Subject: [NEXTEL-1] Maricopa County (AZ)Voices Strong Opposition To The 'Scam Plan"

From: [email-masked]
Date: Wed, 10 Sep 2003 14:48:51 -0400

Maricopa County (AZ)Voices Strong Opposition To The 'Scam Plan"

Wireless Systems

August 20, 2003
Marlene H. Dortch
Secretary
Federal Communications Commission
445 12th Street, SW
Washington, DC  20554
RE: Docket 02-55

Dear Ms. Dortch:

I am writing to express Maricopa County Wireless Systems' strong opposition to the
.Consensus Plan. filed by Nextel in the above referenced proceeding regarding
interference to 800 MHz public safety systems. We favor the .Balanced Approach. 
offered by Motorola and others. We believe that technological improvements in
end-user assets will mitigate many existing interference issues. Though the the
Balanced Approach places the cost to upgrade or modify equipment on the end user,
we feel that the interference problem is not as widespread as Nextel and others
claim, and can be mitigated in most cases either through cooperation between
Nextel and public safety or by modest equipment upgrades. Either option is much
less disruptive and expensive than the solution proposed in the Consensus Plan. 
Maricopa County operates an 800 MHz Motorola SmartZone 3.0 system on an
analog/digital, 14-site microwave network. We support the Maricopa County
Sheriff.s Office, four non-county police departments, and several public works
agencies using a variety of digital and analog radios. In all, more than 6,000
subscribers rely on the radio coverage we provide throughout this 9,200
square-mile county, which includes the metro Phoenix area.

In the past five years we have had just a single instance of Nextel interference
in one of our low-signal areas. In that case, Nextel worked closely with us to
resolve the issue by adjusting transmit power and down-tilt at the interfering
site. In our case and, we believe, many, many others throughout the country, the
minimal interference presented by Nextel's use of "interleaved" frequencies does
not warrant the time, expense, and disruption of service that the Consensus Plan
would necessitate for public safety agencies.
Earlier this year, we changed all frequencies at 12 of our sites in accordance
with FCC PR Docket NO. 91-143, dated October 15th, 2001 (DA 01-2222), and
reprogrammed all of our 6,000 subscribers. We did this in voluntary cooperation
with the cities of Phoenix and Mesa, Arizona, to minimize interference between our
system and their new 800 MHz Project 25 system. Accomplishing this enormous
undertaking involved extensive planning, considerable time and expense, and the
absolute cooperation and understanding of our customers. Repeating the event would
be very hard to justify, and the rewards few, if any.  We do not believe that
adopting Nextel's Consensus Plan will completely eliminate all interference issues
in the interleaved band, as has been so widely claimed.  Further, we reject the
plan's underlying premise, that the party being interfered with should bear the
burden of relocating. Customarily, the interfering entity is responsible for
resolving all interference issues it causes.

There also seems to be significant vagueness on Nextel.s part regarding its
funding commitment should it not be approved/awarded the 1.9 GHz PCS spectrum
promised by the FCC. (This was brought to light during the "800 MHz Super Session"
at the APCO national convention in Indianapolis on August 12th of this year, which
a representative of the FCC attended.) That commitment, currently set at $850
million, may or may not adequately cover the costs of the move. The price tag is
an estimate; likely, the cost to public safety agencies will be much higher. 
Although APCO National has thrown its support behind the Consensus Plan, it did
not present the issue to its membership for a vote. To our surprise and dismay,
neither our local Arizona APCO chapter nor the Region 3 Arizona Regional Review
Committee was directly involved in APCO National.s decision.  We are unhappy with
APCO's and the FCC's readiness to place the burden of this enormous change on the
backs of already underfunded public safety agencies, to the substantial benefit of
a single private cellular carrier. Given that equipment must be replaced as it
ages, and that new radio equipment is less susceptible to interference, we believe
that most agencies will eventually migrate to radios that are not affected by
Nextel interference. Meanwhile, that interference is not significant enough to
justify our supporting the Consensus Plan.  Should you need further clarification
from me on any aspect of this correspondence, please do not hesitate to contact
me.

Respectfully,
Charles C. Brotherton
Wireless Systems Manager

http://svartifoss2.fcc.gov/prod/ecfs/retrieve.cgi?native_or_pdf=pdf&id_document=6514982014

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