Subject: [NEXTEL-1] National Association of Manufacturers

From: [email-masked]
Date: Tue, 04 Nov 2003 10:59:22 -0500

National Association of Manufacturers on 02:55

November 3, 2003

Marlene S. Dortch
Secretary
Federal Communications Commission
445 12th Street, NW
Washington, DC  20554
Re:  Ex Parte Presentation
WT Docket No. 02-55

Dear Ms. Dortch:

This is to advise that on October 31, 2003, Lawrence A. Fineran,
Vice-President, National Association of Manufacturers; Marvin McKinley,
President, MRFAC, Inc.; Richard C. Crawford, Director, Federal
Government Affairs, Coors Brewing Company; Jennifer Warren, Senior
Director, Trade & Regulatory Affairs, Lockheed Martin Corporation; and
the undersigned met with Commissioners Abernathy, Adelstein, and Martin,
and their legal assistants, and with Paul Margie, legal assistant to
Commissioner Copps, regarding the above-captioned proceeding.  The
NAM/MRFAC representatives addressed the points set forth in the
attachment.  In addition, copies of NAM.s The Facts About Modern
Manufacturing were exchanged (additional copies of which are being
supplied under separate cover for the record).
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(w/out encl.):
Commissioner Kathleen Abernathy
Commissioner Jonathan Adelstein
Commissioner Kevin Martin
Jennifer Manner
Barry Ohlson
Sam Feder
Paul Margie

WDC 322051.1
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
Systems
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=6515288597