Subject: [NEXTEL-1] COMMENTS OF PCIA On Amendment of the Commission’s Rules in the 450-470 MHz Band of the Private Land Mobile Radio Services

From: Marcel <[email-masked]>
Date: Thu, 02 Jan 2003 20:27:32 -0500

In the Matter of )
)
Amendment of the Commission’s Rules ) WT Docket No. 02-318
Concerning Airport Terminal Use Frequencies ) RM-10184
in the 450-470 MHz Band of the Private Land )
Mobile Radio Services )

COMMENTS OF PCIA

PCIA, the Wireless Infrastructure Association, through counsel and pursuant to Section
1.415 of the Commission’s Rules, 47 C.F.R. §1.415, hereby respectfully submits its
Comments in
the above-captioned proceeding.

This proceeding was initiated as the result of a Petition for Rule Making filed by PCIA in

June of 2001. It was necessitated by changes in the Universal Licensing System, and
growing
incidences of airlines being unable to communicate within the airport grounds. The
Commission
Notice of Proposed Rule Making (“NPRM”) asks several questions regarding PCIA’s proposal,
and
offers some potential alternatives. PCIA herein responds to the Commission’s questions.
The limited output power of mobile units is particularly problematic at larger airports,
such
as San Francisco International Airport (“SFO”), Dallas/Fort Worth Airport and Chicago’s
O’Hare
Airport. These facilities are broad and feature underground baggage facilities. It is
difficult, if not
impossible, for the same ATU radio channel to communicate between the hangar at one side
of the
airport, the terminal at another side, and the underground baggage facility which
traverses several
terminals. United Airlines, for example, has had to implement a “zone” system at SFO,
whereby
United employees utilize different frequencies when they are in different parts of the
airport. This?2
very inefficient system hampers the ability of United personnel to effectively dispatch
their
personnel, or alert them when emergencies arise.

A. Impact On Non-ATU Licensees From ATU Repeater Power Change

PCIA does not expect any negative impact on non-ATU licensees. Changing Transmitter
Power Output (“TPO”) to ERP will not have the impact of increasing the service area of ATU

systems. Rather, it will better delineate the service area of each system. This, in turn,
will aid both
ATU and non-ATU licensees in ensuring non-interference to each other.

Typically, the actual coverage area or footprint of an airport is very small when compared

to that of non-ATU licensees. Most airlines encourage the use of low gain antennas, which
have a
radiation pattern which is more in line with local airport operations. High gain antennas
do not serve
most airline needs, as these antennas are optimized for distance, and not ground coverage
directly
underneath the antenna. Since most ATU antennas are on the airport grounds, the optimum
case
would be the use of low gain antennas and higher power, which will allow a more dense
concentration of RF energy in the areas where radio coverage is needed most.

Existing power limitations cause significant design limitations and hamper communications
and operation in several ways. First, in multi-channel system architecture, it has proven
to be more
economical and provide better isolation from interference when raido transmitters are
grouped
together in antenna combining systems. These combining systems offer significantly better
filtering
to interference, which benefits both the system operator and those that share radio
spectrum.
However, this filtering comes at a significant price, the sacrifice of approximately fifty

percent of the transmitter output power. Often, by the time the on-channel signal is
delivered to the
antenna, only twenty-five percent or less of the power delivered by the transmitter
remains. Since?3
the nature of airline operations precludes (or discourages) the use of high-gain antennas,
airlines are
faced with the dilemma of sacrificing distance coverage across the airport, or using a
higher gain
antenna to reach the airport boundaries, sacrificing saturation coverage in areas directly
underneath
the antenna (particularly below-ground areas). The use of ERP as a limitation will give
airlines
flexibility to design their systems for optimum airport ground coverage, while still
maintaining the
same absolute distance reach that any ATU could achieve with high-gain antennas.

B. Impact On Non-ATU Licensees From ATU Mobile ERP Increase

Because a system’s service area is defined, both by rule and by technology, by the
repeater
transmitter power, there will not be any negative impact on non-ATU licensees from the
increase
of ATU mobile ERP. However, the current limitation has a very significant negative impact
on
ATU licensees. First, for example, many larger airports have underground baggage transfer
areas.
Low power mobiles do not have the ability to “talk-back” to the repeater in these areas.
Low power
radios are particularly troublesome in areas where a land line connection is not
available, and the
radio is used for control station purposes. Since the control station is fixed, it is
often difficult to
achieve a sufficient signal for the operation.

Signal boosters do not adequately address this problem. First, it is a very expensive
solution
to meet a problem which impacts no user other than airlines. Further, installation of
these units
require major electrical conduit modifications, at a time when airports are increasingly
restrictive
in permitting additional construction. Signal boosters require a very high skill level on
the part of
the service professional, and frequently are installed improperly, causing a
communications problem
for many in the area. If an unrelated radio user is in the area with a high power mobile,
the high

 In addition, PCIA does not believe that the rule change would impact air-to-ground
communications. Airlines typically do not utilize 450 MHz radio systems for their
air-to-ground
communications, and PCIA’s consultations with its ATU-eligible members does not indicate
any
potential interference problem.

If an unrelated radio user is in the area with a high power mobile, the high
power mobile will overload the booster, blocking out all other users, rendering the system
useless
for intended users.

While an increase from three watts to five watts for mobile radios, a 2.2 dB gain, would
be
significant, PCIA believes that there is little rationale for this arbitrary restriction.
Again, since the
service area is dictated by the reach of the repeater, and these mobile do not ordinarily
travel off-site,
their does not seem to be a reason to limit the availability to full-featured mobile units
for ATU-eligible
entities.

C. Automatic Conversion Of ATU Licenses And New Station Class Code

PCIA does not support the automatic conversion of ATU licenses to an ERP classification.
Different licensees may have different ultimate ERP from their ATU operations, and the
amendment
should be performed by each licensee. The change can be made during a renewal cycle, or
when
a licensee is making other system changes.

However, PCIA does support the addition of a station class code for ATU-eligible
operations. By doing so, primary vs. secondary licensees can be readily identified and the
ULS can
be coded to permit additional power only for ATU eligible applicants.

D. Interference To WMTS Licensees

Although the Commission is concerned that increased mobile ERP for ATU licensees might
cause interference to Wireless Medical Telemetry Service (“WMTS”) licensees, PCIA expects
no
such impact. Hospital and related facilities are not close enough to airports to be
impacted by the?2 JPJ Electronic Communications, Inc., 17 FCC Rcd 5512 (2001).

Hospital and related facilities are not close enough to airports to be impacted by the
mobile ERP proposed in this proceeding. In addition, the Commission has regularly waived
its
“high power deadline” for former offset frequencies in the band where the applicant
pledges to
provide interference protection for WMTS and other low power licensees that do not yet
need to
vacate the frequencies. Therefore, PCIA does not support delaying implementation of the
rule
change until October 17, 2003. However, PCIA believes that the Commission can (if it so
desires)
require ATU licensees amending their authorizations for increased mobile power to make the
same
representation as offset licensees, for the brief several months between a Report and
Order in this
proceeding and October, 2003.

E. Non-Compliant Authorizations

With non-compliant licenses granted years ago for the only primary users on the
frequencies,
but without a single reported case of interference, there is little rationale for the
Commission to take
any action regarding previously non-compliant authorizations. The rule changes as proposed
herein
by PCIA will bring these licenses into compliance. Further, the Commission has frequently
grandfathered non-compliant authorizations, where no interference has been reported.2?6
WHEREFORE, the premises considered, it is respectfully requested that the Commission
act in accordance with the views expressed herein.

Respectfully submitted,
PCIA, The Wireless Infrastructure Association
By: Alan S. Tilles, Esquire
Its Attorney
Shulman, Rogers, Gandal, Pordy & Ecker, P.A.
11921 Rockville Pike, Third Floor
Rockville, Maryland 20852
(301) 230-5200
Date: December 20, 2002

http://gullfoss2.fcc.gov/prod/ecfs/retrieve.cgi?native_or_pdf=pdf&id_document=6513398926

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