Subject: [NEXTEL-1] UTC's "Balanced Approach" 800 MHz solution- 800 MHz Balanced Approach Proponents Response to FCC Inquiries

From: Marcel <[email-masked]>
Date: Fri, 02 May 2003 16:15:55 -0400

May 2, 2003

Marlene Dortch, Secretary
Federal Communications Commission
445 Twelfth Street, S.W., Room TW A-325
Washington, DC   20554

Re: Ex Parte Notice . WT Docket No. 02-55

Improving Public Safety Communications in the 800 MHz Band

To the Secretary:

This is to provide notice that, on May 1, 2003, the United Telecom Council (UTC)
submitted the attached document to Michael Wilhelm of the Wireless
Telecommunications Bureau concerning the above-referenced docket.  The
document provides responses to questions asked by Mr. Wilhelm in an earlier
meeting with UTC and other interested parties.

UTC, as part of the .Balanced Approach Proponents,. has suggested specific
changes to the technical rules for the 800 MHz land mobile frequency band to
help eliminate current and prevent future harmful interference to Public Safety
and other licensees operating in the band. The attached responses represent
further details and revisions to the group.s original proposal following additional
meetings among engineers representing several user groups.

This Notice is being filed pursuant to Section 1.1206 of the Commission's Rules
and Regulations, 47 C.F.R. § 1.1206.  If there are any questions concerning this
matter, please do not hesitate to contact me.

Sincerely,

Jill M. Lyon
Vice President and General Counsel
Cc: Michael Wilhelm
David Kaufman, Esq.
=========================================================================================
Attachment

800 MHz Balanced Approach Proponents
Response to FCC Inquiries

Summary

The 800 MHz Balanced Approach Proponents (Proponents) offer an alternative to the
rebanding of the 800 MHz band proposed by the Nextel Group. Details of the proposal
may be found in the FCC record and in documents used in ex parte meetings with the
FCC.

During the meetings with the Commission, FCC staff posed several technical questions
of the Proponents, so that they may come to an informed technical decision. This
document addresses those questions and is intended as a vehicle toward the end of
providing the FCC with a complete technical solution to replace the PWC group
proposal.

1) We claim a 89% reduction in intermodulation from the adoption of the 10-
watt transmitter ERP for low sites. How was that number calculated?
According to Pinnacle West Corp. (AZ Public Service) these figures came from early
Motorola comments in this proceeding and Pinnacle.s own comments. Some Proponent
participants subsequently have questioned the proposed 10-watt limit.

An alternative proposal is to limit the ERP of base stations with an antenna height of
100 feet above ground (30 meters) or less, to 100 watts. This power level is acceptable
to the Proponents and represents a 7 dB reduction in power over the 500 watts allowed
for rural systems and a 10 dB reduction in ERP over the 1000 watts allowed in suburban
environments. This power reduction should reduce significantly the signal level .on the
ground. from cellular-like systems in the 800 MHz band.

2) We suggest Part 101 be used to provide measurement criteria for system
reliability in connection with our "harmful interference" definition. These
rules do not easily transfer from microwave to land mobile -- how do we
propose to use these?

The intent here is to determine the percentage degradation of an existing system from
a proposed system. While the Part 101 engineering criteria calculates interference in
percentage degradation, it is true that these criteria cannot be directly applied to a
base
mobile system. As an alternative, the only available algorithm to calculate percentage
degradation for land mobile systems is the TSB-8.8 algorithm. While the TSB-8.8
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-8.8 could address potential interference from digital
operations on channels directly adjacent to proposed facilities. Frequency coordinators
800 MHz Balanced Approach Proponents 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 20-mile radius is proposed.

3) We recommend adjacent-channel spacing criteria be adopted by
coordinators. The WTB would like a proposal for this spacing.
Recommending an arbitrary adjacent-channel separation without knowledge of the
systems on those adjacent channels could be challenged on a technical basis. Input
from equipment manufacturers will lend some credibility to this approach. A reasonable
case could be made for an adjacent-channel separation by using the emissions
characteristics for digital equipment in the band. Unfortunately, emission characteristics

also are dependent on the ERP of the adjacent-channel base station. An accepted
model for digital, cellular-like base stations must be developed in order to come up with
a strong technical argument for this approach.

Use of TSB-8.8, rather than a strict adjacent-channel mileage separation, could resolve
any technical challenge with this approach.

4) We refer to "sideband emissions" separate from OOBE and suggest that
the 700 MHz rules be adopted. Are we referring to sideband noise, and how
is this different from OOBE?

We believe that all operations in the 800 MHz band (806-824/861-869 MHz) 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), which applies specifically to 700
MHz harmonics) for 12.5 kHz or wider operations, should replace the current rules
sections dealing with emission masks for various portions of the band. To implement
this standard, 47 CFR 90.691- Emission mask for EA-based systems, should be
modified. Should the Commission wish to take this opportunity to implement a unified
emission restriction across the 700-900 MHz bands, 47 CFR 90.669 - Emission limits for
MTA licensees also should be modified to apply 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.
Any interference that should occur after the implementation of these standards could be
resolved easily through .Best Practices. measures such as careful design 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.

We believe that the combination of low-site ERP restrictions, the adoption of the ACCP
attenuation requirements of 47 CFR 90.543, and the use of TSB-8.8 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.

http://gullfoss2.fcc.gov/prod/ecfs/retrieve.cgi?native_or_pdf=pdf&id_document=6514083015
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