A CLEAR CHOICE BETWEEN
AVM/LMS AND PART 15 DEVICES

   
   
   _________________________
   
   ...is the choice between an inefficient and unnecessary technology
   (wideband AVM/LMS) and an efficient and low-cost technology ideally
   suited to this spectrum. 
   
   Other technologies, such as Global Positioning Satellites and wideband
   wide area networks, and the use of other frequencies, can perform
   vehicle location functions less expensively and more effectively than
   wideband AVM/LMS -- an old, 20-year-old technology that cannot compete
   with emerging, next-generation technologies.
   
   ...is the choice between supporting and ignoring the clear decision of
   the economic marketplace.
   
   Millions of consumers and businesses nationwide have already chosen
   license-free wireless devices such as cordless telephones, utility
   meter readers, retail security scanners, and home security systems,
   and in the near future millions more Americans will have access to
   them. So far the largest wideband AVM/LMS system has only 6,000
   customers in six cities. While the FCC has previously encouraged the
   marketplace to render a verdict here, it would now be saying that,
   although the market has spoken, it will not only be ignored, but
   repudiated.
   
   ...is the choice between creating and destroying the next generation
   of low-cost, consumer-friendly wireless devices.
   
   It is estimated that more than $2 billion has been invested in the
   research and development of next-generation license-free wireless
   devices. These cordless phones, portable computers, home security
   systems, and other technological marvels will make life easier and
   more convenient for all Americans.
   
   ...is the choice between expanding and limiting the access of schools,
   libraries, and museums to data communications devices.
   
   At a time of scarce public resources, most community institutions
   cannot afford the enormous cost of traditional hard-wiring for their
   facilities. It is estimated that it would cost about $250,000 to wire
   each of the nation's 118,000 elementary and secondary schools alone.
   License-free wireless devices are a low-cost way for these
   institutions to gain access to the expanding National Information
   Infrastructure.
   
   ...is the choice between better management of our energy resources and
   continuing to operate under the status quo.
   
   Dozens of major utilities use license-free wireless devices to assist
   in wireless meter reading and intelligent power distribution systems.
   These resource management tools are paying off in better operating
   efficiencies for utilities and lower utility rates for consumers.
   
   ...is the choice between helping and hurting our environment.
   
   The use of license-free wireless devices will allow utilities to
   reduce energy consumption (including avoiding the construction of new
   power plants) and is helping create traffic-control systems that can
   cut down on pollution.
   
   ...is the choice between assisting and neglecting our citizens with
   disabilities.
   
   License-free wireless devices like portable phones and remote controls
   can help enhance the quality of life for tens of thousands of
   Americans with disabilities.
   
   _____________________
   
THE CHOICE IS CLEAR

   
   
   The decision by the FCC should reflect the choice already made by the
   marketplace and be for emerging technology, consumers, the
   environment, education, and jobs. The wrong choice will be for an
   outdated technology and a setback for the technology already chosen
   by the marketplace.
   
   On a technical level, the FCC should:
   
       
        * Offer a presumption of non-interference between Part 15 devices
       and AVM/LMS reverse links;
       
       * Keep all multilateration systems, their forward links, etc. out
       of 910-920 MHz;
       
       * Allow no wideband LMS forward links;
       
       * Require all narrowband LMS forward links to be at the top of the
       band, i.e. 927.5-928 MHz; and
       
       * Give reasonable power and duty cycles specifications for LMS
       reverse links.