Subject: [NEXTEL-1] 800 MHz USER COALITION BALANCED APPROACH STATEMENT OF INTEREST

From: [email-masked]
Date: Sat, 12 Jul 2003 20:10:43 -0400

800 MHz USER COALITION BALANCED APPROACH
                               STATEMENT OF INTEREST

This coalition of parties believes that there are better alternatives to solving
the Public Safety interference problems in the 800 MHz band than the “Consensus
Plan” filed on December 24, 2002. The participants in this coalition include
entities from the 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. This group represents an even broader group of affected parties than
the so-called “Consensus Parties,” and it is representative of the licensees that
would suffer harm from the implementation of the “Consensus Parties’” Plan.

The premise of the 800 MHz User Coalition approach 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.” Given that, according
to the APCO database, only 1% of Public Safety systems reported interference
incidents last year, the common sense approach is to focus first on mitigating
those problems and preventing future interference, instead of jumping to a
“solution” that would disrupt 100% of Public Safety systems, not to mention all
other licensees in the 800 MHz band. The attached Statement of Principles and
detailed action plan describe a concrete alternative to the “Consensus Plan” that
relies on enhanced mitigation techniques that build upon, but go beyond, existing
“best practices." The proposed approach recognizes technical advances described in
recent filings by equipment manufacturers that further improve the potential for a
mitigation-oriented solution.

The 800 MHz User Coalition Balanced Approach offers a comprehensive alternative
plan to resolve interference in the 800 MHz band that, at the same time, promotes
spectrum efficiency and maximizes the future utility of the frequency band,
without the inefficient, heavy-handed, command and control aspects of the
“Consensus Plan.”

                        800 MHz USER COALITION SIGNATORIES
                                 Access Spectrum
                             Alameda Power & Telecom
                              ALLTEL Communications
                                Ameren Corporation
                          American Electric Power (AEP)
                          American Gas Association (AGA)
                     American Public Power Association (APPA)
                          Applied Technology Group, Inc.
                           AT&T Wireless Services, Inc.
                                 CLC Repeater Co.
            Cellular Telecommunications & Internet Association (CTIA)
                         Cherry Todd Electric Cooperative
                               Cinergy Corporation
                                Cingular Wireless
                           City of Baltimore, Maryland
                        City of Colorado Springs, Colorado
                               Consumers Energy Co.
                                     Dominion
                                   Duke Energy
                         Edison Electric Institute (EEI)
                                Exelon Corporation
                            Fresno Mobile Radio, Inc.
                         Holy Cross Electric Association
                            Kansas City Power & Light
                             Mobile Relay Associates
            National Rural Electrical Cooperative Association (NRECA)
                              Palomar Communications
                                 Peak Relay, Inc.
                           Pinnacle West Capital Corp.
                         Preferred Communication Systems
                       Small Business in Telecommunications
                          Southern Company/SouthernLINC
                        Supreme Radio Communications, Inc.
                               U.S. Cellular Corp.
                           United Telecom Council (UTC)
                                 Verizon Wireless
                                 Western Wireless
                                    Xcel Energy

STATEMENT OF PRINCIPLES FOR ADDRESSING 800 MHZ INTERFERENCE

Step 1: Solve interference through mandated mitigation using enhanced best
practices.
Immediate steps to improve mitigation techniques include:

  Licensees in the 800 MHz band should take pro-active steps to ensure that
potential interference situations are identified and avoided, to the extent
possible. Procedures to implement this approach are detailed in Attachment A.I.

  FCC should clarify and codify a policy that entities creating interference to
licensees in the 806-824/851-869 MHz band should be responsible for mitigating the
reported interference within 60 days of being contacted by the affected licensee,
at the cost of the interfering licensee. This policy would apply even if the
interfering licensee/equipment were operating consistent with current FCC rules
while causing the interference. Procedures to implement this approach are detailed
in Attachment A.II.
  Non-Public Safety 800 MHz licensees should provide engineering expertise and
assistance to Public Safety. All incumbent licensees in the 800 MHz band should be
full partners with other stakeholders in identifying incidents of interference and
evaluating and implementing solutions. Interference may be caused by transmitter
or receiver equipment.

  The APCO “Best Practices” recommendations should be enhanced and incorporated
into the FCC’s Rules, and all licensees operating in the 800 MHz band, including
Public Safety and private licensees, should be required to abide by these rules to
minimize interference.

  The FCC should adopt modified technical rules to prevent future interference,
incorporating many of the technical advances identified in filings by equipment
manufacturers. (See Attachment B for further detail on these technical measures).
  The FCC should allow more flexibility in current user pool eligibility
restrictions to allow private market agreements such as frequency swaps as a means
of reducing and preventing interference.

  Mitigation techniques that address interference to incumbent systems should not
come at the expense of non-interfering licensees, particularly Critical
Infrastructure licensees. The function of Critical Infrastructure licensees is
particularly vital in today’s atmosphere of heightened homeland security, and they
should not be accorded secondary treatment.

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

The review should be coordinated by an independent agent, working with a steering
committee including all affected stakeholders (a focused industry-Public Safety
working group), and should build on /incorporate existing efforts.

The review should be initiated immediately, and focus first on monitoring and
evaluating the track record of the enhanced best practices approach in resolving
interference concerns. It should, in addition, examine the nature and extent of
any remaining interference problems that are not adequately resolved by the
measures in Step 1, and develop concrete recommendations to fix them. The review
should be comprehensive, and include recommendations on solutions to avoid
specific problems (technical mitigation approaches beyond “ Enhanced Best
Practices”) as well as broader solutions if interference is not sufficiently
mitigated.

The review would involve the affected 800 MHz stakeholders contributing
engineering expertise and assistance to Public Safety.  The review should include
recommendations on funding of any appropriate remediation measures. Remediation
measures should be limited if initial mitigation techniques are as successful as
anticipated.

ATTACHMENT A
PROPOSED PROCEDURES FOR INTERFERENCE MITIGATION
IN 806-824/851-869 MHz BAND

I. Procedures to Identify and Avoid Incidences of Interference in the
806-824/851-869 MHz band.
  Any licensee wishing to install a new antenna in the 851-869 MHz band at height
of less than 30 meters AGL (“low-site transmitters”) shall notify co- and adjacent
channel licensees within the protected service contour (via filing at the FCC in
ULS or an alternative database) and appropriate frequency coordinators 30 days in
advance of the installation of the site providing the following information:

 Licensee Name
 Point of Contact-Information: Name, address, telephone number, and e-mail address
for technical person knowledgeable about site.
Site Coordinates

Certification: The licensee shall certify that it has performed an engineering
analysis pursuant to generally accepted industry practices and has determined that
its operation of that site is not predicted to cause co-channel or adjacent
channel interference to other licensees in the 806-824/851-869 MHz Band within
service areas that overlap a 5,000 foot radius around its transmitter site.

II. Procedures to Address Identified Interference 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 to be established and
operated jointly by the licensees of low-site systems in this band. Specific
geographic location where interference is occurring, FCC license information for
the Complainant’s system, Point of Contact Information for the Complainant’s
system.

The Complainant shall identify:

All licensees receiving notice of complaint via the website shall respond within
two business days and shall confirm whether they have systems operating within
5,000 feet of alleged site of interference. On-site analysis: The Complainant
shall contact the potentially responsible contributors to the interference to
arrange for an on-site analysis to take place within five businessdays (or later
at the discretion of the complaining entity). The Complainant and all potential
contributors shall support the analysis effort.

Mitigation steps:

If the analysis finds that interference is caused by something other than the
equipment belonging to potential contributor system operators (e.g., a
bi-directional amplifier (“BDA”) installed by a third party, or
“receiver-generated” IM interference), the owner of the equipment shall be
responsible for mitigating the interference. The participants in the on-site
analysis shall be responsible for notifying the equipment owner of this finding.

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. The FCC shall order appropriate steps to resolve
interference in the most efficient manner, including by such means as specifying
the transmitter power, antenna height or frequency, or requiring other changes in
operation or equipment to correct the problem.

When the analysis shows that one or more of the suspected interfering operators
are actually interfering with the system in question, the contributors to the
interference shall correct the interference per industry-standard mitigation
techniques. The resolution of the interference shall be documented and copies
provided to each contributor and the complaining licensee.
If mitigation of interference at a site requires that contributors make changes
that can be easily reversed or substantially modified (e.g., changing of
transmitter frequencies to avoid intermodulation (“IM”) product formation on a
particular frequency, or a reduction in on-street power), then the contributor
making the change shall continue to coordinate both with the other contributors
and the complaining entity before making further changes to the site.

ATTACHMENT B

TECHNICAL RULE MODIFICATIONS

  The following technical rules, in addition to the requirement, described above,
that interfering licensees correct their interference, should be adopted as part
of the effort to resolve interference through improved mitigation techniques. The
FCC should: Require licensees in the 800 MHz band to comply with the procedures
outlined in Attachment A, i.e.:

• Notify co- and adjacent channel licensees within the protected service contour
(via filing at the FCC in ULS) and appropriate authorized 800/900 MHz frequency
coordinators 30 days in advance of initiating transmissions from a new “low site
transmitter”.

• Respond to interference complaints within two business days and resolve
interference expeditiously through industry-standard mitigation techniques.

Require Licensees in the 806-824/851-869 MHz band to calculate percentage
degradation for land mobile systems by using the TSB-88 algorithm. While the
TSB-88 algorithm was developed to address interference issues associated with land
mobile refarming, the methodology could be used at 800 MHz to evaluate co-channel
and adjacent-channel systems. Implementing the use of TSB-88 could address
potential interference from digital operations on channels directly adjacent to
proposed facilities. Frequency coordinators in the band must decide on mileage
criteria that would necessitate evaluation of adjacent-channel facilities. Absent
a current recommendation from 800 MHz frequency coordinators, a 70-mile radius is
proposed.
Codify or amend the regulations as necessary to allow for external filtering and
other added equipment to be used to reduce or eliminate 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.

• “Low sites” may be defined similarly to the “cellular” definition offered by the
Consensus Plan, i.e.: sites: 1) that are included within a system with five or
more overlapping sites with handoff capability; 2) with twenty or more operating
frequencies; and 3) with antennas at a height of up to 30 meters above ground.

All base station operations in the 806-824/851-869 MHz band should be subject to a
single rules section concerning emission restrictions. The requirements of 47 CFR
90.543 – Emissions limitations, including the ACCP
Tables addressing adjacent channel and OOBE levels (excepting subparagraph (e))
for 12.5 kHz or wider operations, should, at an appropriate future date, replace
the current rules sections dealing with emission masks for various portions of the
band, modified as necessary to accommodate bandwidths currently not included in
the ACCP Tables. To implement this standard, 47 CFR 90.691- Emission mask for
EA-based systems, and 47 CFR 90.669 - Emission limits for MTA licensees, should be
modified to conform to the above standard. This, coupled with ERP restrictions,
would significantly reduce the possibility of
interference between and to noise-limited systems operating in the vicinity of low
sites.

• The combination of low-site ERP restrictions, the adoption of the ACCP
attenuation requirements of 47 CFR 90.543, and the use of TSB-88 for adjacent
channel separation, coupled with the removal of eligibility barriers to permit
“frequency swapping” and other measures to allow operators to reduce or eliminate
interference, will eliminate the need for the creation of a “guard band” as
described in the PWC Plan, Appendix F, Section 4.1.2. As has been stated
previously, the “sliding scale” of protection for frequencies in the proposed
guard band might not significantly impact low-power campus systems, but would have
a devastating impact on wide-area users currently licensed and operating in the
proposed guard band, as well as the many non-public safety incumbent systems that
would be required to retune to the 859-861 MHz portion of the band under the PWC
proposal.Establish adjacent channel spacing standards for use in coordinating
non-EA channels, to facilitate the ability of frequency coordinators to review the
spacing of channels adjacent to the frequency under consideration, as well as the
co-channel spacing, during the coordination process.

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. Under this proposal, manufacturers would be able to produce equipment
usable across the entire band, maintaining economies of scale, encouraging
manufacturer involvement and innovation and benefiting the 800 MHz market in
general.

• Motorola, for example, is testing the use of switchable attenuators in portable
receivers to reduce the strength of signals entering the receiver in strong signal
areas that would otherwise result in non-linear operation of the low noise
amplifier and mixer, creating intermodulation interference.

• Motorola is also testing software-controlled tunable filters in their portable
receivers that retune the filter based on received signalstrength, allowing the
portable to operate correctly in the presence of strong CMRS signals. Further,
Motorola has written that “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.”3
3 Id.

http://svartifoss2.fcc.gov/prod/ecfs/retrieve.cgi?native_or_pdf=pdf&id_document=6514285540

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