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

From: [email-masked]
Date: Fri, 14 Nov 2003 13:03:19 -0500

From : NAM/MRFAC

November 13, 2003
Secretary
Federal Communications Commission
The Portals, TW-A325
445 Twelfth Street, SW
Washington, D.C.  20554
Re:  Written Ex Parte Presentation
WT Docket No. 02-55

Dear Ms. Dortch:

This is to advise that on November 12, Lawrence A. Fineran, Vice-President,
National Association of Manufacturers, and the undersigned met with Edmond J. Thomas,
Chief, Office of Engineering and Technology, and James Schlichting, Deputy Chief, and the OET
staff members noted below, regarding the above-captioned proceeding.  The NAM/MRFAC
representatives addressed the points set forth in the NAM/MRFAC filings in this
proceeding.

An original and one copy of this letter are submitted for inclusion in the
Docket.

Respectfully submitted,
/s/ William K. Keane
William K. Keane
Their Counsel

Cc:
 Edmond J. Thomas
 James Schlichting
 Michael Marcus
 Robert Eckert
 Salomon Satche
 Rashmi Doshi

800 MHz Interference
The Latest Revisions to the Nextel Consensus Plan Do Not Resolve Concerns
Expressed in
Earlier NAM/MRFAC Comments

Five-Nine Year (or More?) Freeze on Additions/Modifications to B/I/LT System

Would Harm Hundreds of NAM/MRFAC Members by Limiting Innovation,

Productivity, and Security Improvements

Five-Year Set-Aside of Channels for Public Safety Would Restrict Business

Growth and Relocation Opportunities for Industrial and Business Licensees

  Cost Estimates for Re-Banding Understated
  Inadequate Assurance of Funding Could Derail Re-Tuning Mid-Stream
  Reimbursement Process Insulated from Effective Commission Oversight Risks

Manipulation and Bias

  Continues to Avoid Hard Issues Associated with Border Regions

More Conservative Treatments Should Be Tried Before Radical Surgery
  Commonality Between Balanced Approach and Nextel Plan Forms Basis For First
Step, e.g.:

  Adopt Rules Specifying Interference Correction Rights and Responsibilities

  Adopt Complaint Procedure In The Event A Cellular Licensee Fails to
 Cooperate

Specify Time Period for Trial of Case-by-Case Solutions, e.g. Six Months
or Less

Provides an Opportunity for Real-World Evaluation of Less Drastic Proposals:  An

Ounce of Experience With This Approach Worth A Pound of Pleadings

 In the Event Step One Fails, Implement Re-Banding Along the Lines of That

Proposed by Consensus Parties -- Assuming Concerns with Present Proposal
Resolved
http://gullfoss2.fcc.gov/prod/ecfs/retrieve.cgi?native_or_pdf=pdf&id_document=6515290173

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