Subject: [NEXTEL-1] Nortel Networks Inc. EADS TELECOM North America on Public Safety Agency Communications- WT

From: Marcel <[email-masked]>
Date: Fri, 03 Jan 2003 10:09:56 -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=6513396530
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                                        Before the
                            Federal Communications Commission
                                 Washington, D. C. 20554
                                    In the Matter of:
                            The Development of Operational, )
                          Technical and Spectrum Requirements )
                          For Meeting Federal, State and Local )
                Public Safety Agency Communications ) WT Docket No. 96-86
                           Requirements through the Year 2010 )
                                            )
                          Proposed revisions to Section 90.543 )
      Joint Comments of Nortel Networks Inc. and EADS Telecom North America to Sixth
                              Notice of Proposed Rule Making

Nortel Networks Inc. (“Nortel Networks”) and EADS TELECOM North America 1
(“EADS Telecom”) (collectively referred to herein as the Joint Commenters) offer these
comments to the Sixth Notice of Proposed Rulemaking, The Development of Operational,
Technical and Spectrum Requirements For Meeting Federal, State and Local Public Safety
Agency Communications Requirements through the Year 2010, WT Docket No. 96-86 (“Sixth
NPRM”). The Joint Commenters support the Commission’s stated goals of increased
competition, interoperability and increased efficiency.

These comments reflect the Joint Commenters’ vision of Commission actions that will
further those goals, particularly with regard to emerging technologies in the public
safety and industrial arenas.
The Joint Commenters are both active on public safety matters in the
Telecommunications Industry Association (“TIA”).

Nortel Networks is a member of the TIA and
is an active participant in the TIA Wireless Communication Division Private Radio Section
Several companies within the Nortel Networks corporate organization collectively hold a
joint venture minority
interest in EDSN SAS, a French company operating as EADS TELECOM that operates in the
United States as?- 2 -
(“PRS”) and the TIA TR8 Mobile and Personal Private Radio Standards subcommittees. EADS
TELECOM is a participant in the TIA TR8 Mobile and Personal Private Radio Standard
subcommittee. As noted by the Commission in the Sixth NPRM, the PRS “recommendations
were developed under TIA processes and therefore represent full consensus opinions without

meaningful objections of any participating manufacturer.”2 While concurring with the
overall
recommendations, the Joint Commenters highlight for Commission consideration the PRS
admonition “that there are emerging technologies under development that may further affect
the
ACCP table recommendations.”3

Emerging Technology Issues

Existing Part 90 regulations call for a 9600 b/s air link rate in a 12.5 kHz channel,
producing a spectrum efficiency of 0.768 b/s/Hz. Past and current proposals in TIA TR8
have
offered a 2-slot TDMA solution for 12.5 kHz channels with anticipated air link rates of
15-16
kb/s in a 12.5 kHz channel and a resultant spectrum efficiency greater than 1.2 b/s/Hz.
The
currently proposed ACP (former ACCP) values in the 12.5 kHz Mobile Transmitter ACP
requirements table call for the first offset from center frequency to be 9.375 kHz,
utilizing a
measurement bandwidth of 6.25 kHz, and requiring a maximum ACP of -40 dBc.4 These
proposed ACP criteria will restrict the development of spectrally efficient technologies
for
deployment in the 700 MHz band.5 The Joint Commenters propose a slight change in the
offset
EADS TELECOM North America. Nortel Networks and EADS TELECOM North America share the same
policy
perspective in this proceeding.

While the Joint Commenters specifically address the 12.5kHz channel ACP requirements in
these comments, the
Joint Commenters feel that identical changes to the first adjacent channel ACP
requirements in the 6.25 and 25 kHz
channels will facilitate the deployment of emerging technologies using such channel
spacings in the 700 MHz band.?- 3 -
from 12.5 kHz center frequency and measurement bandwidth to allow future deployment of the

identified 2 slot TDMA and other emerging and spectrally efficient technologies utilizing
the
narrowband channels of the 700 MHz band. As identified in the tables below, the Joint
Commenters suggest that the measurement bandwidth for the first adjacent channel for 12.5
kHz
transmitter measurements be changed to 5.9 kHz and the offset from center frequency be
adjusted to 9.555 kHz.

12.5 kHz Mobile Transmitter ACP Requirements
Offset from
Center Frequency (kHz)
Measurement
Bandwidth (kHz)
Maximum
ACP (dBc)
9.55 5.9 -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
12.5 kHz Base Transmitter ACP Requirements
Offset from
Center Frequency (kHz)
Measurement
Bandwidth (kHz)
Maximum ACP (dBc)
9.55 5.9 -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?- 4 -
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) -100

Conclusion

In closing, the Joint Commenters urge the Commission to continue to consider emerging
technology factors as rules are adopted in this proceeding. With this goal in mind, the
Joint
Commenters urge the Commission to adopt final rules consistent with the proposed first
adjacent
channel interference tables described above and thereby enable the unimpeded development
of
new and emerging technology in the public safety and industrial arenas.

Respectfully Submitted,

/s/ Raymond L. Strassburger /s/ Scott Carlson
Vice President, Global Government Relations Division Counsel
Nortel Networks Inc. EADS TELECOM
801 Pennsylvania Ave. NW North America
Suite 700 5057 Keller Springs Rd.
Washington, DC 20004 Addison, Texas 75001
(202) 347-6410 (972) 341-7983

Of Counsel:
John Lamb
Senior Counsel
Nortel Networks
2221 Lakeside Boulevard
Richardson, Texas 75082-4399
December 9, 2002

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