POSITION OF ROBERT GEHMAN, JR., CONCERNING THE POSTPONEMENT OF THE FCC FILING WINDOW FOR TWO-WAY MDS AND ITFS

 I have been a full member of the Association of Federal Communications Consulting Engineers for nineteen years. I support the Association’s petition for revision of the initial filing window.

On September 25, 1998, the FCC released the Report and Order enabling MDS and ITFS licensees to engage in fixed two-way transmissions. The Report and Order included an Appendix D titled “Methods for Predicting Interference from Response Station Transmitters and to Response Station Hubs and for Supplying Data on Response Station Systems”. About December 1999, our firm started getting serious inquiries about preparing two-way applications, so I began to develop software to meet the design and interference analysis requirements of Appendix D. By the end of January I completed a Fortran program that would calculate interference from a single site with multiple transmitting antennas (sectorized transmitting system) into the service area of another station. I also completed a Fortran program to generate the grid points for the Response Service Area meeting the 3-dB criteria of Appendix D, and to establish the highest ground elevation for the worst-case analysis. I knew the next step would be difficult; the terrain and field strength analysis from each grid-point in the RSA to each grid point within the service area of another station. The minimum number of grid points required in an RSA depends on a lot of factors, but a 35-mile protected service area must have at least 3,850 grid points. A study from an RSA to one incumbent protected service area could easily involve a million path profiles and signal calculations. After learning that EDX was working on a new tool to meet the requirements of Appendix D, and that the FCC had revised Appendix D, I decided, at least temporarily, to wait for someone else to supply the software to meet these requirements.

I first heard of CelPlan in January of this year. I found their web site and inquired about a tool to conduct the Appendix D analysis. I explained my interest and provided some background on my firm. I received no answer and tried again. Soon thereafter I heard that CelPlan was working with Sprint, and so I speculated that CelPlan was perhaps not planning to sell their software to outside consultants.

In April I was told by an ITFS client that MCI intended to make available a limited version of CelPlan to permit ITFS licensees to conduct their own interference analysis for the purpose of issuing interference consents. I was asked to provide a quote for making the studies, so I contacted CelPlan to determine the cost of the limited-use software. I found that no decision had been made to produce such a limited-use tool. Instead I was given a price of a one-year license to use the CelPlan suite consisting of CelPlanner and CelFCC. I was told that the tool was 95% complete. Also in April we received an invitation from Sprint and MCI to attend a free training seminar on the use of CelPlan to evaluate the affects of two-way interference caused to our ITFS client stations. However, it did not seem reasonable to attend the seminar because the cost of the CelPlan tool would not be affordable for our ITFS clients. Two of us eventually attended the seminar on April 26-28, at our own expense, primarily out of concern that not to attend would somehow let down our ITFS clients.

By this time we were receiving more requests for quotes to provide two-way design services and FCC applications, both from ITFS and MDS entities. We advised them all of the probable high fees due to the cost of the software necessary to conduct the interference analyses and generate the Appendix D file required for submission to the FCC. We explained that we could not predict the amount of time required to complete a project without any experience with the software. A sufficient number of agreements were eventually made to justify the purchase of the CelPlan software, with the understanding that some applications may not be completed by the filing deadline. The EDX software was not available at that time. We ordered the CelPlan software and reserved a place in their training seminar scheduled for May 10 to 12, but the seminar was postponed one week. We received the CelPlan tool on May 15 and attended the seminar on May 17 to 19. The CelFCC tool still has no printed or electronic manual, or “help” function. We have had to seek answers to many questions via e-mail. We discovered that different settings could produce different results without any indication that one or more results are erroneous. We also received several software upgrades through June 6. Note that the tool does not yet have the capabilities to analyze pre-existing interference, import Appendix D files, or calculate hub interference, but those capabilities are anticipated.

CelPlan and EDX are to be congratulated for their fine work. These are powerful tools requiring massive computing power. The learning curve is steep and, after three weeks of continuous use, we are becoming comfortable with the CelPlan product. The approach to a two-way design is at best an iterative process. One must establish the parameters of the subscriber stations, create a boundary around the desired service area, generate a system of grid points within the service area, and then conduct interference studies. If any of the studies fail to meet the FCC criteria, then either the parameters of the subscriber stations must be changed or the service area must be reduced, or both. The iterative process can be very time consuming even with a powerful computer.

As of today, June 13, there are 27 days, including weekends and holidays, left to prepare applications. How many applications can be completed in the remaining time? Probably not enough to meet the demand.

Robert Gehman, Jr., P. E.

President

KESSLER AND GEHMAN ASSOCIATES, INC.

June 13, 2000

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