Subject: [NEXTEL-1] Boeing supports the principles underlying the 800 MHz User Coalition Balanced Approach

From: [email-masked]
Date: Fri, 18 Jul 2003 15:06:03 -0400

The Boeing Company
Frequency Management Services
P.O. Box 3707
Seattle, Washington 98124

July 17, 2003

VIA ELECTRONIC FILING
Ms. Marlene H. Dortch
Secretary
Federal Communications Commission
TW-A325
445 12th Street, S.W.
Washington, D.C. 20554

Re:   Improving Public Safety Communications in the 800 MHz Band

(WT Docket No. 02-55)
Dear Secretary Dortch:

The Boeing Company (.Boeing.) takes this opportunity to express its opinion on
recent developments in the Commission.s pending 800 MHz proceeding.  As one of the
larger private business users of the 800 MHz band and a user of 800 MHz spectrum
in the Canadian border region, Boeing is demonstrably affected by the proposed
resolutions to interference to public safety and other users in the 800 MHz band.

Boeing supports the principles underlying the 800 MHz User Coalition.s Balanced
Approach (hereinafter referred to as the .Balanced Approach.).  Boeing believes
that the Balanced Approach provides interference resolution and prevention without
the accompanying detriments of forced rebanding.  The Balanced Approach will
provide immediate, effective solutions that better serve the interests of the
majority of users of the 800 MHz band.  It provides near-term benefits that will
likely provide an adequate long-term solution as well, and wisely defers drastic
action pending an impartial assessment of the sufficiency of its .Step 1.
measures.1  Furthermore, because the Balanced Approach does not mandate rebanding,
it avoids the complex issues that exist with respect to renegotiating border
region bilateral agreements.

1  Although Boeing supports  the  Balanced Approach, Boeing  recommends one change
to the proposal.   Specifically, the Balanced Approach  calls  for  Commission
intervention  60  days after the parties fail to reach an interference
resolution.    Boeing would encourage  the Commission to become involved in
interference resolution as soon as either party considers it necessary to request
the Commission.s assistance.

Boeing also believes that the technical options recently advanced by Motorola
(e.g., switchable attenuators and software-controlled tunable filters) can be used
in conjunction with the Balanced Approach to further reduce the prospects of
interference.  Consistent with the current practice that interference causers pay
for interference mitigation, Boeing believes that those causing harmful
interference  in the 800 MHz band should bear the costs of either modifying their
own systems or providing these new technologies to public safety and other
entities where needed.  In stark contrast, after well over a year of industry
vetting, the .Consensus Proposal. remains an inadequate approach to resolve the
800 MHz problem.  It is an interest group driven, overly  complex, and inequitable
proposal that would cause unrivaled displacement and inconvenience to incumbent
users without a guarantee of funding or success.  Furthermore, as detailed in
Boeing.s prior comments, Boeing remains  critically concerned regarding the
failure of the .Consensus Proposal. to address adequately issues related to the
Canadian and Mexican border regions.
The time has come for the Commission to adopt a resolution to the 800 MHz
interference problems raised in this proceeding.  Boeing urges the Commission to
maintain its focus on the overall public interest and the elimination of harmful
interference to public safety operations.  This goal can be attained without
.reinventing the wheel. or a wholesale reorganization of the band.  Through the
use of the Balanced Approach and vigilant enforcement of the Commission.s existing
rules, the Commission has the tools and the authority necessary to perform this
task.

Sincerely,

__/s/  Sheldon R. Bentley__________
Sheldon R. Bentley
Spectrum Management and Radio Services
Shared Services Group
The Boeing Company
P.O. Box 3707, MC 3U-AJ
Seattle, WA 98124-2207
(253) 657-6713

http://svartifoss2.fcc.gov/prod/ecfs/retrieve.cgi?native_or_pdf=pdf&id_document=6514286254

------------------------ Yahoo! Groups Sponsor ---------------------~-->
Get a FREE REFINANCE QUOTE - click here!
http://us.click.yahoo.com/nHYuCC/ca0FAA/ySSFAA/61FxlB/TM
---------------------------------------------------------------------~->

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