Exhibit 1 Narrative

0049-EX-PL-2003 Text Documents

Canby Telephone Association

2003-03-16ELS_60557

    Exhibit 1:                      Narrative Statement
                                        in support of
                               Experimental License Application
                               by Canby Telephone Association

1. Background

Canby Telephone Association is a rural telephone Cooperative based in Oregon. Our objective,
as a member of the Advanced Rural Communications Consortium, is to introduce new wireless
services to our members and to underserved areas within a four county area. Members of
Canby Telephone Association include primarily small businesses and residential subscribers.

2. Proposed experimentation program

Canby Telephone Association wishes to provide advanced services to its membership that have
either no wireless service or where only limited Cellular services are available. We propose to
offer a limited mobility, voice and data service, to our subscribers throughout our serving area
and eventually other remote communities. These communities are un-served by PCS and other
newer services because they are small and there is no economic justification for the major
carriers to serve them. Additionally, there is no incentive for these carriers to partition their PCS
spectrum to allow the operation of the type of small, local system proposed here. The units
specified in this application will be deployed in specific areas with limited options for CMRS
service.

This experiment will test the market viability of a limited mobility, mobile local loop service in
within our serving area. While this type of service offer has proven to be very popular in other
countries as an addition to basic local telephone service, the etiquette requirements of the
Unlicensed PCS Band as well as the restrictive licensing of the Licensed PCS band have made
this service unavailable to our subscribers. This experiment, using the existing Unlicensed PCS
band between 1910MHz and 1920MHz, will demonstrate the economic viability of this type of
offer to our Members.

3. Technical information

For cost reasons, Canby proposes operation of Mobile Local Loop and Wireless Local Loop
equipment based on the Japanese RCR28 PHS Standard. This equipment is already approved
to operate in the US in the Licensed PCS band just below 1910MHz, though most license holders
for that spectrum have shown no willingness to allow small operators to have access to their
licensed spectrum. Because of frequency allocations in other countries, including Mexico and
much of the Americas, as well as countries in Asia, inexpensive equipment can operate in the
range up to 1920MHz. Canby proposes operation here in the Unlicensed PCS Spectrum from
1910MHz ~ 1920MHz using equipment manufactured by UTStarcom, Inc. and JSM Electronics, a
US based WBE, that is approved for deployment in the low power half of the PCS band. Canby
proposes deployment of units with a maximum peak power of 1.6W for fixed infrastructure and
80mW for mobile units. Due to the low power nature of these deployments; the fact that all
equipment expected to be deployed is already approved for use in the adjacent licensed PCS
band; as well as the remote areas where service is expected to be provided, Canby believes that
granting this license will have no adverse impact on other operators in nearby bands.


Equipment currently under consideration includes:

 Type                            manufacturer                     model number
 handset                         UTStarcom/JRC                    UTS708J
                                 UTStarcom                        UTS702U
                                 UTStarcom                        UT618
                                 UTStarcom                        UTS-701
 Radio Port                      UTStarcom/JSM Electronics        EA-7H74
                                 UTStarcom/JSM Electronics        EA-7H75
                                 UTStarcom/JSM Electronics        EA-7T56B
 Cell Station                    Sanyo/JSM Electronics            EA-7H81
 Fixed Subscriber Unit           UTStarcom                        UTS800/UTS801

All subscriber units have a transmission power limit of 10mW Average Power/80mW Peak Power
while the infrastructure units transmit up to 200mW Average Power/1.6W Peak Power. Other
RCR28 Standard PHS equipment will also be considered for use and in all cases this equipment
will first be approved under Part 24 for operation below 1910Mhz. In the application, these units
are shown as being “Experimental”. This is true for the 1910MHz ~ 1920MHz band being
requested here. In all other ways, these units are not experimental and are, in fact, production
units certified for use in the licensed PCS band.

5. Station identification

Canby requests that the station call sign requirement of 47CFR5.152 be waived in view of the
low-power nature of the transmissions and the unsuitability for this purpose of the PHS air
protocol as well as due to the distributed nature of the deployments.



Document Created: 2003-03-17 07:11:25
Document Modified: 2003-03-17 07:11:25

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