Subject: [NEXTEL-1] What is it, and why does APCO, IACP, IAFC, NPSTC, and other public safety organizations support it?

From: [email-masked]
Date: Wed, 30 Jul 2003 11:59:52 -0400

The 800 MHz Consensus Plan:

What is it, and why does APCO, IACP, IAFC, NPSTC, and other public safety
organizations support it?

The Plan was developed by a coalition of public safety and private wireless
organizations, along with Nextel, to address the serious, growing problem of
interference to 800 MHz public safety radio systems.

The interference is fundamentally a function of the interleaving of Nextel’s
cellular-type channels with public safety and private wireless channels in the 800
MHz band.  Adjacent cellular-band operations are also a significant contributing
factor, especially as to interference to NPSPAC channels.

 Case-by-case efforts to resolve interference have been largely ineffective and,
in any event, are “reactive” to interference after it occurs.  What’s needed is a
plan to prevent the interference from occurring in the first place.  That can only
be accomplished by “re-banding” to segregate frequencies used by public safety for
high-site, high power from frequencies used by Nextel and others for low-site,
low-power cellular systems.

A comprehensive, proactive solution is necessary as the interference problem is
severe, wide-spread, and getting worse as both cellular and public safety systems
expand their networks and add sites.

? The Plan calls for frequency shifts within the band, which for the vast majority
of impacted licensees can be accomplished through re-tuning of existing radios.
Once the Plan is fully implemented, channel interleaving will have been
eliminated, with Nextel and other cellular-type operations at the “high-end” of
the band, and public safety/private wireless at the low end of the band (adjacent
to the new 700 MHz public safety band).

The Plan will help alleviate all forms of interference, including both
intermodulation and out-of-band emissions caused by the current interleaving of
channels in a proactive manner. Strictly “reactive” approaches advocated by some
factions are insufficient in the long run for the critical nature of public safety
systems. There is no 100% solution to interference.  Generally accepted Best
Practices must become an additional supportive tool to help the overall situation.

 Nextel has pledged $850 million to pay costs of frequency shifts (though the FCC
may decide to impose an unlimited financial obligation on Nextel to pay all
reasonable costs).

 The Plan will yield a significant amount of new public safety channels in the 800
MHz band, as well as some additional 700 MHz band spectrum for public safety (in
addition to existing allocations).
 The “Balanced Approach” is Inferior to the Consensus Plan

CTIA (representing cellular firms), United Telecom Council (an electric utility
trade association), and other various parties have advocated a so-called “Balanced
Approach” as an alternative to the Consensus Plan. The Balanced Approach relies on
reactive mitigation efforts to address interference problems once they have
already occurred.  A recent proposal from Motorola to improve radio equipment and
to make it less susceptible to some forms of interference would not address the
fundamental problem (band plan), would not address OOBE, will potentially not
benefit legacy equipment, represents a significant cost that must be bourn by
public safety agencies, and may not be embraced by other equipment manufacturers.

Problems with the Balanced Approach:

It’s largely reactive to interference problems, and does little to prevent
interference from occurring in the first place.

? Some of the interference mitigation steps could actually lead to an increase in
interference, by requiring Nextel to add cell sites.

? The Balance Approach recommends specific channel swap with Nextel as a possible
remedy.  That is useless for resolving interference to NPSPAC channels, which are
in a contiguous block of public safety channels.

? In some cases, the responsibility for correcting interference under the Balanced
Approach will fall on public safety licensees.

? Motorola’s proposed equipment improvements, while welcome, are only a partial
answer.  At most, the improvements only address interference caused by
intermodulation, not by out-of-band emissions (a factor in approximately 50% of
interference cases).  Furthermore, the equipment improvements are only effective
for public safety systems that already meet certain minimum levels of
performance.  Systems not meeting those levels would need to increase power levels
or add transmitter sites, at considerable expense.

? The Balanced Approach does not include any viable plan to pay the cost of its
implementation (e.g., upgrading Motorola radios and/or system performance).

? The Balanced Approach does not include any new spectrum for public safety.

 We hope that you agree that the Consensus Plan is the most effective means of
addressing public safety needs in the 800 MHz band.   You can voice your support
for the Plan by sending a letter to the FCC in the following format:

[Agency letterhead]

Marlene H. Dortch
Secretary
Federal Communications Commission
445 12th Street, SW
Washington, DC 20554

 RE:  Docket 02-55

Dear Ms. Dortch:

 I [or name of agency] would like to express my [its] support for the “Consensus
Plan” filed by public safety organizations, private wireless organizations, and
Nextel, in the above-reference proceeding regarding interference to 800 MHz public
safety systems.

[insert paragraph describing your agency, its 800 MHz system (if any), and
experience that it may have had with interference problems in the 800 MHz band.]

[insert paragraph in your own words indicating why you believe that the FCC should
adopt the Consensus Plan.  Among the issues that you may want to include are:

it will eliminate most interference to critical systems
it addresses the root cause of interference (rather than just fixing it after the
fact)
it provides for funding to implement the plan
it will provide additional 800 MHz band channels for public safety]
.

       Respectfully submitted,

       [name of agency]

       By:_________________
       [TYPE NAME AND TITLE OF          SIGNATORY]
[DATE]
_______________________________________________________________________
The letter can be filed on the Internet through the FCC’s Electronic Comment
Filing System (ECFS).  Go to
http://gullfoss2.fcc.gov/prod/ecfs/upload_v2.cgi                         , and
fill out the “cover sheet” using “02-55” as the proceeding number.  Your letter
can be attached as a pdf, Word, or Wordperfect file.

Should you have any questions regarding the process for filing comments, contact
Robert Gurss, APCO’s Director of Legal and Government Affairs, at (202) 833-3800
or [email-masked].  Questions regarding the Consensus Plan can be addressed to
[    ]

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