Subject: [NEXTEL-1] Robert H. Schwaninger, Jr. On BPL- Carrier Current Systems, including Broadband Pover Power Line Systems ET Docket No. 03-104

From: [email-masked]
Date: Tue, 04 May 2004 21:37:09 -0400

Before the FEDERAL COMMUNICATIONS COMMISSION
Washington, D.C. 20554

In the Matter of

Carrier Current Systems, including Broadband Pover Power Line Systems
ET Docket No. 03-104
Amendment of Part 15 regarding new requirements  ET Docket No. 04-37 and
measurement guidelines for Access )
Broadband over Power Line Systems

To: The Commission

COMMENTS OF SMALL BUSINESS IN TELECOMMUNICATIONS (SBT)
SBT is a nonprofit organization of small businesses that operate
throughout the United States within the telecommunications market. Its
members include carriers, manufacturers, amateur radio operators, and a
host of other entities which will be affected by the Commission’s
decisions within this proceeding. SBT members are, therefore, vitally
interested in the outcome of this rule making and appreciate the
opportunity to provide their comments as follows:

Concerns

Although SBT recognizes the Commission’s desire to find means to provide
high-speed internet services to consumers across the Country,
particularly in rural areas where the number of providers is often quite
limited, SBT is concerned that in the Commission’s zeal to provide those
services it may not provide adequate protection for licensed operators.
Therefore, SBT would ask that the Commission proceed carefully,
balancing the laudable goal of providing new services against the
potential harm to existing services. The Commission’s Notice of Proposed
Rule Making, although comprehensive, does not adequately address the
means by which the Commission would be 2 able to effectively enforce the
dictates of unlicensed use when applied to BPL delivery.  For example,
SBT members recall clearly the number of times that cable television
systems have suffered signal leakage that caused harmful interference to
VHF operations. The harmful conditions have been suffered for weeks
during those times when cable operators would deny that their systems
were causing problems. Meanwhile, wireless systems were highly disrupted
and customers of VHF paging systems often questioned the viability and
reliability of carriers whose systems were suffering from these
problems.

The NPRM does suggest that BPL carriers will, in essence, be
self-monitoring, with the capacity to shut down all or a portion of a
system that experiences improper leakage, resulting in harmful radiation
of signals. However, the Commission has not fully articulated how such a
mechanism for interference correction would be implemented or enforced.
Given the fact that BPL is focused on delivery in rural areas, far from
the capacity of the agency’s monitoring stations to detect problems, the
issue of enforcement of the Commission’s rules becomes a matter of great
practical importance to those licensed users whose businesses may be
affected.  SBT’s concern arises out of its members’ recent experience
with the Commission’s failure to enforce its rules against manufacturers
of television antennas that also amplify the received signal.  Many of
these antennas have been found to be a source of harmful interference to
UHF land mobile and broadcast facilities, and have ruined the businesses
of operators of UHF commercial systems.  Yet, despite the Commission’s
knowledge of the fact that the antenna/amplifiers were the direct 3
source of harmful interference, which antennas were sold by the tens of
thousands across the United States for installation on recreational
vehicles and as a means of delivering local UHF television service to
persons employing DBS for non-local broadcasting, the Commission did not
order the manufacturer of the devices to perform a recall, did not
produce a cease and desist order in the further marketing of the
devices, and did not provide any remedy to any adversely affected
licensed operator.

It is against this backdrop of recent experience that licensed operators
examine the Commission’s proposal to allow for the creation of BPL as a
kind of ubiquitous delivery system for delivery of constant data
communications. Although the Commission’s proposals include expectations
of proper operation which would continue to provide quiet enjoyment of
the spectrum by licensed radio users, expectations have too often been
shown to be unrealized in practice. And even if the comments provided by
proponents are deemed to be fully sincere in every regard as to the
measures that BPL operators might go to fulfill obligations under Part
15, i.e. operation at sufferance to licensed radio operations, some
greater consideration must be given to the Commission’s anticipated
actions in responding to complaints of harmful interference which will
likely arise.
It is already well known that the Commission provides little priority to
complaints from commercial operators of harmful interference to their
systems. The Commission’s proper and first priority is the resolution of
harmful interference to public safety operations. However, as all SBT
members can report, the importance assigned to commercial operations is
way, way down the field 4 offices’ list of priorities, to the point
where often the field office will do little more than eventually send a
letter of inquiry to an offending party, if anything.

The Commission’s history of limited resources to deal with problems
suffered by HF, VHF and UHF operators suffering interference from all
kinds of sources of interference is well known. Although affected
operators have been told time and again that the agency’s limited budget
dictates the Commission’s capacity to respond to complaints, this
explanation does nothing to reduce the fears of persons who, because of
this rule making, are being made to confront a new and larger source of
potential harmful interference.  Already, Part 90 and 22 operators must
investigate and attempt to resolve interference from drive thru
restaurants’ equipment, surveying equipment, transceivers mounted on
golf carts, inventory tracking systems, etc., with little assistance
ever provided by the Commission’s staff. And the problem is not getting
better, but worse. To date, the Commission has been nearly unresponsive
to these problems and has rejected requests for something as simple as a
Public Notice to remind persons that even though their radio equipment
was obtained lawfully from a manufacturer, use of that radio equipment
must conform to the operational guidelines contained in the Commission’s
rules which require that operators avoid the creation of harmful
interference.  SBT is fully aware that the parameters of this rule
making are not sufficiently broad to allow for the Commission’s
treatment of each known form of harmful interference suffered by SBT’s
members. Nor does SBT request that the agency expand the nature of this
rule making to deal with each of the illustrations employed herein.
However, these illustrations point up the need for the Commission to
move cautiously in this area and to provide necessary assurances to
those licensed 5 operators whose lawful, licensed operations are
threatened by the introduction into the radio environment of a system
which might potentially radiate over an unquantifiable number of areas.

Information Is Essential

The Commission has proposed a new Section 15.209(g) that would require
that BPL carriers participate in the creation of a data base which would
show the locations and frequency bands of operation for BPL systems. SBT
commends the Commission on this suggestion as a good step in the
direction of assuring that BPL carriers provide some diagram of spectrum
use that might be employed to assist in resolving incidents of harmful
interference. Information regarding the source of interference and the
responsible party is essential to create the ability of persons to
assist in identifying problems for resolution.
Although the Commission’s proposal is a good first step, the proposal
does not go far enough in providing necessary utility to the collection
of this information, nor does it state with any specificity the means by
which the information would be kept current. SBT agrees that the
information collected be made available to any and all requesting
parties for the purpose of determining whether a source of harmful
interference to licensed operation might be the introduction into the
environment of BPL radiation.

An operator of licensed equipment which suffers harmful interference
should not be made to wonder whether the source might be BPL radiation.
That operator should be able to make a determination or educated
estimation based on information provided via the data base. If the area
of 6 interference coincides with the presence of power lines that are
thought to carry BPL, the licensed operator should be able to confirm
those suspicions by accessing the BPL data base created under Section
15.209(g).
The data base should also contain 24-7 contact information for each of
the BPL carriers, which information could be employed by the affected
licensed operator for the purpose of informing the BPL carrier of a
potential problem. This contact is the first step between operators for
the purpose of engaging in a meaningful dialogue to seek peaceful
resolution of the matter without the need to involve the Commission.
Licensed operators should not be put to the task of having to negotiate
an often byzantine telephone system to reach the proper person within an
organization as large as a utility company, to discover by chance the
proper individual for the purpose of reporting a problem. A simple
inclusion of 24-7 contact information within the data base would solve
this problem.

All information within the data base should be required to remain
current. The proposed Section 15.209(g) does not speak to updating of
information or whether the information to be provided must be made
available before deployment of BPL in a given area or along specific
lines.  Given the essential nature of the information and the value in
maintaining current all technical and contact information, the
Commission’s directions to BPL operators in reporting and collecting
this information should be made far more specific. As it stands, the
content of the NPRM does not make clear the Commission’s requirements
regarding the quality of the data base.

7

Based on the foregoing, SBT respectfully recommends that proposed
Section 15.209(g) be amended prior to adoption to read:
(g) Entities operating Access Broadband over Power Line systems shall
supply to a Federal Communications Commission/National
Telecommunications and
Information Administration recognized industry-operated entity,
information on all
existing, changes to existing and proposed Access BPL systems for
inclusion in a
data base. Such information shall be kept current and shall include the
specific
installation locations, frequency bands of operation, type of modulation
used, and
contact information for persons given responsibility by each carrier for

resolving reports of harmful interference from operation. No
notification to the
FCC is required, however, such information shall be made fully available
in
electronic form for public inspection and use.1

To assure compliance with this vital effort, the Commission should
clearly state in its Order that the responsibility, for assuring that
the information provided to the collecting entity operating under
Section 15.209(g) is current and accurate, will fall on each of the
Access BPL carriers whose duties shall include assuring that all of
their information is provided to the collection entity for publication
before the carrier constructs and commences operation of each location,
or prior to the carrier’s modification of any portion of the BPL system
which would render the information provided inaccurate or incomplete. To
wit, the Commission should state that each BPL operator is individually
responsible for monitoring the data base to assure accuracy and
completeness, and that an operator’s failure in assuring that the
information published on the data base regarding the operator’s system
is current, complete and accurate shall be deemed that operator’s
violation of the agency’s rules and policies. In sum, the Commission
should place the responsibility for the quality and completeness of the
data on those entities who are responsible for reporting that
information.

1 SBT’s proposed language is indicated by bold typeface.

It is SBT’s strong belief that the Commission’s commitment to spurring
cooperation by 8 insistence on the availability of accurate information
will go a long way toward encouraging operators of licensed systems and
BPL systems to cooperate. Absent the availability of this information,
licensed operators may jump to the conclusion that a BPL system is the
source of harmful interference when such may not be the case. If, by
being able to access the data base, the utility company’s operations
might be eliminated as a possible source, the utility company will not
receive needless complaints and licensed operators will be informed to
seek for other sources of interference that may be disturbing legitimate
operations.

SBT supports the creation of a centralized data base for these purposes,
rather than data bases which are spread among individual BPL carriers.
Ease of information collection and retrieval should be the goal of the
data base, which goal is best gained via the creation of a central data
base. This stated, SBT suggests that the Commission direct BPL service
providers to install a hot link on their web sites to the BPL central
data base, to ease navigation from the BPL providers’ sites to the
central data base. SBT further suggests that the data base include
mapping software that is sufficiently detailed as to show the exact
locations of the lines over which BPL is traveling. Meets and bounds or
general descriptions are insufficient for narrowing the licensed
operator’s search in determining whether a specific power line is a
potential source of interference. Thus, the Commission should provide
some degree of direction and input into making the information within
the data base understandable, user friendly, and clear.

Although the Commission has stated in its proposed Section 15.209(g)
that notification to the 9 agency is not required, SBT respectfully
requests that the Commission state clearly that the content and quality
of the data base is deemed within the Commission’s area of concern and
that the Commission’s authority extends to its ability and willingness
to demand that the data base be improved, made more specific, kept
current, or otherwise altered to reach more efficiently and properly the
intended purpose of the data base’s existence. SBT would not expect that
the Commission would constantly monitor the data base or attempt any
micro-management of the dayto-day operations of the data base. However,
SBT believes that it is important, given the vital nature of this
effort, that the Commission assure licensed operators that the agency
will continue to be concerned and involved in insuring that the
protection and cooperation to be promoted by the data base will become
and remain a reality. The data base will be a vital tool in assuring a
peaceful introduction of BPL service, however, its maintenance and
utility will need to be judged by the Commission periodically, including
receipt of suggestions from licensed operators to improve the quality
and accessability of information from the data base.  The Commission’s
Order should emphasize the requirement that BPL systems are operated
under Part 15, thus at full sufferance to licensed radio services.
Therefore, the burden to demonstrate that a given line, system,
installation or use of BPL is operating without the creation of harmful
interference must rest squarely upon the BPL operator. This requirement
calls for stern vigilance by BPL operators, committed to assuring that
such operations are not detrimental to licensed use of the radio
spectrum. Such vigilance must extend not only to the intended operations
upon fundamental frequencies, but should include those harmonics which
are a likely byproduct of operations and which are often a source of
interference from unlicensed radio devices. The myriad 10 of receivers
which may suffer increased noise floors from harmonics operating in
their receive bandwidth should not be taken lightly or ignored.

The central data base described above should, therefore, inform persons
of the possibility that a BPL system may create harmonics which would be
observed at other locations within the radio spectrum, perhaps,
including a chart for persons to easily recognize that harmonics from
BPL operations may be the actual cause of some observed problem. The
basic idea should be to protect licensed radio services, whether
engaging in cochannel operations or upon harmonic frequencies.

Interference Mitigation Requirements

The Commission should carefully express to BPL operators that the
receipt of a notification of harmful interference should be handled
quickly and expeditiously to respond to each such instance. The problem
should not be one that is allowed to languish for days, weeks or months,
while an instance is studied by a phalanx of technicians looking to
confirm the cause of the interference. Such actions, which have been all
too common among licensed users, places the victim of the interference
in the position of having to suffer interference for prolonged periods
while supposedly equitable actions are being deployed. Yet, the
Commission has already found and codified the equities to be protected
in the operation of licensed and unlicensed radio devices, with the
latter deemed to have no rights to protection or continued operation
during times of harmful interference.
The temptation of commerce will be for BPL operators to go to lengths to
avoid shutting off 11 service to customers. Although SBT understands
this circumstance, BPL operators must be willing to fully accept the
consequences of operating their systems under the current regulatory
framework.  Whether BPL is deemed the panacea for distribution of high
speed internet services or simply another competing service provider in
the market, the discussion and hyperbole of the potential benefits of
BPL cannot be allowed to obscure now, or in the future, the legal
reality of operations.  And the actions taken by BPL operators to
protect licensed radio uses must be a strict requirement to enjoy
continued operation of any system, in whole or in part.  SBT compliments
the Commission on its inclusion of Section 15.209(f) within the proposed
rules and joins with the Commission in its concern that incidents of
harmful interference be dealt with quickly, employing such technology as
is available to cause BPL operators to correct incidents of
interference. However, SBT requests that the Commission join this rule
to a strong statement within the agency’s Order which directs and
instructs BPL operators that the agency’s codification of Section
15.209(f) speaks to capacity to react, but that BPL operators’ duties do
not end there.  BPL operators must be clearly directed to use this
technology, even if such use requires terminating service to a given
area. Further, SBT requests that the Commission state clearly that even
if a system is equipped with the ability to employ adaptive interference
mitigation techniques, such equipping of systems alone will not be
deemed to be tantamount to compliance with the agency’s rules.
Compliance, it should be made clear, is viewed as a BPL operator’s
obtaining the necessary capacity to mitigate interference AND that
operator’s demonstrated willingness to use that technology.

12

Fidelity to the agency’s rules is rarely demonstrated solely by the
inclusion of additional hardware within a given system. For example, the
ability to monitor operations prior to transmitting is not equal to the
performance of actual monitoring. Thus, adherence to law requires that
the operator of a radio system employ all reasonable efforts to avoid
interference and to resolve quickly all problems caused by operation.
Such requirements include detection, cooperation and reaction. It will
be difficult for BPL operators to detect each incident of interference.
Thus, the Commission can seek cooperation from licensed radio operators
to inform BPL operators through use of the data base and suggested 24-7
contact information. However, once an incident is detected, the BPL
operator’s demonstration of compliance must be judged by how and when
mitigation techniques are employed.  To encourage BPL operators to take
seriously their obligations, SBT respectfully requests that the
Commission state that it will entertain complaints from licensed
operators whose operations receive interference from BPL operators that
exhibit an inability or unwillingness to cooperate and react to
incidents of harmful interference. The Commission is assisting in
creating a new form of delivery system which is under-tested,
particularly in real world settings. The comments are highly mixed and
controversial in persons’ contentions regarding the potential of harmful
interference to licensed radio services that may result from the
Commission’s participation in the deployment of BPL systems. The
Commission has shown a healthy concern for the possibility that BPL
systems might, in some instances, cause problems in real world settings.
Thus, the Commission, as the arbiter and regulator of these systems,
should create a welcome environment for those persons who are aggrieved
by BPL operations and who have not received adequate cooperation from a
given BPL operator.

13
The concern expressed herein is that the Commission might allow BPL
systems to proliferate without necessary oversight regarding the means
by which BPL operators respond to incidents of interference. The
Commission should focus on the reality of operations and not simply the
theoretical model. The reality is that BPL is to be deployed across
infrastructures which were not originally designed or considered for
such operations. The reality is that many portions of utility companies’
infrastructure have been in place for years, exposed to the weather,
loosening, rusting, and wind. The reality is that some BPL systems may
be lit up before it is known whether the infrastructure is capable of
producing the service without a myriad of adverse byproducts due to
existing conditions. The reality is that some BPL operators may treat
licensed operators as test subjects for determining the viability of
their network for delivering services. The reality is that the
consequences of allowing BPL operations might be quite detrimental to
some licensed radio users.  These are the realities, apart from the
supposed performance of units in laboratories and display sites.
Particularly in the early years of BPL’s inception, it is vital that the
Commission balance the needs of licensed users and the rights enjoyed by
them, against the real threat of harmful interference by BPL operators
who might seek to improve the bottom line through failures to properly
construct, test, and operate systems in a manner which demonstrates full
acknowledgment of the BPL operator’s regulatory responsibilities, and
the fact that the burden is on and must remain on those operators to
produce a service which protects licensed operations, even if such
protection requires terminating services from a BPL system at given
locations.

14

Means Of Regulation

Absent from the text of the NPRM is a clear definition of BPL services,
i.e. are these services to be regulated as “telecommunications services”
or “information services” as those terms are treated within In the
Matter of IP-Enabled Services, WT Docket No. 04-36 (released March 10,
2004) (“IP Services”)? Since the Commission has proposed regulating the
operation of these systems under Part 15 of its rules, 47 U.S.C. §302,
the issue of the means of regulating the use of these systems is even
more unclear. Although SBT is not concerned within this proceeding with
the Commission’s ultimate decision as to matters related to application
of CALEA, the Universal Service Fund, etc., see IP Services at para. 42,
the protections afforded persons under 47 U.S.C. §208 are deemed
necessary to protect licensed radio operators who suffer injury as a
result of BPL radiation. The transmission services provided by BPL
operators should be deemed a “telecommunications service” for the
purpose of assuring potentially affected persons all available remedies
for adverse operations, including the application of
Section 208 of the Act.

The problem which underlies the Commission’s potential adoption of
regulation regarding BPL is the agency’s reliance upon Part 15
exclusively in setting forth the regulatory framework.  Yet, typically
Part 15 devices are low-power consumer devices with limited range and
effect and opportunity for the creation of harmful interference to
multiple persons. Additionally, Part 15 devices are not normally
employed as the delivery system for hundreds of thousands of consumers’
telecommunications services, except as Part 15 applies to broadcast
receivers. In this proceeding, the Commission has not addressed
adequately the regulatory effect of allowing unlicensed electromagnetic
energy to be carried across and radiated from miles of wires, for the
purpose of providing “for hire” services in a manner which is
functionally equivalent to the provision of 15 common carriage. That the
Commission has bifurcated its consideration of this issue between this
proceeding and IP Services is troubling.
Within this proceeding, the Commission has requested comment regarding
the protections for
licensed radio operation as are articulated within the NPRM and whether
such protections are
sufficient. And although SBT believes that the Commission intends to
provide equal regulatory
treatment to BPL services as it applied to cable modem services in In
the Matter of Inquiry
Concerning High-Speed Access to the Internet Over Cable and Other
Facilities; Internt Over Cable
Declaratory Ruling; Appropriate Regulatory Treatment for Broadband
Access to the Internet Over
Cable Facilities, Declaratory Ruling and Notice of Proposed Rule Making,
GN Docket No. 00-185,
CS Docket No. 02-52 (released March 15, 2002) at paras. 34-59 (“Internet
Over Cable”); thus,
declaring that BPL services are “information services” not subject to
regulation under Title II of the
Act, SBT avers that the practical threat of harmful interference to
licensed radio operations is
sufficiently greater here as to warrant some vehicle for the bringing of
formal complaints by
aggrieved parties. Indeed, the Commission will find little, if any,
treatment of the issue of harmful
interference within the Internet Over Cable proceeding.2 Therefore, this
issue is not adequately
2

The Commission may note that the issue of interference from cable
systems is treated
by that definition under 47 U.S.C. §602(7) which states that a cable
system consists of “a set of closed transmission paths.” The proposed
definition for Access BPL does not include the requirement that the
transmission paths be “closed,” thus, the definition of Access BPL
proposed by the Commission supports the assumption that the paths will
not be closed and, therefore, a known and greater threat to cause
harmful interference.

16 treated in that earlier proceeding and is central to the matters
addressed in this proceeding, begging the question as to whether the
outcome of the two matters should be equal in all respects.  SBT argues
that the nature of this service and the condition of the infrastructure,
including the age of most power lines, requires that the Commission
consider carefully whether it is appropriate to limit the availability
of remedies for noncompliance. As previously stated, SBT supports a
strong and sincere statement from the Commission that it will take
seriously all violations of law, rule and policy in the construction and
operation of BPL systems. SBT urges the Commission to pledge to employ
its enforcement authority, including the issuance of fines, cease and
desist orders, and all other means at the agency’s disposal to assure
that BPL provides the promises and not the problems. The Commission
should not be tolerant of haphazard or dilatory actions by BPL operators
in resolving incidents of interference. Instead, the Commission should
state its willingness to assure licensed radio operators quiet enjoyment
of the radio spectrum.  Additionally, the agency should state clearly
that the burden of demonstrating that a BPL service is operated in
accord with Part 15 and 47 U.S.C. §302 shall rest squarely on BPL
operators. Only by expressing its commitment in the strongest of terms
can licensed operators receive necessary assurances that the agency is
not unleashing an unrestrained threat of harmful interference upon the
public that, once set free, will create havoc with impunity.

SBT respectfully requests that the Commission set forth specific
procedural guidelines for addressing complaints from aggrieved persons
whose licensed radio systems suffer uncured interference from operation
of BPL systems. If such procedures do not involve application of Section
208 of the Act, the Commission should set out clearly in its Order that
aggrieved persons 17 may seek redress in state or federal courts. Absent
some procedural and jurisdictional treatment of these issues, persons
are left to wonder what steps are available to them in the event that
their radio systems are disrupted intolerably by the operation of BPL
systems.

Conclusion

SBT is impressed with the Commission’s concern about protecting licensed
operations from the threat of harmful interference which may be the
result of deployment of BPL systems. SBT supports the Commission in its
articulated direction to BPL operators to do all that is necessary to
avoid and resolve interference. Although the Commission is, thus far,
convinced that BPL systems pose a workable threat of interference that
might be mitigated through vigilance and strict fidelity to the dictates
of Part 15 operations, SBT is highly concerned that the Commission not
allow its oversight to wane. SBT respectfully requests that the
Commission remain available, responsive, and prepared to employ its
considerable enforcement authority to assure licensed operators that any
deployment of BPL be performed in a manner which demonstrates a healthy
fidelity to both the letter and the spirit of the law for the operation
of Part 15 devices.
Respectfully submitted,

SMALL BUSINESS IN TELECOMMUNICATIONS
/s/

Robert H. Schwaninger, Jr.
Dated: April 22, 2004
Schwaninger & Associates, P.C.
1331 H Street, N.W., Suite 500
Washington, D.C. 20005
18
Phone: (202) 347-8580
Facsimile: (202) 347-8607

http://gullfoss2.fcc.gov/prod/ecfs/retrieve.cgi?native_or_pdf=pdf&id_document=6516182833

--
    "NEXTEL-1 IT'S NOT JUST NEXTEL"
  Note The New address
Subscribe to Nextel-1: http://www.groups.yahoo.com/subscribe/NEXTEL-1

  "NEXTEL2 FOR iDEN SOFTWARE DEVELOPERS"
Subscribe to Nextel2: http://www.groups.yahoo.com/subscribe/NEXTEL2

  "WIRELESS FORUM HOMELAND SECURITY GROUP"
     The Complete Resource for Wireless Homeland Security.
Subscribe to WFHSG:  http://www.groups.yahoo.com/subscribe/WFHSG

------------------------ Yahoo! Groups Sponsor ---------------------~-->
Buy Ink Cartridges or Refill Kits for your HP, Epson, Canon or Lexmark
Printer at MyInks.com.  Free s/h on orders $50 or more to the US & Canada.
http://www.c1tracking.com/l.asp?cid=5511
http://us.click.yahoo.com/mOAaAA/3exGAA/qnsNAA/61FxlB/TM
---------------------------------------------------------------------~->

-- 
    "NEXTEL-1 IT'S NOT JUST NEXTEL"
  Note The New address 
Subscribe to Nextel-1: http://www.groups.yahoo.com/subscribe/NEXTEL-1

  "NEXTEL2 FOR iDEN SOFTWARE DEVELOPERS"
Subscribe to Nextel2: http://www.groups.yahoo.com/subscribe/NEXTEL2

  "WIRELESS FORUM HOMELAND SECURITY GROUP"
     The Complete Resource for Wireless Homeland Security.
Subscribe to WFHSG:  http://www.groups.yahoo.com/subscribe/WFHSG

Yahoo! Groups Links

<*> To visit your group on the web, go to:
     http://groups.yahoo.com/group/NEXTEL-1/

<*> To unsubscribe from this group, send an email to:
     [email-masked]

<*> Your use of Yahoo! Groups is subject to:
     http://docs.yahoo.com/info/terms/