Subject: [NEXTEL-1] Subject: 800 Mhz Interference

From: [email-masked]
Date: Sat, 01 May 2004 08:03:15 -0400

-----Original Message-----

From: [email-masked]
Sent: Wednesday, April 21, 2004 1:27 AM

To: [email-masked]; [email-masked];
[email-masked]; [email-masked]; [email-masked]

Subject: 800 Mhz Interference

FCC Commissioners;

                Our company is one of the few that did not sell our 800
mhz license's to Nextel. We have system's located both in a
major metropolitan area (Phoenix, AZ) and several rural Arizona cities,
so obviously I have been following the 800 mhz interference issue with
great interest. Over the last three years I have had several occasions
where Nextel has caused harmful interference to our systems. While I am
no fan of Nextel, I will say that the people that I have dealt with have
always been very cooperative and responsive, and once notified of a
problem, they have always turned off their interfering transmitter(s)
quickly.

Sounds like I am a proponent of "case by case" interference resolution,
right? Not so. I have the of advantage being in the
communications field. I know exactly what frequencies that I am
operating on and know that they can be interfered with, plus I
possess the equipment to quickly monitor and locate an offending
transmitter. The police officer or FedEx driver that can't use
their radio at Main St. and Central in Hometown USA, doesn't have a clue
that their communications are being interfered with by a transmitter
operating on an adjacent channel to theirs, on the 100 foot tower
located 1300 feet away that is licensed to radiate 1000 watts ERP! This
interference can continue indefinitely undetected because most end users
will simply assume that they are in a "dead spot" and may not even
report a problem to their radio company or internal communications
department.

While the primary focus of this interference issue has always been the
public safety community, let's not forget about the other
users of this band. As an SMR we have high profile users on our systems
that require consistent communications too. School
districts that transport our children everyday. Hazardous materials
trucking firms. Armored transport companies. Medical air
ambulance's. Then there are the large airline and delivery companies
that have their own private systems that support thousands
of individual radio units. They need to move products and people 24-7
efficiently. The continued smooth operation of their core
business's is essential to the economy of our nation.  Everyday Nextel
continues to construct and activate new cell sites, so the
interference continues to expand. We are simply out of time to remedy
this situation.

While the "Consensus Plan" seems to have the best plan for long term
resolution, it is too complex, requires too much additional
negotiation with individual licensees to retune to a different part of
the 800mhz band, and simply will take too long to
implement. Then we have the big issue of is their enough money to pay
for all of this? Nextel has stated that they will only
pay $850 million (not enough) IF they get spectrum at 1.9 Ghz. If they
don't get what THEY want; no deal. I'm sorry but this is just blatantly
wrong. Who exactly is in charge here? Since when does any licensee TELL
the FCC what they will or won't do? There are "many" individual public
safety, and BILT analog licensees interleaved in the 800 band. There is
"one" Nextel that has acquired analog systems that were peacefully
coexisting as one of these "many" users for years, converted the
channels to their digital format and subsequently created the current
situation. The needs of the "many" should easily outweigh the needs of
the
"one". While you can never make everyone happy, it seems to me that a
solution that involves less parties will be much easier
and faster to implement. Somebody is going to have to be inconvenienced
and possibly lose some spectrum. Why not the entity
that has the ability to easily make system changes to more "efficiently"
use spectrum? Nextel does not have to coordinate with its users when
replacing or retuning equipment. If customer equipment upgrades are
necessary; they can migrate to different
handsets over time and only affect their own systems and customers. Oh
yeah; almost forgot; did I mention that this entity
created the problem?? If they have to be "inconvenienced" to solve them
problem, too bad!  Everyone else in the 800 mhz band has been suffering
for years now!

The following is respectfully submitted for your consideration.

1) Let Nextel spend their money on their system.

Nextel & Motorola can engineer handsets that will work on spectrum that
is already licensed to Nextel. Let them use their top 200 channels at
800 mhz, their 700 & 900 mhz spectrum. They can design their system to
use more low level, low power (not 1000 watt ERP) sites. If they cut
their power, sectorize, and increase their number of sites, they can
reuse frequencies at closer distances. They will benefit from a larger
system capacity, they will not have to negotiate with incumbents (legal
fees) and
ultimately pay for the incumbents to relocate. Their resources are spent
entirely on their system. Since they believe that $850
million is sufficient to relocate ALL affected public safety and BILT
users nationwide, surely it is more than enough to upgrade only their
system to eliminate this interference.

2) Nextel terminates digital transmissions in the interleaved part of
the band below 861 mhz.

Nextel could turn around and "sell" their license interests in this part
of the band, and use the income to acquire additional
spectrum at 700 or 900 mhz. They are experienced with negotiating deals
to acquire licenses, simply reverse the procedure and
market what they now have. The outcome of their success is entirely up
to them, they haven't lost or had any spectrum actually
taken away from them. They will have been required to cease transmitting
only due to their inability to peacefully coexist with
other users, who were ALREADY operating without interference. There
obviously should be a very short (almost immediate)
timeline imposed to implement this requirement.

3) Nextel agrees to coordinate with adjacent NPSPAC users.

As Nextel is not "interleaved" with users in this portion of the band,
and not all areas of the country will even use this portion of the band,
Nextel should easily be able to coordinate with the local agencies
desiring use of this spectrum. This coordination needs to be required
before either entity can obtain FCC authority to construct their system.
Nextel can simply deploy channels at the low end of their 800 mhz band,
or 700 or 900 mhz channels in a potentially effected area. Again by
using less power and more sites they can operate without causing harmful
interference to the public safety entity.

This is my summarized opinion of a potential rapid solution to a problem
that has plagued this frequency band for too long. I made reference in
the beginning of this letter, that we operate both in a major metro
market and rural markets. In the rural market our systems were retuned
to the 856-860 mhz part of the band when Nextel was granted exclusive
use of 861-865 mhz. We currently peacefully coexist operating from the
same facility, serving the same geographic area, with NO detrimental
interference realized. Why? Because Nextel has agreed with us to operate
their system in this area on frequencies only above 861 mhz.

Nextel's system has caused the problem, technical solutions applied to
Nextel's system, combined with a mandatory
Nextel band realignment, with the burden for compliance 100% on Nextel's
shoulders will certainly make the 800 mhz band very usable again.

Sincerely;

Christopher F. Salgot

C&M Communications

R&M Repeater

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