License Renewal

0175-EX-RR-2007 Text Documents

Qwest Corporation

2007-10-18ELS_85311

                                                                           FCC FORM 405
                                                                              EXHIBIT 1
                                                                             PAGE 1 OF 2



        APPLICATION FOR RENEWAL OF EXPERIMENTAL LICENSE

        Pursuant to Section 5.71 of the Commission’s rules, Qwest Corporation (the
“Applicant”) seeks to renew its experimental radio service station license (WD2XTK),
for a period of 18 months, up to an including May 1, 2009, in order to continue its
technical trial of non-type accepted wireless broadband equipment utilizing Worldwide
Interoperability for Microwave Access (WiMAX”) technology in the 3.5 GHz band. The
instant request seeks license renewal only; Qwest proposes to continue conducting its
experimental operations consistent with all technical parameters set forth in its current
instrument of authorization. For the reasons set forth below, the Applicant respectfully
submits that favorable Commission action on the instant request will serve the public
interest, convenience and necessity.

                                       Background

        The Applicant is a wholly-owned, indirect subsidiary of Qwest Communications
International Inc. (together with the Applicant, “Qwest”), a premier provider of full-
service voice, video and data services for people at work, home and on the move. Indeed,
Qwest’s broadband network, designed with the latest advances in network technology for
speed and efficiency, spans the globe, enabling new products and services that benefit
businesses and consumers worldwide. In order to continually expand, enhance and
evolve these service and product offerings, Qwest aggressively seeks out and tests new
technologies to enable broadband connectivity.

                                    Purpose of Request

        Since initiating experimental operations, Qwest has been testing WiMAX
hardware, software and network management systems. To date, the results of these
experiments have been excellent, yielding valuable technical and operational data. In
order to expand its knowledge of WiMAX technology, Qwest seeks Commission
authority to continue these experiments. In particular, Qwest seeks to compile additional
technical data from operational monitoring, including mean-time failure rates and service
outage statistics, as part of its larger analysis of long-term system reliability. Qwest also
plans to study new WiMAX technologies and products, such as handoff protocols,
adaptive antenna systems, new indoor consumer premises equipment and, in general,
newly-certified WiMAX component hardware. Finally, Qwest proposes to conduct load
testing of new software and firmware releases.

       By continuing its experimental operations, Qwest expects to gain a fuller
understanding of the strengths and limitations of WiMAX technology in providing
broadband IP access, video distribution, voice services, and other wireless broadband
services and products. Qwest understands and acknowledges that its experimental


                                                                         FCC FORM 405
                                                                            EXHIBIT 1
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operations must be conducted on a secondary basis only. Accordingly, Qwest will adhere
to good engineering practices at all times, and will suspend operations in the event its
experimental program causes harmful interference to primary users of the band.
Moreover, Qwest will continue to exercise appropriate care to ensure that all end-user
equipment is returned once its experimental trials conclude.

                                 Public Interest Benefit

         Qwest’s experimental program already has generated valuable technical data
regarding a promising new technology for delivering wireless broadband access. As a
leading provider of broadband solutions, Qwest is ideally suited to test and evaluate the
utility of this new technology, including the new round of testing described above.
Accordingly, Qwest respectfully submits that inasmuch as approval of the instant
application for license renewal will benefit the development of wireless broadband
technology, and will thus help advance the art of radio science, it should be granted as
consistent with the public interest, convenience and necessity as expeditiously as
possible.



Document Created: 2007-10-18 11:03:55
Document Modified: 2007-10-18 11:03:55

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