Subject: [NEXTEL-1] 5/28/03- 800 MHz USER COALITION BALANCED APPROACH

From: [email-masked]
Date: Wed, 28 May 2003 20:22:56 -0400

5/28/03

800 MHz USER COALITION BALANCED APPROACH
STATEMENT OF INTEREST

This coalition of parties believes that there are better
alternatives to solving the Public Safety interference problems in
the 800 MHz band than the .Consensus Plan. filed on December 24,
2002.  The participants in this coalition include entities from the
electric, gas and water utilities, business and industrial users,
non-Nextel EA General Category Auction licensees, incumbent SMR
licensees operating on General Category channels, equipment
manufacturers, and CMRS licensees.  This group represents an even
broader group of affected parties than the so-called .Consensus
Parties,. and it is representative of the licensees that would
suffer harm from the implementation of the .Consensus Parties..
Plan.

The premise of the 800 MHz User Coalition approach is that something
must be done in the near term to address interference that is more
immediate, more effective, less disruptive and less costly than the
.Consensus Plan.. Given that, according to the APCO database, only
1% of Public Safety systems reported interference incidents last
year, the common sense approach is to focus first on mitigating
those problems and preventing future interference, instead of
jumping to a .solution. that would disrupt 100% of Public Safety
systems, not to mention all other licensees in the 800 MHz band.  
The attached Statement of Principles and detailed action plan
describe a concrete alternative to the .Consensus Plan. that relies
on enhanced mitigation techniques that build upon, but go beyond,
existing .best practices."  The proposed approach recognizes
technical advances described in recent filings by equipment
manufacturers that further improve the potential for a
mitigation-oriented solution.

The 800 MHz User Coalition Balanced Approach offers a comprehensive
alternative plan to resolve interference in the 800 MHz band that,
at the same time, promotes spectrum efficiency and maximizes the
future utility of the frequency band, without the inefficient,
heavy-handed, command and control aspects of the .Consensus Plan..

Initial Coalition Parties

ALLTEL Communications
Ameren Corporation American Electric Power (AEP)
Applied Technology Group, Inc.
AT&T Wireless Services, Inc.
Cinergy Corporation
City of Baltimore, Maryland
City of Colorado Springs,
Colorado Consumers Energy Co.
Edison Electric Institute (EEI)
Fresno Mobile Radio, Inc.
Holy Cross Electric Association
Mobile Relay Associates
National Rural Electrical Cooperative Association (NRECA)
Preferred Communication Systems
Small Business in Telecommunications
Southern Company/SouthernLINC 
Supreme Radio Communications, Inc.
U.S. Cellular Corp.
United Telecom Council (UTC)
Western Wireless

STATEMENT OF PRINCIPLES FOR

ADDRESSING 800 MHZ INTERFERENCE

Step 1:  Solve interference through mandated mitigation using
enhanced best practices.
Immediate steps to improve mitigation techniques include:

Licensees in the 800 MHz band should take pro-active steps to ensure
that potential interference situations are identified and avoided,
to the extent possible.  Procedures to implement this approach are
detailed in Attachment A.I.

FCC should clarify and codify a policy that entities creating
interference to licensees in the 806-824/851-869 MHz band should be
responsible for mitigating the reported interference within 60 days
of being contacted by the affected licensee, at the cost of the
interfering licensee.  This policy would apply even if the
interfering licensee/equipment is operating consistent with current
FCC rules while causing the interference.
Procedures to implement this approach are detailed in Attachment
A.II.
Non-Public Safety 800 MHz licensees should provide engineering
expertise and assistance to Public Safety.  All incumbent licensees
in the 800 MHz band should be full partners with other stakeholders
in identifying incidents of interference and evaluating and
implementing solutions.  Interference may be caused by transmitter
or receiver equipment.

The APCO Best Practices. recommendations should be enhanced and
incorporated into the FCC.s Rules, and all licensees operating in
the 800 MHz band, including Public Safety and private licensees,
should be
required to abide by these rules to minimize interference.

The FCC should adopt modified technical rules to prevent future
interference, incorporating many of the technical advances
identified in filings by equipment manufacturers.  (See Attachment B
for further detail on these technical measures).

The FCC should allow more flexibility in current user pool
eligibility restrictions to allow private market agreements such as
frequency swaps as a means of reducing and preventing interference.

Mitigation techniques that address interference to incumbent systems
should not come at the expense of non-interfering licensees,
particularly Critical Infrastructure licensees.  The function of
Critical Infrastructure licensees is particularly vital in today.s
atmosphere of heightened homeland security, and they should not be
accorded secondary treatment.

Step 2: Initiate a review to assess progress and effects of Step 1
mitigation measures, and to evaluate longer-term measures that might
prove necessary if and only if these mitigation techniques and rule
changes do not adequately resolve interference.

The review should be coordinated by an independent agent, working
with a steering committee including all affected stakeholders (a
focused industry-Public Safety working group), and should build on
/incorporate existing efforts.

The review should be initiated immediately, and focus first on
monitoring and evaluating the track record of the enhanced best
practices approach in resolving interference concerns.  It should,
in addition, examine the nature and extent of any remaining
interference problems that are not adequately resolved by the
measures in Step 1, and develop concrete recommendations to fix
them.  The review should be comprehensive, and include
recommendations on solutions to avoid specific problems (technical
mitigation approaches beyond . Enhanced Best Practices.) as well as
broader solutions if interference is not sufficiently mitigated.

The review would involve the affected 800 MHz stakeholders
contributing engineering expertise and assistance to Public Safety. 
The review should include recommendations on funding of any
appropriate remediation measures.  Remediation measures should be
limited if initial mitigation techniques are as successful as
anticipated.

ATTACHMENT A

PROPOSED PROCEDURES FOR INTERFERENCE MITIGATION
IN 806-824/851-869 MHz BAND

I. Procedures to Identify and Avoid Incidences of Interference in
the 806-824/851-869 MHz band. Any licensee wishing to install a new
antenna in the 851-869 MHz band at height of less than 30 meters AGL
(.low-site transmitters.) shall notify co- and adjacent channel
licensees within the protected service contour (via filing at the
FCC in ULS or an alternative database) and appropriate frequency
coordinators 30 days in advance of the installation of the site
providing the following information:

Licensee Name Point of Contact-Information:  Name, address,
telephone number,  and e mail address for technical person
knowledgeable about site.
Site Coordinates Certification: 

The licensee shall certify that it has performed an engineering
analysis pursuant to generally accepted industry practices and has
determined that its operation of that site is not predicted to cause
co-channel or adjacent channel interference to other licensees in
the 806-824/851-869 MHz Band within service areas that overlap a
5,000 foot radius around its transmitter site.
II. 

Procedures to Address Identified Interference Problems A
806-824/851-869 MHz licensee receiving interference will immediately
notify any suspected interfering low-site system operator or
operators of the problem by:
Posting the interference complaint to an e-mail address to be
established and operated jointly by the licensees of low-site
systems in this band.
The Complainant shall identify:

Specific geographic location where interference is occurring, FCC
license information for the Complainant.s system, Point of Contact
Information for the Complainant.s system.
All licensees receiving notice of complaint via the website shall
respond within two business days and shall confirm whether they have
systems operating within 5,000 feet of alleged site of interference.
On-site analysis: The Complainant shall contact the potentially
responsible contributors to the interference to arrange for an
on-site analysis to take place within five business days (or later
at the discretion of the complaining entity).  The Complainant and
all potential contributors shall support the analysis effort.
Mitigation steps:

When the analysis shows that one or more of the suspected
interfering operators are actually interfering with the system in
question, the contributors to the interference shall correct the
interference per industry-standard mitigation techniques.    The
resolution of the interference shall be documented and copies
provided to each contributor and the complaining licensee.
If mitigation of interference at a site requires that contributors
make changes that can be easily reversed or substantially modified
(e.g., changing of transmitter frequencies to avoid intermodulation
(.IM.) product formation on a particular frequency, or a reduction
in on-street power), then the contributor making the change shall
continue to coordinate both with the other contributors and the
complaining entity before making further changes to the site.  If
the analysis finds that interference is caused by something other
than the equipment belonging to potential contributor system
operators (e.g., a bi-directional amplifier (.BDA.) installed by a
third party, or .receiver-generated. IM interference), the owner of
the equipment shall be responsible for mitigating the interference. 
The participants in the on-site analysis shall be responsible for
notifying the equipment owner of this finding.
The Complainant shall have a duty to cooperate in the implementation
of the most cost-effective solution.
If an agreement between the parties is not reached within 60
calendar days after receipt of the written notice of interference,
any affected party may submit the matter to the FCC for resolution. 
The FCC shall  order appropriate steps to resolve interference in
the most efficient manner, including by such means as specifying the
transmitter power, antenna height or frequency, or requiring other
changes in operation or equipment to correct the problem.

ATTACHMENT B

TECHNICAL RULE MODIFICATIONS
The following technical rules, in addition to the requirement,
described above, that interfering licensees correct their
interference, should be adopted as part of the effort to resolve
interference through improved mitigation techniques.  The FCC
should:
Require licensees in the 800 MHz band to comply with the procedures
outlined in Attachment A, ie:
Notify co- and adjacent channel licensees within the protected
service contour (via filing at the FCC in ULS) and appropriate
authorized 800/900 MHz frequency coordinators 30 days in advance of
initiating transmissions from a new .low site transmitter.

Respond to interference complaints within two business days and
resolve interference expeditiously through industry-standard
mitigation techniques.

Require Licensees in the 806-824/851-869 MHz band to calculate
percentage degradation for land mobile systems by using the TSB-88
algorithm. While the TSB-88 algorithm was developed to address
interference issues associated with land mobile refarming, the
methodology could be used at 800 MHz to evaluate co-channel and
adjacent-channel systems. Implementing the use of TSB-88 could
address potential interference from digital operations on channels
directly adjacent to proposed facilities. Frequency coordinators in
the band must decide on mileage criteria that would necessitate
evaluation of adjacent-channel facilities. Absent a current
recommendation from 800 MHz frequency coordinators, a 70-mile radius
is proposed.

Codify or amend the regulations as necessary to allow for external
filtering and other added equipment to be used to reduce or
eliminate interference.

Adopt the .APCO Best Practices. recommendation to require that user
receiver equipment in the 806-824/851-869 MHz band provide a minimum
75 dB intermodulation specification.

Require licensees of low-site. systems in the 806-824/851-869 MHz
band to limit the ERP of base stations with an antenna height of 30
meters or less above ground to 100 watts/25 kHz channel. Low sites.
may be defined similarly to the cellular. definition offered by the
Consensus Plan,  i.e.: sites:

1) that are included within a system with five or more overlapping
sites with handoff capability;

2) with twenty or more operating frequencies; and

3) with antennas at a height of up to 30 meters above ground.  All
base station operations in the 806-824/851-869 MHz band should be
subject to a single rules section concerning emission restrictions.

The requirements of 47 CFR 90.543 . Emissions limitations, including
the
ACCP Tables addressing adjacent channel and OOBE levels (excepting
subparagraph (e)) for 12.5 kHz or wider operations, should, at an
appropriate future date, replace the current rules sections dealing
with emission masks for various portions of the band, modified as
necessary to accommodate bandwidths currently not included in the
ACCP Tables. To implement this standard, 47 CFR 90.691- Emission
mask for EA-based systems, and 47 CFR 90.669 - Emission limits for
MTA licensees, should be modified to conform to the above standard. 
This, coupled with ERP restrictions, would significantly reduce the
possibility of interference between and to noise-limited systems
operating in the vicinity of low sites.

The combination of low-site ERP restrictions, the adoption of the
ACCP attenuation requirements of 47 CFR 90.543, and the use of
TSB-88 for adjacent channel separation, coupled with the removal of
eligibility barriers to permit .frequency swapping. and other
measures to allow operators to reduce or eliminate interference,
will eliminate the need for the creation of a .guard band. as
described in the PWC Plan, Appendix F, Section 4.1.2.  As has been
stated previously, the .sliding scale. of protection for frequencies
in the proposed guard band might not significantly impact low-power
campus systems, but would have a devastating impact on wide-area
users currently licensed and operating in the proposed guard band,
as well as the many non-public safety incumbent systems that would
be required to retune to the 859-861 MHz portion of the band under
the PWC proposal.

Establish adjacent channel spacing standards for use in coordinating
non-EA channels, to facilitate the ability of frequency coordinators
to review the spacing of channels adjacent to the frequency under
consideration, as well as the co-channel spacing, during the
coordination process.

Any interference that should remain after the implementation of the
above measures could be resolved through .Enhanced Best Practices. 
measures such as careful design or redesign of antenna systems,
filters, and other non-transmitter-specific remedies. Under this
proposal, manufacturers would be able to produce equipment usable
across the entire band, maintaining economies of scale, encouraging
manufacturer involvement and innovation and benefiting the 800 MHz
market in general.

Motorola, for example, is testing the use of switchable attenuators
in portable receivers to reduce the strength of signals entering the
receiver in strong signal areas that would otherwise result in
non-linear operation of the low noise amplifier and mixer, creating
intermodulation interference.
Motorola is also testing software-controlled tunable filters in
their portable receivers that retune the filter based on received
signal (See Letter to Edmond Thomas, Chief, OET, from Steve Sharkey, 
Motorola, May 6, 2003.) strength, allowing the portable to operate
correctly in the presence
of strong CMRS signals. 

 Further, Motorola has written that All of the
deployed dual-band XTS 2500 and XTS 5000 model radios (which began
shipping in 4th quarter 2001) are physically capable of implementing
this solution, but will require additional software.

--
    "NEXTEL-1 IT'S NOT JUST NEXTEL"
  Note The New address
Subscribe to Nextel-1:
http://www.groups.yahoo.com/subscribe/NEXTEL-1

"NEXTEL2 FOR iDEN SOFTWARE DEVELOPERS"
Subscribe to Nextel2: http://www.groups.yahoo.com/subscribe/NEXTEL2

"WIRELESS FORUM HOMELAND SECURITY GROUP"
The Complete Resource for Wireless Homeland Security.
Subscribe to WFHSG:  http://www.groups.yahoo.com/subscribe/WFHSG

------------------------ Yahoo! Groups Sponsor ---------------------~-->
Get A Free Psychic Reading! Your Online Answer To Life's Important Questions.
http://us.click.yahoo.com/Lj3uPC/Me7FAA/CNxFAA/61FxlB/TM
---------------------------------------------------------------------~->

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