Subject: [NEXTEL-1] Nortel's Technical Interference Solution Re:02-55

From: [email-masked]
Date: Wed, 11 Jun 2003 06:07:03 -0400

Nortel's Technical Interference Solution Re:02-55
RURAL TELECOMMUNICATIONS GROUP
advocate of rural wireless telecommunications providers
1000 Vermont Avenue, NW, 10th Floor
Washington, DC 20005

June 10, 2003

Mr. Michael J. Wilhelm
Public Safety and Private Wireless Division
Wireless Telecommunications Bureau
Federal Communications Commission
445 12th Street, SW, Room 4C-305
Washington, DC 20554

Re: Ex Parte

WT Docket No. 02-55

Dear Mr. Wilhelm:

On April 8, 2003, Caressa D. Bennet, Gregory W. Whiteaker, and Kenneth C. Johnson
of Bennet & Bennet, PLLC, representing the Rural Telecommunications Group ("RTG"),
spoke with you regarding the costs to small, rural wireless carriers to implement
the 800 MHz relocation of Nextel pursuant to the "Consensus Plan." RTG had noted
that Motorola had determined that it would need to develop filtering equipment in
accordance with the Consensus Plan's technical specifications regarding
interference, and install and calibrate the filters on each carriers' individual
cell sites. At that time, we had not heard from Nortel regarding the possible need
to develop interference filters in line with any relocation of Nextel.

In order to update the record, we have attached a recent letter from Nortel in
response to inquiries from RTG members regarding the need for costly RF filters.
Nortel concludes, "it is likely that operators would be required to add
Interference Mitigation Filtering to Nortel Networks Base Station configurations."
As noted in the Nortel letter, Nortel is examining the "potential impact" of
proposed changes to the 800 MHz Band pursuant to this proceeding, leading us to
conclude that most any change to the 800 MHz Band will result in a negative
financial impact on small, rural A-Band carriers. Consistent with RTG's February
25, 2003 comments filed in this proceeding, we suggest that the Commission
consider a reimbursement mechanism or have Nextel and other carriers who
competitively profit from the relocation plan to bear the cost for the
interference filters.
If you have any questions regarding this filing, please communicate directly with
the undersigned.

Sincerely,

_________/s/____________
Caressa D. Bennet
General Counsel
Rural Telecommunications Group
Enclosure
cc:	

============================================================================================================

To the Attention of Nortel Networks Customers:

The Federal Communications Commission is currently evaluating options and
proposals for changing the
spectrum environment within the 800 & 900 MHz, frequency bands. This letter is
intended to provide Nortel
Networks' customers with information that may help in assessing the potential
implications of proposed
changes for existing 800 MHz TDMA, and CDMA networks in the United States.

In March of 2002, the FCC released the "Notice of Proposed Rulemaking that
Explores Options and
Alternatives for Improving the Spectrum Environment for Public Safety Operations
in the 800 MHz Band
and Consolidating the 900 MHz Industrial/Land Transportation and Business Pool
Channels" (WT Docket
No. 02-55). Following the public release of this notice, various stakeholder
groups began submitting
comments and proposals to the FCC as part of an ongoing dialogue. A complete
listing of all submissions is
available via the FCC web site: www.fcc.gov

A joint proposal submitted by a consortium of wireless operating companies on Dec.
24, 2002 has generated
considerable discussion amongst Wireless Network Operators and various Industry
Organizations as well as
within the FCC (DA 03-19 "Wireless Telecommunications Bureau seeks Comment on
'Supplemental
Comments of the Consensus Parties' filed in the 800 MHz Public Safety Interference
Proceeding - WT
Docket No. 02-55" released January 3, 2003). 

This proposal not only includes a number of suggested modifications to the current
spectrum environment and re-allocation of frequency blocks within the 800 MHz
band, but also makes specific recommendations for revising Out-of-Band Emission
(OOBE) specifications that could have potential implications for existing cellular
operators (detailed in Appendix F, section 4.1.2 of the above document).

The current FCC Standard for OOBE in the 800 MHz Band is as follows:

The power of any emission outside of the authorized operating frequency ranges
must be attenuated
below the transmitting power (P) by a factor of at least 43 + 10 log(P) dB.
Following the FCC's
measurement guidelines, this translates to OOBE that are less than -13 dBm/100
KHz.

There is some ambiguity in the phrasing of the submission from the Consensus
Parties concerning the
proposed OOBE specifications. Assuming that the existing 100 KHz measurement
bandwidth is used,however, if the proposed new OOBE specifications are accepted by
the FCC in their current form, existing base station transmitters operating in the
851-895 MHz band would be expected to comply with tighter OOBE performance
standards. The new OOBE standards recommended by the Consensus Parties are
summarized below:

o At 860.0 MHz; < -28 dBm/100 KHz*
o At 859.5 MHz; < -43 dBm/100 KHz*

o For all frequencies between 851 and 859 MHz; <-58 dBm/100 KHz* *Note: While the
measurement bandwidth applicable to the proposed new OOBE specifications is not
explicitly stated in the Consensus Parties' documents, it is assumed that the
current FCC methodology would apply (i.e., using a 100 KHz bandwidth).

While Nortel's CDMA and TDMA equipment meets or exceeds existing FCC standards,
including OOBE limits, should the proposed new standards be adopted by the FCC,
some Base Station configurations may no longer be compliant. 

It is expected that "A-band" cellular operators would be most directly affected by
this change. An analysis of current CDMA and TDMA base station performance
relative to the existing and proposed standards at 859 MHz is summarized in the
table below.

Summary of Nortel Networks Base Station Out-of-Band Emissions Performance

Nortel Base Station
Configuration

FCC Spec
< 859 MHz
(dBm/100 KHz)
Nortel BTS
OOBE
Performance
Spec
(dBm/100 KHz
@ 859 MHz)1
Proposed
Spec
< 859 MHz
(dBm/100 KHz)
Additional RF -
OOBE Filtering
Requirement
(dB)
CDMA
800 MHz SFRM with DPM - 13 - 36 - 58 Yes (~22 dB)
800 MHz SFRM with DPM &
Combiner - 13 - 48 - 58 Yes (~10 dB)
800 MHz SFRM with DPM & IMF - 13 - 101 - 58 No
800 MHz MFRM with DPM - 13 - 36 - 58 Yes (~22 dB)
800 MHz MFRM with DPM &
IMF - 13 - 101 - 58 No
TDMA
Macro (SCLPA) - 13 - 30 - 58 Yes (~28 dB)
Metro (DPA) - 13 - 30 - 58 Yes (~28 dB)
Urban (MCPA) - 13 - 30 - 58 Yes (~28 dB)
Minicell (MCPA) - 13 - 30 - 58 Yes (~28 dB)
Microcell (No PA) - 13 - 30 - 58 Yes (~28 dB)

NOTES:

1. The above analysis is intended only to illustrate the potential impact of the
proposed new OOBE standards on various Nortel Base Station configurations at 859
MHz. Should the FCC decide to assign new OOBE standards, Nortel will undertake a
detailed assessment of Base Station performance for TDMA and CDMA configurations
based on whatever specifications and measurement methodologies are adopted. 

 The Nortel Networks Base Station Specifications shown above represent product
performance specifications as measured under laboratory test conditions in
accordance with current FCC test procedures (with Nortel Networks' equipment
operating at the bottom end of the A band licensed spectrum). 

Actual OOBE field measurements for a given base station may vary depending upon
specific Base Station configuration and deployment parameters (i.e., including
antenna, cabling, filtering, carrier frequency, etc.). As can be seen from the
table above, it is likely that operators would be required to add Interference
Mitigation Filtering to Nortel Networks Base Station configurations that do not
meet the proposed new OOBE emissions standards.

 The type and extent of filtering required will vary depending on the air
interface technology in use (e.g., TDMA or CDMA) and the specific hardware
configuration deployed at each cell site.  Similarly, the cost, complexity and RF
performance impact of deploying any such additional filtering will vary depending
on the air interface technology and base station configuration in question. 

 Nortel is providing this information to help customers understand and assess the
potential impact of the proposed changes to their wireless networks operating in
the 800 MHz band. While customers are encouraged to assess the implications of the
proposed specification changes in terms of network RF performance and regulatory
compliance, it should be emphasized that the proposed new Out-of-Band Emissions
standards for the 800 MHz Band remain under review by the FCC. 

Should new standards be approved and implemented by the FCC, however, Nortel
Networks will immediately begin working with all affected customers to ensure that
the appropriate hardware upgrades are identified and made available for ordering
to bring affected sites into compliance.  This notice should not be viewed as a
Nortel Networks' statement of position either for, or against, the proposed new
800 MHz OOBE standards. Customers may, or may not, choose to provide comments to
the FCC, but are advised to monitor the FCC web site on a regular basis to keep
apprised of the ongoing discussion.

Please contact me should you have any questions or require further information.

On Behalf of Nortel Networks,

(COL or Account Representative)
--
http://svartifoss2.fcc.gov/prod/ecfs/retrieve.cgi?native_or_pdf=pdf&id_document=6514182303

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