Subject: [NEXTEL-1] NAM/MRFAC On 02-55

From: [email-masked]
Date: Sat, 02 Aug 2003 00:30:53 -0400

July 31, 2003
Ms. Marlene H. Dortch
Secretary
Federal Communications Commission
The Portals, TW-A325
445 Twelfth Street, SW
Washington, DC  20554

Re: Written Ex Parte Presentation

WT Docket No. 02-55

Dear Ms. Dortch:

The National Association of Manufacturers and MRFAC, Inc. (.NAM/MRFAC.) hereby
submit these further comments in the 800 MHz interference proceeding.

In NAM/MRFAC.s view, the record in this proceeding continues to improve.
Motorola.s filing of May 6, 2003, supplemented with its filings of June 20 and
July 18, provide important information  which  should  be  given  careful
consideration by the Commission in  reaching  a decision.    These  filings
demonstrate  that  switchable  attenuators, for example,  can  rectify  what even
Nextel  has  characterized  as  .the  most  frequently  observed  and dominant
interference mechanism,.  i.e.  intermodulation.

These  filings  have  special  significance  given  Motorola.s unique position as
the principal equipment supplier to both public safety/industrial users, on the
one hand, and Nextel, on the other hand. Motorola  has  also  presented  data
from  field  tests  verifying  the  utility of  attenuators  at numerous
locations  in  and  around  Las  Vegas,  San  Diego,  Broward  County
and  the  so-called Northwest Central Dispatch area in  Illinois.  Which  is  to
say,  at each of these locations public safety  system  signal  strength  was
found  sufficient  to  employ attenuators,  and  attenuators successfully
mitigated  the  intermodulation  interference.    Moreover,  in response  to
NAM/MRFAC questions as to whether users would have to significantly upgrade their
systems in order to take advantage of attenuators,

Motorola has responded that no significant changes in user  equipment  is
anticipated,  i.e.,  .  no  increase  or  change in desired signal strength was
necessary in the areas where Motorola has conducted testing and the solution has
worked..
This is not to say that attenuators are practical in every case, i.e., that the
victim system.s signal  strength  is  sufficient,  and  that  no  other
interference  mechanisms are  present.    Motorola itself  observes  that  at
one  of  the  four  sites  studied  in  San  Diego, attenuators produced a 50
percent  improvement  (as  opposed  to  100  percent  at  the  others);  and that
the  remaining interference  appeared  due  to  out-of-band  emissions (.OOBE.)
for  which additional  measures would be necessary.  Moreover, Nextel claims that
OOBE interference is present in about half of the interference cases.
It  is  to  say,  however,  that  before  resorting  to  radical  surgery  --
re-banding  --  the Commission  should  consider  more  conservative  treatments
which  did  not seem  as  practical earlier in this proceeding.

This is particularly the case given the unresolved issues pertaining to
implementation  of  re-banding  in  border  areas  and  the  over-wrought
complexity  and  legal deficiencies  in  the  Consensus  Parties.  re-banding
implementation  proposal.
Although  some have  argued  that  a  best  practices approach is too reactive, or
resource-intensive, the proposal contemplated  by  at  least  one  group  of
commenters  entails  an aggressive  outreach program  to identify and correct
interference cases.

A best practices approach which  includes  the  technical  .tool box. that
Motorola has described  could  be  implemented  at  least  as  soon  as  the
multi-year transition  that  re-banding would  require.    Moreover,  a
case-by-case  solution  is  likely  to  entail much  less  cost  than  that
involved  in  upending  many  hundreds,  if  not  thousands,  of  public  safety
and  industrial  radio systems, as re-banding would entail.  In this regard, the
record suggests that the cost  estimates presented  for  re-banding  may  be
unrealistically  low,  such  that  further information  should  be requested from
the equipment vendors on this point.
Respectfully submitted,
National Association of Manufacturers MRFAC, Inc.
[s] [s]
______________________________ ___________________________
Lawrence A. Fineran, Vice President Marvin McKinley, President
Regulatory and Competition Policy
cc: * Chairman Michael Powell Robert Eckert
 Commissioner Kathleen Abernathy Robert Bromery
 Commissioner Kevin Martin Ziad Sleen
 Commissioner Michael Copps Brian Marenco
 Commissioner Jonathan Adelstein William Hurst
 John Muleta
 David Means
 Edmond Thomas
 William Inglis
 Bryan Tramont
 Ira Keltz
 Jennifer Manner
 Solomon Satche
 Sam Feder
 Kathleen O.Brien-Ham
 Paul Margie
 Bruce Franca
 Barry Ohlson
 James Schlichting
 Cathy Seidel
 Rashmi Doshi
 D.wanna Terry
 Michael Marcus
 Herb Zeiler
 Julius Knapp
 John Schauble
 Fred Thomas
 Michael Wilhelm
 Alan Scrime
 Shelley Blakeney
 Bruce Romano

*All cc.s sent via electronic mail radios would need replacement).  While the
Motorola numbers did not relate to the Consensus Plan, they nonetheless raise a
question which should be explored further.

http://svartifoss2.fcc.gov/prod/ecfs/retrieve.cgi?native_or_pdf=pdf&id_document=6514288244

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