Subject: [NEXTEL-1] RE: State of New York Office for Technology supports modified Consensus Plan

From: [email-masked]
Date: Wed, 19 Nov 2003 20:43:35 -0500

-------- Original Message --------
From: [email-masked]
Subject: RE:  State of New York Office for Technology supports modified
Consensus Plan

	In a recent test of an interference case that I've been a witness
to, Nextel was using a "post consensus plan" channel alignment along with
the PS agency. The PS signal levels were above the "consensus plan"
threshold, and there are still interference problems in this situation.
	As stated in the email below: "This plan, as modified, now promises
to "virtually eliminate" interference from cellular mobile radio service
("CMRS") to public safety by an average of 99 percent for current National
Public Safety Planning Advisory Committee ("NPSPAC") licensees, and by an
average of 88 percent for public safety licensees in the non-cellular block
(809-814/854-859 MHz)"
	So, I guess this falls under the 88% "virtual" category. 
	As a matter of fact out of approx. 57 locations to have been
identified as  interference problems in a particular county caused by
Nextel, 35 sites were able to be resolved by downtilt, power, and/or freq.
changes on Nextel's part. Another 14 of them are expected to be resolved
with purchase of new PS portables with better IMD specs. Leaving 8 locations
that are not expected to be resolved. That's 8 of 57 locations....14% of the
locations that are expected not to be resolved. And that is without
re-banding. So if the Consensus Plan is saying 12% of the interference
locations can not be resolved with rebanding, then why do it if there are
ways for the interfering party to resolve interference without rebanding and
disrupting a major number of licensees with little if any more gain than can
be realized with other methods?

Bryan

EX PARTE COMMENTS OF THE
NEW YORK STATE OFFICE FOR TECHNOLOGY

STATEWIDE WIRELESS NETWORK

November 18, 2003

1. The New York State Office for Technology, Statewide Wireless Network
(SWN),
submits the following comments in support of the August 7, 2003 Ex Parte
Submission
of the Consensus Parties in the above-captioned proceeding. With 441
licenses in the
806-824/851-869 MHz band, SWN is one of the largest 800 MHz Public Safety
license
holders in the US, and therefore has a tremendous stake in the outcome of
this
proceeding. New York State supports the modified Consensus Proposal, and
urges the
Commission to adopt the modified "Consensus" proposal so that the re-banding
process
may proceed as quickly as possible.

2. The latest version of the "Consensus Plan" proposes to make changes to
Appendix F of
the December 2002 version of the plan - and we specifically cite Attachment
1 of the
August 7, 2003 Ex Parte Comments, which is intended to provide additional
interference
protection to post-re-banded 806-816/851-861 MHz users. This plan, as
modified, now
promises to "virtually eliminate" interference from cellular mobile radio
service
("CMRS") to public safety by an average of 99 percent for current National
Public Safety
Planning Advisory Committee ("NPSPAC") licensees, and by an average of 88
percent
for public safety licensees in the non-cellular block (809-814/854-859 MHz)
(1) The State
is supportive of these proposed changes, which afford public safety enhanced
interference
protection against both out of band emissions (OOBE) and intermodulation
from CMRS.

3. The State is very encouraged to see relaxation of the minimum signal
level thresholds -
which is necessary for reliable operation, and to protect public safety and
private wireless
operators from CMRS interference (2) Furthermore, all licensees operating in
the noncellular
806-816/851-861 MHz band are now protected, not just those outside of the
previously defined 814-816/859-861 MHz "guard band". The proposed plan now
protects public safety licensees by lowering the median (3) desired levels
required for
interference protection to -101 dBm for portable radios and -104 dBm for
mobile radios
in the area of interference (4) The key aspect of these reduced thresholds
is that they will
no longer require public safety systems to be designed on an
interference-limited basis in
order to receive interference protection. This is extremely important to the
State, and has
been reiterated time and again within many of our previous filings.

4. The State supports the relief provided to licensees in the 851-861 MHz
guard band
channels through the removal of the mitigation threshold sliding scale (5)
The proposed
change prohibits CMRS to public safety interference on guard band channels
resulting
from OOBE and intermodulation. The proposed plan will require CMRS to take
the
same corrective actions for guard band licensees as they do for those who
have relocated
to the "new" NPSPAC channels (6) This eliminates our previous concerns that
licensees
within international border areas would be forced into guard band
operations, and thus
suffer under an unbearable minimum signal requirement in order to obtain
interference
protection.

5. Our comments in the past only offered conditional support of the
consensus plan. This
was mainly due to the high minimum threshold levels that were specified, and
the lack of
guard band (7) interference protection (8) Higher threshold levels and lack
of protection in
the guard band would have serious consequences on the design of future
public safety
radio systems due to an increased noise floor. Imposing these constraints on
radio system
engineers requires systems to be designed on an interference-limited basis.
Due to the
increased number of tower sites associated with interference-limited
designs, the impact
felt by public safety would be financial. In fiscally challenged communities
these
constraints can seriously affect the ability to fund and construct public
safety radio
systems.

6. The State feels the proposed modifications to the Consensus Plan will be
beneficial to the
interests of public safety. We feel the proposed threshold levels will
adequately protect
public safety operation from harmful interference caused by CMRS.
Additionally, these
thresholds will not require public safety radio systems to be designed on an
interference-
limited basis. To ensure the plan's success due diligence is required from
CMRS
licensees in remedying interference caused by OOBE and intermodulation. This
plan
will go a long way to protect licensees from CMRS interference. However,
once the plan
has been enacted the incumbents must remain vigilant to ensure the same
mistakes are
not repeated. The problems that resulted in proceedings of WT Docket 02-55
must be
avoided to prevent them from happen again. Note that cellular like
operations within the
segregated block can be handled quite easily, since effective frequency
coordination can
geographically partition the technologies as necessary (9).

7. Although we feel that there are additional minor aspects of the Consensus
Proposal that
remain to be addressed, we feel comfortable at this point they can and will
be resolved as
this Docket proceeds. Therefore we place the support of New York State
behind the
modified Consensus Plan Proposal, and urge the Commission to adopt the
proposal so
that the re-banding process may proceed as quickly as possible.

Respectfully Submitted,

Hanford C. Thomas
Director - Statewide Wireless Network
New York State Office for Technology
State Capital ESP, PO Box 2062
Albany, New York 12220-0062
(518) 443-2041
November 18, 2003

1 Ex Parte submission of Consensus Parties submitted August 7, 2003, page
45.
2 Ex Parte submission of Consensus Parties submitted August 7, 2003, Page
47.
3 Furthermore, the measurement methods have now been better defined.
4 Ibid, Attachment I, page 8.
5 Ibid, Page 47.
6 Ibid, Page 47, NPSPAC licensees relocated to 806-809/851-854 MHz.
7 Specifically, the border region consequences, and the associated minimum
signal requirements
8 Filings on WT Docket 02-55 by the New York State Office for Technology
Statewide Wireless Network (SWN), Comments of
May 6, 2002, Reply Comments of August 6, 2002, Comments of 9/23/02, February
10, 2003, and Reply comments of February
25, 2003.
9 In fact, if effective frequency coordination had been employed in the past
across all of the services (i.e. Public Safety and
Nextel/CMRS/Cellular), then 800 MHz interference may never have become an
issue

http://svartifoss2.fcc.gov/prod/ecfs/retrieve.cgi?native_or_pdf=pdf&id_docum
ent=6515290716

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From: [email-masked]
Date: Thu, 20 Nov 2003 01:12:36 -0500

-------- Original Message --------
From: Jack Daniel <[email-masked]>
Subject: Re:  State of New York Office for Technology supports modified
Consensus Plan

Bob, 

You forgot to ask Bryan for his social security number and bank
password.
(just kidding)

At first glance I though you might be on a big fishing trip to find
anything you could use to discredit Bryan.

BUT, after closer examination, I think you have a fantastic idea.
Aand I'm sure you agree what's fair for one is fair for all don't you?

Since it sounds as though you may have had a little experience with
Nextel interference yourself, as a service to us all, can you post the
information you have requested from Bryan on tests YOU have been
involved in ?

While we're at it, let's also request Nextel and all the other cellular
companies to provide us detailed report on every site they have had a
complaint on, when and where it was, what were the interference metrics,
who conducted the test and what technical credentials did they have, the
type/model of instrumentation, a copy of the last calibration, a list of
witnesses and their affiliations, street address, telephone, fax and
email addresses in the form of a notarized affidavit, full disclosure of
all business relations between all parties and a list of any gifts or
grants passed between the parties for the last 24 months, what was the
resolution, what frequency changes were made, what additional equipment
(such as filters) was added or removed, how long the corrective action
took to implement, how long the corrective action is guaranteed to be
effective. Photos and maps would be nice too.

Of course if anyone refuses to respond or don't supply adequate
information or use methods or equipment we don't approve of,  it's
obvious they have something to hide and are totally incompetent.

But I could be wrong.............

Jack  Daniel
===================================================