Before the
`FEDERAL COMMUNICATIONS COMMISSION
`Washington, D.C. 20554
`
`RM- 717&
`
`) ) ) ) ) ) ) )
`
`In the Matter Of:
`
`Mobile Telecommunication
`Technologies Corporation
`
`Petition for Rulemaking to
`Allocate 150 kHz in the 930-931
`MHz Band and to Establish Rules
`and Policies for a New Nationwide
`Wireless Network (NWN) Service
`
`PETITION FOR RULEMAKING
`
`Richard E. Wiley
`R. Michael Senkowski
`David E. Hilliard
`Eric W. DeSilva
`WILEY, REIN & FIELDING
`1776 K Street, N.W.
`Washington, D.C. 20005
`(202) 429-7000
`
`for
`
`MOBILE TELECOMMUNICATION
`TECHNOLOGIES CORPORATION
`
`Dated: November 12, 1991
`
`Juniper Ex 1005-p. 1
`Juniper v MTel891
`
`

`
`Before the
`FEDERAL COMMUNICAnONS COMMISSION
`Washington, D.C. 20554
`
`RM-
`
`_
`
`) ) ) ) ) ) ) )
`
`In the Matter Of:
`
`Mobile Telecommunication
`Technologies Corporation
`
`Petition for Rulemaking to
`Allocate 150 kHz in the 930-931
`MHz Band and to Establish Rules
`and Policies for a New Nationwide
`Wireless Network (NWN) Service
`
`PETITION FOR RUlEMAKING
`
`Richard E. Wiley
`R. Michael Senkowski
`David E. Hilliard
`Eric W. DeSilva
`WILEY, REIN & FIELDING
`1776 K Street, N.W.
`Washington, D.C. 20005
`(202) 429-7000
`
`for
`
`MOBILE TELECOMMUNICATION
`TECHNOLOGIES CORPORATION
`
`Dated: November 12, 1991
`
`Juniper Ex 1005-p. 2
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`

`
`TABLE OF CONTENTS
`
`SUMMARY
`
`I.
`
`INTRODUCTION
`
`IV
`
`.
`
`A.
`
`B.
`
`Mtel Consistently Has Been a Pioneer In Developing And
`Implementing High Technology Wireless Services
`
`Mtel Has Developed A Needed, Affordable and Efficient
`Nationwide Wireless Network Service . . . . . . . . . . . . . . . . . ..
`
`II.
`
`PROVISION OF NWN WOULD MEET A SIGNIFICANT DEMAND
`FOR TWO-WAY PORTABLE DATA COMMUNICATIONS
`
`A.
`
`B.
`
`C.
`
`There is an Increasing and Unaddressed
`Demand for Economic, Two-Way Portable Data Communications..
`
`NWN Will Allow Virtually Unlimited User Access for Message
`OngmatlOn
`
`NWN Utility Would be Enhanced By Permitting Use of NWN as
`an "Answer-Back" Service. . . . . . . . . . . . . . . . . . . . . . . . ..
`
`III.
`
`MTEL'S MODEL NWN SYSTEM ARCHITECTURE ILLUSTRATES
`THAT EFFICIENT, EXPANDABLE AND RELIABLE TWO-WAY
`COMMUNICATIONS SERVICE CAN BE PROVIDED TODAY.
`
`. . . ..
`
`1
`
`4
`
`8
`
`8
`
`11
`
`12
`
`13
`
`Mtel's Model NWN System . . . . . . . . . . . . . . . . . . . . . . . ..
`
`13
`
`A.
`
`B.
`
`Mtel's NWN System Capacity
`
`IV.
`
`V.
`
`THE COMMISSION SHOULD ALLOCATE 150 kHz FROM THE 930-
`931 MHz BAND FOR AN NWN SERVICE . . . . . . . . . . . . . . . . . ..
`
`THE COMMISSION SHOULD DEVELOP NWN LICENSING
`PROCEDURES AND STANDARDS THAT FOSTER COMPETITION
`PROMOTE INDIVIDUALITY AND DISCOURAGE SPECULATION . ..
`
`A.
`
`NWN Licensing Procedures and Standards Should Accommodate
`Multiple Providers . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 20
`
`- 1 -
`
`17
`
`18
`
`20
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`
`B.
`
`C.
`
`NWN Rules Should Provide Licensees Flexibility to Design
`Unique Systems
`
`The Commission Should Adopt Rules that Discourage the Filing
`of Speculative Applications
`
`1.
`
`2.
`
`3.
`
`The Commission Should Adopt Stringent Threshold Filing
`Requirements
`
`The Commission Should Use Streamlined Comparative
`Hearings to Award NWN Licenses
`. . . . . . . . ..
`
`The Commission Should Adopt Strict Antitrafficking Rules
`
`.
`
`30
`
`21
`
`25
`
`25
`
`27
`
`VI. CONCLUSION..................................... 31
`
`APPENDIX A - Mtel's Model NWN System Architecture
`
`TAB A
`
`FORWARD AND REVERSE CHANNEL SIMPLEX OPERATION .... A2
`
`I.
`
`II.
`
`FORWARD CHANNEL TRANSMISSIONS IN MTEL'S MODEL
`NWN SYSTEM
`
`Mtel's National Simulcast Provides an Efficient Transmission
`Method for Forward Channel Messaging
`
`A3
`
`A4
`
`A8
`
`A10
`
`A12
`
`A.
`
`B.
`
`C.
`
`Mtel's Use of Innovative Enhanced Multitone Modulation
`Technology Significantly Increases Total Forward Channel
`. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . A5
`Throughput
`
`Adaptive Zoning of the Forward Channel Transmission Network
`Allows Mtel's Model NWN System to Increase Throughput to
`Satisfy Demand
`
`D.
`
`Forward Channel Transmission Protocol
`
`III.
`
`REVERSE CHANNEL TRANSMISSIONS IN MTEL'S MODEL NWN
`SYSTEM
`
`A.
`
`B.
`
`Deterministic Interval Protocol
`
`. . . . . . . . . .. A13
`
`Contention Interval Protocol . . . . . . . . . . . . . . . . . . . . . . .. A14
`
`- 11 -
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`
`APPENDIX B - Simulcast Network Primer
`
`TRADITIONAL SIMULCAST SYSTEMS
`
`TAB 8
`
`Bl
`
`I.
`
`II.
`
`III.
`
`IV.
`
`MODERN SIMULCAST TECHNIQUES . . . . . . . . . . . . . . . . . . . ., B2
`
`SIMULCASTING COMBATS MULTIPATH
`
`SIMULCASTING VERSUS CELL BASED RE-USE . . . . . . . . . . . ..
`
`84
`
`B5
`
`APPENDIX C - Proposed Rules
`
`TAB C
`
`- iii -
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`
`SUMMARY
`
`Mobile Telecommunication Technologies Corporation ("Mtel ") urges the
`
`Commission to adopt rules and policies providing for the licensing of carriers to
`
`operate in a new Nationwide Wireless Network ("NWN") Service. Three nationwide
`
`licensees should be authorized. Each of these licensees would employ a 50 kHz
`
`channel in the 930-931 MHz band for a two-way, high speed messaging service to
`
`portable terminals.
`
`To illustrate the vast capabilities and potential of an NWN service, Mtel also
`
`describes in its petition an efficient means for implementing NWN. As operated by
`
`Mtel, an NWN facility would feature:
`
`•
`
`•
`
`Nationwide determination of the relative location of subscribers;
`
`Two-way and one-way high speed data communications;
`
`• Wide area coverage expandable in a straightforward and economic fashion using
`proven simulcast techniques;
`
`•
`
`•
`
`Spectrum efficient enhanced multitone modulation; and,
`
`Large regional zoning for capacity re-use.
`
`A high capacity infrastructure and an intelligent architecture to manage the network are
`
`the keys to implementing NWN in a modest amount of spectrum.
`
`Mtel predicts that demand for NWN service will prove to be substantial. By
`
`1996, Mtel forecasts an installed base of more than three million units equipped for --
`
`and needing -- the data transfer capabilities that could be provided by NWN. NWN
`
`-
`
`IV -
`
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`
`will address the need for a universal, highly flexible open access data transmission
`
`medium.
`
`In so doing, NWN will bring to the two-way data market the ease of use and
`
`vast coverage now available in the nationwide paging service.
`
`Mtel also has proposed herein a regulatory framework designed specifically to
`
`increase substantially the options available for the digital transmission of two-way
`
`messages by allowing licensees considerable flexibility to design innovative NWN
`
`systems. Sharing the Commission's concerns with regard to speculation and delay in
`
`the initiation of service to the public, however, Mtel also has proposed rules in this
`
`petition that call for threshold demonstration of applicant qualifications, selection from
`
`among competing mutually exclusive applicants by expedited comparative hearings, and
`
`limitations on alienability of NWN licenses.
`
`Mtel believes that NWN is capable of satisfying an acute and growing need for
`
`wireless two-way data transfer services. As shown in Mtel' s petition, NWN services
`
`can be made available now, and, unlike many proposals, NWN will not be a stopgap
`
`measure. Rather, NWN offers evolutionary capabilities that will allow NWN to remain
`
`a viable and functional service for the foreseeable future. Mtel consequently requests
`
`the Commission to act favorably upon its petition and initiate a rulemaking to explore
`
`fully the potential for NWN service.
`
`- v -
`
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`

`
`Before the
`FEDERAL COMMUNICATIONS COMMISSION
`Washington, D.C. 20554
`
`RM -
`
`_
`
`) ) ) ) ) ) ) )
`
`In the Matter Of:
`
`Mobile Telecommunication
`Technologies Corporation
`
`Petition for Rulemaking to
`Allocate 150 kHz in the 930-931
`MHz Band and to Establish Rules
`and Policies for a New Nationwide
`Wireless Network (NWN) Service
`
`PETITION FOR RULEMAKING
`
`Mobile Telecommunication Technologies Corporation (tlMtel Ol
`
`) , by its attorneys,
`
`hereby requests the Commission to initiate a rulemaking to allocate 150 kHz in the
`
`930-931 MHz band and to establish rules and policies for a new Nationwide Wireless
`
`Network (tlNWNtI) service. Mtel submits that an allocation of 150 kHz is in the public
`
`interest because it would permit three licensees to establish high capacity two-way
`
`nationwide data networks.
`
`I.
`
`INTRODUCTION
`
`A.
`
`Mtel Consistently Has Been a Pioneer In Developing And
`Implementing High Technology Wireless Services
`
`Mtel and its corporate predecessors consistently have been world trendsetters
`
`and pioneers at the forefront of messaging developments, with extensive experience in
`
`designing, constructing, and operating high technology wireless communications
`
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`

`
`- 2 -
`
`servIces. Mtel and its subsidiaries hold licenses in the nationwide paging service, the
`
`public air-to-ground service, the specialized mobile radio service, and various marine
`
`radio services. Mtel and its corporate predecessors have over five years of experience
`
`as nationwide system operators and over fifteen years of experience as wide area
`
`system operators.
`
`Mtel consistently has been at the forefront of messaging developments.
`
`In
`
`1965, Mtel' s predecessor company obtained an FCC license to operate a then state-of-
`
`the-art paging service. Seeing the future for ll1essaging services, by 1973 the company
`
`acquired nine additional paging companies and applied for and received FCC licenses
`
`to operate paging services throughout much of the southeastern United States and in
`
`New York State.
`
`In the early 1980's, Mtel was actively involved in the FCC proceedings
`
`regarding allocating spectrum for a nationwide paging service. Mtel was convinced
`
`that consumers would respond favorably to a high quality nationwide service.
`
`Ultimately Mtel's subsidiary, SkyTel, Inc. (" SkyTel"), was awarded the first
`
`nationwide paging license at 931.9375 MHz. 1 At that time, three construction permits
`
`The license was awarded in 1985 to .. American Satellite Paging." Since that time, the
`o-.vnership of the company and the name have changed. The name was officially changed to .. SkyTel" in
`1989. At present, Mtel owns approxirnalely 91 percent of SkyTel and the remainder is owned by
`Radiofone, Inc.
`
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`- 3 -
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`for nationwide paging were awarded but Mtel was the first licensee and the only one of
`
`the three that successfully built and launched a nationwide paging service. 2
`
`As predicted, SkyTel's nationwide service has become more and more popular.
`
`Business executives who frequently travel have discovered it to be an invaluable tool
`
`which provides uninterrupted reachability across the major cities of the U. S. combined
`
`with convenience, privacy and security.3 SkyTel had approximately 19,800 units in
`
`service as of December 31, 1988. By September of this year, that figure had grown to
`
`over 115,000 units in service, an increase of approximately 580 percent over a 33
`
`month period. Forecasts are for continued high growth and, in fact, one report
`
`estimates that the number of nationwide pagers by 1995 will reach 870,000.4
`
`2 Development of the service involved the creation of sophisticated central computer technology,
`with toll-free access and a spread-spectrum VSAT satellite interconnection system. Several monitoring
`and alarm functions also were built into the nationwide paging network to ensure maximum reliability
`and minimum downtime.
`
`SkyTel typically transmits radio pages to any network city in less than one minute. Callers
`3
`reach the central computer using a toll-free number. The computer's synthesized "voice prompts· guide
`the caller through steps to enter messages or to use any of the more than a dozen pager functions. The
`computer validates subscribers' personal identification numbers, records billing information, formats
`messages and transmits them to the satellite uplink terminal. The messages are uplinked to a satellite
`which rebroadcasts them simultaneously to each downlink terminal in every SkyTel network city. The
`paging messages are then fed to terrestrial transmitters for simulcast transmission to paging receivers on
`the 931 MHz frequency.
`
`4 Donaldson, Lufkin & Jenrette has modeled the nationwide paging industry and has concluded
`that "10-15% of total paging customers will eventually subscribe to a nationwide system. Currently,
`estimates call for 10-15 % annual growth in the current 8 million-subscriber paging population, resulting
`in approximately 15.1 million paging customers in the U.S. by 1995. Going out to 1995, our model
`conservatively places aggregate nationwide paging subscribers at 870,000, or 5.7% penetration of total
`. .• Donaldson, Lufkin & Jenrette, Company Analysis of Mobile Telecommunication
`pagers.
`Technologies, June 19, 1990, at 5.
`
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`- 4 -
`
`Mtel also is a major shareholder in the American Mobile Satellite Corporation
`
`(It AMSC"), the consortium licensed by the Commission to provide mobile satellite
`
`service in the United States. AMSC's mobile satellite service will provide a full range
`
`of advanced, high technology land, maritime and aeronautical message services,
`
`including public safety services.
`
`Mtel's paging innovation continues.
`
`In addition to operating the first nationwide
`
`messaging network, Mtel recently announced the first 2,400 bps simulcast messaging
`
`technology. 5 Even more recently, Mtel announced plans to provide nationwide one-
`
`way wireless mailbox service to AT&T's SafariTK computer through the SkyTel
`
`network.
`
`In this service, AT&T's EasylinkTK electronic mail service will be linked to
`
`SkyTel via a gateway and permit users to send mail to SafariTK computers equipped
`
`with a low cost adapter. 6
`
`B.
`
`Mtel Has Developed A Needed, Affordable and Efficient
`Nationwide Wireless Network Service
`
`Mtel's extensive experience with a broad base of communications systems
`
`provides it with unique insights into identifying public need for new radio services.
`
`In
`
`this petition, Mtel addresses a deficiency in commercial radio services designed to meet
`
`the growing data transmission needs of portable computer users. Although a number of
`
`5
`
`See Telocator Bulletin, Vol. 91 No. 32, p. 2 (August 11, 1991).
`
`6 Although somewhat analogous to the proposed NWN service in terms of ease of use and area of
`operation, NWN will be a fully two-way service, unlike the Easylink'" gateway service.
`
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`
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`
`radio based local area network concepts have been proposed and eventually may
`
`provide wireless office data transfer capability for portable computers, the benefits of
`
`this technology have not been extended much beyond the physical building. Some two(cid:173)
`
`way data services have been designed for SPeCialized out-of-building applications.
`
`These services, however, lack universally accessible and adaptable public interfaces;
`
`the nationwide, ubiquitous coverage familiar to today's one-way messaging customers;
`
`and adequate building penetration characteristics.
`
`Mtel anticipates extensive demand for a service designed to fill this void -- a
`
`nationwide wireless network ("NWN") service. NWN will provide an efficient and
`
`convenient means for the public to interchange data with users travelling throughout the
`
`nation as well as a mechanism to address the significant market for messaging where an
`
`acknowledgement to a message is required or desirable. Mtel's initial market research
`
`indicates that demand for a highly portable general messaging service from the installed
`
`base of portable computers alone potentially could reach up to 3.5 million terminal
`
`units by 1996, with combined demand from "answer-back" and "acknowledge-only"
`
`pager units even higher.
`
`Mtel has designed an affordable NWN service to address these needs,
`
`transferring its extensive technical resources and knowledge of wide area simulcasting
`
`into the two-way context. Mtel's proposed NWN service departs significantly from the
`
`existing commercial radio service concepts. NWN is not just an adjunct or
`
`complementary service, but rather a full service that contemplates:
`
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`
`- 6 -
`
`•
`
`•
`
`•
`
`•
`
`•
`
`•
`
`•
`
`A nationwide system with wide area coverage of metropolitan areas.
`
`A graceful, evolutionary deployment scheme allowing NWN to
`circumvent saturation by subdividing the existing network in a low cost,
`incremental fashion.
`
`An architecture facilitating efficient two-way transmission of short as
`well as extended length messages.
`
`Portable user terminals resembling "notebook" or "palmtop" computers
`in size and weight equipped with displays, keyboards, and extensive
`memory.
`
`Acknowledgment and error checking of messages sent or received by
`user terminals, including preformatted responses from pager-sized
`terminals.
`
`Nationwide automatic determination of the general location of
`subscribers.
`
`Enhanced, high-speed one-way messaging services.
`
`Mtel's use of simulcasting is ideally matched to the coverage and spectrum
`
`requirements of the NWN service. While simulcasting is not appropriate for some real
`
`time applications such as voice, where users must be allocated dedicated subchannels
`
`composed of frequency or time slices, NWN's storage and queuing operation does not
`
`demand real time access. Conversely, spectrum efficiency measures utilized in real
`
`time systems, like FDMA cell-based re-use schemes or narrowbanding, are not ideal
`
`for systems where acceptable delay is measured in seconds rather than microseconds.
`
`Simulcasting, however, provides superior building penetration characteristics and
`
`permits simpler, less expensive expansion of coverage since there is no need to alter
`
`the existing time or frequency usage patterns of adjacent transmitters. Simulcasting
`
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`
`- 7 -
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`also fully utilizes all available capacity at any point, both in the frequency and time
`
`domains.
`
`Previously, a service combining all of the characteristics of NWN would have
`
`been prohibitively expensive for both subscribers and carriers due to the spectrum
`
`demands and transmission technology required for implementation.
`
`In particular, the
`
`destructive summing of "mis-synchronized" signals that occurs in simulcast systems
`
`effectively limits the baud rate to approximately 3,000 baud.7 Utilizing state-of-the-art
`
`modulation schemes, the 3,000 baud limit translates into an effective maximum bit rate
`
`of only 6,250 bits per second ("bps"), the rate proposed for the European Radio
`
`Messaging System ("ERMES"). At this throughput, either messages must be very
`
`short or subscribers must pay excessively high service costs.
`
`Mtel, however, recently developed a proposed service offering that goes beyond
`
`the current state-of-the-art by incorporating several innovative technologies in a
`
`synergistic fashion to accommodate significant amounts of NWN traffic. 8 Mtel's
`
`offering not only will provide effective transmission rates up to 24,000 bps, but also
`
`will allow capacity re-use. Mtel's integration of highly advanced technologies thus will
`
`The baud rate differs from the bit rate in that the baud rate describes the rate at which symbols
`7
`can be transmitted, and the bit rate describes the throughput achieved by decoding the symbols into a
`binary stream. Mtel has described the limitation on the baud rate in detail in the attached Appendix B.
`
`8 Mtel concurrently is filing a request for a pioneer's preference for the NWN service. Mtel
`believes its advances in the current state-of-the-art for messaging services satisfy the Commission's
`criteria for award of a pioneer's preference as stated in Establishment of Procedures to Provide a
`Preference to Applicants Proposing an Allocationfor New Services, 6 FCC Red 3488 (1991).
`
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`
`- 8 -
`
`enable the proposed NWN service to be priced such that significant volumes of
`
`commercial traffic will be generated.
`
`The key to Mtel's proposed NWN service offering is the marriage of high
`
`speed, spectrally efficient enhanced multitone modulation techniques with an
`
`"intelligent" infrastructure. By placing the burden of arranging compact and efficient
`
`communications on a central scheduler, Mtel will be able to meet expected demand
`
`with far less spectrum than would be possible using existing systems. Mtel, however,
`
`does not believe the Commission should restrict NWN operators to the specific system
`
`configuration developed by Mtel, although alternative implementations should provide a
`
`comparable level of efficiency, service quality, and throughput.
`
`II.
`
`PROVISION OF NWN WOULD MEET A SIGNIFICANT DEMAND
`FOR TWO-WAY PORTABLE DATA COMMUNICATIONS
`
`A.
`
`There is an Increasing and Unaddressed Demand for
`Economic, Two-Way Portable Data Communications
`
`Increasing use of portable digital devices is driving demand for two-way
`
`wireless data communications. This demand from compact devices for high-speed,
`
`wide area, digital communications nationwide has not been met by current mobile
`
`services.
`
`In particular, demand for wireless data interchange with remote digital
`
`devices and electronic mail ("E-Mail") systems is unsatisfied by current commercial
`
`radio based providers, since current systems lack:
`
`(1) public interfaces that are both
`
`utilitarian and "user-friendly," (2) adequate building penetration, and (3) ubiquitous
`
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`

`
`- 9 -
`
`wide area operation -- characteristics critical to serving today's portable user
`
`environment.
`
`As designed, Mtel's NWN service will offer significant advantages over existing
`
`services in other respects as well. For example, unlike current systems that require
`
`that users to log on or to take affirmative actions indicating their position prior to
`
`receiving or transmitting messages, Mtel' s proposed NWN architecture will
`
`automatically and transparently locate user terminals across the nation. Thus, a user
`
`need do nothing but push the "send" button to initiate a data transfer. Mtel also
`
`believes NWN will provide superior data transfer capabilities than current cellular
`
`systems, offering lower cost service, better building penetration, and, ultimately, wider
`
`service area coverage.
`
`The explosive growth in use of laptop and notebook computers has created an
`
`acute need for two-way radio data transfer links. Business Week estimates that there
`
`will be 1.8 million laptops in use by 1992 and 2.3 million by 1993, apparently not even
`
`including the proliferation of proprietary handheld computer-based devices used by
`
`companies with widely dispersed employees such as delivery, maintenance and sales
`
`companies. 9
`
`Mtel's market research is consistent with these figures, and indicates that there
`
`will be a cumulative installed base of 3.5 million of these compact computing devices
`
`See Business Week, March 18, 1991 at 119. The demand for such proprietary systems will be
`9
`met in part by existing and other developing two-way data services even though Mtel's proposed NWN
`system may serve some of these needs. More notably, however, NWN is targeted to meet the demand
`for a universal system for a wide variety of users who require a large measure of public access.
`
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`
`

`
`- 10 -
`
`equipped with RF capability by the end of 1996. Radio links are urgently needed to
`
`allow the highly mobile users of these portable computers to exchange data with
`
`personal computers, larger mainframe machines, and other notebook computers while
`
`away from the home or office.
`
`Demand for radio links also is driven by the rapidly increasing sophistication of
`
`these portable computing devices. Notebook computers with greater computing power
`
`than some minicomputers of 10 years ago are available today for under $2000. The
`
`increased power of these devices has created demand for a plethora of new
`
`applications, from services as simple as electronic yellow pages, stock market
`
`quotations, database updating for sales personnel from national inventories, remote
`
`downloading of prepared sales agreements or contracts, and online airline reservations,
`
`to services as complex as transmission of specialized repair procedures for technicians
`
`in the field.
`
`E-Mail represents a well understood, if simple, example of demand for NWN
`
`services. E-Mail already is a communications staple on local and wide area networks.
`
`The next logical step -- and one for which there already is growing demand -- is E(cid:173)
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`Mail to portables in the field. Because real-time interaction is not required, E-Mail
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`messaging to NWN user terminals will be a highly efficient means of communicating
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`with business executives or others on travel.
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`The power of combining reliable two-way wireless digital transmission with
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`portable computers is immense.
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`It is a power that also is untapped because adequate
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`spectrum has not been made available for two-way systems and technologies have not
`
`been implemented to enable user friendly, cost effective utilization on a universal basis.
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`Allocating spectrum for NWN would alleviate much of this pent up demand, since
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`custom interfaces and applications easily can be designed for NWN to accommodate a
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`wide variety of data transfer needs.
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`B.
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`NWN Will Allow Virtually Unlimited User Access for
`Message Origination
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`NWN contemplates a fully open user community utilizing a variety of adaptable
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`interfaces. At one end of the spectrum, institutional users will coordinate with NWN
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`system operators to obtain individually tailored computer-to-computer interfaces that
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`may include encryption, specialized mapping of symbols to data, and specific
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`codewords. These institutional users will be able to establish X.400 connections
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`between their E-Mail systems and the NWN system.
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`Importantly, this illustrates the
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`application independent nature of NWN. Each user of the NWN system is free to
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`establish its own unique association between symbols transmitted and message content.
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`In other words, while one user may wish to transmit alphanumerics, another may wish
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`to transmit proprietary database information.
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`The benefits of NWN, however, will not be limited to large institutions. For
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`example, small businesses and individual users with modems will be able to access
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`NWN via public telephone numbers. Users with E-Mail boxes on other commercial
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`systems will be able to initiate X.400 transfers to the NWN system using the existing,
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`and thus transparent, E-mail interface. Confirmation of message delivery, driven by
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`the NWN acknowledgements, will be stored and forwarded through the various NWN
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`links. Users also will be able to access NWN operators via voice telephone for
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`transcription and transmission of shorter messages. Notably, NWN user terminals will
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`be able to initiate data transfers to the system that are routed to a specific subset of
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`other radio or landline NWN users. Thus, the proposed NWN service will offer a
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`multilayer, application independent interface adaptable to most user needs.
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`C.
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`NWN Utility Would be Enhanced By Permitting Use of
`NWN as an "Answer-Back" Service
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`As with virtually all new telecommunications technologies, time is necessary to
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`lower per unit terminal costs, to establish a basic infrastructure, and to penetrate the
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`widest possible market for data services. One of the benefits of the NWN system will
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`be its ability to offer the public an initial level of service on a less costly basis,
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`satisfying some public demand while a larger two-way market develops.
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`Mtel's market research indicates extensive consumer demand for initial use of
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`pager-sized NWN terminals with two-way, "answer-back" capability. 10
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`In fact,
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`Mtel's initial research discloses a potential for several million "answer-back"
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`"Answer back" terminals. as opposed to "ack-only" terminals or fully two-way NWN terminals,
`10
`allow transmission of an acknowledgement that a message was received coupled with one of several
`preformatted responses. For example. the messages could be mapped by a company to responses such as
`"yes," "no," "I will call," "busy," "emergency," etc.
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`

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`customers, within realistic service and unit pricing ranges. II Further, because wide
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`area forward channel transmitters can be deployed rapidly, one-way services could be
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`provided even as the receiver network is established in new areas. Many of these one-
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`way and "answer-back" customers are expected to upgrade their NWN equipment as
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`prices for the larger units fall and consumers become aware of potential applications.
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`At the same time, as demand increases, the system architecture provides for the
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`infrastructure to grow to meet all demand.
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`III.
`
`MTEL'S MODEL NWN SYSTEM ARCHITECTURE ILLUSTRATES
`THAT EFFICIENT, EXPANDABLE AND RELIABLE TWO-WAY
`COMMUNICATIONS SERVICE CAN BE PROVIDED TODAY
`
`A.
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`Mtel's Model NWN System
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`In addition to describing below the allocation and rules that are necessary to
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`establish a NWN service, Mtel has provided a specific and detailed model of how Mtel
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`currently would implement NWN service. 12 The example illustrates the capabilities
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`that can be readily developed, the highly efficient nature of the service, and NWN's
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`commercial feasibility. A description of Mtel's model is summarized below.
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`II Since "answer-back" terminals will consume far less capacity on the reverse channel, NWN will
`accommodate a substantial number of "answer-back" pagers without degrading capacity available for full
`NWN users.
`
`12 Mtel concurrently is filing an application for an experimental license to finalize its NWN system
`concept. Depending upon the results obtained through Mtel's experiments, the actual implementation of
`NWN could vary from the model summarized herein and described in detail in Appendix A.
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`

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`As designed, Mtel's proposed NWN service offering will operate as a simplex
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`system using a single 50 kHz channel. The forward (base to user terminal) and reverse
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`(user terminal to base) transmissions will share the channel using a dynamic time
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`division scheme to accommodate fluctuations in forward and reverse channel use. Both
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`the forward and reverse channels in Mtel's system combine a number of advanced, but
`
`known, technologies to achieve a synergy in operation. For forward channel
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`transmissions, Mtel's innovative design includes:
`
`•
`
`•
`
`•
`
`•
`
`Nationwide Simulcasting. Simulcast operation will enhance coverage
`continuity and building penetration, as well as allowing low cost network
`growth.
`
`Enhanced Multitone Modulation. Enhanced multitone modulation
`techniques, particularly appropriate for simulcast systems, will allow
`transmission speeds of up to 24,000 bits per second ("bps") on a 50 kHz
`channel.
`
`Adaptive Zoning. NWN's architecture will provide automatic "follow
`me" delivery of messages to users changing zones, enhancing operational
`efficiency.
`
`Variable Length Batching. Forward communications will be organized
`in repeating cycles. Each cycle is divided into dynamically adjusted
`address group time intervals, permitting efficient adaptation to variable
`load conditions.
`
`Using enhanced multitone modulation, adaptive zoning, and variable length batching,
`
`NWN will be able to provide a high-speed, high-throughput simulcast network.
`
`Mtel's proposed forward channel architecture employs simulcasting in a very
`
`spectrally efficient manner. As the Commission has recognized, there is no single
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`

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`spectrum efficient technology. 13 The most appropriate technique depends upon the
`
`problem to be solved. 14 For NWN messaging, Mtel believes that high speed
`
`simulcasting offers the best solution.
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`Up to the capacity limits of the channel, simulcasting uses less spectrum than
`
`other methods that require additional channels to cover the same geographic area.
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`Simulcasting also is a proven technique employed for over fifteen years in the paging
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`industry. Mtel proposes to bring the advantages of simulcasting to two-way messaging.
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`Portable NWN terminals will be small and likely will have relatively inefficient
`
`antennas. NWN user terminals also will need to operate from within buildings as well
`
`as inside vehicles. Simulcasting, with its ability to use controlled multipath, will place
`
`a more usable signal more often at a terminal's antenna. Use of a single frequency
`
`also will facilitate the deployment of additional base stations within a system and
`
`simplify the design of portable terminals. A more economic design without the need
`
`for scanning and the loss of time in locking onto a channel will mean longer battery life
`
`and more efficient operation.
`
`In short