*Pages 1--12 from Microsoft Word - 15536* Federal Communications Commission DA 02- 558 Before the Federal Communications Commission Washington, D. C. 20554 In the Matter of CINGULAR WIRELESS LLC Request for Waiver of the Cellular Vertical Wave Polarization Requirement ) ) ) ) ) ) ) ) ) DA 02- 558 ORDER Adopted: March 7, 2002 Released: March 8, 2002 By the Deputy Chief, Commercial Wireless Division, Wireless Telecommunications Bureau: I. INTRODUCTION 1. In this Order, the Commercial Wireless Division of the Wireless Telecommunications Bureau (“ Bureau”) addresses the request for waiver of the cellular vertical wave polarization requirement filed by Cingular Wireless LLC, with respect to all cellular licensees under its control (collectively, “Cingular”). 1 Specifically, Cingular requests waiver of Section 22.367( a)( 4) so that it can employ polarization diversity (dual- polarization) antenna arrays. For the reasons stated below, we grant Cingular’s waiver request, as limited and conditioned herein. II. BACKGROUND 2. In November 2001, Cingular requested a waiver of the cellular vertical wave polarization requirement, as set forth in Section 22. 367( a)( 4) of the Commission’s rules, 2 to permit the use of non-vertical wave polarization at any transmitter location. Section 22.367( a)( 4) requires vertical polarization of the electromagnetic waves radiated by cellular radiotelephone service base, mobile and auxiliary test transmitters. In its Petition for Waiver, Cingular stated that grant of its waiver request would serve the public interest by permitting the use of polarization diversity (dual- polarization) antennas. 3 Cingular stated that, unlike with a spatial diversity antenna array, the antennas of a polarization diversity antenna array need not be spaced apart, thus requiring less physical space and permitting a given tower to accommodate a greater number of antennas. 4 Cingular further stated that the use of dual- polarization at 1 Cingular Wireless LLC, Petition for Waiver of Section 22. 367 of the Rules Concerning Wave Polarization in the Cellular Radiotelephone Service (filed Nov. 20, 2001) (“ Petition for Waiver”); Cingular Wireless LLC, Petition for Waiver of Section 22. 367 of the Rules Concerning Wave Polarization in the Cellular Radiotelephone Service, Supplement to Petition for Waiver (filed Jan. 14, 2002) (“ Supplement to Petition for Waiver”). 2 47 C. F. R. § 22. 367( a)( 4). 3 Petition for Waiver at 6. 4 Id. 1 Federal Communications Commission DA 02- 558 2 base stations “can reduce the total number of antennas needed at a given site,” thereby resulting in “lower costs, reduced visual impact, reduced tower loading, and minimization of zoning issues.” 5 3. Cingular further argued that grant of its waiver request would not undermine the purpose of the cellular vertical wave polarization requirement, either by (1) frustrating interoperability with mobile units using vertically- polarized antennas or (2) presenting significant interference with upper UHF- band television channels. 6 With respect to interoperability, Cingular argued that antennas of mobile units are rarely held so that their antennas are vertical; further, Cingular stated that in urban and suburban areas, polarization is not retained due to multipath interference. 7 With respect to interference with broadcast television reception, Cingular stated that “there are very few stations in the upper UHF channels,” and at any rate, that these channels are being cleared of broadcasting incumbents due to reallocation. 8 Cingular further stated that because cellular base stations transmit on frequencies that are distant from the upper UHF channels, even cellular base stations using the same polarization as the television channels are unlikely to cause significant interference. 9 Cingular also stated that, in practice, cellular mobile units “have been operating with essentially random polarization for years without any evidence of interference to television.” 10 4. On January 14, 2002, Cingular supplemented its Petition for Waiver to provide information regarding its intended upgrade of its TDMA and analog network to third generation wireless data technology. 11 Cingular explained that the timely grant of its waiver request would permit Cingular to implement dual- polarized antennas in conjunction with its upcoming network overlay of General Packet Radio Service (“ GPRS”) and Global System for Mobile Telecommunications (“ GSM”), and ultimately its upgrade to Enhanced Data Rates for Global Evolution (“ EDGE”) technology. 12 5. On February 1, 2002, the Bureau placed Cingular’s waiver request on public notice. 13 In response, a total of five comments and four reply comments were filed. Of these commenters, six parties supported grant of a waiver. 14 One party, OnStar Corporation (“ OnStar”), recommended that Cingular’s 5 Id. at 4. 6 Id. at 7. 7 Id. 8 Id. at 7- 8. 9 Id. at 8. 10 Id. 11 See Supplement to Petition for Waiver. 12 Id. at 2- 3. 13 See “Wireless Telecommunications Bureau Seeks Comment on Cingular Wireless LLC’s Request for Waiver of the Cellular Vertical Wave Polarization Requirement,” Public Notice, DA 02- 240 (rel. Feb. 1, 2002). 14 See Comments of Andrew Corporation; Decibel Products; Allgon Telecom; and CSA Wireless (CSA Wireless filed its comments on February 15, 2002; because initial comments were due February 11, 2002, these comments were late- filed); Reply Comments of AT& T Wireless Services, Inc. (“ AT& T Reply Comments”); Reply Comments of Dobson Communications Corporation. Cingular Wireless LLC also filed reply comments supporting its waiver request. AT& T requested that, in addition to granting Cingular’s waiver request, we issue “an immediate waiver of the [cellular vertical wave polarization] rule’s restrictions for all similarly- situated parties.” AT& T Reply Comments at 2. This grant of Cingular’s waiver request, as limited and conditioned herein, pertains to Cingular only and does not extend to “similarly- situated parties.” Cingular has filed documentation supporting its waiver request and has satisfied the requirements of section 1.925 of the Commission’s rules for grant of a waiver; any entity seeking a waiver of the cellular vertical polarization requirement similarly must submit a petition for waiver and satisfy the waiver standard. 2 Federal Communications Commission DA 02- 558 3 waiver request be granted with respect to urban areas, but denied with respect to rural areas. 15 AirCell, Inc. opposed grant of Cingular’s waiver request. 16 III. DISCUSSION 6. Pursuant to section 1.925 of the Commission’s rules, a waiver may be granted if the petitioner establishes either that: (1) the underlying purpose of the rule would not be served or would be frustrated by application to the instant case, and that grant of the waiver would be in the public interest; or (2) in light of unique or unusual factual circumstances, application of the rule would be inequitable, unduly burdensome, or contrary to the public interest, or the applicant has no reasonable alternative. 17 As explained below, we find that a waiver is warranted based upon the totality of the circumstances presented. Specifically, we find that the combination of factors, as explained by Cingular and taken together, present unique factual circumstances and that application of the wave polarization rule would be unduly burdensome and contrary to the public interest. Therefore, by this Order, we grant Cingular a waiver of the cellular vertical wave polarization requirement to permit the use of non- vertical polarization at any of its transmitters, to the extent specified herein. We condition the grant of this waiver upon Cingular’s commitment that it shall not reduce or impair analog coverage when operating pursuant to this waiver grant. We reserve the right, as discussed below, to reconsider and/ or modify this grant, as necessary, in the event that we receive documented instances of interference with upper- band UHF television stations as a result of operations pursuant to the terms of this grant. We further subject this grant to any future decision in the context of the Commission’s biennial review of Part 22 regulations. 18 We limit the scope of this grant to the licenses specified in Appendix A, attached, and limit the term of this grant to be concurrent with the remaining duration of the term of the licenses, subject to automatic renewal in the event that the underlying licenses are renewed. 19 7. On the facts before us, we believe that grant of this waiver, as limited and conditioned herein, is justified. We believe the unique combination of factors and public interest benefits cited by Cingular, taken together, are sufficient to satisfy the waiver requirements of section 1. 925. As explained in Cingular’s Supplement to Petition for Waiver, Cingular intends to upgrade its network to EDGE technology; as part of this transition, Cingular will overlay its present TDMA and analog markets with GPRS and GSM, necessitating the “installation of new antennas at each of Cingular’s cell sites.” 20 Cingular states that “[ b] y the end of the fourth quarter of 2002,” it “plans to have installation [of new antennas] complete in 21 markets,” “affect[ ing] over 5,000 cell sites or over 45, 000 antennas.” 21 Cingular hopes to utilize dual- polarized antennas in conjunction with this network upgrade, claiming that the use of dual- polarized antennas “will serve the public interest by reducing the visual impact of the towers, reducing tower loading, minimizing the need for new tower construction, minimizing zoning issues, and 15 See Comments of OnStar Corporation (“ OnStar Comments”). 16 Reply Comments of AirCell, Inc. (“ AirCell Reply Comments”). 17 47 C. F. R. § 1. 925. Alternatively, pursuant to section 1. 3, the Commission has authority to waive its rules if there is “good cause” to do so. 47 C. F. R. § 1. 3. See also Northeast Cellular Telephone Co. v. FCC, 897 F. 2d 1164 (D. C. Cir. 1990); WAIT Radio v. FCC, 418 F. 2d 1153 (D. C. Cir. 1969). 18 Year 2000 Biennial Regulatory Review – Amendment of Part 22 of the Commission’s Rules to Modify or Eliminate Outdated Rules Affecting the Cellular Radiotelephone Service and other Commercial Mobile Radio Services, Notice of Proposed Rulemaking, WT Docket No. 01- 108 (rel. May 17, 2001) (“ Part 22 Biennial Review”). 19 Cingular has requested that we extend the waiver to “any licensee that may be under its control now or subsequently.” Petition for Waiver at 2. We decline Cingular’s request with respect to the scope of this waiver grant; instead, we limit this waiver to only those licenses specified in Appendix A. 20 Supplement to Petition for Waiver at 1. 21 Id. at 2. 3 Federal Communications Commission DA 02- 558 4 lower the cost of the upgrade.” 22 Cingular states that because dual- polarized antennas do not have to be “physically spaced apart” “a polarization diversity antenna array can be packaged in a single compact radome,” reducing the number of antenna modules required at a given cell site. 23 Cingular notes that, “at a typical cellsite,” it could introduce its network overlay without increasing the number of antennas already used to provide TDMA/ analog service. 24 Cingular states that, absent grant of its waiver request, it would “be required to deploy twice the number of antennas and feed lines,” potentially resulting in the need for rezoning or the construction of new towers (where present towers could not handle additional capacity). 25 Cingular notes that rezoning potentially could implicate a delay ranging from three months to one year. 26 We are persuaded that, based upon the totality of the record before us, requiring strict adherence to the vertical wave polarization requirement would be unduly burdensome and contrary to the public interest. In light of the unique combination of factual circumstances presented, we find that the use of dual- polarized antennas, in conjunction with Cingular’s intended GSM/ GPRS/ EDGE upgrade, will afford public interest benefits by reducing the environmental impact of the network overlay, promoting collocation, expediting new services to the public and reducing the cost of Cingular’s network upgrade. 8. OnStar objected to granting Cingular’s waiver request with respect to rural areas, on the basis that non- vertical antenna polarization could result in reduced RF coverage and impair telematics’ ability to provide geographic location information for emergency services. 27 In its comments, OnStar noted that it utilizes analog cellular to provide location- based telematics service offerings, such as automatic crash notification, through systems embedded in vehicles of certain automobile manufacturers. 28 OnStar expressed concern that grant of Cingular’s waiver request, with respect to rural areas, would “adversely affect[ ] the delivery of automatic crash notification and other emergency and telematics services.” 29 Similarly, AirCell stated that non- vertical polarization may affect cellular performance and may affect certain applications that utilize hard- mounted, vertically polarized antennas. 30 AirCell expressed concern with respect to reduced performance in both rural and urban areas. 31 We note that absent appropriate technical adjustments to account for varying polarization of transmit and receive antennas, grant of Cingular’s waiver request could affect cellular performance at the boundaries of a rural cell site and could result in a reduced coverage area. In its Reply Comments, however, Cingular explicitly states that it “is well aware that in some rural scenarios, the replacement of vertically polarized antennas with dual polarization antennas could result in degradation of coverage, and Cingular has no intention of reducing or impairing its analog coverage if and when it replaces its antennas.” 32 We believe that Cingular’s assurance that it will “ensure that service quality is maintained or improved” adequately addresses concerns that certain areas will suffer diminution in analog service coverage. 33 Cingular’s 22 Id. at 2. 23 Petition for Waiver at 6. 24 Supplement to Petition for Waiver at 2. 25 Id. at 3. 26 Id. 27 OnStar Comments at 6- 7. 28 Id. at 1, 4. 29 Id. at 6. 30 See AirCell Reply Comments at 3- 4. 31 Id. at 4. 32 Reply Comments of Cingular at 3 (“ Cingular Reply Comments”). Cingular also “envisions that in very rural areas, where coverage degradations might occur, vertical polarization would be continued.” Petition for Waiver at 6, n. 15. 33 Cingular Reply Comments at 3. 4 Federal Communications Commission DA 02- 558 5 statement that it “does not intend to simply swap one antenna for another” but “will make engineering changes as needed to ensure that service quality and coverage— including to vehicles with vertically polarized antennas— are not impaired” 34 also addresses concerns with respect to cellular performance more generally. We also note that in the majority of the markets where Cingular holds licenses, Cingular is one of two analog cellular carriers; accordingly, customers and service providers are rarely, if ever, dependent upon Cingular for analog service. Furthermore, grant of this limited waiver will not affect all cellular markets, but only a subset of licensed cellular markets, as reflected by Appendix A. In order to ensure that cellular service and coverage degradation does not result from the use of non- vertical polarization, however, we will condition the grant of this waiver request upon Cingular’s adherence to its statements. Accordingly, we will require that Cingular neither reduce nor impair its analog coverage when operating pursuant to the terms of this waiver. 9. We do not believe that grant of the instant waiver, as limited and conditioned herein, will nullify the purposes of the cellular wave polarization requirement. As noted in the context of our biennial regulatory review of Part 22 regulations, the cellular vertical wave polarization requirement was adopted for two reasons: (1) to promote interoperability by accommodating mobile units employing a vertically polarized antenna; and (2) to guard against cellular transmitters’ interference with broadcast television reception on the upper UHF channels. 35 We are persuaded that, on the facts before us, grant of this limited waiver will have little effect on interoperability or UHF television channels. First, as noted in the record, even if a base station’s transmissions are vertically polarized, many hand- held mobile units may not benefit from vertical polarization because they are either held in a manner such that their antenna is not vertical, or because the transmission will experience multipath interference that depolarizes the signal. 36 Accordingly, whether a transmission is vertically polarized likely will provide little interoperability benefit. Furthermore, Cingular states that cellular base stations transmit on frequencies above 869 MHz— a minimum distance of 63 MHz from the closest UHF television frequency— thereby reducing the likelihood of interference with upper- band UHF television channels. 37 In addition, Cingular notes “mobile units, which are located much closer to television, have been operating with essentially random polarization for years without any evidence of interference to television.” 38 Moreover, as stated above, this limited waiver grant will not affect all cellular markets, but only the subset of cellular licenses specified in Appendix A. For these reasons, we are persuaded that waiver of the cellular vertical wave polarization requirement, to the extent described herein, will not result in increased interference to upper-band television. Nevertheless, we reserve the right to reconsider and/ or modify this waiver grant, as necessary, in the event that an incumbent upper- UHF band television broadcast licensee provides the Commission with substantiated claims of interference as a result of operations pursuant to the terms of this waiver grant. We note that as part of our biennial review of certain Part 22 regulations, we are considering whether to eliminate the cellular vertical wave polarization requirement and, in the context of this proceeding, have tentatively concluded to “relax this portion of the rule with regard to all cellular stations.” 39 We subject this grant to any future decision in the Commission’s Part 22 Biennial Review proceeding. 10. As a final matter, we note that other providers of commercial mobile radio service, such as personal communications service providers, are not subject to the vertical wave polarization 34 Id. at 6. 35 Part 22 Biennial Review at ¶ 43; Revision of Part 22 of the Commission’s Rules Governing the Public Mobile Services, Report and Order, CC Docket No. 92- 115, 9 FCC Rcd 6513, 6558 (1994). 36 See Petition for Waiver at 7; AT& T Reply Comments at 3. 37 Petition for Waiver at 8. 38 Id. 39 Part 22 Biennial Review at ¶ 47. 5 Federal Communications Commission DA 02- 558 6 requirement. We believe that providing Cingular with the opportunity to deploy dual- polarized antennas, as described herein, will promote regulatory parity and flexibility where Cingular has persuasively shown that it satisfies the waiver standard set forth in section 1.925. IV. ORDERING CLAUSE 11. Accordingly, IT IS ORDERED, pursuant to authority delegated by section 4( i) of the Communications Act, as amended, 47 U. S. C. § 154( i), and by sections 0.331 and 1.925 of the Commission’s rules, 47 C. F. R. §§ 0.331, 1.925, that the request for waiver of the cellular vertical polarization requirement filed by Cingular Wireless LLC, on behalf of any licensees under its control, IS HEREBY GRANTED to the extent described herein, with respect to the licensees and licenses listed in Appendix A and subject to the following conditions: (1) the duration of this waiver grant shall be concurrent with the duration of the remaining license terms, subject to automatic renewal in the event that the underlying licenses are renewed; (2) Cingular shall not reduce or impair analog coverage when operating under the terms of this waiver; (3) in the event that we receive documented claims of interference to upper- band UHF television stations, as a result of operations pursuant to the terms of this waiver, we reserve the right to reconsider and/ or modify this grant as necessary; and (4) this grant is subject to any future decision in the Commission’s Part 22 Biennial Review proceeding. FEDERAL COMMUNICATIONS COMMISSION Roger Noel Deputy Chief, Commercial Wireless Division Wireless Telecommunications Bureau 6 Federal Communications Commission DA 02- 558 APPENDIX A LICENSEE NAME: CALL SIGN: ABILENE SMSA LIMITED PARTNERSHIP KNKA559 ACADIANA CELLULAR GENERAL PARTNERSHIP KNKN499 KNKN804 ALABAMA CELLULAR SERVICE, LLC KNKA262 KNKA575 KNKA609 KNKA621 KNKA660 KNKN685 KNKN761 KNKN959 KNKQ276 KNKQ369 AMARILLO SMSA LIMITED PARTNERSHIP KNKA620 AMCELL OF ATLANTIC CITY, LLC KNKA791 AMERICAN CELLULAR COMMUNICATIONS LLC KNKA424 KNKN901 KNKQ258 AMERICAN CELLULAR NETWORK COMPANY, LLC KNKA311 KNKA319 KNKA353 KNKA382 KNKN720 KNKN836 AMERITECH MOBILE COMMUNICATIONS, LLC KNKA807 KNKN201 KNKN508 KNKN570 KNKN866 ANNISTON- WESTEL COMPANY, LLC KNKA461 KNKN679 ATLANTA- ATHENS MSA LIMITED PARTNERSHIP KNKA217 KNKA534 KNKN873 KNKN958 KNKN966 KNKQ328 AURORA/ ELGIN CELLULAR TELEPHONE, LLC KNKA760 BCTC OF TEXAS, LLC KNKA568 KNKN336 BELLSOUTH MOBILITY LLC KNKN822 KNKN823 KNKQ269 BELLSOUTH PERSONAL COMMUNICATIONS, LLC KNKA249 KNKQ262 KNKQ286 KNKQ293 7 Federal Communications Commission DA 02- 558 Appendix A - 2 KNKQ305 BLOOMINGTON CELLULAR- TELEPHONE – COMPANY KNKA654 CCPR OF THE VIRGIN ISLANDS, INC. KNKN523 CCPR SERVICES, INC. KNKA451 KNKA467 KNKA627 KNKA804 . KNKN517 KNKN521 KNKN682 KNKN843 KNKQ240 KNKQ343 KNKQ362 CELL SOUTH OF NEW JERSEY, LLC KNKA513 CHAMPAIGN CELLTELCO KNKA478 CHATTANOOGA MSA LIMITED PARTNERSHIP KNKA289 CINCINNATI SMSA LIMITED PARTNERSHIP KNKA222 KNKA285 KNKA288 KNKA426 KNKA445 KNKN970 KNKN985 KNKQ288 KNKQ295 KNKQ318 CORPUS CHRISTI SMSA LIMITED PARTNERSHIP KNKA388 KNKA542 KNKA546 KNKN594 KNKN727 KNKN728 DALLAS SMSA LIMITED PARTNERSHIP KNKA229 KNKA484 DECATUR CELLULAR TELEPHONE COMPANY, LLC KNKA742 DECATUR RSA LIMITED PARTNERSHIP KNKN903 DETROIT SMSA LIMITED PARTNERSHIP KNKA231 KNKA362 EASTERN MISSOURI CELLULAR LIMITED PARTNERSHIP KNKA218 KNKN391 KNKN497 KNKN653 FLORIDA CELLULAR SERVICE, LLC KNKA225 KNKA264 KNKN793 KNKQ360 KNKQ361 FLORIDA RSA NO 2B (INDIAN RIVER) LIMITED PARTNERSHIP KNKN990 GALVESTON CELLULAR TELEPHONE COMPANY KNKA676 8 Federal Communications Commission DA 02- 558 Appendix A - 3 KNKP971 GEORGIA RSA NO. 1 LIMITED PARTNERSHIP KNKN697 GEORGIA RSA NO. 2 LIMITED PARTNERSHIP KNKN950 GEORGIA RSA NO. 3 LIMITED PARTNERSHIP KNKN765 GTE MOBILNET OF AUSTIN LIMITED PARTNERSHIP KNKA302 GTE MOBILNET OF TEXAS RSA #11 LIMITED PARTNERSHIP KNKN538 GTE MOBILNET OF TEXAS RSA #16 LIMITED PARTNERSHIP KNKN608 HOUMA/ THIBODAUX CELLULAR PARTNERSHP KNKA686 HOUSTON CELLULAR TELEPHONE COMPANY, L. P. KNKA367 HUNTSVILLE MSA LIMITED PARTNERSHIP KNKA392 INDIANA 8, LLC KNKN340 INDIANA CELLULAR LLC KNKN445 JACKSONVILLE MSA LIMITED PARTNERSHIP KNKA287 KNKQ335 JOLIET CELLULAR TELEPHONE, LLC KNKA625 KANSAS CITY SMSA LIMITED PARTNERSHIP KNKA223 KNKA551 KENTUCKY CGSA, LLC KNKA245 KNKA394 KNKN956 KNKN964 KNKQ255 KNKQ391 LAFAYETTE MSA LIMITED PARTNERSHIP KNKA492 KNKN500 LOUISIANA CELLULAR HOLDINGS, L. L. C. KNKA224 KNKA268 KNKQ455 LOUISIANA RSA NO. 7 CELLULAR GENERAL PARTNERSHIP KNKN614 LOUISIANA RSA NO. 8 LIMITED PARTNERSHIP KNKQ454 LUBBOCK SMSA LIMITED PARTNERSHIP KNKA421 MADISON SMSA LIMITED PARTNERSHIP KNKA414 KNKA498 KNKN325 MCALLEN- EDINBURG- MISSION SMSA LIMITED PARTNERSHIP KNKA430 KNKA444 MCTA KNKA403 KNKN878 KNKN917 KNKN961 KNKN980 KNKQ298 KNKQ309 KNKQ368 KNKQ394 KNKQ395 MIDLAND- ODESSA SMSA LIMITED PARTNERSHIP KNKA671 KNKA674 9 Federal Communications Commission DA 02- 558 Appendix A - 4 MILWAUKEE SMSA LIMITED PARTNERSHIP KNKA214 KNKA600 KNKA624 KNKA727 KNKN324 MISSOURI RSA 8 LIMITED PARTNERSHIP KNKN575 MISSOURI RSA 9B1 LIMITED PARTNERSHIP KNKN907 MISSOURI RSA 11/ 12 LIMITED PARTNERSHIP KNKN726 KNKN825 NEW YORK HOLDINGS, LLC KNKA210 KNKA263 KNKA294 KNKA317 KNKA468 KNKA738 KNKN827 KNKN856 NORTHEAST MISSISSIPPI CELLULAR, LLC KNKQ253 NORTHEASTERN GEORGIA RSA LIMITED PARTNERSHIP KNKN875 KNKN983 OKLAHOMA CITY SMSA LIMITED PARTNERSHIP KNKA296 OKLAHOMA RSA 3 LIMITED PARTNERSHIP KNKN821 OKLAHOMA RSA 9 LIMITED PARTNERSHIP KNKN981 ORLANDO SMSA LIMITED PARTNERSHIP KNKA253 KNKA406 KNKA703 KNKN994 KNKQ274 ST. JOSEPH SMSA LIMITED PARTNERSHIP KNKA488 SAN ANTONIO SMSA LIMITED PARTNERSHIP KNKA279 SAN JUAN CELLULAR TELEPHONE COMPANY KNKA785 SBMS CELLULAR TELECOMMUNICATIONS BLOOMINGTON, LLC KNKA792 SBMS CELLULAR TELECOMMUNICATIONS SPRINGFIELD, LLC KNKA747 SNET MOBILITY, LLC KNKA239 KNKA241 KNKA252 KNKA256 KNKA292 KNKA345 KNKA418 KNKA666 KNKN589 KNKN759 KNKN769 KNKN849 SOUTHWESTERN BELL MOBILE SYSTEMS, LLC KNKA226 KNKA254 KNKA320 10 Federal Communications Commission DA 02- 558 Appendix A - 5 KNKN328 KNKN468 KNKN479 KNKN635 KNKN705 SOUTHWESTERN BELL WIRELESS, LLC KNKA476 KNKA479 KNKA776 KNKN496 KNKP970 KNKQ315 TEXAS RSA 6 LIMITED PARTNERSHIP SOUTHWESTERN BELL WIRELESS, INC. KNKN369 TEXAS RSA 7B1 LIMITED PARTNERSHIP KNKN730 TEXAS RSA 9B1 LIMITED PARTNERSHIP KNKN905 TEXAS RSA 9B4 LIMITED PARTNERSHIP KNKN906 TEXAS RSA 10B1 LIMITED PARTNERSHIP KNKN886 TEXAS RSA 10B3 LIMITED PARTNERSHIP KNKN888 TEXAS RSA 18 LIMITED PARTNERSHIP KNKN696 TEXAS RSA 19 LIMITED PARTNERSHIP KNKN576 TEXAS RSA 20B1 LIMITED PARTNERSHIP KNKN945 TOPEKA SMSA LIMITED PARTNERSHIP KNKA442 USVI CELLULAR TELEPHONE CORPORATION KNKN524 VINELAND CELLULAR TELEPHONE COMPANY, LLC KNKA652 WASHINGTON/ BALTIMORE CELLULAR LIMITED PARTNERSHIP KNKA242 KNKA243 KNKN567 KNKN634 KNKN662 KNKN838 WESTEL- INDIANAPOLIS LLC KNKA208 KNKA558 KNKA661 KNKA762 KNKA806 KNKN307 WESTEL- MILWAUKEE COMPANY, LLC KNKA277 KNKA517 KNKA576 KNKA672 KNKN449 KNKN600 KNKN673 KNKN674 KNKN748 KNKN830 KNKN841 KNKN861 KNKN946 KNKN947 11 Federal Communications Commission DA 02- 558 Appendix A - 6 KNKN963 KNKQ261 WICHITA SMSA LIMITED PARTNERSHIP KNKA255 WORCESTER TELEPHONE COMPANY KNKA359 12