Subject: [NEXTEL-1] Motorola Presents Technical Solutions To Nextel Interference as an Alternate to "The Plan" 02-55

From: Marcel <[email-masked]>
Date: Tue, 06 May 2003 21:01:30 -0400

Motorola, Inc., Global Government Relations
1350 I Street, N.W., Suite 400, Washington, DC 20005 T: (202) 371-6900

May 6, 2003

Mr. Edmond Thomas
Chief, Office of Engineering and Technology
Federal Communications Commission
445 12th St., N.W.

Washington, DC 20005
Re: WT Docket No. 02-55

Dear Mr. Thomas,

Thank you for your letter dated April 18, 2003, requesting updated information relevant to
the
above captioned proceeding considering ways to resolve interference to public safety
operations in the
800 MHz band. Motorola has been active in this proceeding, providing information on the
mechanisms
resulting in inference from low-site CMRS base stations to public safety receivers, on
potential technical
solutions to the interference, and on the challenges in implementing these technical
solutions.

Motorola has continued to work to overcome these challenges and, as the record in this
proceeding has developed, it appears that there are new opportunities for successfully
resolving many of
the instances of interference through advances in receiver technology and increased signal
strength for
public safety systems. Motorola believes that technical advances in receiver design are
commercially
viable, will have limited impact on the cost of portable public safety equipment and
provide a real
opportunity for alleviating interference to public safety. While we are still in the
process of testing to
fully understand the degree to which these advances will mitigate interference to public
safety, testing
and analysis to date is very promising and Motorola plans to deploy the receiver
technology
advancements by the end of 2003. Motorola believes that it possible to alleviate a
majority of the
interference being experienced through best practices and new technical solutions.

Interference to any public safety system is serious and must be proactively avoided, if
possible,
and dealt with as rapidly as possible when it does occur. This approach has the advantage
of limiting the
disruption to public safety operations to those areas that experience, or are likely to
experience
interference, which is relatively small compared to the 2,139 public safety systems
deployed in the 800
MHz band.1 A review of the APCO database on interference shows 24 unique customer issues
in 2000,
7 in 2001, 23 in 2002, and 5 in the first quarter 2003. A total solution must include
coordination
between public safety and CMRS operators to identify areas where interference is likely,
so that the
 Number of public safety systems is derived from the FCC licensing database.

problem can be addressed before it happens. Motorola believes that the technical solutions
discussed
herein provide the means to do so, while not impacting the public safety systems that are
not
experiencing interference.

Motorola is pleased to provide the Commission with currently available information on the
status
of our efforts and to provide additional information as it becomes available. We would
also welcome
the opportunity to work with the Commission to develop as complete a solution as possible.

 Interference is the Result of Dissimilar Systems Developed for Dissimilar Service
Requirements
The interference addressed by this proceeding has developed as CMRS operators have moved
from relatively high-site operations to low-site configurations that provide greater
channel reuse and
higher system capacity. Conversely, public safety systems are primarily deployed using
high antenna
heights to achieve maximum coverage for a smaller number of users. As a result of this
difference in
system deployment, public safety receivers in some areas experience a large relative
difference between
the desired signal strength of public safety systems and the undesired signal strength for
CMRS
operations. This large relative difference in signal strengths results in intermodulation
interference,
interference from out-of-band emissions, and receiver overload interference as described
in your letter.
The interference is exacerbated by the interleaved or adjacent channel operation of
low-site CMRS
systems with public safety in the 800 MHz band.

CMRS operators have recognized their responsibility to resolve the interference and have
worked with public safety users pursuant to a best practices guide to resolve interference
on a case-bycase
basis as it occurs.2 Seeking a proactive, longer-term solution, Nextel, working with
associations
that represent public safety and private radio interests, has developed a plan (“consensus
plan”), which
would significantly reduce the interference in the 800 MHz band by consolidating public
safety use and
eliminating the interleaving of CMRS channels with public safety.

In developing the consensus plan, the parties recognized that eliminating channel
interleaving is
not sufficient to eliminate interference to non-cellular operations, but that additional
procedural and
technical changes are necessary. Accordingly, the consensus plan proposes that the
Commission take
steps to further limit the out-of-band emissions from cellular operations, that best
practices continue to
2 The Best Practices Guide was developed in December 2000 by a working group of experts
from the Association of Public-
Safety Communications Officials-International, the Cellular Telecommunications & Internet
Association, Motorola, Nextel
Communications, and the Public Safety Wireless Network and provides guidance on avoiding
interference between public
safety systems and CMRS.

Significantly, the consensus plan also proposes that interference protection only be
afforded to
non-cellular operators, including public safety and private users, if they meet the
following threshold
requirements, 1) the desired signal levels at the non-cellular receive must meet or exceed
–98 dBm for
existing systems or –95 dBm for new systems, and 2) the users’ receivers must meet the
Telecommunications Industry Association (“TIA”) Class A performance specifications.4 In
areas where
these threshold conditions are met, the consensus agreement calls for use of best
practices to resolve
interference should it occur. No protection would be afforded in areas where the threshold
conditions
are not met and it is the responsibility of the party receiving interference to resolve
interference should it
occur.

Limiting the areas where interference protection is afforded is a significant deviation
from
current practice. Motorola noted in its comments that the threshold levels of –95 dBm and
–98 dBm do
not correspond to the minimum expected usable signal strength of today’s public safety
systems.6 The
proposed criteria would require some public safety systems to increase the signal strength
by
approximately 8 to 11 dB from current levels to retain the right to operate “free from
measurable
interference.”7 In agreeing to a minimum signal strength as part of the solution for
resolving
interference, representatives of public safety and private radio users have significantly
expanded the
options available for a technical resolution. Motorola’s technical advances detailed here
are, in large
part, a consequence of this significant agreement on increased signal strength.

 Radio Receiver

Throughout this proceeding, CMRS carriers have challenged manufacturers to develop public
safety radio receivers that offer greater immunity to interference than radios that are
currently deployed.

Carriers have focused largely on the intermodulation rejection performance of receivers
and on the filter
characteristics of the receivers. Motorola has provided information demonstrating that our
public safety
receivers already provide from 1 - 14 dB greater intermodulation rejection than radios
deployed by
CMRS systems.

Motorola has also described the negative impacts of further improving
intermodulation performance at this time – primarily increased power drain resulting in
unacceptable
battery life for portable units. With regard to use of narrower filters as proposed by
some CMRS
carriers, Motorola has provided information showing the increased insertion loss for
narrower filters
compared to filters currently employed. An across-the-board increase in insertion loss
reduces the
sensitivity of the radio at all times, thereby reducing public safety coverage in weak
signal areas.

Despite these challenges, Motorola has continued to dedicate engineering resources to
respond to
changing customer requirements as the radio environment in the 800 MHz band has moved from
one in
which predominately high-site systems were deployed to one in which public safety
high-site systems
must operate adjacent to and interleaved with low-site commercial systems. Implementing
technical
solutions proved to be daunting based on the current noise limited design of public safety
systems that
require reliable operation in weak signal areas. The technical solutions are not
compatible with public
safety’s current need to operate reliably in weak signal areas.

However, based on the consensus plan, it appears that all parties recognize the need for
increasing the signal strength for public safety systems to provide maximum reliability
and to overcome
interference. Motorola is confident that, with increased signal strength in previously
weak signal areas,
some of the technical solutions that Motorola has pursued are feasible and will largely
mitigate the
interference. These solutions can be incorporated into best practices procedures and used
in the shortterm
to resolve interference in areas where it is experienced or where it is likely, while also
providing
long-term mitigation of interference.12 This approach focuses resources and disruption in
the limited
number of areas where interference occurs rather than disrupting public safety operations
nationwide.
At the same time, this approach offers a long-term increase in the overall reliability of
public safety
systems.

At the request of the Office of Engineering and Technology, Motorola has participated in a

number of discussions exploring the feasibility of resolving interference to public safety
on a case-bycase
basis. These discussions have focused largely on increasing the desired signal strength in
areas
where public safety is receiving interference. While simply increasing signal strength
will address
interference in many cases, Motorola notes that it is often not a straightforward
proposition to do so.14
In some cases adding additional base stations can be difficult because of cost, tower
construction and
site leasing needs. In some areas it also will not be possible just to add an additional
base station
because no additional frequencies are available. In such cases, users will have to convert
their systems
to support simulcast operation. Adding simulcast sites creates additional intrasystem
interference
concerns. Motorola has taken these issues into consideration as it has explored solutions.

a. Switchable Attenuators

In its October 30, 2002 ex parte presentation to the Office of Engineering and Technology,

Motorola discussed one method of addressing interference by using a switchable attenuator
to reduce the
strength of signals entering the receiver that would otherwise result in non-linear
operation of the low
noise amplifier and mixer, creating intermodulation interference. However, activating the
attenuator
desensitizes the radio and would result in loss of coverage in weak signal areas.
Accordingly, while a
switchable attenuator can be used to mitigate interference in strong desired signal areas,
it is not feasible
to use it at the edge of coverage for current public safety systems. One challenge of such
a solution is
ensuring that the attenuator is only activated in areas where the desired signal is
sufficient to ensure
reliable communications.

Motorola has made substantial progress in addressing the challenges of implementing a
switchable attenuator in a way that reduces interference in areas of sufficient desired
signal strength
while ensuring that the attenuator does not degrade the reliability of public safety
communications by
activating when the desired signal is too low. Motorola now views this as a commercially
viable feature
when the public safety signal strength is sufficiently strong. Testing has shown a
significant
improvement in immunity to interference for portable receivers equipped with this feature
over current
designs.

The user requirement is for 95% coverage (5% outage) on the edge of the service area for a
typical
public safety system. Interference results largely because of a relative difference
between the desired
public safety signal and the undesired CMRS signal. Accordingly, the potential for
interference is
greatest in areas far from the public safety site, where the public safety signal is
weakest, and close to a
CMRS site, where the undesired signal is strongest. Radios with a higher IMR17 are more
tolerant of a
difference between desired and undesired signals making it possible to increase the
spacing between a
CMRS base station and a public safety base station. In a noise limited environment (no
interference) the
size of the public safety site can typically be up to 15 miles as indicated by the green
line. For radios
with IMR performance of 70 dB, the percent outage increases significantly around the CMRS
site as the
separation between the public safety site and a potentially interfering18 CMRS site
increases. A 70 dB
IMR radio will meet the target coverage (solid red line) only when potentially interfering
CMRS sites
are located within 3 miles of the public safety site. Potentially interfering CMRS sites
within
approximately 8 miles can be tolerated (solid black line) if a 75 dB IMR radio is used.

A 70 dB IMR radio that turns on 15 dB of attenuation when the desired signal is greater
than -95
dBm is shown in Figure 1 as the red line with tick marks. Results indicate that the IM
performance of
this radio approximates the performance of 75 dB IMR radio without the attenuator. A radio
with IM
performance of 75 dB and a switchable attenuator that turns on 10 dB of attenuation when
the desired
signal level is greater than -99 dBm, indicates that potentially interfering CMRS sites
within
approximately 12 miles will allow the public safety users to achieve the 95% coverage
criteria. The
performance of a 75 dB IM portable with the switchable attenuator approximates or exceeds
the level of
performance experienced by Motorola’s current mobile radios that meet the TIA class A 75
dB IMR
parameter. Motorola is not aware of any cases of interference reported for mobile radios
that meet that
specification.

Motorola believes that a combination of switchable attenuators and increased public safety
signal
strength in weak signal areas will mitigate the interference being experienced to a large
extent.
Implementing a switchable attenuator solution would require replacing or retrofitting
radios in areas
where interference can’t be resolved by other best practices. Motorola believes that a
field upgrade kit
could be developed for some radios. Radios with switchable attenuators will also be
implemented
through the normal purchasing cycle for users, raising the future overall immunity of
systems to
interference. Motorola expects to have radios with switchable attenuators commercially
available by the
end of 2003. The addition of a switchable attenuator will have only a minimal impact on
the cost of
receivers.

b. Tunable Varactors

Another solution that Motorola has pursued is to tune dynamically the varactor filter on
its radios
that operate in both the 700 MHz and 800 MHz bands. Filter performance for public safety
radios has
been a significant focus of some CMRS carriers, which claim that filters on newer public
safety radios
are unnecessarily wide and allow excessive energy from out-of-band sources into the front
end of the
radio.19 Motorola has provided information describing the purpose of the radio filters and
the
performance implications of reduced public safety coverage due to higher insertion loss
with narrower
filters. This loss of coverage on all radios under all circumstances is unacceptable for
public safety users
and Motorola believes that the use of narrower filters is therefore not feasible.

However, the filters that are in radios covering both the 700 MHz and 800 MHz bands, the
XTS
2500 and XTS 5000 models, are equipped with tunable filters. The filters have been tuned
to maximize
receiver sensitivity (low insertion loss) while preventing interference from receiver
image spurs.20
While narrowing the pass band of these filters is not feasible, Motorola has been testing
new software
that retunes the filter based on received signal strength. Motorola has found that, with
the tunable
varactor filter tuned away from the cellular radio frequencies, increasing the in-band
attenuation and
providing the same effect as the switchable attenuator, interference has been
significantly mitigated.
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.

c. Improved Intermodulation Rejection Performance

Finally, Motorola has provided information to the record of this proceeding describing the

superior intermodulation rejection performance of public safety radios and the
consequences of
significantly improving performance with currently deployed technology. Improving
performance
would come at the cost of increased current drain, which would shorten the usable duration
of a battery
to unacceptable levels – less than a full shift for a public safety user. However, as
Motorola has
previously stated, IMR performance has improved by 10-15 dB over the last 15 years.21
While we do
not see any reason to expect a sudden, significant improvement in performance, it is
reasonable to
expect the trend in incremental improvements in IMR performance to continue as technology
and design
advances. Accordingly, in addition to the solutions described above, the Commission could
reasonably
expect to see interference decrease in the future as technology continues to advance.

III. Results of Testing
Motorola is in the process of testing the solutions described above to ensure that they
can be
implemented in a way that mitigates interference while meeting the high reliability
requirements
necessary for the public safety community. Testing has been conducted in both the
laboratory and the
field and has focused on two areas,

1) to determine whether the solutions create any adverse behavior on
the part of the receiver and,

2) to determine how effectively the solutions reduce intermodulation
interference.

Motorola has previously provided information on potential adverse behavior for a solution
involving a switchable attenuator.

Because the attenuator desensitizes the radio, it cannot be used in
areas where the desired signal is relatively weak. Accordingly, proper control of
attenuator switching is
critical to ensuring that public safety personnel do not miss calls. It is important that
the attenuator
control mechanism not mistakenly activate the attenuator in an area where the undesired,
rather that the
desired, signal is strong. The feature must also interact properly with all of the radio
features, including
scanning, and system handover. Since use of these features may involve both strong and
weak desired
signals, the radio must be able to protect itself in strong signal areas, but remain
available for weak
signals when necessary. Testing also ensured that the attenuator hysteresis is properly
adjusted to avoid
rapid switching, particularly as the radio experiences rapid fading.

With laboratory and field testing at several sites, Motorola has gained confidence that
the
attenuator decision algorithm is sufficiently reliable and sophisticated enough to handle
the situations
described above Beta testing with customers is the next step in the evaluation of the
attenuator
technology. Motorola sees no significant technical problems remaining for implementation.
.
The other focus of testing, determining the effectiveness of the solutions in reducing
outages due
to intermodulation interference, has also been very encouraging. Figure 2 shows laboratory
testing of
the IM rejection of several Motorola radios versus the desired signal power, all of which
meet TIA Class
A receiver specifications. The XTS3000 and XTS5000 are portable radios, the Astro Spectra
and
XTL5000 are mobile radios. The XTS5000, modified by adding an attenuator, data shows how
the
front-end attenuator provides significant improvement in the IM rejection when the
attenuator is
enabled. In fact, the portable with the attenuator turned on will exceed the IM rejection
performance of
mobile radios. Motorola is not aware of any CMRS interference issues with mobile radios
that meet
TIA Class A receiver requirements.

Field Testing:

Motorola has very recently begun field testing of radios with modified software for
detuning the
front end filters as well as radios with switchable attenuators. Motorola has conducted
this testing on
customer sites with little customer involvement because of the newness of the technology.
However,
customer testing and certification of the results is in progress. This testing focuses on
several areas
including, evaluation and enhancement of the decision algorithm, qualitative performance
of the
attenuator and detuned front-end filter, and some feature interaction. Following is a
brief summary of
current, in progress, testing and our earlier findings.

1) Anne Arundel County– The 700/800 MHz dual-band radios having a wider front end
characteristic are more susceptible to energy from the cellular 800 MHz bands than the
older generation
800 MHz only radios. This has led to interference at some customer sites that was not
present from
previous generation radios. Testing with switchable attenuator and retuned front end has
shown that
both of these implementations mitigated this interference. Beta testing of retuned
front-end software
upgrade is planned to begin in May 2003.

2) Columbus, Ohio – The situation is similar to that experienced in Anne Arundel county
and
similar improved results were experienced. In addition, at two sites we found that the
700/800 MHz
dual-band radios with modifications did have better audio performance than the existing
800 MHz only
radios. Beta testing of retuned front-end software upgrade is planned to begin in May
2003.

3) Sacramento Metro Fire Department –The fire department has been unable to communicate
with existing radios in a “tank-farm” area due to interference. With the modified
700/800MHz dualband
radios communication was possible in the tank-farm where it was not possible before.

4) Phoenix/Mesa: This is a new Motorola system that is being installed and has not yet
been
turned over to the customer. One site in east Mesa was found to have interference from
CMRS sites.
Testing with radios with retuned front-end software and radios with switchable attenuators
eliminated
the interference found at this site.

5) Washington County – This was one of the earliest cases of interference. This testing
incorporated unmodified MTS2000 portables, modified MTS2000 portables23 and portables with

switchable attenuators. At the test location, the unmodified MTS2000 would not receive or
function in
any Trunked mode. The modified MTS2000 functioned in all scenarios, but only marginally,
it would
break up and be noisy and occasionally lose a channel assignment in Trunking mode. The
portables
with the switchable attenuator worked perfectly in all scenarios, there was negligible
noise on desired
signals and Trunking mode functioned normally.

These results are largely qualitative, but demonstrate a marked reduction in
intermodulation
interference. Motorola is in the process of developing more quantitative test information
and is
dedicated to moving forward aggressively on testing products with the solutions discussed
above to
quicken commercial availability. Motorola plans to begin beta testing with customers as
early as May
2003 and to have the switchable attenuator solution available in commercial products by
the end of
2003.

III. Revised and Forward Looking Best Practices for Avoiding Interference
a. Revised Best Practices

Motorola believes that an updated set of best practices, incorporating the technical
advances
described above, provides a foundation on which to address interference to public safety
in the 800 MHz
band.

The current best practices guide calls for a number of steps to be taken, including
retuning
CMRS channels away from public safety operators channels; modifying CMRS power levels,
antenna
height and antenna characteristics; assuring proper operation of base station equipment;
and improving
the local signal strength of the public safety communications system.24 With the
availability of
advanced receiver designs, Motorola now recommends that the best practices guide be
modified to
include deployment of enhanced receivers in areas where the public safety signal strength
is sufficient to
support their use. Accordingly, where interference cannot be otherwise resolved, the
public safety
signal strength would need to be evaluated and deployment of new receivers would be
included in
conjunction with a plan to improve the public safety signal strength, if necessary, to
improve the overall
performance of the public safety system.

Motorola notes that rebanding the 800 MHz band does not eliminate the need for best
practices.
The consensus parties recognized this and included recommendations for revising the
current best
practices guide to include improving out-of-band emissions for CMRS systems, improving the
signal
strength of public safety systems, and ensuring that public safety receivers are
compatible with the
newly defined operating environment. Motorola agrees with this approach and, as stated in
our previous
comments, recommends that the industry work together to fully define the radio environment
in which
radios are expected to operate. This will provide a clear target for radio performance
requirements while
providing flexibility for manufactures to meet these requirements as effectively as
possible.

b. Forward Looking Best Practices

It is important that best practices not be focused on reactive procedures to address
interference
after it occurs. Public safety communications must not be compromised with only the
promise of
working to solve the problem after the fact. Accordingly, a key part of best practices
should be for
public safety and CMRS operators to work together to identify areas or situations where
interference is
likely, and to address the problem before it occurs. As recommended by the consensus
parties, best
practices must include agreed methods for measurement procedures and procedures for
predicting
interference. The best practices guide should establish procedures for when parties must
conduct an
analysis and the type of information that must be provided. It is only through a
collaborative effort that
interference will be successfully controlled.

c. Benefits of Best Practices – Limited disruption and Limited Expense

Interference to public safety must be addressed as efficiently and effectively as
possible, and in a
way that minimizes disruption of services. A revised best practices approach has the
advantage of
limiting disruption to only those systems and areas experiencing or likely to experience
interference.
While interference is serious when it occurs, the record indicates that it is occurring in
a relatively small
number of systems compared to the total number of public safety systems. A review of the
APCO
database on interference shows 24 unique customer issues in 2000, 7 in 2001, 23 in 2002,
and 5 in the
first quarter 2003. This is compared to a total of 2,139 public safety systems deployed at
800 MHz
Accordingly, focusing on these areas makes sense, provided that long-term mitigation is
possible.
Enhanced public safety receiver performance, and increased public safety signal strength
provides such
long-term mitigation. Regardless of whether these changes are made in addressing an
individual case of
interference, overall improvements will be incorporated by public safety over time as
equipment is
replaced. Best practices therefore offer both a quickly available short-term solution and
a long-term
solution.

IV. Conclusion

Motorola is pleased to provide the FCC with updated technical information related to
resolving
interference to public safety in the 800 MHz band. Advances in radio receiver design,
combined with an
agreement by user representatives that increased signal strength should be part of a
solution, make a
technical solution to resolving interference in the 800 MHz a viable option.

While Motorola is still in the process of testing new receivers, the results of testing to
date are
very promising. Advanced receivers would successfully mitigate interference in a number of
instances
where it has occurred. The addition of switchable attenuators brings the performance of
portable radios,
in areas of sufficient signal strength, to levels exceeding current TIA Class A mobile
radios, and
Motorola is not aware of any reports of interference to mobile radios which meet the TIA
Class A
specification. Based on these results, Motorola believes that a technical solution, based
best practices
offers both a long-term and short-term solution for addressing interference. Coordination
between
CMRS and public safety will provide a viable mechanism for preventing interference before
it happens.
Because a technical solution can be focused on areas where interference occurs or is
likely, this
approach avoids widespread disruption to public safety operations. Motorola would welcome
the
opportunity to work with the Commission to further refine such an approach and to provide
additional
information as testing continues.

Sincerely,

/s/ Steve B. Sharkey
Steve B. Sharkey
Director, Spectrum and Standards Strategy
Motorola, Inc.

1350 I St., N.W.
Suite 400
Washington, D.C. 20005
(202) 371-6953
cc: Julius Knapp
James Schlichting
Alan Scrime
Fred Thomas
--
    "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

---

From: Marcel <[email-masked]>
Date: Thu, 08 May 2003 11:25:12 -0400

I hope everyone has had a chance to digest this since Tuesday. The Mainstream Media and
Wall Street is just catching on to Motorola's alternative to the "Plan Scam".

This just threw a BIG WRENCH in Timmy's plans and they are drinking Pepto-Bismol for
breakfast in Reston today.
Motorola's plan has some good points and some bad points. The suggestion of increasing the
power to overcome interference is detrimental to the 800 Mhz band. Nextel will just do the
same and the higher noise floor will render distant communication for Public Safety NULL..

Nextel has been on their normal PUMP UP THE STOCK routine for a few weeks and this news
will bring it back down quickly.

As they say-

                            Stay Tuned....We will be here
                                                                            Same Bat
Time...............

Same Bat Channel!

Marcel wrote:

> Thank you for your letter dated April 18, 2003, requesting updated information relevant
> to the
> the instances of interference through advances in receiver technology and increased
> signal strength for

------------------------ Yahoo! Groups Sponsor ---------------------~-->
Rent DVDs Online - Over 14,500 titles.
No Late Fees & Free Shipping.
Try Netflix for FREE!
http://us.click.yahoo.com/YoVfrB/XP.FAA/uetFAA/61FxlB/TM
---------------------------------------------------------------------~->

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