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0233-EX-PL-2003 Text Documents

Qwest Communications

2003-10-30ELS_63669

Exhibit 1:                Narrative Statement
                              in support of
                     Experimental License Application
                        by Qwest Communications

1. Background

Qwest Communications is publicly held Local Exchange Carrier based in Denver
Colorado. Our objective is to evaluate a PHS based wireless communication
service to determine the viabililty of providing various Enterprise markets in the
United States with this service.

2. Proposed experimentation program
Qwest Communications has identified significant opportunities to serve it’s
Enterprise customer base with wireless communications services as an
extension of current PBX or Centrex service offerings. We propose to offer a
limited mobility, voice and data service, to subscribers in their office locations. If
the technology is determined to be a viable technology for this purpose, this type
of small, localized system proposed here would be deployed in small numbers in
different business facilities in the United States. The specific locations have yet
to be identified.

This experiment will test the market viability of a limited mobility, voice and data
service for this market. While this type of service offer has proven to be very
popular in other countries as an extension of basic wired services, 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 the US market.
This experiment, using the existing Unlicensed PCS band between 1910MHz and
1920MHz, will demonstrate the economic viability of this type of offer in the US
and can be used to justify additional development in available bands.


3. Technical information

 Qwest Communications proposes operation of Mobile telephone line extension
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, however the location of the testing facilities identified for this
experiment are outside of Qwest’s Licensed PCS area. Qwest Communications
proposes deployment of units with a maximum peak power of 200mW 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; Qwest believes operation of this equipment will have no
adverse impact on other operators in nearby bands.


Equipment currently under consideration includes:

 type                       manufacturer                model number
 handset                    UTStarcom                   WTL00535
 MCU                        UTStarcom                   20570004


 CSC/WRT                    UTStarcom                   41060074




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.



Document Created: 2003-10-30 16:16:19
Document Modified: 2003-10-30 16:16:19

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