Form 442 Question 7 Experimentation and Modification Description

0041-EX-ML-1999 Text Documents

Mountain Telecommunications, Inc.

1999-07-21ELS_11281

Question 7: Response
Form 442 Confirmation Number -- Modification Application

This modification application seeks an additional 250 subscriber units to complete the
limited market and interference studies begun under the original experimental station
grant. The demand for Fixed Wireless Access (“FWA”) service to underserved residents
of the Salt River Community was higher than initially expected. In addition, the initial
150 FWA deployments (which are almost completed) have revealed additional demand
for internet, business and second line usage on the reservation. As with the original
experimental license, the equipment will be owned by the Salt River Community, but
operated under contract by Mountain Telecommunications, Inc. To complete the limited
market study for which the experimental license was granted, Mountain
Telecommunications, Inc. and the Salt River Pima Maricopa Indian Community must
examine the market characteristics and economics for higher traffic and higher density
configurations than are permitted by the current experimental license restrictions.
Therefore, authorization for an additional 250 subscriber stations is necessary and will
serve the public interest.

Regarding concerns about what happens to these customers if the spectrum ultimately is
not licensed for the FWA application, the Applicant shares that concern and will make
the significant additional expenditures to upgrade the copper grid if that is the only
solution.

Attached below for the Commission’s information and convenience is Attachment 2 to
the original Experimental Station Application describing the nature and scope of the
experimentation. The other attachments to that application are incorporated herein by
reference.


ATTACHMENT 2

2.0 PROGRAM OF RESEARCH AND EXPERIMENTATION

Mountain Telecommunications Inc. (MTI) seeks Radio Station Authorizations under Part
5 of FCC Rules - Experimental Radio Service - for the purpose of conducting a pilot
deployment of the Nortel Proximity I Fixed Wireless Access system on the Salt River
Pima Maricopa Indian Community (SRPMIC) reservation near Scottsdale, AZ.

MTI specifically references the following types of operations (per section 5.202 of FCC
rules governing the Experimental Radio Service) as being applicable:
(i)     Development of radio technique, equipment, operational data or engineering data
        related to an existing or proposed radio service.
(ii)    Limited market studies
(iii)   Other types of experiments that are not specifically covered under paragraphs (a)
        through (j) of this section

MTI intend to operate the system under conditions approximating those that would exist
in full-scale commercial deployments of the system, in order to evaluate its technical and
operational viability and its ability to satisfy the telecommunications service requirements
of SRPMIC members.

For this pilot deployment, MTI is planning to deploy and operate up to three Proximity I
base stations on the reservation. These base stations will interface directly to MTI’s
existing DMS-500 local exchange and support up to 150 live (non-commercial)
subscribers, of which 65 are presently un-served and would be receiving telephone
service for the first time.

The trial subscribers would utilize a range of standard telephone apparatus (DTMF
telephones, cordless telephones, FAX machines, answering machines and voiceband data
modems) and have access to the full set of data and telephony services provided by the
DMS-500 and supported by the Proximity I system. This includes local voice telephony,
CLASS services, FAX and data services, Internet access, intra- and inter-LATA toll,
operator services and 911 emergency services.

The trial subscribers would have the Proximity I RSS installed at their premises and be
expected to provide feedback to MTI and the equipment vendor (Nortel), on the
performance and overall acceptability (aesthetics, ease of use, service benefits) of the
system and the services provided. This feedback data would then be used to optimize the
operational, performance and deployment characteristics of the system and prepare MTI
for future commercial deployment.


As the Proximity I base stations and subscriber terminals will be radiating and receiving
RF signals in the 3.4-3.5 Ghz band, MTI understands that the system may be susceptible
to interface from, and have the potential to interfere with, other systems operating in this
band. As part of the research and experimentation to be carried out under this
experimental authorization, MTI will assist Nortel in collecting data on the nature of any
interference observed and its effect on the performance of the Proximity I system.

It is our understanding that Nortel has been working with the NTIA, DoD and Joint
Spectrum Centre (JSC) on technical characterization of the Proximity I to determine
whether this system can coexist with other systems in this band and what the coordination
rules would need to be. MTI fully supports this activity and by conducting this pilot
deployment, believes it can demonstrate the economic and social benefits available to
SRPMIC members through shared access to the 3.4 – 3.5 GHz band.


3.0 OBJECTIVES

A summary of the objectives of this program of research and experimentation then
follows:

Mountain Telecommunications Inc. Objectives

   •   demonstrate economic and social benefits of Fixed Wireless technology
   •   evaluate customer acceptance of services provided
   •   demonstrate progress towards becoming facilities-based CLEC
   •   evaluate system performance in a real network environment
   •   investigate service, application and business opportunities
   •   develop staff knowledge on technology and associated functions/processes
   •   develop plans for product standardization, market introduction and deployment
   •   address regulatory aspects of wireless technologies

Nortel Objectives

   •   support regulatory and spectrum initiatives, including DoD/JSC technical project
   •   characterize system performance in US network and propagation environment
   •   confirm performance within operator’s environment
   •   develop application and economic/business case scenarios
   •   identify and resolve product deployment issues
   •   address operational support and operations process issues


4.0 CONTRIBUTION TO RADIO ART

This program of research and experimentation will enable MTI, Nortel and the industry
to evaluate and observe the application of wireless technology in providing wireline-
equivalent telephony services and the associated economic and social benefits. Fixed
Wireless systems such as Proximity I can be enablers for the provision of urban services


to under-served rural areas and true facilities-based competition, given the availability of
suitable spectrum.

This activity will also serve to demonstrate that commercial applications can coexist with
existing government or military applications in the same spectrum and that sharing
arrangements are technically feasible and should be encouraged.

Based on the track record of the Proximity I system (50,000+ subscribers in service in
15+ countries), MTI and Nortel are extremely confident in its ability to successfully test
and ultimately deploy this system in its service area in Arizona.




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Document Created: 2001-08-22 14:29:41
Document Modified: 2001-08-22 14:29:41

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