Subject: [NEXTEL-1] 800 MHz User Coalition Presentation-

From: [email-masked]
Date: Wed, 25 Jun 2003 02:07:59 -0400

800 MHz User Coalition
                                 Presentation to
                                   Paul Margie
                                  June 24, 2003

                CELLULAR TELECOMMUNICATIONS & INTERNET ASSOCIATION

                              800 MHz USER COALITION

      •The wireless industry remains committed to working with Public Safety
     and the other licensees in the 800 MHz band to address the ultimate goal
             of this proceeding –resolution of interference problems.

        •Over 30 signatories, including representatives from Public Safety,
         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 have signed on to the Coalition
                                    Proposal.

                  THE JOINT COMMENTERS’ PROPOSAL IS NOT WORKABLE

                          •The proposal is too complex:
              –Numerous working parts over almost four year period.

                      •The proposal lacks adequate funding:
        –NextWave-type installment mechanism, 3% percent downpayment on its
                                     pledge.

       –Many doubt that Nextel’s estimates are realistic. If money runsout,
                 unfinished relocation could exacerbate problem.

                  •The proposal suffers from legal infirmities:
            –Illegal under section 309 (j) of the Communications Act.

          THE 800 MHz USER COALITION PROPOSAL PROVIDES A BETTER SOLUTION

       •The premise of the 800 MHz User Coalition proposal 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.”

      •The proposal is based on a common sense approach that focuses first on
          mitigating existing interference problems andpreventing future
      interference, instead of jumping to a “solution”that would disrupt 100%
                            of Public Safety systems.

      •The proposal relies on enhanced mitigation techniques that build upon,
                     but go beyond, existing “best practices.”

           STATEMENT OF PRINCIPLES FOR ADDRESSING 800 MHz INTERFERENCE

    •Step 1 -solve interference through mandated mitigation using enhanced best
                              practices, including:

               –Pro-active steps to identify and avoid interference

     –Codification of policy that entities creating interference must mitigate
                  interference within 60 days of being contacted

–Non-Public Safety 800 MHz licensees would provide engineering expertise to Public
                                      Safety

      –All 800 MHz licensees should participate in working toward solutions

    –FCC should adopt modified technical rules to prevent future interference

–FCC should allow more flexibility for private market agreements such as frequency
                                      swaps

           STATEMENT OF PRINCIPLES FOR ADDRESSING 800 MHz INTERFERENCE

  •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 ifand
  only if these mitigation techniques and rule changes do not adequately resolve
                                  interference.

  –Review coordinated by an independent agent, working with a steering committee
                       including all affected stakeholders.

  –Review initiated immediately, focusing first on monitoring and evaluating the
  track record of the enhanced best practices approach in resolving interference
                                    concerns.

    –Review to include recommendations on any broader solutions thatmight prove
 necessary if interference is not sufficiently mitigated, as well as on funding of
                      any appropriate remediation measures.

     –Remediation measures should be limited if mitigation is as successful as
                                   anticipated.

                  PROPOSED PROCEDURES FOR INTERFERENCE MITIGATION

              I. Procedures to identify and avoidinterference in the
                            806-824/851-869 MHz band:

   –Licensees installing any new low-site antennas in the 851-869 MHz band shall
notify co-and adjacent channel licensees and appropriate frequency coordinators 30
          days in advance of installation of the following information:

                          •Point of contact information

                                •Site coordinates

                      •Certification of engineering analysis

                 PROPOSED PROCEDURES FOR INTERFERENCE MITIGATION

            II. Procedures to address identifiedinterference 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, identifying the specific
               geographic location where interference is occurring.

 –All licensees receiving notice of complaint via the website shall respond within
  two business days, confirming whether they have systems operating within 5,000
                                      feet.

      –An on-site engineering analysis including all potentially responsible
   contributors and the complainant will take place within five business days.

                 PROPOSED PROCEDURES FOR INTERFERENCE MITIGATION

       III. Procedures to address identified interference problems (cont.):

                                –Mitigation steps
•The contributors to the interference identified in the engineering analysis shall
     correct the interference using industry-standard mitigation techniques.

     •When changes can be easily reversed or substantially modified, then the
  contributor making the change shall coordinate both with the other contributors
                and the complaining entity before making changes.

  •If the analysis finds that interference is caused by something other than the
  equipment belonging to potential contributor system operators, the owner of the
         equipment shall be responsible for mitigating the interference.

 –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.

                            TECHNICAL RULE MODIFICATIONS

   •The FCC should adopt the following technical rules as part of the effort to
           resolve interference through improved mitigation techniques:

    –Require Licensees in the 806-824/851-869 MHz band to calculate percentage
                    degradation by using the TSB-88 algorithm.

 –Codify or amend the regulations as necessary to allow for external filtering and
                  other added equipment to reduce 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.

 –All base station operations in the 806-824/851-869 MHz band should be subject to
            a single rules selection concerning emission restrictions.

   –Establish adjacent channel spacing standards for use in coordinating non-EA
                                    channels.

                           TECHNICAL RULE MODIFICATIONS

    •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.

  –Motorola is testing the use of switchable attenuators in portable receivers to
     reduce the strength signals entering the receiver in strong signal areas

  –Motorola is also testing software-controlled tunable filters in their portable
        receivers that retune the filter based on received signal strength

http://svartifoss2.fcc.gov/prod/ecfs/retrieve.cgi?native_or_pdf=pdf&id_document=6514282234