Subject: [NEXTEL-1] Haven's latest reply comments

From: Marcel <[email-masked]>
Date: Tue, 12 Nov 2002 18:07:52 -0500

-------- Original Message --------
From: "Todd Ellis" <[email-masked]>
Subject: Haven's latest reply comments

For those who didn't read Warren Haven's last submission to the
Commission...comments from the group?

This is from WT Docket No. 02-310...and is contained verbatim in the Reply
Comments of Warren C. Havens and Telesaurus Holdings GB, LLC DBA LMS
Wireless.  There are also comments about 900 MHz deployment possibilities
that are not transcribed below.

New rules for AMTS 217-218 and 219-220 MHz, 218 MHz, 220-222 MHz, and
222-225
MHz (in total, 217-255 MHz) (there's a typo there, it is 217-225 MHZ - TE)

See discussion of these bands in each attachment below for the basic LMSW
proposal for
a new service composed of these bands.  Consistent with Attachment 1 below,
replace current
rules with rules providing as follows:

Create a new Part 90 service.  Use the rules currently in 220 MHz as the
basic
framework: for site placement, permitted services, operations, etc.

This would create a viable 8 MHz-wide service, sufficient in scope for
development of
needed advanced digital technology and integration with 902-928 MHz as under
the ATLIS plan.
All current licensees would be benefited, as would equipment providers.
Amateurs could take
advantage of the components developed for the band and use it in 222-225 MHz
on a non-
interfering basis.

In 220-225 MHz, Amateurs would remain but on secondary basis, as in 219-220
MHz.
See comments above under 902-928 MHz: by the increased viability of the
band, including more
advanced and cost effective equipment, Amateurs use would be benefited, and
Amateurs could
more effectively plan roles in Civil Defense situations.

Regarding AMTS:  The Commission in the 5th Report and Order removed the
requirement to provide service coverage to waterway traffic.  In recent
Orders it removed
requirements to provide protection to TV stations, in the Fill-in station
rule, and by defining
?only suitable? (to protect TV stations) as ?especially suitable? (to allow
station placement that the applicant favors for its purposes without regard
to TV protection).  Also, the Commission adopted the 220 MHz service and
interference protection contours.  There is no remaining basis for
distinguishing AMTS and 220 MHz.   A similar situation applies to the 218
MHz service.

Differing sets of basic rules (site placement, permitted services,
operation, etc.) will substantially hinder development of these bands as one
more viable service.

Todd Ellis
Operations Manager, Telecommunications Division
Booth & Associates, Inc., a Utility Services Associates company
An Employee-Owned Business
1011 Schaub Drive, Raleigh, NC 27606
Phone: (919) 851-8770, ext. 109  Fax:  (919) 859-5918
Cellular:  (919) 418-3358  Alpha Pager:  (877) 205-9320
E-mail:  [email-masked]
Two-way SMS: [email-masked]
Web:  www.booth-assoc.com
Telecommunications, Transmission & Distribution, System Planning and Special
Projects,
Mapping and Field Services, Substations & Relaying, Strategic & Financial
Services

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