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U S WEST Communications . 426 North Fairview Room 101 St. Paul, MN 55104 Wireless llj..WEST VVednesday,OctoberI6,1996 To VVhom It May Concern: US \VEST Communications is scheduled to deploy a wireless Personal Communications System (PCS) for the Minneapolis! St. Paul Twin Cities area in 3Q '97. The intent of the deployed system will be to provide ubiquitous wireless services to the Twin Cities communities. It is the goal of this letter to outline the reasons that US VVEST must request Special! Conditional Use Permits in some areas of your community. Distinguishing features from conventional Cellular services currently available will be the PCS system's voice quality, capacity and coverage depth. Utilizing Code Division Multiple Access (COMA) technology, US VVEST's system will provide voice quality that compares favorably to landline quality with site capacity capabilities of approximately six times that of an analog cell site. In addition, since US \VEST intends to utilize PCS as an affordable VVireless Local Loop service, coverage at the neighborhood level is essential (unlike Cellular, which is typically a high~st, mobile service). Coverage: One of the major and most visible differences between PCS and Cellular systems is the area of coverage of an individual cell. Due to the higher frequency of operation, PCS cells will have considerably smaller coverage areas than Cellular cells. (For purely coverage, all things except frequency being equal, to cover a given area at the PCS frequency (1900 MHz) versus the Cellular frequency (900 MHz) requires 2-3 times more cells). Every attempt has been made by US VVEST to locate siteS in zoneable areas, preferably currently occupied by Cellular providers. However, as a result of the higher frequency of operation and the desire to provide truly ubiquitous service to the Twin Cities metro area, US VVEST will be required to build sites in areas that have not been utilized by the existing Cellular providers. AdditionaUy, since the coverage footprint ofPCS cells is smaller, there is much less "slack" allowed in the system design (i.e., the tolerance for moving sites is less) and there is much less ability to relocate sites and cover restrictive districts from a distance. Capacity: COMA technology has an inherent capacity advantage over comparable (current) analog teclmologies. A conservative calculation puts this capacity advantage at six times for comparable operating bandwidths. In addition, given the US VVEST will deploy (due to the higher operating frequency) up to twice the number of sites required by a Cellular operator for coverage, the overall PCS capacity advantage increases to twelve rimes. So, although the higher operating frequency directly translates into an increased number of sites requiring zoning, nothing is forfeited - and in fact, gains are made - in traffic carrying capacities. It can be stated, therefore, that coverage, not capacity, tends to be the initial driver for cell site location. Conclusion: Higher operating frequencies directly translates into increased cell count and less flexibility in site location in designing wireless communications systems. Insofar as is possible, US VVEST has designed a wireless PCS system for the Twin Cities metro area that attempts to work with allowable zoning ordinances without compromising the intended service requirements of the system. In applying for Special! Conditional Use Permits, it should be understood that, to the best knowledge of US VVEST's system designers, all reasonable avenues of design modification have been exhausted. Sincerely, 0Jf f\J~ Lawrence P. Nolan Senior Radio Frequency Engineer US \VEST Communications, Inc. VVireless