CARL T. JONES CORPORATION

ITFS/MMDS INITIAL TWO-WAY FILING WINDOW

SOFTWARE FUNCTIONALITY CONCERNS

June 13, 2000

Carl T. Jones Corporation is committed to the preparation of applications for two-way systems to be filed by ITFS licensees during the initial filing window. Additionally, we have been retained to assist in the preparation of applications in behalf of ITFS licenses represented by ITFS 2020, L.L.C.

Upon release of the REPORT AND ORDER (FCC 98-231) on September 25, 1998 we realized, when we evaluated Appendix D, that task specific software would be required to perform the analyses called for. We have been searching for such a tool since. In April 1999 we received from EDX Engineering a preliminary MMDS module for evaluation. We continued to search for other possible remedies as well.

When we became aware of CelPlan Wireless Global Technologies we immediately sought to obtain access to their software package. In April 2000 we purchased licenses for CelPlanner, CelOptima and CelFCC. We had eight people participate in a three-day training program prior to the official software release on April 15, 2000. We also learned that EDX Engineering was about to release its new module designed to perform the Appendix D analyses calculations. We had two people participate in a two-day training seminar during the week following its official release on May 15, 2000.

In our process of application preparation we have identified some characteristics of both software packages which require some adjustments in order for us to successfully use them to prepare certifiable applications. Although the FCC  has not yet fully clarified the details of the “limited exception” to the 35 mile radius protected service area, we believe that neither software package can provide an efficient solution for that exception. (Nor has the FCC yet released an adequate ITFS/MMDS database, but that is a subject for another time) Further, neither software tool is yet capable of accepting system design output data from a diskette or CD-ROM for evaluation of potential interference from a proposed two-way system to an incumbent licensee’s system.

We have found that the time required to prepare a two-way application is extensive. The interference analyses required for all incumbent licensees potentially affected by a two-way system design proposal requires complex iterative calculations to search for predicted interference. We believe that the design and application process for a single licensee’s two-way system can require hundreds of man-hours, depending on the number of response hubs and boosters the system design might require.

Both CelPlan and EDX continue to provide improvements in their respective software tools. However, even if all software issues were to be resolved today, there is still insufficient time remaining prior to the initial filing window to meet the demand for ITFS application preparation. In this regard, this firm is still receiving inquiries this week from both ITFS and MMDS licensees unable to obtain engineering assistance in the design and application process for expansion to two-way service.

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