s) -80
12 MHz to paired
receive band 30 (s) -80
In the paired
receive band 30 (s) -85
150 kHz Base Transmitter ACP Requirements
Offset from
Center Frequency (kHz)
Measurement
Bandwidth
(kHz)
Maximum ACP
(dBc)
100 50 -40
200 50 -50
300 50 -55
400 50 -60
600-1000 30(s) -65
1000 to receive band 30(s) -75 (continues at
6dB/oct)
In the receive band 30(s) -100?17

SUMMARY/CONCLUSION

M/A-COM endorses the ACCP or ACP values that have been proposed by the Commission in the
6th Notice of Proposed Rulemaking, WT Docket No. 96-86, as specifically discussed herein.
While M/A-COM generally endorses the proposed ACCP or ACP values, M/A-COM does not
agree that a 6.25 kHz measurement bandwidth is appropriate or wise for the first adjacent
6.25 kHz
channel. We question if consensus was reached within TIA on this particular value. In
fact, we believe
that the majority, although maybe not a consensus, of the TIA participants agree that the
6.25 kHz
measurement bandwidth for the immediately adjacent 6.25 kHz channel is incorrect.
Furthermore we
expect that this majority of the TIA participants believe an appropriate measurement
bandwidth for this
channel would be a value consistent with the values proposed herein.

M/A-COM strongly encourages the Commission to also take whatever steps are necessary to
implement ACCP or ACP values for the wideband 700 Hz transmitters in an expeditious
manner. These
wideband values should be consistent with the methodologies and policies underlying the
narrowband
values proposed in the Sixth Notice of Proposed Rulemaking, as well as being consistent
with the
recommendations in the July 16, 2002 TIA comments.

Robert J. Speidel, Esq.
Manager, Regulatory Policy
M/A-COM Private Radio Systems, Inc.
P.O. Box 2000
3315 Old Forest Road
Lynchburg, VA 24501
(434) 385-2465

http://gullfoss2.fcc.gov/prod/ecfs/retrieve.cgi?native_or_pdf=pdf&id_document=6513398661

Your use of Yahoo! Groups is subject to http://docs.yahoo.com/info/terms/