Subject: [NEXTEL-1] FCC Q & A To SouthernLinc- Re: 02-55

From: [email-masked]
Date: Fri, 13 Feb 2004 04:42:13 -0500

February 11 , 2004
Via Email
Mr. Edmond 1. Thomas
Chief Engineer
Office of Engineering and Technology
Federal Communications Commission
445 Twelfth Street, S.
Washington, DC 20554

Re: Southern LINC; 800 MHz Public Safety Interference Proceeding,
WT 02-55; Ex Parte Presentation

Dear Mr. Thomas:

This is to follow up on several questions that arose during our meeting on
January 27
2004, concerning the FCC' s ongoing proceeding on interference to public safety
systems in the
800 MHz band. During that meeting, we described Southern s proposal for
accommodation of
its system in the 800 MHz band in spectrum that would be designated as
commercial
cellularized spectrum but would extend below the 861 MHz line suggested by the
"Consensus
Plan. " As we discussed, Southern does not support rebanding; but it feels
strongly that if the
Commission proceeds with rebanding, Southern must be accommodated on spectrum of
an equal
quality and quantity to that of other commercial providers in the band, most
prominently N extel
Communications.

Q: Why would it be more difficult/costly/complicated for Southern s system to be

relocated completely above 861 MHz, rather than a band extending primarily below
861 MHz?

As explained below, if Southern LINC were forced to relocate into spectrum that
begins
at 861 MHz and goes up, none of Southern s current subscriber units would have
enough
channels in the 861-866 MHz range programmed into their "bandmap" to supply more
than a
handful of cell sites in Southern s system with matching control channels. That
would mean that
every handset within the Southern LINC system would have to be "touched. " With
a subscriber
base of over 270 000 customers, this would be an extremely burdensome and costly
exercise.

Also, every frequency within every cell site in the Southern LINC system would
likely have to
be changed, resulting in the maximum possible retuning cost for the Southern
LINC network.
By way of background, programmed into each subscriber unit on the Southern LINC
system is a control channel scan list or "bandmap." The bandmap primarily
contains frequencies
below 861 MHz, although there are a few channels in this group above 861 MHz.
The purpose
of this bandmap is to allow a subscriber unit access to the Southern LINC
network during its
power-up phase, which is when a person turns the radio " " from the "off' state.
At least one
frequency in the subscriber unit bandmap must match a cell site frequency to
allow the access
process to work at any given site. Since the length of the power-up phase of the
subscriber unit
is directly proportional to the number of frequencies in the bandmap, not all of
the 600 channels
between 851-866 MHz can be included in the bandmap. Even if it were practical to
include all
six hundred, a carrier normally would only be authorized to transmit on a
portion of this number.
A subscriber unit's bandmap typically consists of between 100 and 200 channels.
During its power-up phase the subscriber unit scans the bandmap and compares it
to all
frequencies on which Southern LINC is transmitting in the user s area. When it
finds a
frequency in the bandmap that has sufficient signal strength, it will request
service from the
Southern LINC network using that frequency. Assuming it is a valid Southern LINC
subscriber
unit and all communications from the subscriber unit via the bandmap frequency
go well, the
subscriber unit will gain access to the Southern LINC system.

Once access to the Southern LINC system is gained, the subscriber unit will
continue to
monitor the bandmap frequency that allowed it access to the system unless
"handed over" to
another frequency. This hand over can occur in one of two ways. Once the
subscriber unit
attempts to place or receive a call, the bandmap frequency will assign it to a
"traffic-carrying
frequency within the same cell. Handovers can also occur from cell-to-cell in
the case of a
subscriber unit that is moving from the coverage area of one cell into the
coverage area of
another cell.

One of the subscriber unit bandmap frequencies is commonly programmed into each
cell
site in the number one frequency position. This frequency is referred to as the
cell site s "control
channel." The frequency designated as the cell site s control channel allows
subscribers to gain
access to the network and also assigns subscriber units to traffic channels (i.
, designated
frequencies within the same cell that are not used as control channels) so that
the subscriber units
can make and receive calls.

Since a cell site s control channel is essentially responsible for allowing
subscriber unit
access and for routing all subscriber unit traffic, every cell site within the
system should have a
control channel that utilizes a frequency that is also in the bandmap of all the
subscriber units. If
this is not the case, the cell will only be able to accept subscriber traffic
that is handed over to it
from another cell because it will not be able to authenticate subscriber units
onto the system.
This results in a cell not having the complete functionality of typical cells
and, in the event of
non-overlapping coverage (such as in rural areas), in a cell being virtually
invisible to subscriber
units.

Considering all these factors, it becomes apparent that for maximum system
efficiency,
all control channels for cell sites must be within the subscriber unit bandmap,
and the carrier
must have a license to use at least one of the bandmap frequencies at each cell
site.
The majority of the frequencies in Southern LINC' s subscriber unit bandmap are
between
854. 7625 and 860. 9875 MHz. The spectrum relocation plan that Southern
suggested in its filing
of February 10, 2003 , will maximize the number of current bandmap channels that
are present
within the spectrum to which Southern would have to be relocated, thereby
significantly
reducing the number of customer handsets and individual cell sites that would
have to be
retuned. In contrast, if Southern is forced to move into a spectrum home that
begins at 861 MHz
and goes up, there would be very few of its existing subscriber bandmap channels
in this group
of channels, and very few matching control channels at Southern s 500 plus cell
sites. That
would mean that every handset would have to be touched and frequencies in every
cell site
within the Southern LINC system would likely have to be changed if Southern were
forced to
relocate to spectrum above 861 MHz. Placing the entire Southern system above 861
MHz also
would impact Nextel directly since there is not enough spectrum above 861 MHz to
accommodate both systems.
This massive retuning effort would mean a dramatic increase in the retuning cost
for the
Southern LINC system alone. If rebanding is adopted, it is likely that Southern
LINC will be
one of the first entities in its area to retune (it is the largest single system
in the 800 MHz band
other than Nextel). Migration exclusively above 861 MHz would result in the
maximum
possible retuning cost for the Southern LINC network and reduce funds available
for other licensees from the $850 million relocation fund Southern believes that
this is neither prudent nor necessary to accomplish any of the objectives of
this docket.

Q: How high above ground are Southern LINC' s antennas in urban and other
parts of its service territory?

A: The Southern LINC system has over 500 antenna sites throughout a four-state
area. As
Southern has stated previously, its system is generally comprised of a mix of
high and low site
antennas.

In the Atlanta metropolitan area, which comprises approximately 20 counties
around
Atlanta, Southern s minimum antenna height is 70 feet above ground level (AGL),
and its
average antenna height is approximately 179 feet AGL. Similar figures are
reflected in the
Birmingham metropolitan area where Southern has a minimum antenna height of 50
feet and an
average antenna height of 170 feet. In addition, over 20% of cell sites in the
Birmingham metropolitan area have an antenna height of less than 100 feet.

Nextel has attempted in this proceeding to portray Southern s system as
architecturally
distinct from its own. While it is true that Southern has not experienced the
types of interference
problems being created by Nextel, both Southern s and Nextel' s systems are a
combination of
1 However, there is no industry or regulatory definition of what constitutes a
high or low antenna site.
high and low site antennas. Accordingly, Southern does not believe that there is
a rational basis
on which to make regulatory distinctions between CMRS competitors based on a
notion of
antenna heights" or "cellular architecture. " Certainly the definition of
"cellularized" found in
the Consensus Plan, i.
, "
a system with (1) more than five overlapping, interactive sites
featuring hand-off capability and (2) sites with antenna heights of less than
100 feet above
ground level on HAATs ofless than 500 feet and (3) sites with more than 20
paired
frequencies 2 would include both Nextel' s and Southern s systems.

Nevertheless, the Consensus Parties seem to imply that, as a regulatory
construct, only one entity is likely to meet
this definition, and that is Nextel. This is simply not true.

Southern reiterates its opposition to rebanding and urges the Commission not to
proceed
in this direction. If it does, however, it should do so only by treating all
participants fairly. The
band plan Southern has proposed for its network on a number of occasions in this
proceeding,
and again herein, would provide the minimum amount of regulatory symmetry to
achieve a
legally viable result for Southern. The Consensus Plan does not do this and
instead significantly
advantages one competitor. The Commission cannot lawfully proceed to adopt the
Consensus
Plan as proposed.

Very truly yours
Isl Christine M Gill
Christine M. Gill
Attachments
cc: Chairman Michael K. Powell
 Commissioner Kathleen Q. Abernathy
 Commissioner Jonathan S. Adelstein
 Commissioner Michael 1. Copps
 Commissioner Kevin 1. Martin
 John B. Muleta, Wireless Telecommunications Bureau
 Julius P. Knapp, Office of Engineering and Technology
 Michael 1. Wilhelm, Wireless Telecommunications Bureau
 Catherine W. Seidel, Wireless Telecommunications Bureau
 Aaron Goldberger, Wireless Telecommunications Bureau
 Marlene H. Dortch, Secretary
2 See Reply Comments of Consensus Parties, at 10.

http://svartifoss2.fcc.gov/prod/ecfs/retrieve.cgi?native_or_pdf=pdf&id_document=6515782079

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