Subject: [NEXTEL-1] Amendment of the Commission’s Rules WT Docket No. 02-318 Concerning Airport Terminal Freqs.

From: Marcelrf <[email-masked]>
Date: Mon, 01 Mar 2004 10:49:28 -0500

Before the
FEDERAL COMMUNICATIONS COMMISSION
Washington, D.C. 20554
In the Matter of

Amendment of the Commission’s Rules  WT Docket No. 02-318 Concerning
Airport Terminal Use Frequencies  RM-10184 in the 450-470 MHz Band of
the Private Land
Mobile Radio Services

EX PARTE COMMENTS OF PCIA

PCIA, the Wireless Infrastructure Association, hereby respectfully
submits the following Ex Parte Comments in the above-captioned
proceeding.

This proceeding was initiated as the result of a Petition for Rule
Making filed by PCIA in June of 2001. It was necessitated by changes in
the Universal Licensing System and growing incidences of airlines being
unable to communicate within the airport grounds. The Commission’s
Notice of Proposed Rule Making (“NPRM”) asks several questions regarding
PCIA’s proposal, and offers some potential alternatives.1 While PCIA’s
comments addressed in detail various aspects of this proceeding,
including support for an increased ERP for mobile units, PCIA did not
address the specific ERP limitation for mobile units. Therefore, PCIA
herein supplements the Commission’s record in this proceeding.

1See, Amendment of the Commission’s Rules Concerning Airport Terminal
Use
Frequencies in the 450-470 MHz Band of the Private Land Mobile Radio
Services, Notice of
Proposed Rulemaking, WT Docket No. 02-318, 17 FCC Rcd 19904 (2002).

It is important that the Commission select power limits that enable
airline licensees to
communicate reliably at the airport, using “off the shelf” equipment,
while at the same time not
cause interference to other users. Accordingly, PCIA would suggest an
ERP limit for mobile
units of forty (40) watts. Such radios are readily available, provide
sufficient coverage in belowgradeareas around airports, and represent
the proper balance between a typical airport system’s “talk-out” versus
“talk-in” range. Limiting the ERP to forty (40), even though 110 watt
radios are available, will limit the possibility of airport systems
interfering with co-channel users.WHEREFORE, the premises considered, it
is respectfully requested that the Commission act in accordance with the
views expressed herein.

Respectfully submitted,
PCIA, The Wireless Infrastructure Association
By: Alan S. Tilles, Esquire

http://gullfoss2.fcc.gov/prod/ecfs/retrieve.cgi?native_or_pdf=pdf&id_document=6515783219

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