**FINAL REPORT**

# March 30, 2001

**SPECTRUM STUDY OF THE**

**2500‑2690 MHz BAND**

**The Potential for Accommodating**

**Third Generation Mobile Systems**

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height="1.8145833333333334in"}

Federal Communications Commission

Staff Report Issued by:

Office of Engineering and Technology

Mass Media Bureau

Wireless Telecommunications Bureau

International Bureau

**ACKNOWLEDGEMENTS**

This Final Report was prepared under the leadership of the Office of
Engineering and Technology, in cooperation with the Mass Media Bureau,
Wireless Telecommunications Bureau, and International Bureau

## Office of Engineering and Technology

> Anthony Asongwed, Donald Campbell, Thomas Derenge, Robert Eckert,
> Bruce Franca, Nancy Gillis, Kathryn Hosford, Ira Keltz, Julius Knapp,
> Geraldine Matise, Rodney Small, Fred Thomas

## Mass Media Bureau

> Charles Dziedzic, Joe Johnson, Keith Larson, Brad Lerner, David
> Roberts

## Wireless Telecommunications Bureau

Charles Rush, John Spencer

## International Bureau

Richard Engelman, Trey Hanbury, Ron Repasi

‑‑‑‑‑‑‑‑‑‑‑‑‑‑‑‑‑‑‑‑‑‑‑‑‑‑‑‑‑‑‑‑‑‑‑‑‑‑‑‑‑‑‑‑‑‑‑‑‑‑‑‑‑‑‑‑‑‑‑‑‑‑‑‑‑

Text extracted from International Telecommunication Union (ITU) material
has been reproduced with the prior authorization of the ITU as copyright
holder. The sole responsibility for selecting extracts for reproduction
lies with the Federal Communications Commission and can in no way be
attributed to the ITU. The complete volume(s) of the ITU material, from
which the texts reproduced are extracted, can be obtained from:

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### Table of Contents

[Section]{.underline} [Page]{.underline}

Executive Summary [1](#executive-summary)

1\. Introduction [1](#section-1-1)

2\. 3G System Description [7](#section-2-1)

3\. Incumbent Systems in the 2500‑2690 MHz Band [13](#section-3-1)

4\. Evaluation of Spectrum Sharing [27](#section-4-1)

5\. Evaluation of Band Segmentation [37](#section-5-1)

6\. Identification and Analysis of Potential Alternate Frequency Bands
for

ITFS/MDS [59](#section-6-1)

7\. Analysis of Costs and Benefits [81](#section-7-1)

[Appendices]{.underline}

Appendices for Section 1 A‑1

Appendices for Section 2 A‑21

Appendices for Section 3 A‑41

Appendices for Section 4 A‑53

Appendices for Section 5 A‑77

Appendices for Section 6 A‑87

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## EXECUTIVE SUMMARY

This Final Report describes the current uses of the 2500--2690 MHz band
and analyzes the potential for using that band for third generation (3G)
wireless systems. This band is one of several frequency bands identified
at the 2000 World Radiocommunication Conference (WRC‑2000) for possible
3G use. Third generation wireless systems will provide mobile,
high‑speed access to the Internet and other broadband services. In the
United States, the 2500‑2690 MHz band is currently used by the
Instructional Television Fixed Service (ITFS), Multipoint Distribution
Service (MDS), and Multichannel Multipoint Distribution Service (MMDS).
The study of the 2500‑2690 MHz band has been conducted in two stages. In
the Interim Report, we examined the nature and technical characteristics
of planned 3G services, the current and planned use of the 2500‑2690 MHz
band by incumbent services, potential opportunities for sharing spectrum
between 3G and incumbent services, and the potential impact on incumbent
services of segmenting this band to provide separate spectrum for 3G and
incumbent services. In this Final Report, we review and evaluate the
earlier analyses and evaluate additional topics, including the possible
relocation of incumbent services and the costs associated with such
relocation.

This band study is one part of the FCC's effort to identify additional
spectrum for advanced wireless systems, including 3G as well as future
generations of wireless systems. The FCC issued the *Advanced Wireless
Services Notice of Proposed Rulemaking* (NPRM) on January 5, 2001, to
examine and propose spectrum for such use. This proceeding explores the
possibility of introducing new advanced mobile and fixed services in
frequency bands currently used for cellular, broadband Personal
Communications Service ("PCS"), and Specialized Mobile Radio ("SMR")
services, as well as in five other frequency bands: 1710‑1755 MHz,
1755‑1850 MHz, 2110‑2150 MHz, 2160‑2165 MHz and 2500‑2690 MHz.

This Final Report represents the results of analyses by FCC staff in the
Office of Engineering and Technology, Mass Media Bureau, Wireless
Telecommunications Bureau, and International Bureau. It does not
necessarily represent the views of the FCC or its Commissioners.

SUMMARY OF FINDINGS

The key findings of our study of the 2500‑2690 MHz band are as follows:

-   The International Telecommunication Union (ITU) has done
    considerable work to develop the key technical characteristics of 3G
    systems and to identify several frequency bands that could be used
    for 3G systems. The ITU is conducting further studies of how
    IMT‑2000 may be implemented in the frequency bands that were
    identified at the 1992 World Administrative Radio Conference
    (WARC‑92) and WRC‑2000, taking into account the impact on incumbent
    systems, opportunities for worldwide roaming, equipment design
    considerations, and backward compatibility with first and second
    generation (1G and 2G) systems. There currently is no single global
    approach as to how the frequency bands identified at WARC‑92 and
    WRC‑2000 will be used to implement 3G systems, and no consensus that
    common global bands for use by 3G systems are achievable.

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-   The 2500--2690 MHz band is in a state of rapid evolution by
    incumbent ITFS and MDS licensees. The MDS industry has invested
    several billion dollars to develop broadband fixed wireless data
    systems in this band, including high‑speed access to the Internet.
    These systems offer a significant opportunity for further
    competition with cable and digital subscriber line (DSL) services in
    the provision of broadband services in urban and rural areas. The
    band is used to provide video services for education and training in
    schools, health care centers and a wide variety of other
    institutions, as well as for the provision of a commercial video
    distribution service known as wireless cable. This spectrum is
    heavily licensed throughout the country, with several licensees
    already providing high‑speed Internet services to customers; other
    licensees are ramping up for full operational use in the very near
    term.

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-   Incumbent ITFS and MDS use of the 2500--2690 MHz band varies from
    one geographic area to another. This lack of uniformity presents
    serious challenges to developing band sharing or segmentation
    options that could be used across the country without severely
    disrupting ITFS and MDS use. For example, ITFS and MDS licensees
    provide a variety of analog and digital one‑way and two‑way
    services; ITFS and MDS are licensed with different authorized
    service or interference protection areas; extensive leasing
    arrangements exist between the two services; ITFS and MDS licensees
    have exchanged channels in various markets as permitted by current
    service rules; and flexible channel band plans for combined ITFS/MDS
    two‑way systems will coexist with some incumbent one‑way systems
    operating under the traditional channel band plan.

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-   This technical analysis shows that if currently contemplated 3G
    systems were to share the same spectrum or channels in any given
    geographic area large co‑channel separation distances would be
    needed between 3G systems and incumbent ITFS and MDS systems.
    Without adequate separation distances, 3G systems and ITFS and MDS
    would cause extensive interference to each other. This is because
    the 2500‑2690 MHz band is licensed to ITFS and MDS systems in most
    populated areas of the country and 3G licensees would likely want to
    operate in these same areas. There are, however, a few geographic
    areas where some spectrum is not used by incumbent systems. In areas
    where spectrum is not yet at full operational capacity, voluntary
    partitioning between incumbent users and 3G operators may offer some
    promise of sharing, although it is unlikely that these areas would
    be sufficient to deploy a viable 3G service in the band.

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-   Segmenting the 2500--2690 MHz band to enable third generation mobile
    wireless systems access to a portion of this spectrum would raise
    significant technical and economic difficulties for incumbents,
    especially if all ITFS/MDS operations were to be relocated within
    the band. While there may be long term options to segment the
    2500‑2690 MHz band, segmentation could affect the economics of
    current and planned ITFS and MDS systems and lessen their ability to
    provide service to rural areas or smaller markets. With reduced
    spectrum, ITFS/MDS providers may need to reduce their service areas
    and services to customers in outlying areas or add more transmitter
    sites to maintain services. In addition, any segmentation option
    would have to account for the flexible service configurations and
    offerings that incumbent licensees are currently implementing.

-   There is no readily identifiable alternate frequency band that could
    accommodate a substantial relocation of the incumbent operations in
    the 2500‑2690 MHz band. Furthermore, relocation of ITFS/MDS
    operations to a band above 3 GHz would affect deployment of these
    systems to account for changes in signal propagation in higher
    bands. Relocation to higher bands could affect significantly the
    economics of current and planned ITFS and MDS systems and lessen
    their ability to provide service to rural areas or smaller markets.
    In addition, incumbent users in those alternate bands would have to
    be relocated, causing serious disruption to other established
    services; and relocation of some incumbent users (*e.g.,* satellite
    systems) could significantly delay ITFS/MDS access to these
    alternate bands.

-   Implementation of either the segmentation or relocation options
    would significantly affect deployment of and impose considerable
    costs on ITFS/MDS. One study suggests, for example, that the cost to
    ITFS/MDS operations over a ten-year period could be up to \$19
    billion. Either option would require considerable time to implement
    and significant costs to re‑engineer and deploy systems; and
    delivery of fixed wireless broadband services to the public and
    educational users would be delayed or, in rural areas or smaller
    markets, may never be realized. The relocation option also would
    require other services to relocate, and the time and costs to move
    those additional services would be significant, ranging from
    approximately \$10.2‑30.4 billion. These costs would need to be
    balanced with the broad‑based benefits to prospective users and the
    national economy of deploying both 3G and fixed wireless broadband
    systems.

The details of the analyses that lead to these findings are provided in
the following Sections and Appendices.

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## SECTION 1

# INTRODUCTION

This Final Report addresses the current spectrum uses and the potential
for sharing or segmenting the 2500‑2690 MHz band for possible third
generation wireless systems, as well as the potential for relocating
incumbent users of the band in order to make spectrum available for
possible 3G wireless systems. This band study, which is in response to
the October 13, 2000 Presidential Memorandum, follows the processes
described in the Study Plan released by the Department of Commerce on
October 20, 2000. This study relies on certain technical assumptions
that are based largely on work conducted by the ITU and on information
provided by industry.

This Final Report represents the results of analyses by the Federal
Communications Commission (FCC) staff in the Office of Engineering and
Technology, Mass Media Bureau, Wireless Telecommunications Bureau, and
International Bureau. It does not necessarily represent the views of the
FCC or the Commissioners.

## THE PRESIDENTIAL MEMORANDUM AND THE STUDY PLAN

The October 13, 2000 Presidential Memorandum establishes guiding
principles for the Executive Agencies to use in selecting spectrum for
3G wireless systems, and strongly encourages independent federal
agencies, such as the FCC, to follow the same principles in any actions
taken related to the development of 3G systems. These principles are:
(1) the federal government must cooperate with industry to identify
spectrum that can be used for 3G systems, whether by reallocation,
sharing or evolution of existing systems; (2) incumbent users of
spectrum identified for reallocation or sharing must be treated
equitably, taking national security and public safety into account; (3)
the federal government must be technology‑neutral in spectrum allocation
and licensing decisions; (4) the federal government must support
policies that encourage competition in services and provide flexibility
in spectrum allocations to encourage competition; and (5) the federal
government must support industry efforts as far as practicable and based
on market demand and national considerations to harmonize spectrum
allocations regionally and internationally.

The Study Plan released by NTIA on October 20, 2000 adheres to the
principles in the Presidential Memorandum. The Study Plan notes that a
variety of frequency bands have been identified for possible 3G system
use by two International Telecommunication Union (ITU) radio
conferences, WARC‑92 and WRC‑2000. Further, the Study Plan indicates
that the United States will give full consideration to all identified
frequency bands in identifying spectrum for possible 3G system use. In
order to have a full understanding of all options available, NTIA and
FCC were tasked with studying two frequency bands identified by WRC‑2000
for possible 3G use. NTIA is studying the 1755‑1850 MHz band, and the
FCC is studying the 2500‑2690 MHz band. The Study Plan states that the
purpose of the studies is to determine whether, and under what
conditions, these bands could be made available for 3G systems and the
cost and operating impacts to incumbent users.

The Study Plan notes that the same analysis will be applied to both
bands under study. The basic requirements for the overall studies cover
three areas: a description of 3G system requirements; a description of
incumbent systems in the study bands; and identification of potential
alternate bands for incumbent users of the study bands. Using this
information, the studies are to include a technical evaluation of the
following sharing/relocation options: (1) system sharing between current
and planned systems in the bands and 3G systems; and (2) band/channel
segmentation, including alternate band combinations to relocate
incumbent users of the study bands. Finally, the studies are to consider
costs for the spectrum sharing/relocation options identified for the
study bands and benefits of using the spectrum in the study bands for 3G
systems.

As noted by the Study Plan, the studies have been conducted in two
phases. Interim Reports on each band were released November 15,
2000,[^1] and each Report includes a description of 3G systems, a
description of incumbent systems, and an evaluation of system sharing
and band segmentation options. Final Reports on each band, to be
released by March 30, 2001, build on the Interim Reports and include the
remainder of the study requirements, including information on other
bands, a description of alternate bands and relocation studies, and
cost/benefit analyses of system sharing, segmentation and relocation
options identified.

Outreach to industry is an important component of the overall process to
identify spectrum for 3G systems. As instructed by the Presidential
Memorandum, NTIA, on behalf of the Secretary of Commerce, initiated the
Department's outreach program to industry. The outreach program, in
which FCC staff participated, consisted of a series of regular public
meetings, which were supplemented by a series of industry sponsored
meetings. Most prominent in this regard was the formation of the 3G
Industry Association Group.[^2] This group held a series of meetings to
develop technical and operational proposals for sharing between 3G and
incumbent systems or for relocation of incumbent systems.[^3]

## FCC's ROLE IN IDENTIFYING SPECTRUM FOR 3G SYSTEMS

The FCC has several key roles in the overall process to identify
spectrum for 3G systems. In addition to studying the 2500‑2690 MHz band,
the FCC issued a *Notice of Proposed Rulemaking* (*Advanced Wireless
Services* *NPRM*) on January 5, 2001, to examine and propose spectrum
for allocation to fixed and mobile services that would be capable of
being used to provide 3G wireless service.[^4] The FCC has solicited
industry input through this *NPRM* and other procedures to develop
recommendations and plans for identifying spectrum for 3G wireless
systems.

The *Advanced Wireless Services NPRM* recognizes that a number of
frequency bands, including those identified by WARC‑92 and WRC‑2000, are
capable of supporting third generation as well as future generations of
mobile wireless systems. This proceeding explores the types of advanced
mobile and fixed communication services that will likely be provided in
the future, including the technical characteristics of such systems, and
the spectrum requirements needed to support the introduction of such
services, including the amount of spectrum needed and frequency bands
that could be used by such systems.

This proceeding also will explore the possibility of introducing new
advanced mobile and fixed services in frequency bands currently used for
cellular, broadband Personal Communications Service ("PCS"), and
Specialized Mobile Radio ("SMR") services, as well as in five other
frequency bands: 1710‑1755 MHz, 1755‑1850 MHz, 2110‑2150 MHz,
2160‑2165 MHz and 2500‑2690 MHz. Concerning the possible use of these
additional bands for advanced wireless systems, the *Advanced Wireless
Services NPRM* does the following:

-   proposes to allocate for mobile and fixed services the 1710‑1755 MHz
    band that was designated for reallocation from Federal Government to
    non‑Federal Government use under two statutory directives, the 1993
    Omnibus Budget Reconciliation Act ("OBRA‑93") and the 1997 Balanced
    Budget Act ("BBA‑97");

-   seeks comment on providing mobile and fixed service allocations for
    the 1755‑1850 MHz band, if spectrum in the band is made available
    for non‑Federal Government use;

-   proposes to designate advanced mobile and fixed service use of the
    2110‑2150 MHz and 2160‑2165 MHz bands that are currently used for a
    variety of fixed and mobile services and that were identified for
    reallocation under the Commission's 1992 Emerging Technologies
    proceeding (ET Docket No. 92‑9);

-   seeks comment on various approaches for the 2500‑2690 MHz band,
    which is currently used for Multichannel Multipoint Distribution and
    Instructional Television Fixed Services (MMDS and ITFS).

The Interim Report and Final Report on the 2500‑2690 MHz band will
become part of the official record for the rulemaking proceeding, and
comments on the Reports will be considered in the context of that
proceeding. Commenters to the rulemaking proceeding also may address the
NTIA Interim Report and Final Report for the 1755‑1850 MHz band.

## SCOPE OF FINAL REPORT ON 2500‑2690 MHz BAND

For purposes of studying the 2500--2690 MHz bands, certain fundamental
assumptions were made concerning the overall spectrum requirements and
technical characteristics of future 3G systems. As we noted in the
*Advanced Wireless Services NPRM*, we recognize that there are many ways
in which various frequency bands may be partitioned or paired to
implement 3G services. We expect further information in this regard to
become available through dialogue with industry, additional
international studies on 3G, and the FCC rulemaking proceeding. The
assumptions made for purposes of this study are intended to facilitate
analyses and are not intended to prejudge or foreclose other options.

The study of the 2500‑2690 MHz band has been conducted in two phases. In
the Interim Report, we examined the nature and technical characteristics
of planned 3G services, the current and planned use of the 2500‑2690 MHz
band by incumbent services, potential opportunities for sharing spectrum
between 3G and incumbent services, and the potential impact on incumbent
services of segmenting this band to provide separate spectrum for 3G and
incumbent services. We invited comment on the Interim Report in the
*Advanced Wireless Services NPRM*.

The Final Report reviews the initial analyses in the Interim Report;
identifies potential alternate bands for relocating incumbent users of
the 2500‑2690 MHz band; analyzes the relocation potential of incumbent
users to alternate bands; and evaluates the cost and migration schedules
for three time periods (2003, 2006, 2010) for the sharing, band
segmentation and relocation options presented. To the extent possible,
we have taken into consideration comments filed on the Interim Report in
response to the *Advanced Wireless Services NPRM,* as well as
information provided by industry during NTIA's outreach program.

The Final Report is organized in the following manner.

Section 2 summarizes the 3G system requirements identified in the
Interim Report and discusses suggested changes to this study information
basic requirement made in the rulemaking or outreach program.

Section 3 summarizes the information in the Interim Report on incumbent
ITFS and MDS systems in the 2500‑2690 MHz band, as well as suggested
changes to this study information basic requirement made in the
rulemaking or outreach program.

Section 4 evaluates the spectrum sharing options between ITFS/MDS and
potential 3G systems presented in the Interim Report, including the
co‑channel and adjacent channel protection requirements of ITFS/MDS
systems and the technical feasibility of co‑channel sharing between
ITFS/MDS and 3G systems.

Section 5 evaluates the possible options for segmenting the
2500‑2690 MHz band to provide spectrum for 3G systems presented in the
Interim Report. Using the Interim Report's assumption that the
introduction of 3G systems in the band would require 90 megahertz of
spectrum, this section addresses the impacts on incumbent systems if no
additional spectrum were made available to them to compensate for the
reduction of spectrum in this band.

Section 6 describes assumptions made in identifying appropriate spectrum
for relocating incumbent ITFS/MDS systems to alternate frequency bands
and identifies potential alternate frequency bands for these systems.
This section also analyzes the potential for relocating ITFS/MDS systems
to the identified potential alternate frequency bands. For each
potential alternate band, this section addresses existing rules and
regulations for the band; whether allocation or regulation changes would
be needed to accommodate ITFS/MDS; whether the existing users of the
potential alternate band would have to be relocated; and whether
operational constraints would exist for ITFS/MDS and existing users of
the potential alternate band.

Section 7 identifies cost estimates and potential benefits for
implementing the sharing, band segmentation and relocation options
discussed in the study. This section also describes the assumptions made
in identifying the cost estimates and potential benefits.

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## SECTION 2

## 3G SYSTEM DESCRIPTION

As noted in the Interim Report, the Study Plan calls for the FCC to
provide a description of 3G system requirements, which include: (1)
nature of proposed use; (2) system technical characteristic description
(as a minimum, the necessary information to perform sharing studies with
candidate band systems); (3) spectrum required including channeling
bandwidths and overall spectrum plans (includes segmentation of
candidate bands) to cover regions or nationwide; (4) timing requirements
for identification of spectrum; (5) planned geographical deployments;
(6) interference thresholds (ITU based if available); (7) potential
relationship with other countries' deployment of 3G and global roaming;
(8) potential alternate spectrum band plans including any band
segmentation; and, (9) any operational considerations that will have a
bearing on the evaluation of the sharing/relocation options.

In the Interim Report, we simplified the presentation of the material
called for in the Study Plan and combined the discussion of related
items. For example, the discussion on 3G technical characteristics also
addressed interference thresholds. The discussion on 3G spectrum
requirements addressed other administrations' current spectrum usage for
wireless mobile services as well as their planned spectrum usage for 3G
systems. In addition, some of the information listed above was discussed
in our analyses of spectrum sharing and band segmentation.

In this section, we provide a summary of the basic 3G system
characteristics that were presented in the Interim Report and that
provide the basis for the study of the 2500‑2690 MHz band. As we noted
in the Interim Report, the ITU has been fostering the development of 3G
systems for a number of years, under the name IMT‑2000 and, earlier,
FPLMTS (future public land mobile telecommunication systems).[^5]
Therefore, for the purposes of this study, we relied largely on the
international definitions and technical characteristics of IMT‑2000 and
3G systems developed by the ITU. We also have incorporated other sources
of information to the extent practicable. The information presented is
intended to facilitate our analyses of the 2500‑2690 MHz band and is not
intended to prejudge or foreclose any future decisions that may be made
regarding the implementation of 3G systems.

**PROPOSED USES**

According to the ITU, third generation or IMT‑2000 wireless systems[^6]
will provide mobile, high‑speed access to a wide range of
telecommunication services supported by fixed telecommunication networks
(*e.g.*, PSTN/ISDN), and to other services that are specific to mobile
users. A range of mobile terminal types is encompassed, linking to
terrestrial or satellite‑based networks, and the terminals may be
designed for mobile or fixed use. Key features of 3G or IMT‑2000 systems
are:

-   high degree of commonality of design worldwide;

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-   compatibility of services within IMT‑2000 and with fixed networks;

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-   high quality;

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-   use of small pocket‑terminal with worldwide roaming capability;

-   capability for multimedia applications, and a wide range of services
    (paging, voice telephony, digital data, audio and visual
    communications) and terminals.[^7]

# 

Table 2.1 describes some of the key service attributes and capabilities
expected of IMT‑2000 or 3G systems:

Table 2.1: IMT‑2000 Systems/Capabilities

+-----------------------------------------------------------------------+
| Capabilities to support circuit and packet data at high bit rates:    |
|                                                                       |
| > ‑ 144 kb/s or higher in high mobility (vehicular) traffic           |
| >                                                                     |
| > ‑ 384 kb/s or higher for pedestrian traffic                         |
| >                                                                     |
| > ‑ 2 Mb/s or higher for indoor traffic                               |
+-----------------------------------------------------------------------+
| Interoperability and roaming among IMT‑2000 family of systems         |
+-----------------------------------------------------------------------+
| Common billing/user profiles:                                         |
|                                                                       |
| > ‑ Sharing of usage/rate information between service providers       |
| >                                                                     |
| > ‑ Standardized call detail recording                                |
| >                                                                     |
| > ‑ Standardized user profiles                                        |
+-----------------------------------------------------------------------+
| Capability to determine geographic position of mobiles and report it  |
| to both the network and the mobile terminal                           |
+-----------------------------------------------------------------------+
| Support of multimedia services/capabilities:                          |
|                                                                       |
| > ‑ Fixed and variable rate bit traffic                               |
| >                                                                     |
| > ‑ Bandwidth on demand                                               |
| >                                                                     |
| > ‑ Asymmetric data rates in the forward and reverse links            |
| >                                                                     |
| > ‑ Multimedia mail store and forward                                 |
| >                                                                     |
| > ‑ Broadband access up to 2 Mb/s                                     |
+-----------------------------------------------------------------------+

A key objective of IMT‑2000 is to enable users of personal terminals to
go anywhere in the world and, in a variety of situations (*e.g.*,
indoor/outdoor and in a range of geographic environments), to have
access to a minimum set of services (*e.g.*, voice telephony and a
selection of data services). Services will cover a wide range of
offerings, and many new applications will be developed for IMT‑2000
systems, of a nature that cannot readily be forecast today. IMT‑2000
users will not, in most circumstances, notice that a radio link is used
to connect their terminal to the world\'s telecommunication networks.

**TECHNICAL CHARACTERISTICS**

The ITU has developed a series of technical recommendations, or
standards, that define the key characteristics of IMT‑2000 radio
systems. The standards are intended to minimize the number of different
radio interfaces, maximize their commonality, and provide a transition
path to 3G from first generation (1G) and second generation (2G)
technologies. There are five recommended radio interfaces for the
terrestrial component of IMT‑2000:[^8]

(1) *CDMA Direct Spread* ‑ This interface is called the Universal
    Terrestrial Radio Access (UTRA) Frequency Division Duplex (FDD) or
    Wideband CDMA. FDD operations require paired uplink and downlink
    spectrum segments. The radio access scheme is direct‑sequence CDMA
    with information spread over a bandwidth of about 5 megahertz with a
    chip rate of 3.84 Mcps. Modulation is dual‑channel QPSK.

(2) *CDMA Multi‑Carrier* ‑ This radio interface also is called cdma2000
    and operates in FDD. The radio interface is a wideband spread
    spectrum system that uses code division multiple access (CDMA)
    technology and provides a 3G evolution for systems using the current
    TIA/EIA‑95‑B family of standards. RF channel bandwidths of
    1.25 megahertz and 3.75 megahertz are supported at this time but the
    specification can be extended to bandwidths up to 15 megahertz.

(3) *CDMA TDD* ‑ This radio interface employs a direct‑sequence CDMA
    radio access scheme. There are two versions: UTRA Time Division
    Duplex (TDD) that uses a 5 megahertz bandwidth and a chip rate of
    3.84 Mcps, and TD‑SCDMA that uses 1.6 megahertz bandwidth with a
    chip rate of 1.28 Mcps. TDD systems can operate within unpaired
    spectrum segments. The UTRA TDD specifications were developed to
    provide commonality with UTRA FDD. In addition, the specifications
    were developed based on an evolved GSM‑MAP but include capabilities
    for operation with an evolved ANSI‑41 based network.

(4) *TDMA Single‑Carrier* ‑ This radio interface also is called
    Universal Wireless Communication‑136 (UWC‑136) and is an FDD system.
    It was developed with the objective of maximum commonality between
    TIA/EIA‑136 and GSM General Packet Radio Service. The radio
    interface is intended for evolving TIA/EIA‑136 technology to 3G.
    This is done by enhancing the voice and data capabilities of the
    30 kHz channels, adding a 200 kHz carrier for high speed data (384
    kbits/s) for high mobility applications and adding a 1.6 megahertz
    carrier for very high speed data (2 Mbits/s) for low mobility
    applications.

(5) *FDMA/TDMA* -- This radio interface also is called Digital Enhanced
    Cordless Telecommunications (DECT) and is defined by a set of
    European Technical Standards Institute (ETSI) standards.

These five radio interfaces support various channel bandwidths and have
significantly different technical characteristics. The FCC has generally
declined to mandate specific air interface standards for commercial
mobile radio services. We anticipate that this policy will likely apply
in any spectrum that may be made available for IMT‑2000 systems.
Therefore, United States providers of these services may choose to
employ the IMT‑2000 standards for 3G systems, or they could deviate from
these standards provided they do not cause interference to other users
of the spectrum.

**SPECTRUM CONSIDERATIONS**

As indicated in the Interim Report, the ITU has identified a number of
frequency bands for possible use by terrestrial 3G operations. WARC‑92
identified the 1885‑2025 MHz and 2110‑2200 MHz bands for future public
land mobile telecommunications systems, including those that later
became known IMT‑2000. Over the past decade, the United States
participated in the ITU's efforts to determine how much additional
spectrum next‑generation wireless systems would require and sought to
identify additional frequency bands outside of the 1885‑2025 MHz and
2110‑2200 MHz bands that could be used for IMT‑2000 systems. ITU Task
Group 8/1 eventually determined that by 2010 up to 160 megahertz of
*additional* spectrum might be needed for terrestrial IMT‑2000 systems--
*i.e.*, spectrum beyond that already allocated for first‑ and
second‑generation wireless systems and previously identified at
WARC‑92.[^9]

WRC‑2000 identified additional spectrum for possible use by terrestrial
IMT‑2000 systems, including the 806‑960, 1710‑1885 and 2500‑2690 MHz
bands. The WRC‑2000 results allow countries flexibility in deciding how
to implement IMT‑2000 systems.[^10] The conference recognized that in
many countries the frequency bands identified for 3G use are likely to
be heavily encumbered by equally vital services that for either
strategic or economic reasons cannot be readily displaced or relocated.
Furthermore, not all countries in the world require equal amounts of
spectrum to support future wireless services. The availability of
spectrum to be used for future wireless services depends upon current
spectrum usage, ease of deployment of future radio‑based systems, and
possible transition of incumbents to different frequency bands.

In the United States, the 698‑746, 746‑794, 806‑960 (includes present
cellular band), 1710‑1850, 1850‑1990 (present PCS bands), 2110‑2150,
2160‑2165 and 2500‑2690 MHz bands could be considered for use by future
3G systems. The FCC has initiated the *Advanced Wireless Services*
proceeding to identify spectrum that could be made available for use by
3G systems.

WRC‑2000 also adopted a plan for the ITU‑R to study the additional
frequency bands identified for IMT‑2000 systems in order to determine
their applicability for providing IMT‑2000 systems. Included in this
plan (Resolution 223[^11] and Annex 1 thereto) are studies that address
the sharing implications of IMT‑2000 with other services in the newly
identified bands above 1 GHz, harmonized frequency arrangements for the
implementation of IMT‑2000 systems taking into account the frequency
arrangements of second generation systems in the bands, and means to
facilitate global roaming in light of different regional band usage. The
ITU‑R studies recognize the fact reflected in the US proposal to
WRC‑2000 that not all the spectrum required for IMT‑2000 systems can,
and must be, obtained from the same frequency bands. ITU Working Party
8F has been tasked to perform these studies over the next three years.
In performing this work, Working Party 8F is expected to examine various
ways in which the spectrum identified both at the WARC‑92 and WRC‑2000
might be divided into blocks and potentially paired to facilitate
backward compatibility with 2G systems. At this time Study Group 8F is
in the early stages of identifying a variety of options for further
consideration and study.

There currently is no global consensus as to how the frequency bands
identified at the WARC‑92 and WRC‑2000 will be used to implement 3G. The
Interim Report described the current and intended used of these bands by
various countries. The chart in Appendix 2.2, which includes excerpts
from ITU‑R Report M.2024, summarizes some of the current uses of the
1710‑1885 MHz and 2500‑2690 MHz bands around the world. Since the
release of the Interim Report there have not been any major changes
involving these bands.

**OTHER CONSIDERATIONS**

For any frequency band identified for possible use by 3G systems, the
time period in which spectrum may need to be made available for 3G
systems will greatly affect the impact on incumbent services in those
bands. Also, various operational considerations often will enable
different systems to share spectrum. For example, fixed satellite and
terrestrial fixed operations often are able to share spectrum due to the
ability to coordinate operations to avoid mutual interference. 3G
systems are expected to be ubiquitous and may operate at any time. These
timing and operational considerations are considered in the sharing,
segmentation and relocation aspects of this study.

## SECTION 3

## INCUMBENT SYSTEMS IN

## THE 2500‑2690 MHz BAND

The Interim Report noted that a basic requirement of the Study Plan is
to describe incumbent systems in the candidate band. Specifically, the
studies are to describe incumbent systems in the candidate bands,
including: (1) nature of use, (2) system technical characteristics (at a
minimum, the necessary information to perform sharing studies with 3G
systems), (3) spectrum currently used, including channeling bandwidths
and overall spectrum to cover regions or nationwide, (4) current
geographical deployments, (5) planned geographical deployments, (6)
system life expectancy, (7) planned replacement systems, (8)
interference thresholds (ITU based, if available), (9) unique
operational features (*e.g.*, specific location, area or elevation
required, or relationship with other frequency bands such as separation
between uplinks and downlinks), and (10) any operational considerations
including national security and public safety that will have a bearing
on the evaluation of the sharing or relocation options.

The Interim Report provided information on the incumbent uses of the
2500‑2690 MHz band. In this section, we provide a summary of the
information presented in the Interim Report as well as some additional
information on incumbents' planned uses of the band.

The predominant use of the 2500‑2690 MHz band is by the Fixed Service
for Multipoint Distribution Service (MDS), Multichannel Multipoint
Distribution Service (MMDS), and Instructional Television Fixed Service
(ITFS).[^12] ITFS licensees make extensive use of the spectrum to
provide formal classroom instruction, distance learning, and
videoconference capability to a wide variety of educational users
throughout the nation. Often supported by leasing arrangements to access
excess capacity from ITFS licensed spectrum, MDS licensees provide a
commercial video programming service in this frequency band. The
frequency band is in a state of rapid evolution and development by both
ITFS and MDS licensees so that they can provide high‑speed, two‑way
access to the Internet. The MDS industry has invested several billion
dollars to develop the band for broadband fixed wireless data systems.
These systems will provide a significant opportunity for further
competition with cable and digital subscriber line (DSL) services in the
provision of broadband services in urban areas and deliver broadband
services to rural areas. These systems also will enable ITFS operators
to bring a wide variety of broadband services to educational users,
often in cooperation with MDS operators in the band.

# NATURE OF USE

The predominant use of the 2500‑2690 MHz band is by ITFS, which is
licensed under Part 74 of the Commission's Rules, and MDS, which is
licensed under Part 21 of the Commission's Rules.[^13] ITFS and MDS
share 190 megahertz of spectrum in the 2500‑2690 MHz band. ITFS
licensees are allotted 120 megahertz of spectrum, and MDS licensees are
allotted 66 megahertz of spectrum. In addition, the 4 megahertz of
spectrum in the 2686‑2690 MHz band is allotted for ITFS response
channels and is shared between ITFS licensees and private operations.

ITFS has approximately 1,275 entities holding over 2,175 ITFS licenses
in urban and rural locations throughout the United States.[^14] Over
70,000 locations serve as registered ITFS receive sites, although the
number of actual locations at which ITFS programming is viewed is likely
much higher since receive sites are typically located within a
56.3‑kilometer (35‑mile) protected service area around an ITFS base
station. ITFS stations traditionally have been utilized for a wide
variety of services, including the provision of formal telecourses (on
the K‑12, secondary, and post‑secondary levels) to schools, hospitals,
workplaces and other places of learning; transmission of other
educationally valuable programming (including news, public affairs and
similar material) into schools; provision of professional and worker
training (such as for teachers, health professionals and public safety
officers); and transmission of teleconferences for educational, training
and administrative purposes. ITFS licensees are permitted to lease
excess channel capacity to MDS licensees, with the income from those
leases typically helping to underwrite the cost of providing ITFS.

Traditionally, MDS spectrum has been primarily used to deliver
multichannel video programming, similar to cable television service, to
residential customers. MDS currently has 2,570 station licensees and
conditional licensees (*i.e.*, authorizations to construct or modify
facilities). ITFS and MDS share the spectrum through complex licensing
and leasing arrangements that have evolved over time and that are not
uniform in all geographic areas.

Although the ITFS/MDS spectrum traditionally was used for one‑way analog
video transmission, the Commission rules permit the spectrum to be used
for very high speed, fixed wireless broadband services. The Commission's
July 1996, *Digital Declaratory Ruling* permitted licensees to digitize
their MDS and ITFS spectrum.[^15] With this Commission ruling and the
advances in digital technology, ITFS/MDS video providers can now deliver
as many as 200 channels of programming. In October 1996, the Commission
allowed wireless cable and ITFS operators to use their spectrum for
high‑speed digital data applications, including Internet access.[^16]

In 1998 the FCC approved the use of two‑way transmissions on MDS and
ITFS frequencies, effectively enabling the provision of voice, video,
and data services.[^17] The introduction of two‑way service will allow
many educational users to develop broadband access to support education
throughout the nation and MDS entities to develop a commercial wireless
broadband alternative, especially to residential and small office/home
office ("SOHO") customers.

Given the complex interference environment in the 2500‑2690 MHz band,
the Commission adopted a specific authorization process for this band.
The initial filing window for two‑way service occurred from August 14,
2000 until August 18, 2000, and approximately 2, 267 applications were
received. On November 29, 2000, we issued a Public Notice listing the
applications tendered for filing.[^18] At the conclusion of a 60‑day
amendment period, we issued a Public Notice on February 1, 2001, listing
the applications that had been accepted for filing; all tendered
applications were accepted for filing.[^19] Absent petitions to deny,
these applications will be granted after an additional 60‑day period,
which ends in early April, 2001. Subsequent to this initial licensing
process, two‑way applications will be processed under a rolling one‑day
filing window.[^20]

MDS entities have been able to provide two‑way service on MDS channels
located at 2150‑2160/2162 MHz since 1998, and MDS providers such as
Sprint, WorldCom and Nucentrix have continued to roll‑out high‑speed
Internet access in new markets across the country.

-   Sprint has acquired interests in more than 90 markets covering about
    30 million households. It holds licenses for 642 MDS/commercial ITFS
    channels; leases to use the capacity of 349 MDS/commercial ITFS
    channels; and leases to use the capacity of 1394 ITFS channels.
    Sprint indicates that it holds a total of 532 leases, two‑thirds of
    which are with ITFS licensees.[^21] Sprint Broadband Direct service
    is now available in Phoenix, AZ, Tucson, AZ, Detroit, MI, Colorado
    Springs, CO (business only), Houston, TX, San Jose, TX, Oakland, CA,
    Denver, CO, Salt Lake City, UT, Wichita, KS, Melbourne, FL, Oklahoma
    City, OK and Fresno, CA. Applications for 15 additional markets were
    granted in December 2000. Sprint was providing advanced fixed
    wireless services to more than 20,000 residential and small business
    customers as of December 31, 2000 and is adding over 2,000 new
    customers every week.[^22] In addition, Sprint and its partners
    filed almost 400 applications in 45 markets prior to the end of the
    Commission's two‑way filing window. Sprint's residential Broadband
    Direct service provides downstream speeds of 1 Mbps,[^23] upstream
    speeds of 512 kbps, and burst rates of up to 5 Mbps.

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-   WorldCom holds MDS licenses covering over 31 million households in
    78 markets.[^24] WorldCom is offering fixed wireless high‑speed
    Internet access to residential and SOHO customers. Currently, the
    company is providing commercial fixed wireless broadband services in
    Jackson, MS; Baton Rouge, LA; and Memphis, TN and plans to provide
    service in 30 markets by the end of 2001.[^25] WorldCom plans to
    roll out fixed wireless service to 30 metropolitan areas by the end
    of 2001.[^26] In August, the company filed over 380 applications to
    offer two‑way service in more than 60 markets.[^27] WorldCom offers
    its residential customers two‑way speeds of 310 kbps and businesses
    speeds of 128 kbps to 8 Mbps.[^28]

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-   Nucentrix Broadband Services, Inc. ("Nucentrix") currently offers
    two‑way high‑speed Internet access service in Austin and
    Sherman‑Denison, TX,[^29] and is conducting a trial of the service
    in Amarillo, TX. In February 2001, Nucentrix announced it would
    extend its trial in Amarillo, where it is testing Cisco's Vector
    Orthogonal Frequency Division Multiplexing (VOFDM) technology[^30]
    with over 125 customers, until April 2001.[^31] Nucentrix holds
    licenses that cover 90 small and medium markets across Texas and the
    Midwest.[^32] In August 2000, Nucentrix filed applications to offer
    two‑way service in 70 markets.[^33]

At least 24 other companies offer fixed wireless services in
approximately 33 different counties. These companies are small,
independent MDS licensees offering Internet access at up to 11 Mbps
downstream to a limited number of residential and small business
customers in one to five markets apiece (generally smaller towns and
cities). For example, LMA Systems offers two‑way Internet access at
1.54 Mbps downstream and 768 kbps upstream in Wilkes‑Barre and Sunbury,
PA. and has plans to enter additional markets.[^34] Oxford Telecom
offers two‑way MDS‑based Internet access in Portland, ME.[^35] Some MDS
carriers ‑ including QuadraVision in Carson City and Reno, NV and
American Rural TV in La Junta, CO -- offer fixed wireless Internet
access on a one‑way basis and use a telephone line for the return
path.[^36]

# SPECTRUM USE

Except for two channels at 2150 MHz, the majority of ITFS and MDS
operations are located in the 190 megahertz in the 2500‑2690 MHz band.
In this band, ITFS licensees are allotted five groups of 6 megahertz
channels (120 megahertz of spectrum), and MDS licensees are allotted
three groups of 6 megahertz channels (66 megahertz of spectrum). Each
6 megahertz channel has associated with it a 125 kHz response channel
(4 megahertz of spectrum). In the largest fifty metropolitan areas in
the country, MDS utilizes two 6 megahertz channels in the 2150‑2162 MHz
band.[^37] In the rest of the country, the 6 megahertz MDS 2 channel is
replaced by a 4 megahertz MDS 2‑A channel (2150 to 2160 MHz). The
channel plan is shown in Figure 3.1.

#### Figure 3.1: ITFS/MDS Channel Plan

![](media/image2.wmf){width="6.0in" height="4.289583333333334in"}

Over the years, the MDS and ITFS operators typically operated in a
symbiotic relationship with MDS operators providing funding used by ITFS
licensees for their educational mission in exchange for the extra
channel capacity needed to make MDS systems viable. Today, most ITFS
licensees lease excess capacity to MDS operators, subject to certain
technical limitations and programming requirements. Although the
Commission's licensing processes can identify in a given geographic area
how many channels MDS licensees own through either area‑wide and site
specific licensing, this information does not reveal how much additional
spectrum is being leased from ITFS licensees or the extent to which MDS
spectrum is being leased to other companies.

In its 1998 *Two‑Way Order*, the Commission established a regulatory
framework under which MDS has become a fully flexible service in which
licensees can provide either one‑way or two‑way service to fixed or
portable locations in response to local marketplace demands. MDS and
ITFS licensees were given the flexibility to reconfigure their licensed
spectrum not only to change the direction of transmissions but also to
change the bandwidth used in any direction. In these two‑way systems,
operators are able to deploy a cellular configuration to take advantage
of frequency reuse techniques and to employ modulation schemes that
would permit the use of variable bandwidth while assuring appropriate
levels of interference protection to other licensed users of the
spectrum. The most common characteristics of the two‑way systems now
being deployed are described below. *See* Appendix 3.3 for a pictorial
representation of ITFS/MDS band plans.

-   Either the highest or lowest frequencies in the 2500‑2690 MHz band
    are used for "upstream" service from the user to the system's
    receiver; downstream voice and/or data channels occupy the remaining
    spectrum. This arrangement provides approximately 30 megahertz
    separation between upstream and downstream transmissions to provide
    sufficient isolation of upstream and downstream signals in the
    duplex switch.

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-   Bandwidth is assigned as needed to meet the asynchronous bandwidth
    needs of their customers, including offering adjustable bandwidth
    "on demand." Licensees can subchannelize and superchannelize[^38]
    the 6 megahertz main channels and the I‑channels (125 kHz response
    channels)[^39] to permit the maximum possible operating flexibility.
    For example, the downstream Internet speeds reported by MDS
    operators range from 750 kbps to 11 Mbps, and MDS Internet systems
    can be designed in point‑to‑point or point‑to‑multipoint
    configurations to meet these requirements. Upstream data channels
    typically are either 200 or 400 kHz, and they are most often
    delivered by subchanneling 6 megahertz main channels. Licensees can
    choose the bandwidth plan for each licensed station, taking into
    account channel availability (both licensed and leased channel
    availability) and interference protection to other authorized users
    of the band. Thus, the bandwidth plans for two‑way systems will
    likely vary from one geographic area to another.

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-   ITFS and MDS licensees can exchange channels, subject to Commission
    approval. Also, under certain circumstances, MDS entities could
    apply for licenses for up to eight ITFS channels per community, and
    ITFS entities have a subsequent right of access to those
    channels.[^40]

## GEOGRAPHIC DEPLOYMENT

ITFS and MDS are licensed with different service areas and thus have
different geographic areas entitled to interference protection. ITFS is
authorized on a site‑specific and channel‑specific basis. Although an
ITFS licensee may be authorized to use multiple channels, not all
available ITFS channels may be licensed at any given site or in any
given geographic area. Originally, ITFS transmit and receive sites were
licensed on a point‑to‑point basis. Eventually the Commission adopted a
protected service area (PSA) concept and, with the adoption of the
*Two‑Way Order*, receive sites located within a 56.3 kilometers
(35 miles) radius of a licensed ITFS transmitter are entitled to
interference protection. The Commission continues to provide
interference protection to numerous previously registered receive sites
that are beyond the 56.3 kilometer (35 mile) PSA boundary. Today,
interference protection for ITFS transmit and receive sites is an
amalgam of different channels and geographic boundaries that vary from
location to location.

MDS originally was licensed on a site‑specific and channel‑specific
basis as well. Because MDS is a point‑to‑multipoint service, the
Commission subsequently provided interference protection to receivers
located within a PSA of 56.3 kilometers (35 miles), surrounding licensed
transmit sites. In 1996, the Commission allotted, through a simultaneous
multiple round bidding process, one MDS authorization for each of the
487 Basic Trading Areas (BTAs) and six additional similar geographic
areas.[^41] The BTA licensees are authorized to construct facilities to
provide service over any usable MDS channel within the BTA and have
preferred rights to the available ITFS channels.[^42] Today, some
incumbent site‑specific MDS licensees continue to provide service within
PSAs that either overlap with or lie within licensed BTAs.

As discussed above, the *Two‑Way Order* allows both ITFS and MDS
licensees to modify the historic band plan and to operate with
subchannels or superchannels. In effect, the traditional channel
boundaries across the band are erased, but the geographic protection
areas licensed to a particular band segment remain for interference
protection purposes. This has practical consequences for combined
systems that utilize interleaved channels from both MDS and ITFS channel
groups. For example, channel B1 is immediately adjacent to channel A1.
Protection of the BTA boundary would only apply to the band segment
licensed under the MDS channel group, whereas a 56.3 kilometer (35 mile)
PSA boundary would apply to the band segment licensed under the ITFS
channel group or MDS stations authorized prior to the BTA auction.
Consequently, the actual overlay of BTA and PSA boundaries would be a
relevant consideration in determining the actual service area boundary
of a superchannel that crosses historic band channel boundaries.

### SYSTEM CHARACTERISTICS

The architectures and technical characteristics of ITFS/MDS systems in
the 2500‑2690 MHz band vary and depend on the type of service being
offered, the population of the market being served, and terrain
characteristics of the area being served. Today there are four basic
service offerings by ITFS/MDS operators: downstream analog video,
downstream digital video, downstream digital data and
downstream/upstream digital data. An ITFS or MDS system may be providing
any one of these services or a combination of services.

The typical system characteristics of traditional one‑way ITFS and MDS
systems as well as proposed two‑way ITFS and MDS systems is considered
below. In Appendix 3.2, the specific technical characteristics for
stations in traditional one‑way ITFS and MDS systems are provided in
Tables 3‑A (base stations) and 3‑B (response stations). These are
primarily specifications for analog systems, and they also apply to any
digital system authorized prior to the adoption of the *Two‑Way Order*
in 1998. In Appendix 3.2, the specific technical characteristics for
stations in two‑way ITFS and MDS systems are provided in Tables 3‑C
(base stations) and 3‑D (response stations). These are primarily
specifications for two‑way digital systems that have been authorized
since 1998.

Traditional One‑Way ITFS Systems

Traditional one‑way ITFS systems provide one‑way video transmission
service to their users. In such a system, a main station transmitter
broadcasts (usually omnidirectionally) to multiple receive sites located
within the system service area, typically a radius of 56.3 kilometers
(35 miles). Such receive sites are typically at schools or similar
facilities where a reception antenna can be located on a tower or roof
in order to provide a line‑of‑sight path back to the main station
location. A 125 kHz response station transmitter may be located at any
or all of the receive sites to enable students (and/or faculty) at the
receive site to communicate with faculty (and/or students) at the main
station site. One or more booster stations may be used to retransmit the
main station signal to locations where the signal cannot be received
directly, *e.g.,* where there is terrain blockage. Most systems make use
of standard 6 megahertz composite NTSC video/audio modulation for the
downstream signal and wideband FM for response transmissions.

Traditional One‑Way MDS Systems

Traditional one‑way MDS systems provide one‑way multichannel video
programming to subscribers, a service known as "wireless cable."
Wireless cable systems operate similar to ITFS systems, with a main
station transmitter broadcasting (usually omnidirectionally) multiple
channels of fee‑for‑service entertainment television programming to
customer premises located within the MDS service area. Each customer
typically has a tower‑mounted or rooftop‑mounted reception antenna and
is connected, via a block downconverter, to one or more television sets.
As in ITFS systems, an MDS system makes use of booster stations to
achieve coverage in portions of the service area where direct coverage
from the main station is impossible. Also in common with ITFS systems,
most MDS systems make use of standard 6 megahertz composite NTSC
video/audio modulation, although a few systems have implemented digital
modulation in recent years.

Two‑Way ITFS/MDS Systems

The *Two‑Way Order* introduced a wholly new method of configuring MDS
and ITFS systems. In discussing the technical aspects of ITFS/MDS
systems, it is important to be familiar with the following terms:

> *Main Station*: The primary station authorized by the Commission to
> the MDS or ITFS licensee for providing coverage within a given service
> area. A maximum station power of 33 dBW (2000 watts) (per 6 megahertz
> bandwidth) effective isotropic radiated power (EIRP) is permitted.
>
> *Booster Station (high power):* A station used by an ITFS or MDS
> licensee to provide service within a given service area to locations
> not served by the main station. Any number of such stations may be
> located within a given service area and they may both repeat main
> station transmissions and originate transmissions. These stations
> operate at a power level greater than ‑9 dBW (125 milliwatts) up to a
> maximum of 33 dBW (2000 watts) (per 6 megahertz bandwidth) EIRP.
>
> *Booster Station (low power):* Same as above except limited to a
> maximum power of --9 dBW (125 milliwatts) (per 6 megahertz bandwidth)
> EIRP. These stations may be activated without prior Commission
> approval and operate so long as they do not cause harmful
> interference.
>
> *Receive Site:* A location at which a receiver is located and used in
> conjunction with an ITFS system. A site may be \'registered' (with the
> Commission) and thus protected from harmful interference or
> 'unregistered' and not protected from interference in certain
> circumstances.[^43]
>
> *Response Station (traditional)*: A transmitting station used within a
> traditional, one‑way ITFS system for transmitting an audio signal from
> a receive site back to the main station using 125 kHz 'response
> channels' located in the 2686‑2690 MHz range.
>
> *Response Station (two‑way system):* A customer‑premises transceiver
> used for the reception of downstream and transmission of upstream
> signals as part of a large system of such stations licensed under the
> authority of a single license. A maximum EIRP of 33 dBW (2000 watts)
> (per 6 megahertz) is permitted.
>
> *Hub Station:* A receive‑only station licensed as part of a system of
> response stations in a two‑way system and used for the purpose of
> receiving the upstream transmissions of those response stations.
>
> *Sectorization (at main or booster stations):* The use of multiple
> directional transmitting antennas for the purpose of achieving
> simultaneous frequency *re*use at a single site.
>
> *Sectorization (at hub stations):* The use of multiple directional
> receiving antennas for the purpose of receiving transmissions on the
> same frequencies from multiple directions simultaneously.

In a two‑way MDS or ITFS system, a main station transmitter is used to
send data using digital modulation to numerous users. Each user has at
least one response station transceiver with its receive antenna oriented
towards the main station and its transmit antenna oriented towards its
associated hub station. Typically, a large number of response stations
will be served by a single main station and by a single hub station
linked to that main station, and in most cases these stations will be
co‑located. Additionally, typical systems will utilize numerous booster
stations, each of which serves its own system of response stations and
is associated with its own hub station. Similar to other cellular
networks, two‑way systems employ frequency reuse techniques such as
using sectored antennas within a cell or splitting one cell into several
cells. Two‑way systems using digital modulation may also 'subchannelize'
and 'superchannelize' their authorized spectrum on a real‑time dynamic
basis to meet needs within the system. There is no limit on the number
or locations of response stations so long as the aggregate interference
generated by the stations within the system falls at or below the level
required for protection of neighboring systems. Bandwidths and
associated data rates may be symmetrical or asymmetrical for upstream
and downstream paths, dependant on system architecture and the nature of
the service(s) provided. 'Hybrid' systems are also permissible,
consisting of both 'traditional one‑way' and 'two‑way' operations within
the same service area.[^44]

In the wake of the *Two‑Way Order*, MDS equipment manufacturers have
begun developing new ways to use the available MDS spectrum more
efficiently, such as sectored antennas and advanced modulation
techniques.[^45] For example, Wireless Online utilizes an antenna
technology that enhances the coverage, quality, and capacity of MDS
networks.[^46] NextNet, Inc. has developed a sectorized base station
that uses 6 megahertz channels, with each of the six 60‑degree sectors
of the base station occupying one channel. The system minimizes
multi‑path signal propagation and reportedly delivers maximum user
capacity per megahertz allocated.[^47] Hybrid Network, Inc.'s equipment
allows licensees to split one 6‑megahertz channel into three 2‑megahertz
channels and thereby offer different levels of service using the
different 2 megahertz channels.[^48] Also, in December 1999, Cisco
Systems released a cellularization technology for MDS and unlicensed
spectrum called VOFDM.[^49] VOFDM captures signals as they bounce off
buildings and other objects and redirects them to end‑user transceivers,
therefore eliminating the need for a fixed line‑of‑sight between a
transmitter and a receiver.[^50] Nucentrix recently completed a field
trial of Cisco's VOFDM equipment in Austin, TX and plans to deploy the
technology in at least 20 markets by the end of 2001.[^51] WorldCom is
also testing VOFDM in its Dallas trial.[^52] All of these innovations
permit MDS licensees to make ever more effective use of their spectrum.

### INTERFERENCE PROTECTION STANDARDS

The calculation of permissible interference levels on an inter‑system
basis is extremely complex. The requirements for MDS system protection
are set out in sections 21.902, 21.909, 21.913, 21.933, 21.937 and
21.938 of the Commission's rules.[^53] The requirements for ITFS system
protection are set out in sections 74.903, 74.939, 74.949 and 74.985 of
the Commission's rules.[^54] Additional requirements and procedures for
interference protection for stations in both services are found in
Appendix D (titled "Methodology") to *Report and Order on Further
Reconsideration and Further Notice of Proposed Rulemaking* in MM Docket
97‑217.[^55] Interference is calculated using desired/undesired (D/U)
signal ratios and field strength values that are always referenced to
the bandwidths of the two signals involved in the calculation. The D/U
values specified in the MDS and ITFS rules are normalized to 6 megahertz
and all calculations are based on these normalized values. Interference
is also calculated using a reference field strength value specified
in dBW per square meter, and this value is also always referenced and
normalized to 6 megahertz bandwidth.

The geographical areas for MDS systems that must be protected fall into
3 basic categories. First, there are protected service areas (PSA),
typically with a 56.3 kilometer (35‑mile) radius, for "incumbent" MDS
licensees who received their authorizations prior to March 1996 when the
MDS channels were auctioned nationwide. The second geographic
classification is a Basic Trading Area (BTA), including portions of BTAs
that are created when a BTA is partitioned. Finally, ITFS registered
receive sites within an area swept by a 56.3 kilometer (35‑mile) radius
surrounding the main station transmitter are entitled to protection.

Interference is calculated using 'aggregated' values for the power flux
density on any given channel, subchannel or superchannel, *i.e.*,
interference potential is based on the summation of all of the
individual potential interference contributions of all of the
transmitters within a system, which might be received in a neighboring
system. Aggregation must be used for calculation of both D/U signal
ratios and field strength values.

Interference protection is calculated with reference to specific, known
locations in an ITFS system, and to general geographic areas. The
calculation is done using a grid of points laid out checkerboard fashion
using a reference antenna pattern and a reference standard antenna
height above ground level (AGL).

The most interference‑sensitive portion of a two‑way system is the hub
station receiver. This receiver must be protected down to its 'noise
floor' by all neighboring systems, using a calculation that takes into
account its noise figure, feedline loss, antenna gain and other
pertinent factors. All ITFS/MDS interference calculations must utilize
the Epstein‑Peterson propagation formulations found in the Methodology.
Because the locations of response stations in two‑way systems are not
known prior to licensing of the system, a totally theoretical construct
was devised for estimating interference from response stations into
neighboring systems.[^56]

## SECTION 4

## EVALUATION OF SPECTRUM SHARING

In the Interim Report, we presented a technical evaluation of options
for sharing between 3G and incumbent ITFS and MDS operations in the
2500‑2690 MHz band. In this section, we review and assess that technical
evaluation. The technical feasibility of co‑channel and adjacent channel
sharing between licensed ITFS/MDS stations and 3G base and mobile
stations was examined by calculating minimum distance separation
requirements using the interference protection criteria established in
the Commission's rules for ITFS and MDS.[^57] ITFS/MDS licenses within
the spectrum band were examined to assess where, in light of the minimum
separation distances, 3G systems could operate without causing harmful
interference to ITFS/MDS systems. In this Final Report, we also assess
the predicted levels of co‑channel interference from an ITFS/MDS
transmitter into 3G base and mobile stations.

## INTERFERENCE PROTECTION REQUIREMENTS

In the Interim Report we calculated the predicted levels of co‑channel
and first adjacent channel interference from 3G base and mobile stations
into an ITFS/MDS licensees' receivers at hub and response sites and
determined the minimum distance separation required to avoid harmful
interference.[^58] As discussed below, we determined that large
co‑channel separation distances are needed between 3G systems and
ITFS/MDS systems to avoid causing harmful interference to ITFS/MDS
systems, and that adjacent channel separation requirements do not appear
to be as limiting.

In order to perform technical analyses of the ability of 3G systems to
share spectrum with incumbent systems, we made certain assumptions about
3G systems and incumbent ITFS/MDS systems:

-   For the likely technical characteristics of 3G systems, such as the
    power levels likely to be used by base stations and mobile units and
    the bandwidths of 3G signals, we used, where appropriate, the ITU
    technical standards for IMT‑2000 systems. These technical
    characteristics have been updated since the release of the Interim
    Report by the Industry Association Group.[^59]

-   Interference from a 3G system into the ITFS/MDS stations receivers'
    could come from either the 3G base station or the 3G mobile unit.
    Because base stations are fixed, it was fairly straightforward to
    predict the interference from a 3G base station into ITFS/MDS
    receivers. We also analyzed the effect that a single typical 3G
    mobile unit would have on ITFS/MDS receivers.[^60]

```{=html}
<!-- -->
```
-   ITFS/MDS systems can be implemented using a main transmitter
    configuration or architecture.[^61] These systems typically have a
    single high power base station transmitter located at high elevation
    with an omnidirectional or wide cardioid antenna pattern. FCC rules
    set the maximum permitted EIRP for ITFS/MDS base stations at 2000
    watts (33 dBW).[^62] Typical EIRP for analog systems are in the
    100‑1000 watt (20‑30 dBW) range and are slightly higher for digital
    or cardioid antennas. Both horizontal and vertical polarization are
    used and are often precisely calibrated to avoid co‑channel
    interference to neighboring systems. Booster stations are also used
    in some system designs to overcome signal loss within a protected
    service area.

-   Cellular architectures are also being developed and deployed for
    two‑way ITFS/MDS data transmission systems in densely populated
    areas. Because transceivers are located close together, power levels
    are scaled back for both downstream and upstream transmissions to
    between 1 and 100 watts (0‑20 dBW) EIRP, using the minimum power
    necessary to achieve path reliability. Interference is controlled
    within the protected service area by careful frequency planning and
    by using polarization, sector geometry and receive antenna
    isolation. For example, antennas located at customer premises have
    downstream gains of 12 to 27 dBi, similar to that for a single cell
    one‑way system, and have upstream gains of 10 to 24 dBi.

```{=html}
<!-- -->
```
-   To determine co‑channel and first adjacent channel protection
    requirements, technical characteristics specified in the FCC rules
    for a typical ITFS/MDS station were used. Current FCC rules require
    co‑channel ITFS/MDS licensees to maintain a D/U signal level of
    45 dB at all unobstructed areas within the 56.3 kilometer (35 mile)
    radius protected service area of an incumbent station.[^63] This is
    particularly important in analog single station architectures, where
    a high D/U ratio is required to maintain a high quality video
    signal. For digital single station architectures, the D/U ratio can
    be less than 45 dB as a practical matter because digital systems can
    tolerate more interference. However, FCC rules do not specify
    different D/U ratio values based upon whether the incumbent licensee
    is operating an analog or digital system. Therefore, for purposes of
    this study the required 45 dB D/U ratio was used for the co‑channel
    analysis. For the adjacent channel analysis, FCC rules specify that
    a D/U ratio of 0 dB be maintained. Tables 4‑A and 4‑B in Appendix
    4.1 summarize the pertinent provisions of the FCC rules for ITFS/MDS
    response stations and ITFS/MDS main stations.

The analysis assumed two operating scenarios for 3G base stations based
on the five IMT‑2000 radio interface standards, one operating with high
power -- 500 watts EIRP (27 dBW), and one operating with low power -- 10
watts EIRP (10 dBW). The analysis of the interference potential from an
IMT‑2000 mobile station into an ITFS/MDS receiver assumed the 3G mobile
station was operating with 100 milliwatts (‑10 dBW) EIRP.

Table 4.1 shows the minimum spacing required to prevent interference
between co‑channel 3G base and mobile stations and ITFS/MDS hub and
response station receivers based on our assumptions and the planning
factors set forth in Tables 4‑A and 4‑B in Appendix 4.1.[^64] The
required separation is first tabulated assuming free space conditions,
as prescribed in the FCC's rules for radio propagation predictions for
ITFS/MDS service.[^65] However, as a practical matter, interference does
not extend beyond the radio horizon. FCC rules recognize this concept by
setting 161 kilometers (100 miles) as a limiting distance for purposes
of establishing minimum distance separations.[^66] Accordingly, if the
calculated free space distance separation exceeds this limit, the
practical limit of 161 kilometers (100 miles) is shown in the table.

**Table 4.1: Calculation of Co‑channel Separation Distances**

**of 3G Stations to ITFS/MDS Stations**

<table style="width:100%;">
<colgroup>
<col style="width: 11%" />
<col style="width: 11%" />
<col style="width: 11%" />
<col style="width: 11%" />
<col style="width: 7%" />
<col style="width: 10%" />
<col style="width: 7%" />
<col style="width: 10%" />
<col style="width: 7%" />
<col style="width: 10%" />
</colgroup>
<thead>
<tr class="header">
<th colspan="2"><p>ITFS/MDS</p>
<p>System Parameters</p></th>
<th colspan="2">3G System Parameters</th>
<th colspan="2"><p>3G Base Station</p>
<p>(500 Watts)</p></th>
<th colspan="2"><p>3G Base Station</p>
<p>(10 Watts)</p></th>
<th colspan="2"><p>3G Mobile Station</p>
<p>(100 milliwatts)</p></th>
</tr>
<tr class="odd">
<th><p>Protected</p>
<p>Receiver</p>
<p>Type</p></th>
<th><p>Bandwidth</p>
<p>(kHz)</p></th>
<th><p>Modulation</p>
<p>Type</p></th>
<th><p>Bandwidth</p>
<p>(kHz)</p></th>
<th><p>EIRP</p>
<p>(dBW)</p></th>
<th><p>Minimum</p>
<p>Separation</p>
<p>(km)</p></th>
<th><p>EIRP</p>
<p>(dBW)</p></th>
<th><p>Minimum</p>
<p>Separation</p>
<p>(km)</p></th>
<th><p>EIRP</p>
<p>(dBW)</p></th>
<th><p>Minimum</p>
<p>Separation</p>
<p>(km)</p></th>
</tr>
</thead>
<tbody>
<tr class="odd">
<td>Hub</td>
<td>125</td>
<td>CDMA</td>
<td>1250</td>
<td>27</td>
<td>161</td>
<td>10</td>
<td>161</td>
<td>‑10</td>
<td>161</td>
</tr>
<tr class="even">
<td></td>
<td>125</td>
<td>CDMA</td>
<td>3750</td>
<td>27</td>
<td>161</td>
<td>10</td>
<td>161</td>
<td>‑10</td>
<td>148</td>
</tr>
<tr class="odd">
<td></td>
<td>125</td>
<td>W‑CDMA</td>
<td>5000</td>
<td>27</td>
<td>161</td>
<td>10</td>
<td>161</td>
<td>‑10</td>
<td>127</td>
</tr>
<tr class="even">
<td></td>
<td>125</td>
<td>TDMA</td>
<td>30</td>
<td>27</td>
<td>161</td>
<td>10</td>
<td>161</td>
<td>‑10</td>
<td>161</td>
</tr>
<tr class="odd">
<td></td>
<td>125</td>
<td>TDMA</td>
<td>200</td>
<td>27</td>
<td>161</td>
<td>10</td>
<td>161</td>
<td>‑10</td>
<td>161</td>
</tr>
<tr class="even">
<td><p>Response</p>
<p>Station</p></td>
<td>6000</td>
<td>CDMA</td>
<td>1250</td>
<td>27</td>
<td>161</td>
<td>10</td>
<td>161</td>
<td>‑10</td>
<td>161</td>
</tr>
<tr class="odd">
<td></td>
<td>6000</td>
<td>CDMA</td>
<td>3750</td>
<td>27</td>
<td>161</td>
<td>10</td>
<td>161</td>
<td>‑10</td>
<td>114</td>
</tr>
<tr class="even">
<td></td>
<td>6000</td>
<td>W‑CDMA</td>
<td>5000</td>
<td>27</td>
<td>161</td>
<td>10</td>
<td>161</td>
<td>‑10</td>
<td>100</td>
</tr>
<tr class="odd">
<td></td>
<td>6000</td>
<td>TDMA</td>
<td>30</td>
<td>27</td>
<td>161</td>
<td>10</td>
<td>161</td>
<td>‑10</td>
<td>161</td>
</tr>
<tr class="even">
<td></td>
<td>6000</td>
<td>TDMA</td>
<td>200</td>
<td>27</td>
<td>161</td>
<td>10</td>
<td>161</td>
<td>‑10</td>
<td>161</td>
</tr>
</tbody>
</table>

Similar to the analysis above, Table 4.2 tabulates the minimum spacing
required to prevent interference between 3G base and mobile stations and
first adjacent ITFS/MDS main and response station receivers.[^67]

**Table 4.2: Calculation of Adjacent Channel Separation Distances**

of 3G Stations to ITFS/MDS Stations

<table style="width:100%;">
<colgroup>
<col style="width: 11%" />
<col style="width: 11%" />
<col style="width: 11%" />
<col style="width: 11%" />
<col style="width: 7%" />
<col style="width: 10%" />
<col style="width: 7%" />
<col style="width: 10%" />
<col style="width: 7%" />
<col style="width: 10%" />
</colgroup>
<thead>
<tr class="header">
<th colspan="2"><p>ITFS/MDS</p>
<p>System Parameters</p></th>
<th colspan="2">3G System Parameters</th>
<th colspan="2"><p>3G Base Station</p>
<p>(500 Watts)</p></th>
<th colspan="2"><p>3G Base Station</p>
<p>(10 Watts)</p></th>
<th colspan="2"><p>3G Mobile Station</p>
<p>(100 milliwatts)</p></th>
</tr>
<tr class="odd">
<th><p>Protected</p>
<p>Receiver</p>
<p>Type</p></th>
<th><p>Bandwidth</p>
<p>(kHz)</p></th>
<th><p>Modulation</p>
<p>Type</p></th>
<th><p>Bandwidth</p>
<p>(kHz)</p></th>
<th><p>EIRP</p>
<p>(dBW)</p></th>
<th><p>Minimum</p>
<p>Separation</p>
<p>(km)</p></th>
<th><p>EIRP</p>
<p>(dBW)</p></th>
<th><p>Minimum</p>
<p>Separation</p>
<p>(km)</p></th>
<th><p>EIRP</p>
<p>(dBW)</p></th>
<th><p>Minimum</p>
<p>Separation</p>
<p>(km)</p></th>
</tr>
</thead>
<tbody>
<tr class="odd">
<td>Hub</td>
<td>125</td>
<td>CDMA</td>
<td>1250</td>
<td>27</td>
<td>101</td>
<td>10</td>
<td>14</td>
<td>‑10</td>
<td>1</td>
</tr>
<tr class="even">
<td></td>
<td>125</td>
<td>CDMA</td>
<td>3750</td>
<td>27</td>
<td>58</td>
<td>10</td>
<td>8</td>
<td>‑10</td>
<td>1</td>
</tr>
<tr class="odd">
<td></td>
<td>125</td>
<td>W‑CDMA</td>
<td>5000</td>
<td>27</td>
<td>51</td>
<td>10</td>
<td>7</td>
<td>‑10</td>
<td>1</td>
</tr>
<tr class="even">
<td></td>
<td>125</td>
<td>TDMA</td>
<td>30</td>
<td>27</td>
<td>161</td>
<td>10</td>
<td>93</td>
<td>‑10</td>
<td>9</td>
</tr>
<tr class="odd">
<td></td>
<td>125</td>
<td>TDMA</td>
<td>200</td>
<td>27</td>
<td>161</td>
<td>10</td>
<td>36</td>
<td>‑10</td>
<td>4</td>
</tr>
<tr class="even">
<td><p>Response</p>
<p>Station</p></td>
<td>6000</td>
<td>CDMA</td>
<td>1250</td>
<td>27</td>
<td>161</td>
<td>10</td>
<td>99</td>
<td>‑10</td>
<td>10</td>
</tr>
<tr class="odd">
<td></td>
<td>6000</td>
<td>CDMA</td>
<td>3750</td>
<td>27</td>
<td>161</td>
<td>10</td>
<td>57</td>
<td>‑10</td>
<td>6</td>
</tr>
<tr class="even">
<td></td>
<td>6000</td>
<td>W‑CDMA</td>
<td>5000</td>
<td>27</td>
<td>161</td>
<td>10</td>
<td>50</td>
<td>‑10</td>
<td>5</td>
</tr>
<tr class="odd">
<td></td>
<td>6000</td>
<td>TDMA</td>
<td>30</td>
<td>27</td>
<td>161</td>
<td>10</td>
<td>161</td>
<td>‑10</td>
<td>64</td>
</tr>
<tr class="even">
<td></td>
<td>6000</td>
<td>TDMA</td>
<td>200</td>
<td>27</td>
<td>161</td>
<td>10</td>
<td>161</td>
<td>‑10</td>
<td>25</td>
</tr>
</tbody>
</table>

These tables show, generally, that large co‑channel separation distances
are needed between 3G systems and ITFS/MDS systems to avoid causing
harmful interference to ITFS/MDS systems. For example, a 3G base
station, whether a high‑powered 500 watt base station or a low‑powered
10 watt base station, would need to be beyond the radio horizon of the
ITFS/MDS station or 161 kilometers (100 miles) to avoid causing
interference to co‑channel ITFS/MDS receivers at either hub or response
stations. Very low‑powered 3G mobile stations must maintain distances
between 100 kilometers (62 miles) and 161 kilometers (100 miles) to
avoid causing harmful interference to co‑channel ITFS/MDS hub and
response stations. The results of this analysis of predicted level of
interference and associated minimum separation distances are consistent
with a similar study conducted by MSI.[^68]

The analyses in the Interim Report relied on appropriate ITU standards
for the 3G system technical characteristics.[^69] As noted above, these
technical characteristics have been superseded by the Industry
Association Group 3G Technical Characteristics Report. A review of the
updated 3G technical characteristics reveals that much of the data we
relied on for calculating co‑channel and adjacent channel separation
distances only has minor changes or is unchanged.[^70] Taking these
changes into account, we believe that the conclusions of our initial
analysis remain valid. In addition, we note that commenters from both
the ITFS/MDS and wireless industries also concluded that sharing in the
2500‑2690 MHz band was not feasible.[^71]

In addition to the interference from a 3G system into an ITFS/MDS
system, we considered the interference that a 3G system would receive
from a co‑channel ITFS/MDS system for this Final Report. In its comments
to our *Advanced Wireless Services NPRM,* the WCA included such an
analysis performed by MSI.[^72] MSI concludes that very large separation
distances are needed to protect co‑channel 3G systems from receiving
interference from ITFS/MDS systems. In general, MSI's analysis shows
that ITFS/MDS and 3G systems must be separated by distances exceeding
the radio horizon (161 km or 100 mi) to ensure that ITFS/MDS
transmitters will not cause harmful interference to 3G receivers. We
agree with the conclusions contained in this analysis and do not believe
that further analysis is necessary at this time.

## ITFS/MDS CHANNEL LICENSING

In the Interim Report, we examined the 2500‑2690 MHz band to determine
if there are any vacant channels (*i.e.*, channels not currently
licensed) that could be made available for 3G use. This study looked at
channel availability in the 50 largest metropolitan areas in terms of
population.[^73] To determine whether there are any vacant channels, the
FCC's database as of November 6, 2000 was used. The database contains
information on licensees, their channel number and geographic
coordinates of the main transmitter. Using this licensing data, the
number of ITFS/MDS channels licensed within 161 kilometers (100 miles)
of the city center coordinates was determined for each of the 50 cities.
Appendix 5.4 of the Interim Report indicated the number of channels
licensed per city. This analysis showed that in 49 of the 50 cities all
31 ITFS/MDS channels are licensed within 161 kilometers (100 miles) of
the 50 cities considered.[^74] We also analyzed the locations of hub and
response stations and the protected service areas for each of the of
31 ITFS and MDS channels.[^75]

We noted that the entire 66 megahertz of spectrum allocated to MDS is
encumbered throughout the entire United States. This is because the
rights to provide MDS in all areas of the country were acquired by
winning auction bidders and are not subject to a site specific license
and protected service area. Recognizing that not all of the BTAs have
been completely built‑out, we also examined the actual occupancy of a
sample MDS channel to identify where licensed facilities exist. This
analysis was done in order to be as complete as possible in describing
the occupancy of this spectrum band for purposes of assessing the
feasibility of sharing with 3G systems, *e.g.*, whether MDS licensees
might be able to partition an area within their BTA to prospective 3G
system operators.[^76]

Our analysis showed that there are no significant differences in use and
occupancy across each of the 11 MDS channels. MDS channels are generally
fully deployed in each of the major metropolitan areas of the United
States. As an example, figures 4.1 and 4.2 show only limited areas
within some BTAs where MDS Channel E1 might be available for 3G systems
use, given a 161 kilometer minimum separation between 3G and MDS
systems.

# Figure 4.1: Single MDS Channel E1

![](media/image3.png){width="4.865277777777778in"
height="3.4659722222222222in"}

Figure 4.1 shows the 56.3 kilometer (35‑mile) protected service areas of
licensed MDS stations on MDS channel E1. Figure 4.2 shows the map of
Channel E1 but substitutes 217 kilometer (135 mile) circles for the
56.3 kilometer (35 mile) protected service areas shown in
Figure 4.1.[^77] Only in the very limited white space of Figure 4.2
would it be possible to locate a 3G station on Channel E1 and maintain
the 161 kilometer (100 mile) base station separation requirement.

Figure 4.2: Single MDS Channel E1 With 217 kilometer (135 mile)
Protected Service Areas

![](media/image4.png){width="5.246527777777778in" height="3.73125in"}

We also conducted a similar analysis of the 20 ITFS channels. Our
analysis showed that at least one ITFS station operates in most areas of
the United States, and that the use and occupancy of the 20 ITFS
channels is not significantly different for any ITFS channel. As an
example, to visualize the degree to which each ITFS channel is used, the
occupancy of ITFS Channel A1 was examined. Our analysis showed that
although co‑channel operation of 3G systems might be possible in some
areas, these areas would be significantly limited if a 161 kilometer
minimum separation were to be achieved between 3G and ITFS systems. For
Channel A1, this is illustrated by figures 4.3 and 4.4.

######## Figure 4.3: Single ITFS Channel A1

![](media/image5.png){width="4.935416666666667in" height="3.4875in"}

The white areas of this map reflect those areas of the country beyond
the 56.3 kilometer (35 mile) protected service area of current ITFS
stations. This reveals that only in the least populated areas of the
country is ITFS spectrum not currently occupied. However, as noted
above, co‑channel sharing of 3G with ITFS/MDS may not occur within
161 kilometers (100 miles) of an ITFS/MDS receive site. Thus, the
available area for locating a 3G system within the ITFS spectrum is
significantly less than the white area depicted in Figure 4.3. To
illustrate, this map is reproduced, but instead of depicting the
56.3 kilometer (35 mile) protected service areas, the circles are
enlarged to 217 kilometers (135 miles) and show the areas of the country
where a 3G system can be deployed without causing harmful interference.
Only in the very limited white space of Figure 4.4 would it be possible
to locate a 3G station and maintain the 161 kilometer (100 mile) base
station separation requirement.

######## Figure 4.4: Single ITFS Channel A1 With 217 kilometer (135 mile) Protected Service Areas

![](media/image6.png){width="5.246527777777778in"
height="3.6458333333333335in"}

Our analyses demonstrated that there is no significant difference
between any of the ITFS or MDS channels and Channels A1 and E1. We
determined that ITFS and MDS channels are used in the major metropolitan
areas, and the areas available for possible 3G services within the
2500‑2690 MHz band is significantly limited when the 161 kilometer
(100 mile) minimum distance separation requirement is considered.

## SUMMARY

Based on the assumptions used, we accordingly concluded in the Interim
Report that sharing between 3G systems and ITFS/MDS operations is
extremely problematic. We affirm this conclusion in this Final Report.
Although voluntary partitioning between incumbent users and 3G operators
could offer some promise of sharing as an interim measure, there does
not appear to be enough spectrum in the 2500‑2690 MHz band in populated
areas to support a viable 3G service based on sharing of existing
spectrum in this band.

## SECTION 5

## EVALUATION OF BAND SEGMENTATION

In the Interim Report, we described three possible band segmentation
options for the 2500‑2690 MHz band. We noted that band segmentation
would require the relocation of ITFS/MDS systems from a portion of the
band so that spectrum could be made available for 3G systems. In this
Final Report, we review the analysis regarding the feasibility of
dividing the 2500‑2690 MHz band into segments to meet the
radiocommunications requirements for 3G systems and ITFS/MDS systems. We
also examine what impact the segmentation options would have on ITFS/MDS
systems if we did not replace the spectrum that would be used by 3G
systems, and instead require ITFS/MDS to operate only on the remaining
spectrum in the 2500‑2690 MHz band. In addition, because segmentation
entails placing ITFS/MDS and 3G systems side‑by‑side at the edges of
segmented spectrum, we estimate the size of the guard band that would be
necessary to protect adjacent channel ITFS/MDS and 3G systems from
interfering with each other.[^78] In this Section, we focus our analysis
primarily on the relationships between decreased spectrum availability,
system deployment, and cell size; possible relocation of ITFS/MDS to
alternate frequency bands is discussed in Section 6. Finally, our
evaluation considered implementation of the three segmentation options
in three possible time periods---2003, 2006 and 2010.

**SPECTRUM REQUIREMENTS FOR 3G SYSTEMS**

In the Interim Report, in order to perform an analysis of band
segmentation options, we made certain assumptions about the overall
amount of spectrum that may be made available for 3G systems in the
2500--2690 MHz band. We believe that these assumptions are still valid,
and we review them below.

First, we assume that a substantial part of the 2500--2690 MHz band
would continue to be required to support ITFS/MDS operations.

Second, a number of options are under consideration in the ITU for
either developing IMT‑2000 for independent operation in the
2500‑2690 MHz band or to pair some portion of this spectrum with other
bands. It is not clear at this time what, if any, spectrum from other
bands will be suggested for pairing with the 2500‑2690 MHz band for 3G
systems. Therefore, for purposes of this study, we assume that 3G
systems would operate independently in this band.

If 3G systems were implemented independently in the 2500--2690 MHz band,
sufficient spectrum would need to be made available to support multiple
licensees to promote competition. Also, the spectrum would need to be of
sufficient size to enable development of systems that are economically
viable and support the economies of scale necessary to warrant
development of transmitters, antennas, consumer handsets, and other
related equipment. For example, the Commission has allocated a total of
120 megahertz of spectrum for Personal Communications Service (PCS) in
the 1.9 GHz band, which provided for three licenses of 30 megahertz and
three licenses of 10 megahertz in each geographic area. Also, a number
of European countries have recently made spectrum available for 3G
services in excess of 100 megahertz.

Spectrum also must be made available in contiguous blocks of some
minimal size, both to facilitate reasonable system design and to allow
licensees to choose from all available technologies. For example,
wideband CDMA technology requires a minimal spectrum block size of about
5 megahertz ‑ paired, duplex operation would require two blocks of
5 megahertz.

In light of these factors, to assess the viability of various
segmentation options in this study, we assume that 90 megahertz of
spectrum in the 2500‑2690 MHz band would be made available for 3G
systems. This would continue to leave more than half of the current
spectrum available for ITFS/MDS. It would also provide sufficient
spectrum for multiple 3G licenses. For example, an allocation of
90 megahertz could provide for three 3G licenses of 30 megahertz each,
or three 3G licenses of 20 megahertz each and three 3G licenses of
10 megahertz each.

In comments filed in response to the *Advanced Wireless Services NPRM,*
Verizon argues that only six megahertz of spectrum is needed to support
an ITFS station's instructional purposes and that both 3G systems and
ITFS can be accommodated through segmentation of the band.[^79] Verizon
states that 30 megahertz appears to be sufficient to ensure the economic
viability of one 3G system, and that at least two operators should be
licensed to facilitate the economies of scale necessary to warrant the
development of 3G equipment. Accordingly, Verizon recommends that at
least 60 megahertz of spectrum be made available for 3G systems in the
2500‑2690 MHz band.[^80] VoiceStream, on the other hand, supports making
at least 120 megahertz of spectrum available in the band for 3G systems,
using two 60 megahertz blocks, in order to ensure that adequate spectrum
is available for 3G systems over the next 5‑10 years.[^81]

For purposes of this study, we continue to assume that 90 megahertz of
spectrum may be needed in this band to support the introduction of 3G
systems. With respect to the comments of Verizon and VoiceStream, we do
not believe that there would be a significant difference in the analysis
of band segmentation options if 60 or 120 megahertz was made available
for 3G systems. We note however, that the assumption of 90 megahertz has
been chosen solely to illustrate possible band segmentation scenarios.
It should not in any way be considered indicative of any position that
the Commission may ultimately take on how much spectrum or which
frequency band(s) should be used for the provision of 3G services.

Other factors are also relevant in analyzing various segmentation
options. For example, the choice of frequency division duplex (FDD) or
time division duplex (TDD) radio interfaces affects the segmentation
options studied. Similarly, the architecture of planned new two‑way
ITFS/MDS systems must be taken into account. As described in Section 3,
most planned implementations use FDD technology and require a separation
of at least 30 megahertz between upstream (customer to base) and
downstream (base to customer) transmissions. For FDD operation, this
separation is necessary to provide sufficient isolation of upstream and
downstream signals in the duplexer.[^82] TDD systems also must be
accommodated. These systems, which tend to be less robust than FDD
systems, generally require a guard band between their band of operation
and adjacent bands to minimize the potential of harmful
interference.[^83]

Finally, a variety of other technical factors may also be relevant to
determining spectrum requirements for future 3G systems. These include
constraints on the separation between paired frequency blocks for
frequency duplex technologies, compatibility with existing channeling
plans for incumbent systems, adjacent channel interference, and backward
compatibility with existing 1G and 2G systems. The traffic loading
requirements for 3G data services, where downstream traffic is much
greater than upstream traffic, may lead to asymmetric pairing of
spectrum bands. These factors were not considered in the Interim Report,
nor are they considered in this Final Report because no new information
has become available.

TWO‑WAY ITFS/MDS SYSTEMS: BAND PLANS

As discussed in Section 3, ITFS and MDS licensees are now beginning to
deploy two‑way systems in the 2500‑2690 MHz band. System configuration
in any given geographic area is subject to certain limitations arising
from current spectrum use in that area. As noted, geographic MDS
licenses have been awarded through the competitive bidding process.
These licensees, in implementing their systems, must protect incumbent
MDS systems licensed on a site‑specific basis for 56.3 kilometers
(35 miles) around each transmitter. With respect to ITFS channels, not
all are licensed in all areas. However, where they are licensed, the MDS
licensee may lease excess capacity on the ITFS channels, and MDS and
ITFS licensees can broker channel swaps with each other. Additionally,
geographic MDS licensees have limited ability to gain access to ITFS
channels that are not licensed at this time. Because of the regulatory
flexibility that the Commission has allowed in this band and the
licensing differences between each geographic area, conclusions cannot
be made regarding the configuration of a typical ITFS/MDS system.

To accommodate this flexibility, the MDS industry has initiated a number
of band plans to accommodate new service offerings, such as two‑way
service, as well as to accommodate existing ITFS and MDS users. The
figure in Appendix 3.1 shows a pictorial representation of the various
band plans that MDS licensees are contemplating. The sample plans
presented in this figure are for study purposes only and do not reflect
other options that could be deployed by ITFS/MDS licensees in the
future. As seen in this figure, WorldCom has indicated that it is
implementing three types of two‑way deployment. WorldCom‑1 depicts a
scheme where two‑way ITFS/MDS is overlaid in a market that has heavy
ITFS video use. WorldCom‑2 depicts a band plan that provides a single
main transmitter and cellular configurations where video would be
accommodated either on the two‑way system or a limited number of ITFS
channels.[^84] WorldCom‑3 depicts a deployment that has to accommodate
various individual licenses. Sprint and Nucentrix both indicate two
generic plans each that depict asymmetric systems by grouping the
upstream transmissions on either the upper or the lower channels. And as
noted above, all plans depict a 30 megahertz separation between the
upstream and downstream data transmissions.

## BAND SEGMENTATION OPTIONS

The Interim Report presented three band segmentation options. These are
depicted in Figure 5.1 below. The Interim Report's analysis of the
impact that these options would have on ITFS/MDS and 3G systems, which
is summarized below, considered the functional and operational factors
described in the previous sections.

#### 

#### Figure 5.1: Band Segmentation Options

![](media/image7.wmf){width="5.8in" height="4.352083333333334in"}

*Option 1* provides two 45 megahertz frequency blocks for 3G services
and leaves the remaining 100 megahertz for ITFS/MDS in two 50 megahertz
segments. A benefit of this option is that it provides frequency
separation between paired channel blocks for both 3G and ITFS/MDS
operations for FDD technology. Just as important, the ability to
implement TDD systems is not precluded by this segmentation plan. An
operator may implement TDD technology on any spectrum block for which it
is licensed. To accommodate the differences between ITFS/MDS and 3G
systems, guard bands between the segments have been included.

Further analysis of this option includes an examination of which current
ITFS/MDS channels would be impacted. As can be seen from Figure 5.1, the
placement of the 3G channels in this option coincide with the lower
portion of the ITFS band (channels A1 through B4) and the MDS band
(channels E1 through F4). This is problematic because, as described
earlier, all of the MDS channels have been licensed on a geographic
basis through the competitive bidding process and these geographic
licensees have legal rights to build systems anywhere within their BTA
that is not encumbered.

Alternatively, a similar segmentation plan with the 3G segments in the
center and upper portion of the band (channels C1 through D4, channels
G1 through G4, and channel I) may be considered. Under this scenario, 3G
channels coincide with fewer MDS channels that have been sold at auction
(the interleaved channels H1, H2, and H3) than the option depicted in
Figure 6.1. This option, however, would cede the response channel
(channel I) to 3G systems. This channel, is used for interactive
systems, such as distance learning, to provide an audio channel so that
persons at remote locations can converse with persons located in the
studio. The response channel is currently able to be accessed by any
licensee in the ITFS/MDS band.

Finally, the examination must assess the number of licensees that may be
affected under segmentation Option 1. As can be seen in the following
map, there are numerous systems deployed all over the United States that
would have to be accommodated.

**Figure 5.2: ITFS/MDS Stations Affected by Segmentation Option 1.**

![](media/image8.png){width="4.935416666666667in"
height="3.5131944444444443in"}

*Option 2* provides a segmentation option in which both the 3G and
ITFS/MDS spectrum is combined in a contiguous block. As seen in
Figure 5.1, 90 megahertz of 3G spectrum is provided at the lower end of
the band. The ITFS/MDS spectrum, including a single guard band, is
located at the upper end of the band. Under this option, the 3G portion
of the band could be divided into six 15 megahertz blocks. These could
be paired to provide three 3G licensees with 30 megahertz of spectrum
with 30 megahertz separation between blocks for FDD technology (*i.e.*,
Block A, Block B, Block C, Block A, Block B, Block C -- each block
contains 15 megahertz of spectrum). This option also lends itself nicely
to TDD technology for both 3G and ITFS/MDS systems. This option provides
flexibility for any individual operator to implement the technology of
its choice.[^85]

Under this option, the spectrum denoted for 3G systems would impact only
ITFS channels (channels A1 through C4) and the channels that were
auctioned to MDS would remain with that service. Because of this, the
option as depicted provides a better choice than reversing the segments
(*i.e.*, placing the 3G segment at the upper portion of the band and the
ITFS/MDS segment in the lower portion of the band) where the 3G segments
would encompass all the MDS channels and the response channel (channel
I).

Finally, as with the option presented above, the map shown below depicts
the numerous stations that are currently licensed on the channels
segmented to 3G systems.

**Figure 5.3: ITFS/MDS Stations Affected by Segmentation Option 2.**

![](media/image9.png){width="4.865277777777778in"
height="3.4770833333333333in"}

*Option 3* provides a combination of options 1 and 2. Under this option,
two 45 megahertz frequency blocks would be provided for 3G systems at
the extreme upper and lower ends of the band. The ITFS/MDS spectrum is
provided between these two 3G spectrum blocks. The frequency separation
provided for 3G systems preserves the ability of system operators to
implement FDD technology and the ITFS/MDS spectrum can be paired in a
similar fashion as the 3G spectrum in Option 2 to accommodate FDD
technology.[^86]

Under this option, the channels segmented for 3G systems would encompass
ITFS channels A1 through B4, and all the ITFS/MDS interleaved channels
G1 through G4 plus the response channel (channel I). As described above
for Option 1, this is problematic in that auctioned MDS spectrum would
need to be retrieved to provide spectrum for 3G operators.

Finally, as with Options 1 and 2, there are numerous ITFS and MDS
assignments that would need to be accommodated to implement this
segmentation option. This is shown on the map in Figure 5.4.

**Figure 5.4: ITFS/MDS Stations Affected by Segmentation Option 3.**

![](media/image10.png){width="4.982638888888889in"
height="3.5347222222222223in"}

## IMPACT OF BAND SEGMENTATION ON DEPLOYMENT OF ITFS/MDS SYSTEMS

The flexible use of the 2500‑2690 MHz band makes it extremely difficult
to assess the actual impact that each segmentation option would have on
deployed systems. Such an analysis would entail an examination of the
complex interaction of stations in any given geographic area, including
the way station operation is influenced by lease arrangements and
channel swaps. In light of this situation, we make some assessments
below regarding the impact that station relocation within band or more
efficient spectrum usage would have on ITFS/MDS operations. Our analysis
does not address legal or policy issues concerning leasing arrangements
or the acquisition of licenses through competitive bidding or transfer
of control, which are beyond the scope of this study.

To obtain a more quantitative evaluation of the effect segmentation
would have on licensees, we examined the number of transmitters that
would be affected by each option. In the Interim Report we stated that,
based on the licensing database, over 60,000 transmitters would need to
be accommodated in any 90 megahertz segment of spectrum in the
2500‑2690 MHz band that is reallocated to 3G.[^87] Because the licensing
database has not substantially changed since then, we believe that this
conclusion is still valid. The majority of the stations represented in
the database are mainly incumbent one‑way systems. As geographic MDS
licensees begin deploying two‑way service, the number of stations will
increase considerably because each subscriber's location becomes an
additional transmit site for upstream traffic. Thus, for every
transmitter that a geographic MDS licensee currently has licensed, there
is the potential for many times that number to ultimately exist.[^88]
Additionally, educational institutions could continue to license ITFS
stations where spectrum is available. Therefore, over 60,000
transmitters would need to be relocated regardless of which segmentation
option is considered.

If 90 megahertz of spectrum is reallocated from the 2500‑2690 MHz band
to 3G systems, the ITFS/MDS would have to provide their services using
only 100 megahertz, rather than the 190 megahertz, of spectrum in the
band. Such a scenario would require some ITFS/MDS operations to move
from the reallocated spectrum to the remaining spectrum. One way to
accommodate the influx of stations in the remaining spectrum would be
for ITFS/MDS stations to transmit with narrower bandwidths or to reduce
power. Thus, options for increasing the spectrum efficiency of ITFS/MDS
operations must be explored.

First, we can consider the effect segmentation would have on traditional
one‑way ITFS/MDS licensees that provide one‑way video transmission
services. Generally, these systems transmit using standard 6 megahertz
composite NTSC video/audio modulation. In addition, the ITFS licensees
may use a 125 kHz response station transmitter located at any or all of
the receive sites to enable students or faculty at the receive site to
communicate with others at the main station site. These response
channels typically operate using wideband FM modulation. In recent
years, some incumbent MDS systems have converted to digital systems.

If the band was segmented, these stations would presumably convert to
digital modulation in order to operate more efficiently. Based on the
broadcasting services experience, we know that, when upgrading from
analog to digital TV and employing MPEG‑2 video compression,[^89]
efficiencies in the range of 4:1 (*i.e.*, 4 distinct programs can be
transmitted over one 6 megahertz channel)[^90] up to about 8:1 can be
achieved depending on the content and desired picture quality.[^91]
Under these digital modulation schemes, though, the transmitted signal
still occupies a 6 megahertz channel; transmitters broadcasting a single
program do not reduce their bandwidth to transmit over 1 or 2 megahertz.
Therefore, to accommodate the continued operations of all incumbent ITFS
and MDS licensees in any given area, at least 6 megahertz of spectrum
per each incumbent user must be dedicated for such use in each area. If
any of these licensees typically broadcast more than 6‑8 programs
simultaneously, additional channels must be set aside. Therefore, in
order to maintain the 70 megahertz of spectrum MDS is currently allotted
under the existing band plan, there could be no more than 5 incumbent
one‑way ITFS and MDS licensees in any given area. This could be
problematic in many metropolitan areas. For example, in New York City, 6
incumbent ITFS licensees hold 9 licenses, and 4 incumbent MDS licensees
hold 5 licenses. Further, many of these licenses are for multiple
channels. In contrast, in Buffalo, NY, there are no incumbent ITFS
licensees and only 1 incumbent MDS licensee, holding 2 licenses.
Analysis of the 50 largest metropolitan areas in terms of population
shows that the average and median number of licenses in each area is 8
and the average number of different licensees holding these licenses is
5. Appendix 5.1 shows the number of incumbent ITFS and MDS licensees in
metropolitan area.[^92]

Licensees may already be using digital modulation techniques to provide
data services at high data rates. For example, Nucentrix points out that
they and other operators deliver data using efficient OFDM and
high‑order QAM modulations,[^93] and Cisco notes that major MDS
licensees are conducting trials using their VOFDM technology.[^94]
Operators that are already using digital modulation, including both
one‑way and two‑way systems, may not be able to compress their signals
to narrower bandwidths and still provide the same grade of service.
These operators would have to decrease the size of the service area of
each tower in order to continue offering high speed data services with
reduced spectrum. This is explored below.

The ITFS/MDS operators argue that to offer acceptable two‑way service
they need to have access to most of the 190 megahertz of spectrum now
allocated for ITFS/MDS in the 2500‑2690 MHz band. In commenting on the
*Advanced Wireless Services NPRM*, WorldCom states that certain channels
are not available in many markets due to co‑channel ITFS/MDS operations
in adjacent markets, that up to 42 megahertz of separation is needed
between upstream and downstream traffic, and that guard bands are needed
between high power video downstream and low power data downstream
channels to avoid station downconverter overload.[^95] Worldcom further
states the these constraints result in an average availability of
158 megahertz (including the 10‑12 megahertz allocated in the
2150‑2160/62 MHz band) of spectrum in most markets for use by two‑way
systems.[^96] Similarly, the HAI Study determined that a reasonable
estimate of the amount of spectrum to which two‑way systems have access
is 158 megahertz (26 channels of 6 megahertz each plus an additional
2 megahertz).[^97] Finally, Cisco points out that to serve the San
Jose‑Silicon Valley market, a micro‑cell network (3 sectors per cell, 3
cells per cluster) is needed in which each cluster requires 9 sets of
frequencies to provide 10.5 megahertz downstream and 7.5 megahertz
upstream shared among all customers for a total of 162 megahertz.[^98]

##### Guard Bands

Each of the segmentation options would provide significantly less
spectrum for two‑way ITFS/MDS systems than is currently available. If
90 megahertz of spectrum was made available for 3G systems, the
remaining 100 megahertz of spectrum would have to support incumbent
ITFS/MDS systems, geographic area MDS systems, and guard bands.
Therefore, the usable spectrum for ITFS/MDS systems would be further
reduced from 100 megahertz based on the size of the guard band needed to
protect adjacent channel operations. Below, we present an analysis
estimating the size of the guard band necessary to ensure interference
free operation between ITFS/MDS and 3G systems.

Just as with the analysis to determine distance separations in Section
4, the technical characteristics for this analysis include the five ITU
IMT‑2000 radio interface standards[^99] and the rules for ITFS/MDS
interference protection.[^100] The analysis calculates the required
mileage separation between ITFS/MDS base stations and 3G base stations
for various guard band sizes. Calculations of separation distance are
made for ITFS/MDS interfering with 3G systems and for 3G systems
interfering with ITFS/MDS systems. The analysis looked at interference
caused by energy contained in the adjacent channel, and for completeness
also looked at energy from the adjacent channel that overlapped the
desired channel (spillover).

For the analysis of ITFS/MDS interference to 3G systems, we assume worst
case operating parameters. For example, we assume that the main
transmitter is operating with a sectored antenna at maximum power. For
this type of operation, the rules allow up to 39 dBW (7943 watts)
EIRP.[^101] A complete list of planning factors used in the analysis is
provided in Appendix 5.2. Also, as with the analysis in Section 4,
computed values that exceed the distance to the radio horizon are
reduced to the distance to the radio horizon or 161 kilometers
(100 miles).

Table 5.1 shows the relationship between guard band size and the
distance separation needed between 3G base stations and ITFS/MDS hub and
response stations to avoid harmful interference due to the energy
present in the adjacent channel.[^102] The table shows that for a guard
band of 2 megahertz, the distance separation necessary between ITFS/MDS
and 3G systems is reduced to almost zero. In fact, from our planning
factors in Appendix 5.1, it is easily deduced that each
additional megahertz added to the guard band reduces the required
separation by a factor of 100.[^103] Therefore, for this situation, we
conclude that a guard band of at least 2 megahertz seems reasonable to
ensure protection of ITFS/MDS stations from 3G base stations.

<table style="width:100%;">
<colgroup>
<col style="width: 12%" />
<col style="width: 10%" />
<col style="width: 12%" />
<col style="width: 11%" />
<col style="width: 12%" />
<col style="width: 11%" />
<col style="width: 0%" />
<col style="width: 10%" />
<col style="width: 4%" />
<col style="width: 7%" />
<col style="width: 6%" />
</colgroup>
<tbody>
<tr class="odd">
<td colspan="11"><strong>Table 5.1: Calculation of Separation Distances,
3G Base Station to ITFS/MDS</strong></td>
</tr>
<tr class="even">
<td colspan="11">Guard Band Analysis Based on Interference Power in
Adjacent or Nearby Channels</td>
</tr>
<tr class="odd">
<td colspan="3">3G System Parameters</td>
<td colspan="3">ITFS/MDS System Parameters</td>
<td colspan="5">Required Separation (km)</td>
</tr>
<tr class="even">
<td rowspan="2"><p>Modulation</p>
<p>Type</p></td>
<td rowspan="2"><p>EIRP</p>
<p>(dBW)</p></td>
<td rowspan="2"><p>Bandwidth</p>
<p>(kHz)</p></td>
<td rowspan="2"><p>Protected</p>
<p>Receiver</p></td>
<td rowspan="2"><p>Bandwidth</p>
<p>(kHz)</p></td>
<td colspan="2" rowspan="2"><p>Desired</p>
<p>Signal</p>
<p>Power</p>
<p>Density</p>
<p>(dBW/m<sup>2</sup>)</p></td>
<td rowspan="2"><p>Adjacent</p>
<p>Channels</p>
<p>(No</p>
<p>Guard</p>
<p>Band)</p></td>
<td colspan="3">Guard Band Width (MHz)</td>
</tr>
<tr class="odd">
<td>0.5</td>
<td>1</td>
<td>2</td>
</tr>
<tr class="even">
<td>CDMA</td>
<td>27</td>
<td>1250</td>
<td rowspan="5">Hub</td>
<td>125</td>
<td colspan="2">‑90</td>
<td>161</td>
<td>16</td>
<td>1.6</td>
<td>0.02</td>
</tr>
<tr class="odd">
<td>CDMA</td>
<td>27</td>
<td>3750</td>
<td>125</td>
<td colspan="2">‑90</td>
<td>161</td>
<td>16</td>
<td>1.6</td>
<td>0.02</td>
</tr>
<tr class="even">
<td>W‑CDMA</td>
<td>27</td>
<td>5000</td>
<td>125</td>
<td colspan="2">‑90</td>
<td>161</td>
<td>16</td>
<td>1.6</td>
<td>0.02</td>
</tr>
<tr class="odd">
<td>TDMA</td>
<td>27</td>
<td>30</td>
<td>125</td>
<td colspan="2">‑90</td>
<td>100</td>
<td>10</td>
<td>1.0</td>
<td>0.02</td>
</tr>
<tr class="even">
<td>TDMA</td>
<td>27</td>
<td>200</td>
<td>125</td>
<td colspan="2">‑90</td>
<td>161</td>
<td>16</td>
<td>1.6</td>
<td>0.02</td>
</tr>
<tr class="odd">
<td colspan="11"></td>
</tr>
<tr class="even">
<td>CDMA</td>
<td>27</td>
<td>1250</td>
<td><p>Response</p>
<p>Station</p></td>
<td>6000</td>
<td colspan="2">‑67</td>
<td>6.4</td>
<td>0.6</td>
<td>0.06</td>
<td>0.00</td>
</tr>
<tr class="odd">
<td>CDMA</td>
<td>27</td>
<td>3750</td>
<td></td>
<td>6000</td>
<td colspan="2">‑67</td>
<td>11.3</td>
<td>1.1</td>
<td>0.11</td>
<td>0.00</td>
</tr>
<tr class="even">
<td>W‑CDMA</td>
<td>27</td>
<td>5000</td>
<td></td>
<td>6000</td>
<td colspan="2">‑67</td>
<td>12.9</td>
<td>1.3</td>
<td>0.13</td>
<td>0.00</td>
</tr>
<tr class="odd">
<td>TDMA</td>
<td>27</td>
<td>30</td>
<td></td>
<td>6000</td>
<td colspan="2">‑67</td>
<td>1.6</td>
<td>0.2</td>
<td>0.02</td>
<td>0.00</td>
</tr>
<tr class="even">
<td>TDMA</td>
<td>27</td>
<td>200</td>
<td></td>
<td>6000</td>
<td colspan="2">‑67</td>
<td>3.2</td>
<td>0.3</td>
<td>0.03</td>
<td>0.00</td>
</tr>
</tbody>
</table>

Table 5.2 also shows that only 2 megahertz of guard band is need to
account for the 3G system energy that overlaps the ITFS/MDS
channel.[^104] Therefore, the energy in the adjacent channel is the
limiting factor in this case. We conclude that to protect ITFS/MDS
stations from harmful interference from adjacent channel 3G systems, a
guard band of at least 2 megahertz is needed.

<table>
<colgroup>
<col style="width: 12%" />
<col style="width: 10%" />
<col style="width: 12%" />
<col style="width: 11%" />
<col style="width: 12%" />
<col style="width: 11%" />
<col style="width: 10%" />
<col style="width: 4%" />
<col style="width: 7%" />
<col style="width: 6%" />
</colgroup>
<tbody>
<tr class="odd">
<td colspan="10"><strong>Table 5.2: Calculation of Separation Distances,
3G Base Station to ITFS/MDS</strong></td>
</tr>
<tr class="even">
<td colspan="10">Guard Band Analysis Based on Co‑Channel Interference
Power (Spill‑over)<a href="#fn1" class="footnote-ref" id="fnref1"
role="doc-noteref"><sup>1</sup></a></td>
</tr>
<tr class="odd">
<td colspan="3">3G System Parameters</td>
<td colspan="3">ITFS/MDS System Parameters</td>
<td colspan="4">Required Separation (km)</td>
</tr>
<tr class="even">
<td rowspan="2"><p>Modulation</p>
<p>Type</p></td>
<td rowspan="2"><p>Off‑Channel</p>
<p>EIRP</p>
<p>(dBW</p>
<p>per</p>
<p>100 kHz)</p></td>
<td rowspan="2"><p>Bandwidth</p>
<p>(kHz)</p></td>
<td rowspan="2"><p>Protected</p>
<p>Receiver</p></td>
<td rowspan="2"><p>Bandwidth</p>
<p>(kHz)</p></td>
<td rowspan="2"><p>Noise</p>
<p>Floor</p>
<p>(NF), or</p>
<p>Desired</p>
<p>Signal</p>
<p>(DS) Level</p>
<p>(dBW)</p></td>
<td rowspan="2"><p>Adjacent</p>
<p>Channels</p>
<p>(No</p>
<p>Guard</p>
<p>Band)</p></td>
<td colspan="3">Guard Band Width (MHz)</td>
</tr>
<tr class="odd">
<td>0.5</td>
<td>1</td>
<td>2</td>
</tr>
<tr class="even">
<td>CDMA</td>
<td>‑16</td>
<td>1250</td>
<td rowspan="5">Hub</td>
<td>125</td>
<td>‑118 (NF)</td>
<td>26</td>
<td>2.6</td>
<td>0.26</td>
<td>0.00</td>
</tr>
<tr class="odd">
<td>CDMA</td>
<td>‑16</td>
<td>3750</td>
<td>125</td>
<td>‑118 (NF)</td>
<td>26</td>
<td>2.6</td>
<td>0.26</td>
<td>0.00</td>
</tr>
<tr class="even">
<td>W‑CDMA</td>
<td>‑16</td>
<td>5000</td>
<td>125</td>
<td>‑118 (NF)</td>
<td>26</td>
<td>2.6</td>
<td>0.26</td>
<td>0.00</td>
</tr>
<tr class="odd">
<td>TDMA</td>
<td>‑16</td>
<td>30</td>
<td>125</td>
<td>‑118 (NF)</td>
<td>26</td>
<td>2.6</td>
<td>0.26</td>
<td>0.00</td>
</tr>
<tr class="even">
<td>TDMA</td>
<td>‑16</td>
<td>200</td>
<td>125</td>
<td>‑118 (NF)</td>
<td>26</td>
<td>2.6</td>
<td>0.26</td>
<td>0.00</td>
</tr>
<tr class="odd">
<td colspan="10"></td>
</tr>
<tr class="even">
<td>CDMA</td>
<td>‑16</td>
<td>1250</td>
<td rowspan="5"><p>Response</p>
<p>Station</p></td>
<td>6000</td>
<td>‑83 (DS)</td>
<td>161</td>
<td>16</td>
<td>1.6</td>
<td>0.02</td>
</tr>
<tr class="odd">
<td>CDMA</td>
<td>‑16</td>
<td>3750</td>
<td>6000</td>
<td>‑83 (DS)</td>
<td>161</td>
<td>16</td>
<td>1.6</td>
<td>0.02</td>
</tr>
<tr class="even">
<td>W‑CDMA</td>
<td>‑16</td>
<td>5000</td>
<td>6000</td>
<td>‑83 (DS)</td>
<td>161</td>
<td>16</td>
<td>1.6</td>
<td>0.02</td>
</tr>
<tr class="odd">
<td>TDMA</td>
<td>‑16</td>
<td>30</td>
<td>6000</td>
<td>‑83 (DS)</td>
<td>161</td>
<td>16</td>
<td>1.6</td>
<td>0.02</td>
</tr>
<tr class="even">
<td>TDMA</td>
<td>‑16</td>
<td>200</td>
<td>6000</td>
<td>‑83 (DS)</td>
<td>161</td>
<td>16</td>
<td>1.6</td>
<td>0.02</td>
</tr>
</tbody>
</table>
<aside id="footnotes" class="footnotes footnotes-end-of-document"
role="doc-endnotes">
<hr />
<ol>
<li id="fn1"><p>Interference due to the energy from the signal centered
in the adjacent channel that is actually transmitted in the desired
channel. This is also referred to as front end overload.<a
href="#fnref1" class="footnote-back" role="doc-backlink">↩︎</a></p></li>
</ol>
</aside>

Tables 5.3 and 5.4 show that the interference to 3G systems from
ITFS/MDS main and response stations is slightly worse than the
interference 3G systems impact on ITFS/MDS.[^105] Table 5.3 indicates
that an ITFS/MDS main transmitter would need to be 57 kilometers away
from a UWC‑136 (TDMA) base station to avoid interference if the guard
band is 2 megahertz. Since, as explained above, each megahertz decreases
this distance by a factor of 100, an additional 2 megahertz will reduce
the distance to 0.01 kilometers. Therefore, we conclude that a guard
band of up to a 4 megahertz is needed to ensure interference free
operation.

<table>
<colgroup>
<col style="width: 12%" />
<col style="width: 12%" />
<col style="width: 8%" />
<col style="width: 12%" />
<col style="width: 12%" />
<col style="width: 12%" />
<col style="width: 10%" />
<col style="width: 4%" />
<col style="width: 7%" />
<col style="width: 6%" />
</colgroup>
<tbody>
<tr class="odd">
<td colspan="10"><strong>Table 5.3: Calculation of Separation Distances,
ITFS/MDS to 3G Base Station</strong></td>
</tr>
<tr class="even">
<td colspan="10">Guard Band Analysis Based on Interference Power in
Adjacent or Nearby Channels</td>
</tr>
<tr class="odd">
<td colspan="3">ITFS/MDS System Parameters</td>
<td colspan="3">3G System Parameters</td>
<td colspan="4">Required Separation (km)</td>
</tr>
<tr class="even">
<td rowspan="2"><p>Type of</p>
<p>Transmitter</p></td>
<td rowspan="2"><p>Bandwidth</p>
<p>(kHz)</p></td>
<td rowspan="2"><p>EIRP</p>
<p>(dBW)</p></td>
<td rowspan="2"><p>Modulation</p>
<p>Type</p></td>
<td rowspan="2"><p>Bandwidth</p>
<p>(kHz)</p></td>
<td rowspan="2"><p>Noise in</p>
<p>Receive</p>
<p>Bandwidth</p>
<p>(dBW)</p></td>
<td rowspan="2"><p>Adjacent</p>
<p>Channels</p>
<p>(No</p>
<p>Guard</p>
<p>Band)</p></td>
<td colspan="3">Guard Band Width (MHz)</td>
</tr>
<tr class="odd">
<td>0.5</td>
<td>1</td>
<td>2</td>
</tr>
<tr class="even">
<td rowspan="5">Main</td>
<td>6000</td>
<td>39</td>
<td>CDMA</td>
<td>1250</td>
<td>‑138</td>
<td>161</td>
<td>161</td>
<td>161</td>
<td>4.7</td>
</tr>
<tr class="odd">
<td>6000</td>
<td>39</td>
<td>CDMA</td>
<td>3750</td>
<td>‑133</td>
<td>161</td>
<td>161</td>
<td>161</td>
<td>2.7</td>
</tr>
<tr class="even">
<td>6000</td>
<td>39</td>
<td>W‑CDMA</td>
<td>5000</td>
<td>‑132</td>
<td>161</td>
<td>161</td>
<td>161</td>
<td>2.4</td>
</tr>
<tr class="odd">
<td>6000</td>
<td>39</td>
<td>TDMA</td>
<td>30</td>
<td>‑154</td>
<td>161</td>
<td>161</td>
<td>161</td>
<td>57.1</td>
</tr>
<tr class="even">
<td>6000</td>
<td>39</td>
<td>TDMA</td>
<td>200</td>
<td>‑146</td>
<td>161</td>
<td>161</td>
<td>161</td>
<td>20.3</td>
</tr>
<tr class="odd">
<td colspan="10"></td>
</tr>
<tr class="even">
<td rowspan="5"><p>Response</p>
<p>Station</p></td>
<td>125</td>
<td>22</td>
<td>CDMA</td>
<td>1250</td>
<td>‑138</td>
<td>161</td>
<td>161</td>
<td>161</td>
<td>2.3</td>
</tr>
<tr class="odd">
<td>125</td>
<td>22</td>
<td>CDMA</td>
<td>3750</td>
<td>‑133</td>
<td>161</td>
<td>161</td>
<td>161</td>
<td>2.1</td>
</tr>
<tr class="even">
<td>125</td>
<td>22</td>
<td>W‑CDMA</td>
<td>5000</td>
<td>‑132</td>
<td>161</td>
<td>161</td>
<td>161</td>
<td>2.1</td>
</tr>
<tr class="odd">
<td>125</td>
<td>22</td>
<td>TDMA</td>
<td>30</td>
<td>‑154</td>
<td>161</td>
<td>161</td>
<td>161</td>
<td>4.0</td>
</tr>
<tr class="even">
<td>125</td>
<td>22</td>
<td>TDMA</td>
<td>200</td>
<td>‑146</td>
<td>161</td>
<td>161</td>
<td>161</td>
<td>3.5</td>
</tr>
</tbody>
</table>

<table>
<colgroup>
<col style="width: 12%" />
<col style="width: 12%" />
<col style="width: 8%" />
<col style="width: 12%" />
<col style="width: 12%" />
<col style="width: 12%" />
<col style="width: 10%" />
<col style="width: 4%" />
<col style="width: 7%" />
<col style="width: 6%" />
</colgroup>
<tbody>
<tr class="odd">
<td colspan="10"><strong>Table 5.4: Calculation of Separation Distances,
ITFS/MDS to 3G Base Station</strong></td>
</tr>
<tr class="even">
<td colspan="10">Guard Band Analysis Based on Co‑Channel Interference
Power (Spill‑over)</td>
</tr>
<tr class="odd">
<td colspan="3">ITFS/MDS System Parameters</td>
<td colspan="3">3G System Parameters</td>
<td colspan="4">Required Separation (km)</td>
</tr>
<tr class="even">
<td rowspan="2"><p>Type of</p>
<p>Transmitter</p></td>
<td rowspan="2"><p>Bandwidth</p>
<p>(kHz)</p></td>
<td rowspan="2"><p>EIRP</p>
<p>(dBW)</p></td>
<td rowspan="2"><p>Modulation</p>
<p>Type</p></td>
<td rowspan="2"><p>Bandwidth</p>
<p>(kHz)</p></td>
<td rowspan="2"><p>Noise in</p>
<p>Receive</p>
<p>Bandwidth</p>
<p>(dBW)</p></td>
<td rowspan="2"><p>Adjacent</p>
<p>Channels</p>
<p>(No</p>
<p>Guard</p>
<p>Band)</p></td>
<td colspan="3">Guard Band Width (MHz)</td>
</tr>
<tr class="odd">
<td>0.5</td>
<td>1</td>
<td>2</td>
</tr>
<tr class="even">
<td rowspan="5">Main</td>
<td>6000</td>
<td>39</td>
<td>CDMA</td>
<td>1250</td>
<td>‑138</td>
<td>161</td>
<td>153</td>
<td>75.6</td>
<td>0.1</td>
</tr>
<tr class="odd">
<td>6000</td>
<td>39</td>
<td>CDMA</td>
<td>3750</td>
<td>‑133</td>
<td>161</td>
<td>101</td>
<td>51.5</td>
<td>0.1</td>
</tr>
<tr class="even">
<td>6000</td>
<td>39</td>
<td>W‑CDMA</td>
<td>5000</td>
<td>‑132</td>
<td>161</td>
<td>42</td>
<td>20.9</td>
<td>0.05</td>
</tr>
<tr class="odd">
<td>6000</td>
<td>39</td>
<td>TDMA</td>
<td>30</td>
<td>‑154</td>
<td>161</td>
<td>161</td>
<td>161</td>
<td>0.4</td>
</tr>
<tr class="even">
<td>6000</td>
<td>39</td>
<td>TDMA</td>
<td>200</td>
<td>‑146</td>
<td>161</td>
<td>161</td>
<td>161</td>
<td>0.3</td>
</tr>
<tr class="odd">
<td colspan="10"></td>
</tr>
<tr class="even">
<td rowspan="5"><p>Response</p>
<p>Station</p></td>
<td>125</td>
<td>22</td>
<td>CDMA</td>
<td>1250</td>
<td>‑138</td>
<td>161</td>
<td>61</td>
<td>30.6</td>
<td>0.06</td>
</tr>
<tr class="odd">
<td>125</td>
<td>22</td>
<td>CDMA</td>
<td>3750</td>
<td>‑133</td>
<td>161</td>
<td>37</td>
<td>17.7</td>
<td>0.03</td>
</tr>
<tr class="even">
<td>125</td>
<td>22</td>
<td>W‑CDMA</td>
<td>5000</td>
<td>‑132</td>
<td>90</td>
<td>10</td>
<td>4.8</td>
<td>0.02</td>
</tr>
<tr class="odd">
<td>125</td>
<td>22</td>
<td>TDMA</td>
<td>30</td>
<td>‑154</td>
<td>161</td>
<td>161</td>
<td>119.1</td>
<td>0.24</td>
</tr>
<tr class="even">
<td>125</td>
<td>22</td>
<td>TDMA</td>
<td>200</td>
<td>‑146</td>
<td>161</td>
<td>16</td>
<td>66.0</td>
<td>0.13</td>
</tr>
</tbody>
</table>

From the Tables, the relationship between distance separation and guard
band size is apparent. When planning a system, these two parameters can
be adjusted to provide the necessary level interference protection.
However, as a practical matter, in Section 4, we showed that the
2500‑2690 MHz spectrum is so heavily encumbered and the distance
separations necessary for sharing are so large, that the only
alternative for deploying 3G systems in this band is to clear spectrum
and provide an adequate guard band between 3G and ITFS/MDS segments. In
this case, we believe that to accommodate each of the ITU IMT‑2000 air
interface standards, a guard band of up to 4 megahertz may be needed to
protect 3G and ITFS/MDS systems from interfering with each other.
However, a more modest 2 megahertz guard band could be sufficient to
protect most 3G systems.

In its comments to the *Advanced Wireless Systems NPRM*, Verizon asserts
that unacceptable interference would occur regardless of the size of the
guard band.[^106] Their analysis is based on the Commission's emission
limits for ITFS/MDS transmitters and assumes maximum out‑of‑band
emissions. Further, Cisco Systems (Cisco), states that its preliminary
analysis indicated that its existing equipment could theoretically
operate with 18 megahertz guard bands separating fixed broadband and 3G
services.[^107] Cisco notes that the design of its current equipment is
based on tradeoffs it made under the assumption that no mobile services
would be permitted in the 2500‑2690 MHz band. They acknowledge that a
narrower guard band could be accommodated through reengineering of its
equipment's channel filtering capabilities and implementing new
duplexers.[^108] Worldcom, in its comments also claims that a guard band
of 12‑18 megahertz may be needed to protect against inter‑service
interference from neighboring allocations.[^109]

Upon reviewing Verizon's analysis, we believe that their claim of
unacceptable interference regardless of guard band size is greatly
exaggerated. They assume that out‑of‑band emissions adhere exactly to
the ITFS/MDS emission mask and continue at 60 dB below the average
6 megahertz channel power level beyond 3 megahertz from the channel
edge.[^110] However, this analysis does not take into account the
behavior of the transmitted energy under real world conditions where the
energy will continue to attenuate below the 60 dB level at distances
greater than 3 megahertz beyond the band edge. While we acknowledge that
with existing equipment, a guard band may be necessary, we believe that
this situation could be necessary only for the short‑term. Even Cisco
admits that a smaller guard band than the 18 megahertz is achievable,
but that it would require some equipment redesign. We realize that such
an endeavor could take as much as a year or more to complete.[^111]
However, because mobile systems do not currently operate in the
2500‑2690 MHz band, and this band is not compatible with existing mobile
allocations, such as the PCS band at 1850‑1990 MHz, mobile radio
equipment manufacturers would also have to undertake a design effort. It
is reasonable to assume that if a decision to put 3G systems in the
2500‑2690 MHz band is made, it would take several years until the first
system is actually deployed. This should provide ample time for ITFS/MDS
equipment manufacturers to complete necessary design changes and for
service providers to begin replacing equipment. Accordingly, we believe
that our conclusion that only a 4 megahertz guard band is necessary to
prevent inter‑service interference at the allocation edges between 3G
and ITFS/MDS systems is reasonable for planning and analysis purposes.
Moreover, we believe that equipment manufacturers can adapt to designing
equipment around such a guard band in timeframes sufficient to deploy
equipment, if a portion of the 2500‑2690 MHz band is made available for
3G systems.

##### Effect of Guard Bands on Band Segmentation Options

In devising our segmentation options, one of our guiding assumptions was
that 90 megahertz of spectrum in the 2500‑2690 MHz band would have to be
made available for 3G services. Therefore, the remaining 100 megahertz
in this band would support incumbent ITFS/MDS systems, geographic MDS
systems, and the guard bands. Below, we examine, based on our analysis
concluding that 4 megahertz guard bands are sufficient, the effect that
the guard bands would have on the amount of spectrum available under
each option.

Under option 1, the spectrum available for two‑way ITFS/MDS systems
would be reduced by 12 megahertz of spectrum to accommodate three guard
bands of 4 megahertz each. Additionally, we showed that, on average,
30 megahertz of spectrum (five 6 megahertz channels) may need to be set
aside for incumbent operators. Depending on how many incumbent one‑way
systems need to be accommodated, as little as 58 megahertz or as much as
88 megahertz of spectrum would be available for two‑way ITFS/MDS
systems. Under option 2 (one guard band), the amount of spectrum
available for two‑way ITFS/MDS systems would range from 66 megahertz to
96 megahertz; and under option 3 (two guard bands), from 62 megahertz to
92 megahertz.

The segmentation options will also effect the way service providers
manage their spectrum and assign channels for specific purposes. Two‑way
ITFS/MDS systems need approximately 30 megahertz of separation between
upstream and downstream traffic to accommodate the duplexer. Under
option 1, 3G systems would use the spectrum separating the ITFS/MDS
spectrum and thus provide ITFS/MDS systems with the needed separation
between upstream and downstream traffic. This would allow the ITFS/MDS
system to operate, at some times, with almost all of the available
88 megahertz of spectrum. Options 2 and 3, however, do not allow use of
the entire available spectrum using a 30 megahertz separation; either
some portion of the spectrum would go unused or would need to employ an
alternative technology such as TDD.

##### Impact of Band Segmentation on Data Rates

In each segmentation option, the amount of spectrum available for
two‑way ITFS/MDS systems is sharply reduced from the approximately
156 megahertz that these systems have under the current allocation and
channel plan. This reduction in spectrum will effect two‑way service by
either reducing data speeds, which may in turn limit the type of service
that these systems can provide or forcing MDS providers to reduce the
coverage area of each cell to keep data rates at their current level.
The latter situation is discussed in the section below. The HMI study
lists data rates for MDS service up to 512 kbps downstream and up to
256 kbps upstream for residential service.[^112] Clearly, if the amount
of spectrum is reduced, these data rates would have to be scaled back.
To understand how such a reduction in data speeds would affect the
marketability of two‑way wireless broadband service a comparison must be
made with the services with which it will compete: digital subscriber
line (DSL) and cable modems. As an example, in Los Angeles County,
California, Pacific Bell offers standard residential and business DSL
service with speeds of between 384 kbps and 1.5 Mbps downstream and
128 kbps upstream.[^113] GTE offers DSL packages ranging from 256 kbps
to 1.5 Mbps downstream and from 64 kbps to 768 kbps upstream; with its
Bronze Plus service (768 kbps downstream and 128 kbps upstream) being
the most popular.[^114] Cable modem service in Los Angeles is offered by
a number of providers. As an example, Media One/AT&T offers service with
up to 1.5 Mbps downstream and up to 300 kbps upstream.[^115] Time Warner
also offers cable modem access with speeds ranging from 2 Mbps to
10 Mbps downstream to up to 384 kbps upstream.[^116] While we are unable
to ascertain the exact decrease in data rates that a reduction in
spectrum would have, we can make certain observations regarding its
effect on the marketability of two‑way service. It is evident that under
current or projected service offerings two‑way wireless broadband
service offers downstream data rates in the low to mid range of DSL and
at the low end of cable modem service. Upstream data rates compare very
favorably with the best rates offered for DSL and slightly below those
of cable modems. Based on these observations, it is likely that any
decrease in two‑way service data rates could reduce or eliminate that
services' ability to compete in the marketplace.

> **Impact of Band Segmentation on Cell Size**

As described above, the net effect of segmentation would be to reduce
the amount of spectrum available for ITFS and MDS operations. The
section above describes the effect such a reduction would have on data
rates. In this section we explore the effect that reduced spectrum would
have on cell size if providers, under segmentation, opted to keep data
rates at current levels. Figure 5.5 below[^117] indicates the amount of
spectrum needed per cell site to serve customers within a specified
distance from that site. As illustrated by the figure, if the total
amount of spectrum available for two‑way ITFS/MDS systems is reduced,
the cell size of the ITFS/MDS system must be reduced to continue
providing the same service. Thus, the licensee can continue operating
the site with reduced grade of service to its customers, continue
operating the site with the same grade of service but serving fewer
customers (most likely rural and underserved areas), or construct and
maintain new transmit sites to continue serving all its current
customers with the same grade of service. For example, the figure shows
that a single main transmitter operating with its full complement of
spectrum (approximately 160 megahertz)[^118] can serve a cell with a
32 mile radius.

# Figure 5.5: Cell Size As A Function of Available Spectrum

> ![](media/image11.wmf){width="5.997222222222222in"
> height="3.2944444444444443in"}

Based on Figure 5.5 and the amount of spectrum we determined would be
available for geographic MDS licensees under each segmentation option,
we present the effect each segmentation option would have on cell size
in the Tables below. Our calculations are based on an existing MDS
system using 160 megahertz (including the 10‑12 megahertz allocated in
the 2150‑2160/62 MHz band) of spectrum[^119] over a cell with a 32 mile
radius.

# Table 5.5: Effect of Segmentation Options on Cell Size for Minimum Available Spectrum

+-----+---------------+---------------+--------+-----+-------+------+
| Opt | Minimum       | Minimum Total | \% of  | C   | Cell  | \%   |
| ion | Spectrum      |               | Total  | ell |       | of   |
|     |               | Spectrum      |        |     | Area  |      |
|     | Available in  | Available     | Sp     | S   |       | Orig |
|     | the           |               | ectrum | ize | (sq.  | inal |
|     |               | (MHz)^\*^     |        |     | mi.)  |      |
|     | 2500‑2690 MHz |               | Ava    | (mi |       | Area |
|     |               |               | ilable | .)^ |       |      |
|     | Band (MHz)    |               |        | \#^ |       |      |
|     |               |               | for    |     |       |      |
|     |               |               | Use    |     |       |      |
+-----+---------------+---------------+--------+-----+-------+------+
| 1   | 58            | 70            | 43.8   | 2   | 1385  | 43.1 |
|     |               |               |        | 1.0 |       |      |
+-----+---------------+---------------+--------+-----+-------+------+
| 2   | 66            | 78            | 48.8   | 2   | 1562  | 48.6 |
|     |               |               |        | 2.3 |       |      |
+-----+---------------+---------------+--------+-----+-------+------+
| 3   | 62            | 74            | 46.3   | 2   | 1479  | 46.0 |
|     |               |               |        | 1.7 |       |      |
+-----+---------------+---------------+--------+-----+-------+------+

> ^\*^ Includes 12 megahertz from the 2150‑2162 MHz band.
>
> ^\#^ Assumes linear interpolation between curves in Figure 5.5.

# Table 5.6: Effect of Segmentation Options on Cell Size for Maximum Available Spectrum

+-----+---------------+---------------+--------+-----+-------+------+
| Opt | Maximum       | Minimum Total | \% of  | C   | Cell  | \%   |
| ion | Spectrum      |               | Total  | ell |       | of   |
|     |               | Spectrum      |        |     | Area  |      |
|     | Available in  | Available     | Sp     | S   |       | Orig |
|     | the           |               | ectrum | ize | (sq.  | inal |
|     |               | (MHz)^\*^     |        |     | mi.)  |      |
|     | 2500‑2690 MHz |               | Ava    | (mi |       | Area |
|     |               |               | ilable | .)^ |       |      |
|     | Band (MHz)    |               |        | \#^ |       |      |
|     |               |               | for    |     |       |      |
|     |               |               | Use    |     |       |      |
+-----+---------------+---------------+--------+-----+-------+------+
| 1   | 88            | 100           | 62.5   | 2   | 1963  | 61.0 |
|     |               |               |        | 5.0 |       |      |
+-----+---------------+---------------+--------+-----+-------+------+
| 2   | 96            | 108           | 67.5   | 2   | 2075  | 64.5 |
|     |               |               |        | 5.7 |       |      |
+-----+---------------+---------------+--------+-----+-------+------+
| 3   | 92            | 104           | 65.0   | 2   | 2011  | 62.5 |
|     |               |               |        | 5.3 |       |      |
+-----+---------------+---------------+--------+-----+-------+------+

> ^\*^ Includes 12 megahertz from the 2150‑2162 MHz band.
>
> ^\#^ Assumes linear interpolation between curves in Figure 5.5.

The data contained in the tables show that to maintain the same
grade‑of‑service under each segmentation, the area served by any one
transmitting site is significantly reduced. Even in the best case, cell
size is reduced by almost forty percent. Under these conditions, we
expect that a licensee could require 3‑5 transmitter sites to cover the
same geographic area as the single main transmitter.[^120] Thus, the MDS
operator either must incur the cost of building additional sites to
continue serving its current customer base or cease providing service to
customers in outlying areas. The economic impact of these choices are
examined in Section 7.

## MIGRATION SCHEDULE

A number of factors would influence the amount of time needed to
implement any of the segmentation options studied. First, as discussed
above, some incumbent one‑way systems would need time to convert from
analog to digital modulation. The use of more spectrally efficient
technology for these types of systems would provide maximum spectrum for
introducing two‑way ITFS/MDS systems in the band. Second, implementation
of any of the segmentation options would require manufacturers to
reengineer planned two‑way systems for operation using reduced spectrum
in the band. Manufacturers and ITFS/MDS operators would have to
reconfigure network design and deploy new equipment. Cisco estimates
that it would need a year or more to complete and test fully new
equipment for use in band if segmentation were implemented.[^121] Cisco
states that it would need to revisit the entire design and manufacture
cycle; redesign both hardware and software; revisit component supply
chains and partner agreements; duplicate lab and field trials; and
reinitialize manufacturing plants.[^122] The introduction of guardbands
also would require equipment modifications. Cisco states that it would
have to reengineer channel filtering technology to achieve more robust
adjacent channel rejection, design new duplexers to accommodate
different transmit and receive capabilities, and assume new reuse and
deployment patterns.[^123]

Given the complex interference environment already present in the
2500‑2690 MHz band, accommodating additional ITFS/MDS operations in only
certain portions of the band will take considerable time and effort if
such an approach is undertaken. Both site‑specific one‑way and two‑way
systems and wide‑area two‑way systems will have to be coordinated.
Furthermore, in any geographic area, adjacent channel use by wide‑area
3G systems also will need to be coordinated.

Because of the localized nature of sharing and leasing agreements
between geographic MDS licensees and incumbent ITFS and MDS licensees,
migration schedules will likely be different for each area. Also,
because all channels in the 2500‑2690 MHz band are licensed in or near
the top 50 metropolitan areas,[^124] the relocation of any specific
station will need to be closely coordinated with all other nearby
stations. And migration may not be able to occur until the equipment
needed for two‑way systems is redesigned, tested, and available to
licensees. Although it may be possible for some incumbent ITFS and MDS
systems to relocate within band by 2003, large‑scale band reorganization
may be necessary before all incumbent systems, two‑way systems, and 3G
systems could operate under band segmentation. Thus, accommodation of
all systems would not likely occur until 2010 or beyond.

## SUMMARY

Based on our analysis of various segmentation options for the
2500--2690 MHz band, we find that the conclusions made in the Interim
Report remain valid. Any segmentation option would need to take into
account the flexible service configurations and offerings that ITFS and
MDS licensees are now implementing. Further, the number of guard bands
affects the impact that band segmentation has on spectrum available for
ITFS/MDS operations. While Option 2, with only one guard band, provides
the most spectrum for ITFS/MDS operations, it may require more equipment
redesign than Option 1 where 3G systems and ITFS/MDS systems are
interspersed. Additionally, under any of the options a substantial
number of licensees would need to be accommodated. Also, if segmentation
is pursued, ITFS/MDS service providers may need to reduce their service
areas and services to customers in outlying areas or add more
transmitter sites to maintain services. Finally, because of the complex
licensing scheme present in this band (*e.g.,* the mix of site‑specific
and wide‑area licensing, channel swaps, and lease agreements), we cannot
describe uniform impacts for each of the segmentation options studied.
To fully understand the implications of any segmentation plan on the
ITFS/MDS, one would need to analyze each geographic area individually.

## 

## 

## 

## 

## 

## 

## 

## 

## 

## 

## 

##  

## SECTION 6

## IDENTIFICATION AND ANALYSIS OF POTENTIAL

## ALTERNATE FREQUENCY BANDS FOR ITFS/MDS

The Study Plan calls for the identification of alternate frequency bands
for incumbent users of the candidate bands being studied for possible 3G
system use. The Study Plan sets forth certain criteria for identifying
alternate frequency bands: (1) consideration should first be given to
those bands in which no, or minimum, disruption would occur to the
incumbents of the identified alternate bands; and (2) potential
alternate bands should afford candidate band incumbent systems that may
require replacement spectrum the capability to function without loss of
functionality or necessary interoperability in the alternate band(s).

The Study Plan also states that any study of alternate bands will
describe the alternate band(s) as to: (1) existing rules and regulations
that govern the use of the bands; (2) the changes in allocation rules
and regulations that would be necessary to make them acceptable to the
candidate band incumbent users; (3) the relocation of alternate band
incumbents if necessary; (4) the operational constraints on the
alternate band incumbents or on the candidate band systems; and (5) any
other considerations, including national security and public safety, in
the use of the alternate bands that would have a negative effect on
candidate band incumbent users.

This section identifies and analyzes potential alternate frequency bands
that could be used by ITFS/MDS systems if spectrum in the 2500‑2690 MHz
band were reallocated for use by 3G systems. The analysis states the
assumptions made, identifies potential alternate frequency bands, and
analyzes the bands in accordance with the Study Plan criteria listed
above.

## ASSUMPTIONS

For purposes of this study, we have made certain assumptions in
identifying potential alternate frequency bands for ITFS/MDS systems.
These assumptions are as follows:

-   Relocation of ITFS and MDS systems would likely be based on policies
    similar to those established in the *Emerging Technologies*
    proceeding), which allow new entrants to provide incumbents with
    comparable facilities using any acceptable technology, and some
    services could be relocated from spectrum‑based networks to
    wireline‑based networks.[^125] For purposes of this study, we assume
    that all ITFS/MDS operations would continue as spectrum‑based
    networks.

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-   ITFS/MDS is in a state of rapid evolution to offer high‑speed,
    two‑way access to the Internet. We assume that any relocation would
    minimize any loss of functionality to ITFS and MDS licensees of
    analog and digital one‑way and two‑way services, which are provided
    on a wide‑area, ubiquitous basis in both urban and rural areas, and
    would allow for future deployment of two‑way systems.

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```
-   ITFS and MDS operations would not be relocated to separate frequency
    bands. The two services currently have extensive and complex channel
    leasing arrangements that provide benefits for education, businesses
    and consumers. Separation of these operations would have extensive
    policy ramifications beyond the scope of this study. It is not clear
    that either service would be viable if they were separated into
    different frequency bands, even if this were technically possible.

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```
-   Alternate frequency bands would need to provide at a minimum
    90 megahertz of contiguous spectrum for ITFS/MDS to replace the
    90 megahertz of spectrum in the 2500‑2690 MHz band that would be
    made available for 3G use under the segmentation analysis of this
    study.

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```
-   Alternate frequency bands may need to provide for the relocation of
    the entire 202 megahertz of spectrum currently occupied by ITFS/MDS
    to assure the continued functionality of ITFS and MDS that is one of
    the criteria for the Study Plan***.***[^126] The actual amount of
    spectrum needed to relocate ITFS/MDS could be affected by other
    factors that were not taken into account here. For example, it may
    be necessary to provide a greater amount of spectrum at higher
    frequencies to offset the impact of increased propagation losses.

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```
-   When considering relocation bands, first preference is for the
    ITFS/MDS operation (incumbents A) to be compatible with existing
    operations in the alternate bands and not displace any existing
    operations in the alternate bands. However, if the incumbents in the
    alternate band (incumbents B) have to be relocated to another band,
    incumbents B cannot displace any other existing operations in which
    they are relocated. We assume that more than one relocation move is
    too disruptive to existing operations and therefore we have not
    explored such possibilities in this study.

Based on these assumptions, we identified the frequency bands listed in
Table 6.1 for further analysis as potential alternate frequency bands
for ITFS/MDS. These are bands that are already allocated for Fixed
Services and that could satisfy the amount of spectrum assumed for our
analysis.

## Table 6.1: Bands for Further Assessment

+-----------------------------------------------------------------------+
| #### Frequency Band Size Allocation Radio Services                    |
|                                                                       |
| (MHz)                                                                 |
|                                                                       |
| 3700‑4200 MHz 500 NG Fixed, Fixed‑Satellite (space‑Earth)             |
|                                                                       |
| 5925‑6425 MHz 500 NG Fixed, Fixed‑Satellite (Earth‑space)             |
|                                                                       |
| 6425‑7125 MHz                                                         |
|                                                                       |
| 6425‑6525 100 NG Fixed‑Satellite (Earth‑space), Mobile                |
|                                                                       |
| 6525‑6875 350 NG Fixed, Fixed‑Satellite (Earth‑space)                 |
|                                                                       |
| 6875‑7075 200 NG Fixed, Fixed‑Satellite (Earth‑space), Mobile         |
|                                                                       |
| 7075‑7125 50 NG Fixed, Mobile                                         |
|                                                                       |
| 7125‑8500 MHz Federal Government "Fixed Band"                         |
|                                                                       |
| 10.7‑13.25 GHz                                                        |
|                                                                       |
| 10.7‑11.7 1000 NG Fixed, Fixed‑Satellite (space‑Earth)                |
|                                                                       |
| 11.7‑12.2 500 NG Fixed‑Satellite (space‑Earth)                        |
|                                                                       |
| 12.2‑12.7 500 NG Fixed, Broadcasting‑Satellite                        |
|                                                                       |
| 12.7‑13.25 550 NG Fixed, Fixed‑Satellite (Earth‑space), Mobile        |
|                                                                       |
| G = Federal Government NG = Non‑Federal Government                    |
+-----------------------------------------------------------------------+

ASSESSMENT OF THE BANDS 3700--4200 MHz and 5925--6425 MHz

**Allocation Description**

The bands 3700‑4200 MHz and 5925‑6425 MHz (500 megahertz each) are
allocated on a primary basis to the non‑Federal Government for the fixed
service (FS) and fixed‑satellite service (FSS). An excerpt from the
Table of Frequency Allocations for this portion of the spectrum is
provided below in Table 6.2.[^127] The applicable service definitions
and associated footnotes for this portion of the Table are provided in
Appendix 6.2 and 6.3 respectively. These bands are paired for
fixed‑satellite purposes, and collectively are known as the "C‑band."
For FSS, the band 3700‑4200 MHz supports space‑to‑Earth (downlink)
operations and the band 5925‑6425 MHz supports Earth‑to‑space (uplink)
operations. These bands may also be used by stations in the
international fixed public and international control services for
operations located in the U.S. Possessions in the Caribbean area.

**Table 6.2: Table of Frequency Allocations for
3700‑4200/5925‑6425 MHz**

**(See Appendix 6.3 for footnote text.)**

+--------------------+---------------------------+---------------------+
| Federal Government | Non‑Federal Government    | FCC Rule Part(s)    |
+--------------------+---------------------------+---------------------+
| 3700‑4200          | 3700‑4200                 | International Fixed |
|                    |                           | (23)                |
|                    | FIXED NG41                |                     |
|                    |                           | Satellite           |
|                    | FIXED‑SATELLITE           |                     |
|                    |                           | Communications (25) |
|                    | (space‑to‑Earth)          |                     |
|                    |                           | Fixed Microwave     |
|                    |                           | (101)               |
+--------------------+---------------------------+---------------------+

**5925‑6425 MHz**

+--------------------+--------------------------+----------------------+
| Federal Government | Non‑Federal Government   | FCC Rule Part(s)     |
+--------------------+--------------------------+----------------------+
| 5925‑6425          | 5925‑6425                | International Fixed  |
|                    |                          | (23)                 |
|                    | FIXED NG41               |                      |
|                    |                          | Satellite            |
|                    | FIXED‑SATELLITE          |                      |
|                    |                          | Communications (25)  |
|                    | (Earth‑to‑space)         |                      |
|                    |                          | Fixed Microwave      |
|                    |                          | (101)                |
+--------------------+--------------------------+----------------------+

**Description of Current and Planned Band Use
(3700‑4200/5925‑6425 MHz)**

The bands 3700‑4200 and 5925‑6425 MHz are heavily used by both the
fixed‑satellite service (FSS) and the terrestrial fixed service (FS).
The FCC rules and regulations for fixed‑satellite and fixed services are
contained in 47 C.F.R. Parts 23, 25, and 101.

C‑band fixed‑satellite systems provide private and commercial
communication links for various businesses and industries, feeds to
terrestrial television and radio broadcast networks and to cable
headends, programming directly to customers with home satellite
receivers[^128] and tracking, telemetry, and control (TT&C) operations
for U.S. and non‑U.S. satellites. C‑band satellites are being used to
provide two‑way, broadband data backbone and services via satellite.).
Currently, there are 35 U.S. licensed geo‑stationary (GSO) satellites
providing international and/or domestic service to the United States in
the C‑band. More than 15 additional satellites are planned to operate in
conjunction with the existing satellites and eventually replace the
currently operating satellites once they reach their end of life. The
satellites are generally spaced at orbital separations of two degrees
around the GSO. A typical C‑band transponder uses 36 megahertz
bandwidths. Transponder loading depends on the type of service offered
over the transponder (*i.e.,* few video channels versus hundreds of low
data rate channels can be offered over one transponder).

There are approximately 13,500 registered earth station antennas within
the United States and its possessions that operate through the C‑band
fixed‑satellites. Further, we estimate that there are tens of thousands
of unregistered receive‑only earth stations in the C‑band used by the
general public for direct‑to‑home (DTH) video programming reception.
Registered earth stations cover the entire country but are concentrated
more heavily in urban areas.[^129] (*See* map in Appendix 6.4) There is
no information on the geographical distribution of the unregistered
earth stations, but historically they have been used in all areas of the
country. In particular, they are used in rural areas where conventional
broadcasting was not available and the potential to receive interference
from other licensed users is relatively lower than in urban areas. The
Commission has proposed to streamline its earth station application
filing requirements to facilitate blanket authorization of satellite
data terminals in the C‑Band (with appropriate coordination and
reporting requirements).

The 3700‑4200 and 5925‑6425 MHz bands also support a number of fixed
point‑to‑point operations. These bands provide "backbone" and
"long‑haul" operations for common‑carrier and private business,
industry, utilities and public safety communications networks.[^130]
There are currently over 11,000 point‑to‑point links in the
3700‑4200 MHz band, and over 38,500 point‑to‑point links in the
5925‑6425 MHz band. For the 3700‑4200 MHz, the average path length is
43 km (26.7 miles) and, for the 5925‑6425 MHz, the average path length
is 39 km (24.2 miles). The current fixed, point‑to‑point channeling plan
for the band 3700‑4200 MHz provides for paired 20 megahertz channels
with 40 megahertz separation between the transmit and receive channels.
However, there are a number of grandfathered systems in this band with
different channel bandwidths and separations. The current fixed
point‑to‑point channeling plan for the band 5925‑6425 MHz provides for a
varied bandwidths from 0.4 to 30 megahertz channels with 250 megahertz
separation between the transmit and receive channels. Both the channel
loading and the geographical distributions of the point‑to‑point
facilities in these bands are fairly uniform across the band and across
the country, respectively. *See* the maps in Appendix 6.4.

Recently, the fixed service community has expressed concern that the
proliferation of satellite earth stations in the C‑Band is freezing any
future growth of fixed operations in this range.[^131] The problem is
worse in the 3700‑4200 MHz portion due to the protection of video
distribution operations to cable head ends and television stations. The
5925‑6425 MHz portion is also impacted and the problem of coordinating
with new fixed operations.

Finally, we note that while there are no Federal Government services
allocated in these bands, the band 5925‑6425 MHz is used by Federal
Government agencies (*e.g.*, USIA, FAA, and Navy) for FSS operations.
These operations are on a case by case, coordinated basis to operate
earth stations that transmit voice, data, video signals through the
non‑Federal Government GSO satellite systems. Additionally, there are
several Federal Government operations in both bands that operate on a
non‑interference basis. Specifically, NASA operates downlink telemetry,
on a non‑interference basis, during launch and emergencies in support of
the NASA Advanced Communications Technology Satellite Space Program.
Further, various Federal Government agencies also operate test stations
of radiolocation systems on a non‑interference basis.

**Assessment for ITFS/MDS Operations (3700‑4200/5925‑6425 MHz)**

These bands are closest to the current ITFS/MDS bands among those
considered for relocation. These bands appear to hold the least
technical impact for the viability of ITFS/MDS operations. Signal
propagation losses would increase somewhat, but the effect would not be
as significant as higher bands.[^132] The cost and availability of
electronic components and antennas may also increase somewhat, but would
benefit from the extensive development that has already occurred for
this band.

With regard to the sharing between ITFS/MDS and the FSS downlink band
3700‑4200 MHz, satellite earth stations would be susceptible to
receiving harmful interference from ITFS/MDS transmitters, and highly
susceptible to receiving interference from subscriber based ITFS/MDS
transmitters deployed for two‑way service. Interference could occur if
an ITFS/MDS transmitter were located within approximately 200 km
(124 miles) of a receiving satellite earth station.

With regard to the sharing in the FSS uplink band 5925‑6425 MHz, because
ITFS/MDS are ubiquitous wide‑area systems with broad‑beam and
omnidirectional antennas and deployed ubiquitously, the ITFS/MDS system
would be highly susceptible to receiving harmful interference from
thousands of earth stations currently operating in this frequency band.
Sharing between these services on a geographic basis does not appear
feasible because they are both effectively ubiquitous. *See* the map in
Appendix 6.4.

Segmenting either of these frequency bands to accommodate ITFS/MDS does
not appear feasible. Satellites are designed to make use of the entire
500 megahertz of spectrum in both the downlink and uplink bands. Any
reduction in spectrum would have a severe impact on existing satellite
operations. There are no frequency bands where C‑band satellite
operations might be reaccommodated.

Neither sharing nor segmentation appears feasible relative to existing
fixed operations. This problem is exacerbated by the fact that this
spectrum was identified for relocation of existing fixed operations in
the 2 GHz region to accommodate personal communications services and
other emerging technologies as laid out in ET Docket 92‑9.[^133] (*See*
the maps in Appendix 6.5.). Higher frequency bands that are available
for fixed operations are also becoming increasingly congested.

**Summary (3700‑4200/5925‑6425 MHz)**

Our analyses indicate that ITFS/MDS operations could not share with the
existing operations in the bands 3700‑4200 MHz and 5925‑6425 MHz. As
demonstrated above, both the FSS and FS heavily use these bands. The
wide‑area, ubiquitous coverage characteristics of ITFS and MDS are not
compatible with either fixed point‑to‑point or fixed‑satellite
operations in any geographic area. Segmenting either band to accommodate
ITFS/MDS operations also does not appear viable because this could not
be accomplished without significant harm to current and future uses of
the FSS and FS. Therefore, reallocation of spectrum to accommodate
ITFS/MDS does not appear feasible for either the 3700‑4200 MHz or the
5925‑6425 MHz band.

# 

**ASSESSMENT OF BAND 6425 -- 7125 MHz**

**Allocation Description**

The 6425‑7125 MHz band is allocated on an exclusive basis to the
non‑Federal Government and consists of four bands. An excerpt from the
Table of Frequency Allocations for this portion of the spectrum is
provided below in Table 6.3.[^134] The applicable service definitions
and associated footnotes for this portion of the Table are provided in
Appendices 6.2 and 6.3, respectively. The band 6425‑6525 MHz
(100 megahertz) is allocated on a primary basis to the fixed‑satellite
and mobile services. The band 6525‑6875 MHz (350 megahertz) is allocated
on a primary basis to the fixed and fixed‑satellite services. The band
6875‑7075 MHz (200 megahertz) is allocated on a primary basis to the
fixed, fixed‑satellite, and mobile services. The band 7075‑7125 MHz
(50 megahertz) is allocated on a primary basis to the fixed and mobile
services. In the band 6875‑7125 MHz, television translator relay station
licensees may be authorized to use frequencies on a secondary basis to
other stations in the television broadcast auxiliary service.

**Table 6.3: Table of Frequency Allocations for 6425‑7125 MHz**

**(See Appendix 6.3 for footnote text.)**

+--------------------+--------------------------+----------------------+
| Federal Government | Non‑Federal Government   | FCC Rule Part(s)     |
+--------------------+--------------------------+----------------------+
| 6425‑6525          | 6425‑6525                | Auxiliary            |
|                    |                          | Broadcasting (74)    |
| S5.440 S5.458      | FIXED‑SATELLITE          |                      |
|                    |                          | Cable TV Relay (78)  |
|                    | (Earth‑to‑space)         |                      |
|                    |                          | Fixed Microwave      |
|                    | MOBILE                   | (101)                |
|                    |                          |                      |
|                    | S5.440 S5.458            |                      |
+--------------------+--------------------------+----------------------+
| 6525‑6875          | 6525‑6875                | Satellite            |
|                    |                          |                      |
| S5.458             | FIXED                    | Communications (25)  |
|                    |                          |                      |
|                    | FIXED‑SATELLITE          | Fixed Microwave      |
|                    |                          | (101)                |
|                    | (Earth‑to‑space) 792A    |                      |
|                    |                          |                      |
|                    | S5.458                   |                      |
+--------------------+--------------------------+----------------------+
| 6875‑7125          | 6875‑7075                | Auxiliary            |
|                    |                          | Broadcasting (74)    |
|                    | FIXED                    |                      |
|                    |                          | Cable TV Relay (78)  |
|                    | FIXED‑SATELLITE          |                      |
|                    |                          |                      |
|                    | (Earth‑to‑space) 792A    |                      |
|                    |                          |                      |
|                    | MOBILE                   |                      |
|                    |                          |                      |
|                    | S5.458 NG118             |                      |
+--------------------+--------------------------+----------------------+
| S5.458             | 7075‑7125                |                      |
|                    |                          |                      |
|                    | FIXED                    |                      |
|                    |                          |                      |
|                    | MOBILE                   |                      |
|                    |                          |                      |
|                    | S5.458 NG118             |                      |
+--------------------+--------------------------+----------------------+

**Description of Current and Planned Band Use (6425 -- 7125 MHz)**

The 6425‑7125 MHz spectrum is used by the fixed‑satellite, fixed,
broadcast auxiliary, and mobile services. We will evaluate each of these
bands below to determine the viability of ITFS/MDS operations in this
range. For the purposes of analysis of assignments, we have divided the
band into three separate portions: 6425‑6525, 6525‑6875, and
6875‑7125 MHz. (*See* Table 6.4:Band Usage 6425‑7125 MHz.) Each is
discussed below.

*[6425‑6525 MHz portion]{.underline}*. As indicated above, the band
6425‑6525 MHz (100 megahertz) is allocated to FSS and mobile services.
In addition to providing uplinks for the FSS, licensed under Part 25 of
the Commission's Rules, this band is used primarily for television
related services. Currently, it supports remote pickup in the broadcast
auxiliary service (BAS), licensed under Part 74 of the Commission's
Rules. BAS offers service to television broadcast stations, television
network entities, cable system operators, and cable network entities via
common carrier providers in the local television transmission services
(LTTS) licensed under Part 101 of the Commission's Rules. The band also
accommodates mobile operations in the cable antenna relay services
(CARS), licensed under Part 78 of the Commission's Rules.

There are currently 304 broadcast auxiliary links, 33 cable relay links,
and 501 temporary fixed links for local television transmissions in the
6425‑6525 MHz band. This band also contains 16 fixed point‑to‑point
microwave links. The Earth‑to‑space (uplinks) configuration supports 522
links associated with licensed earth stations and an unknown number of
unregistered receive only earth stations. The Commission's Rules allow
BAS and LTTS bandwidths of 1, 8, or 25 megahertz, while CARS may employ
bandwidths of 25 megahertz. The fixed rules provide for operations of 1,
8, or 25 megahertz bandwidths with 50 megahertz separation between
transmit and receive channels. Both the channel loading and the
geographical distributions of licensed links in this band are shown in
maps in Appendix 6.4.

*[6525‑6875 MHz portion]{.underline}*. As mentioned above, the band
6525‑6875 MHz (350 megahertz) is allocated to the FSS and FS, licensed
respectively under Parts 25 and 101 of the Commission's Rules. The band
6525‑6875 MHz supports general‑purpose fixed microwave FS operations for
a variety of public and private entities, such as, non‑Federal
Government, industrial, common carrier, and transportation licensees.
For the FS, the average path link is 32 km (19.9 miles). The channeling
plan provides for varied bandwidths from 0.4 to 10 megahertz channels
with 250 megahertz separation between transmit and receive channels. In
addition to the FS operations, the band 6525‑6875 MHz (extending through
to 7075 MHz) also provides feeder uplinks (Earth‑to‑space) including
tracking, telemetry, and control of satellites, for \"Big LEO\" and
digital audio radio services (DARS) satellites.

The band 6525‑6875 MHz currently supports 4 U.S. licensed geo‑stationary
(GSO) satellites and 6 feeder links associated with U.S. licensed
non‑geo‑stationary (NGSO) satellites. Moreover, the band supports fixed
microwave operations with over 25,000 point‑to‑point links. Both the
channel loading and the geographical distributions of the point‑to‑point
facilities in this band are fairly uniform across the band and across
the country, respectively. *See* the map in Appendix 6.4. Additionally,
the band 6525‑6875 MHz was identified in 1993 in the Emerging
Technologies proceeding as a future home for fixed point‑to‑point
operations to be relocated from the 2 GHz band.[^135] (*See* the maps in
Appendix 6.5.) The band 6700‑7075 MHz also is the subject of a proposal
to add feeder downlinks for NSGO satellites in support of mobile
satellite service (MSS) satellites ("Big LEOs").[^136] The frequency
6427 MHz (along with 4202 MHz) is available, but unused, for two‑way
satellite time signal communications.

*[6875‑7125 MHz portion]{.underline}*. The band 6875‑7125 MHz
(250 megahertz) is allocated to the fixed and mobile services, and
200 megahertz of this band, *i.e.,* 6875‑7075 MHz, is shared on a
co‑primary basis with the fixed‑satellite service. At present the band
6875‑7075 MHz supports approximately 120 uplinks for the FSS. The
6875‑7125 MHz provides for television related services similar to the
mobile band 6425‑6525 MHz discussed above, but on both a fixed and
mobile basis. For the 6875‑7125 MHz band, there are currently
approximately 6,000 fixed links and 1,700 mobile operations licensed for
the BAS. This band also supports about 10 fixed and 9 mobile links for
CARS, and approximately 27 temporary fixed and 250 mobile links for
LTTS. The bandwidths for one‑way, fixed BAS operations are 16, 17, or
25 megahertz channels. The average path length is 42 km (26.1 miles).
The bandwidth for BAS mobile operations is 25 megahertz. The CARS use
bandwidths of 12.5 or 25 megahertz for fixed and 25 megahertz for mobile
operations, and the average path length for fixed links is 40 km
(24.9 miles). The LTTS uses bandwidths of 16, 17, or 25 megahertz for
both fixed and mobile operations. The channel loading and the
geographical distributions of licensed links in this band are shown in
maps in Appendix 6.4.

> **Table 6.4: Band Usage 6425‑7125 MHz**

+-------------+-----------------+--------+--------------+-------------+
| FSS         | FSS (uplink)    |        |              |             |
|             |                 |        |              |             |
| (uplink)    |                 |        |              |             |
+-------------+-----------------+--------+--------------+-------------+
|             |                 | Pr     |              |             |
|             |                 | oposed |              |             |
|             |                 | FSS    |              |             |
|             |                 |        |              |             |
|             |                 | (NGSO  |              |             |
|             |                 | MSS    |              |             |
|             |                 | down   |              |             |
|             |                 | links) |              |             |
+-------------+-----------------+--------+--------------+-------------+
| MOBILE      | FIXED           |        | FIXED/MOBILE |             |
|             |                 |        |              |             |
| BAS, CARS,  | Point‑to‑Point  |        | Po           |             |
|             |                 |        | int‑to‑Point |             |
| LTTS        | Microwave       |        |              |             |
|             |                 |        | Microwave    |             |
|             |                 |        |              |             |
|             |                 |        | BAS, CARS,   |             |
|             |                 |        | LTTS         |             |
+-------------+-----------------+--------+--------------+-------------+
|             |                 |        | Secondary TV |             |
|             |                 |        |              |             |
|             |                 |        | Translators  |             |
+-------------+-----------------+--------+--------------+-------------+
| Federal     |                 |        |              |             |
| Agency      |                 |        |              |             |
| Testing     |                 |        |              |             |
|             |                 |        |              |             |
| NASA        |                 |        |              |             |
| passive     |                 |        |              |             |
| microwave   |                 |        |              |             |
| sensor      |                 |        |              |             |
| m           |                 |        |              |             |
| easurements |                 |        |              |             |
| over oceans |                 |        |              |             |
|             |                 |        |              |             |
| Radio       |                 |        |              |             |
| astronomy   |                 |        |              |             |
| spectral    |                 |        |              |             |
| line        |                 |        |              |             |
| o           |                 |        |              |             |
| bservations |                 |        |              |             |
| (66         |                 |        |              |             |
| 68.518 MHz) |                 |        |              |             |
+-------------+-----------------+--------+--------------+-------------+

> \| \| \| \| \| \|
>
> 6425 6525 6700 6875 7075 7125

**Assessment for ITFS/MDS Operations (6425 -- 7125 MHz)**

The technical characteristics of this band would be somewhat more
challenging for ITFS/MDS, but would not be insurmountable. However,
because ITFS and MDS use is ubiquitous in nature, these services will
not be able to share with the current users of the band. The mobile and
fixed operations of BAS, CARS, and LTTS would pose particular problems
to the bands 6425‑6525 and 6875‑7125 MHz, as well as the extensive
deployment of fixed point‑to‑point operations in the band 6525‑6875 MHz.
Therefore, to provide for ITFS/MDS, 202 megahertz of spectrum will have
to be cleared by relocating or segmenting all of the incumbent users in
that spectrum.

*[6425‑6525 MHz (100 megahertz)]{.underline}* Reaccommodating ITFS/MDS
in the 6425‑6525 MHz band is impractical due to the international nature
of fixed‑satellites and operational characteristics of mobile services.
As discussed in Section 4 above, sharing between ITFS/MDS and mobile
operations in the same geographic area is not feasible. ITFS/MDS are
ubiquitous wide‑area systems with broad‑beam and omnidirectional
antennas. As mentioned above, there are over 800 licensed stations with
an unknown number of mobile units that could operate anywhere. Because
the incumbent mobile services could be dispersed throughout the country
and ITFS/MDS cannot coordinate with these incumbent operations to avoid
interference, sharing between ITFS/MDS and mobile service is not
feasible. Additionally, sharing between ITFS/MDS and FSS is also
impractical. Because the band 6425‑6525 MHz supports over 500 uplink
facilities for the FSS, ITFS/MDS stations would receive interference
from these earth stations if located within approximately 200 km
(124 miles) of each other. Again, due to the wide‑area deployment of
ITFS/MDS throughout the country sharing with FSS does not appear to be
feasible. With regard to segmentation of the band, we note that this
band would only provide 100 megahertz of the 202 megahertz that may be
needed to accommodate the ITFS/MDS service. Therefore, we conclude that
if ITFS/MDS were to be relocated into the band 6425‑6525 MHz, the
incumbent FSS and mobile operations would have to be relocated to other
bands and an additional 102 megahertz of nearby spectrum would need to
be found.

*[6525‑6875 MHz (350 megahertz)]{.underline}* Relocating ITFS/MDS into
the band 6525‑6875 MHz would be extremely difficult due to the very
extensive use of this band by fixed point‑to‑point microwave services
(over 25,000 licensed links). As shown in the other band assessments,
sharing between ITFS/MDS and the fixed service is not practical in most
situations.[^137] While it may be possible for co‑channel sharing in
remote areas, most fixed, point‑to‑point microwave operations in this
band are located in areas where ITFS/MDS operations will operate.
Additionally, this band also is allocated to the FSS. Although this band
currently is lightly used for FSS (6 feeder links), half the band
(175 megahertz) is the subject of current examination to permit feeder
downlinks for MSS NSGO satellites (Big LEOs).[^138] Again we note that
sharing between ITFS/MDS and FSS incumbents is impractical due to
technical characteristics of ITFS/MDS operations, which provide
ubiquitous wide‑area systems using broad‑beam and omnidirectional
antennas. Therefore, sharing is not possible and if ITFS/MDS were to be
accommodated in this band, the incumbent services would have to be
relocated into the remaining spectrum or to higher frequency bands.
Segmentation of the band 6525‑6875 MHz for ITFS/MDS would also be
difficult due to the paired nature of satellite operations in the band
and the congestion that already exists in this band.

*[6875‑7125 MHz (250 megahertz)]{.underline}* Accommodation of ITFS/MDS
into this band would create severe disruption to the incumbent services.
As noted above, the 6875‑7125 MHz band is heavily used by fixed and
mobile services, and by the fixed‑satellite service particularly for
feeder links. The band 6875‑7125 MHz is used extensively for both fixed
(over 6,000 links) and mobile operations (almost 2,000 licenses) to
support television and cable stations. As shown previously, sharing
between ITFS/MDS and fixed and mobile operations are not feasible in the
same geographic area. Additionally, a portion of this band 6875‑7075 MHz
(200 megahertz) is shared with the FSS. Again we note that this band is
the subject of a proceeding to permit feeder downlinks for MSS NSGO
satellites (Big LEOs),[^139] and that sharing between ITFS/MDS and FSS
impractical. Segmentation of the band also is not feasible due to the
heavy use by fixed and mobile operations that would have to be
accommodated within the remaining 48 megahertz of spectrum.

*[Other matters]{.underline}*. In addition to the points discussed
above, while there are no Federal Government services allocated in this
band, there are several Federal Government operations that operate on a
non‑interference basis. Specifically, NASA operates downlink telemetry,
on a non‑interference basis, during launch and emergencies in support of
the NASA Advanced Communications Technology Satellite Space Program.
Further, various Federal Government agencies also operate test stations
of radiolocation systems on a non‑interference basis. For radio
astronomy, the frequency 6668.518 MHz is an important tracer of star
formation activity.

**Summary (6425 -- 7125 MHz)**

As discussed above, the propagation characteristics and technical
considerations start to affect the design of the incumbent system as
frequency increases. While the 6‑7 GHz range could technically
accommodate ITFS/MDS operations, the impact on coverage and equipment
design begins to be more complicated at higher frequency ranges.
Moreover, we have determined from the above investigation that ITFS/MDS
operations would not be compatible with incumbent FS, FSS, and mobile
operations. ITFS and MDS are two‑way, point‑to‑multipoint operations
that are designed to provide ubiquitous coverage over a wide area. Such
operations would not be capable of sharing with either fixed
point‑to‑point or fixed‑satellite operations in any geographic area. As
discussed above, sharing between ITFS/MDS and mobile operations in the
same geographic area also is not practical. Because the incumbent mobile
services could be dispersed throughout the country and ITFS/MDS cannot
coordinate with these incumbent operations to avoid interference,
sharing between ITFS/MDS and mobile service is not feasible. Our
analysis indicate that both of these bands are extensively used by
fixed‑satellite, fixed and mobile operations across the United States
with concentrations in populated areas where ITFS and MDS deployment is
desired and likely. Therefore, sharing between ITFS/MDS and the
incumbent services in the 6425‑7125 MHz spectrum range is not possible.

As indicated above, if ITFS/MDS was to be relocated into the
6425‑7125 MHz range, perhaps 202 megahertz of spectrum would have to be
cleared by segmentation and reaccommodation of the incumbent users to
higher frequency bands. However, our investigations indicate that
removing any significant amount of spectrum to accommodate ITFS/MDS
would have a significant impact to the incumbent fixed and mobile
services due to their extremely heavy use. Relocation of the satellite
links to other spectrum would also be extremely disruptive, would take
several years, and be extremely costly due to the need to construct new
satellites and replace earth stations that are extensively deployed.
While relocation of terrestrial fixed and mobile operations could be
done in shorter time and at lesser costs, identification of alternative
spectrum would be extremely difficult as discussed above. Accordingly,
relocating ITFS/MDS systems into the 6425‑7125 MHz would significantly
impact the incumbent fixed‑satellite, fixed and mobile operations in
this frequency band.

ASSESSMENT OF THE BAND 7125 -- 8500 MHz

The band 7125‑8500 MHz is currently restricted exclusively for Federal
Government operations and is allocated on a primary basis to the fixed,
fixed‑satellite and other services. This spectrum is included in this
report because it has technical and propagation characteristics that
potentially could accommodate ITFS/MDS similar to the bands 5925‑6425
and 6425‑7125 MHz described above. However, because these bands are
allocated for exclusive Federal Government use and because the
Commission only has limited information about their loading, this will
be a cursory review of this spectrum.

This spectrum is divided into 13 bands and each band is shared with one
or more other Federal Government services. The other Federal Government
allocations and uses in this spectrum include space research,
mobile‑satellite, meteorological‑satellite, and Earth
exploration‑satellite. Many Federal Government agencies use this
spectrum for fixed, point‑to‑point microwave links, including
"long‑haul" and "backbone" systems, for their internal communication.
The NTIA's March 2000 Report on "Spectrum Usage for the fixed services"
indicates that there are 8226 Federal Government fixed assignments
listed in the Government's master frequency (GMF) file in this
band.[^140] The largest listing of fixed assignments is held by the
Federal Aviation Administration (FAA), which has over 4,000 assignments
in a nationwide network to support air traffic control with
communications and radar data from remote sites. The Department of
Defense (DoD) agencies have about 2,000 fixed assignments to support
their voice and data networks, and the Department of Energy (DoE) has
1,200 fixed assignments used for system control and data acquisition
(SCADA) for electric power distribution networks.

With regard to FSS operations in the 7125‑8500 MHz spectrum, the DoD
uses portions of this spectrum for military satellite communications,
such as the Defense Satellite Communications Systems (DSCS) for voice
and data communications including NATO communication requirements. The
FAA also uses this spectrum for the FSS Radio Communication Link (RCL)
network connecting air traffic and radar sites. Other uses include deep
space communications, such as the NASA's Mars Pathfinder program in the
7190‑7235 MHz (uplink) and 8400‑8450 MHz (downlink) bands. The band
7450‑7550 MHz is used by the meteorological‑satellite service to
downlink weather data. Further, the band 8025‑8400 GHz is allocated for
earth exploration‑satellite service and is used for land remote sensing
to deliver images and some satellite telemetry and control.

This description attempts to note some of the major uses of the band
7125‑8500 MHz; however, it is neither exhaustive nor complete.
Specifically no attempt has been made to investigate incumbent use other
than the fixed operations or numbers of assignments within this
spectrum. Nevertheless, this cursory review indicates that the number of
fixed assignments for this 1375 megahertz of spectrum is far less
per megahertz than is found in the non‑Federal Government fixed bands.
While this fact alone is not sufficient to conclude that ITFS/MDS
systems could be relocated to this band it may warrant further
consideration if ITFS/MDS systems are to be relocated from the
2500‑2690 MHz band.

ASSESSMENT OF THE BAND 10.7 -- 13.25 GHz

**Allocation Description**

The spectrum between 10.7‑13.25 GHz is allocated exclusively to the
non‑Federal Government and consists of five bands. An excerpt from the
Table of Frequency Allocations for this portion of the spectrum is
provided below in Table 6.5.[^141] The applicable service definitions
and associated footnotes for this portion of the Table are provided in
Appendices 6.2 and 6.3, respectively. The 10.7‑11.7 GHz (1000 megahertz)
band is allocated on a co‑primary basis to the fixed and fixed‑satellite
services. This band may also be used by stations in the international
fixed public and international control services for operations located
in the U.S. Possessions in the Caribbean area.[^142] The band
11.7‑12.2 GHz (500 megahertz) is allocated on a primary basis to the
fixed‑satellite service and secondarily to mobile services (except for
aeronautical mobile). In the band 11.7‑12.2 GHz, transponders on space
stations in the fixed‑satellite service may be used additionally for
transmissions in the broadcasting‑satellite service, provided that
certain limitations are met. The satellite community refers to this
spectrum range as the "Ku‑band." The band 12.2‑12.7 GHz (500 megahertz)
is allocated on a primary basis to the fixed and broadcasting‑satellite
services, but licensing of fixed stations in the United States has been
frozen to protect Direct Broadcast Satellite (DBS) operations. The bands
12.7‑12.75 GHz (50 megahertz) and 12.75‑13.25 GHz (500 megahertz) are
allocated on a primary basis to the fixed, fixed‑satellite, and mobile
services. In the band 12.7‑13.25 GHz (along with bands 2025‑2110 MHz,
6875‑7125 MHz), television translator relay stations may be authorized
on a secondary basis to other services. Further, the band
12.75‑13.25 GHz is also allocated to the space research service (deep
space, space‑to‑Earth) for reception only at Goldstone, California.

**Table 6.5: Table of Frequency Allocations for 10.7‑13.25 GHz**

**(See Appendix 6.3 for footnote text.)**

+------------------+---------------------------+----------------------+
| Federal          | Non‑Federal Government    | FCC Rule Part(s)     |
| Government       |                           |                      |
+==================+===========================+======================+
| 10.7‑11.7        | 10.7‑11.7                 | International Fixed  |
|                  |                           | (23)                 |
| US211            | FIXED NG41                |                      |
|                  |                           | Satellite            |
|                  | FIXED‑SATELLITE           |                      |
|                  |                           | Communications (25)  |
|                  | (space‑to‑Earth) S5.441   |                      |
|                  |                           | Fixed Microwave      |
|                  | US211 NG104               | (101)                |
|                  |                           |                      |
|                  | US355                     |                      |
+------------------+---------------------------+----------------------+
| 11.7‑12.1        | 11.7‑12.2                 | Satellite            |
|                  |                           |                      |
| S5.486           | FIXED‑SATELLITE           | Communications (25)  |
|                  |                           |                      |
|                  | (space‑to‑Earth) NG143    | Fixed Microwave      |
|                  | NG145                     | (101)                |
|                  |                           |                      |
|                  | Mobile except             |                      |
|                  | aeronautical              |                      |
|                  |                           |                      |
|                  | Mobile                    |                      |
+------------------+---------------------------+----------------------+
| 12.1‑12.2        | S5.486 S5.488             |                      |
+------------------+---------------------------+----------------------+
| 12.2‑12.7        | 12.2‑12.7                 | International Fixed  |
|                  |                           | (23)                 |
| S5.490           | FIXED                     |                      |
|                  |                           | Satellite            |
|                  | BROADCASTING‑SATELLITE    |                      |
|                  |                           | Communications (25)  |
|                  | S5.487A S5.488 S5.490     |                      |
|                  |                           | Direct Broadcast     |
|                  |                           | Satellite (100)      |
|                  |                           |                      |
|                  |                           | Fixed Microwave      |
|                  |                           | (101)                |
+------------------+---------------------------+----------------------+
| 12.7‑12.75       | 12.7‑12.75                | Satellite            |
|                  |                           |                      |
|                  | FIXED NG118               | Communications (25)  |
|                  |                           |                      |
|                  | FIXED‑SATELLITE           | Auxiliary            |
|                  |                           | Broadcasting (74)    |
|                  | (Earth‑to‑space)          |                      |
|                  |                           | Cable TV Relay (78)  |
|                  | MOBILE                    |                      |
|                  |                           | Fixed Microwave      |
|                  | NG53                      | (101)                |
+------------------+---------------------------+----------------------+
| 12.75‑13.25      | 12.75‑13.25               |                      |
|                  |                           |                      |
| US251            | FIXED NG118               |                      |
|                  |                           |                      |
|                  | FIXED‑SATELLITE           |                      |
|                  |                           |                      |
|                  | (Earth‑to‑space) S5.441   |                      |
|                  | NG104                     |                      |
|                  |                           |                      |
|                  | MOBILE                    |                      |
|                  |                           |                      |
|                  | US251 NG53                |                      |
+------------------+---------------------------+----------------------+

**Description of Current and Planned Band Use (10.7‑13.25 GHz)**

The band 10.7‑13.25 GHz has a variety of operations including fixed
point‑to‑point operations, DBS, intercontinental FSS and VSAT FSS,
broadcast auxiliary links and cable system backbone links. We also note
that this frequency range is the subject of an ongoing Commission
proceeding to allow non‑geostationary orbit (NGSO) FSS and terrestrial
multichannel video distribution and data service (MVDDS) operations on
these and other bands through out the Ku‑band.[^143] We have evaluated
each of these bands below to determine the viability of ITFS/MDS
operations in this range. For the purposes of this analysis, we have
divided the band into four segments: 10.7‑11.7, 11.7‑12.2, 12.2‑12.7,
and 12.7‑13.25 GHz (*See* Table 6.6: Band Usage 10.7‑13.25 GHz).

*[10.7‑11.7 GHz portion]{.underline}*. As indicated above, the band
10.7‑11.7 GHz is currently allocated on a co‑primary basis to the FS,
licensed under Part 101 of the Commission\'s Rules; and to the FSS for
international systems (downlinks),[^144] licensed under Part 25 of the
Commission\'s Rules.[^145] The FS links in this band support a wide
array of communication services used by utilities, railroads, telephone
companies, state and local governments, public safety agencies, and
others. There are currently over 31,000 point‑to‑point links licensed in
this band. The average path length is 32 km (19.9 miles). The channeling
plan provides for varied bandwidths from 1.25 to 40 megahertz channels
with 500 megahertz separation between the transmit and receive channels.
There are also several GSO FSS earth stations for international systems
in this band. Currently, there are 10 U.S. licensed geo‑stationary (GSO)
satellites providing international service and almost 600 downlinks
associated with licensed earth stations. Further, this band is also used
for telemetry, tracking, and control ("TT&C") functions for the GSO FSS
satellites authorized within this band.[^146] In 2000, the Commission
authorized NGSO FSS downlink gateway earth stations in this frequency
range.[^147] Both the channel loading and the geographical distributions
of the incumbent facilities in this band are fairly uniform across the
band and across the country, respectively. *See* the map in Appendix
6.4. Moreover, the band 10.7‑11.7 GHz was identified in 1993 in the
Emerging Technologies proceeding and in 1997 in the mobile‑satellite
service ("MSS") 2 GHz allocation proceeding as a future home for fixed
point‑to‑point operations to be relocated from the 2 GHz band.[^148]
(*See* the maps in Appendix 6.5.)

*[11.7‑12.2 GHz portion]{.underline}*. As mentioned above, the band
11.7‑12.2 GHz is allocated in the U.S. on a primary basis for FSS
downlinks and is heavily used by television program distribution and
VSAT operations. The downlink FSS band 11.7‑12.2 GHz is paired with the
uplink FSS band 14.0‑14.5 GHz. These bands accommodate 25 U.S. licensed
GSO satellites, including VSAT operations. Transponders on space
stations in the FSS may be used, depending upon certain limitations, for
Direct‑to‑Home (DTH) transmissions. The Commission has also authorized
NGSO FSS service downlink operations in this band to user terminals. The
band 11.7‑12.2 GHz supports over 4,200 links associated with licensed
earth stations. We also note that mobile operations are permitted in the
band on a secondary basis, but there are only a few mobile operations in
the band.

*[12.2‑12.7 GHz portion]{.underline}*. The band 12.2‑12.7 GHz is
allocated on a primary basis to BSS for use by DBS systems. The DBS
service provides for direct reception of radiocommunications signals by
the general public and DBS programming typically includes video
distribution, pay‑per‑view movies, and CD‑quality audio channels. The
two domestic DBS licenses are DirecTV and EchoStar's DISH Network, which
combined service in excess of 15 million customers using 11 U.S.
licensed GSO satellites. The FCC rules and regulations for DBS are
contained in 47 C.F.R. Part 100. While the band has a primary allocation
for the FS, fixed systems licensed in the band after September 9, 1983
must operate on a non‑harmful interference basis to the BSS.[^149]
Currently, there are approximately 400 links in the terrestrial fixed
services, with an average path length of 15 km (9.3 miles). In ET Docket
98‑206, the Commission allocated this spectrum band for NGSO FSS service
downlinks to user terminals and concluded that one‑way terrestrial
point‑to‑multipoint operations could be designed around incumbent BSS
operations if technical parameters are constrained and systems were
designed to protect BSS or mitigate any harmful interference. The
specific method of protecting DBS systems from terrestrial interference
is the subject of an ongoing proceeding.[^150]

*[12.75‑13.25 GHz portion]{.underline}*. The band 12.75‑13.25 GHz band
is allocated on a co‑primary basis to fixed, FSS uplink, and mobile
operations. This band is primarily used by Part 74 broadcast auxiliary
services (BAS), Part 78 cable relay services (CARS), and Part 101 FS
operations. Television stations use the fixed allocation for BAS
studio‑transmitter links and the mobile allocation for electronic news
gathering (\"ENG\"). CARS licensees use this band to send video signals
between points in their networks.[^151] GSO FSS operations in this band
must meet the requirements of the ITU Appendix 30B plan, and Part 2 of
the Commission\'s Rules limits these operations to international
systems.[^152] Similar to the 10.7‑11.7 GHz band, the international
system only requirement for GSO FSS uplink operations has limited the
number of earth stations in this band.[^153] Further, our rules do not
currently address coordination between FSS operations and BAS
operations, but this is the subject of an upcoming proceeding. The band
may also be used for vital TT&C functions for GSO FSS satellites. ET
Docket No. 98‑206 permitted NGSO FSS uplink gateway operations in this
band subject to appropriate coordination and sharing criteria.

This band is used primarily by CARS operations plus BAS, LTTS, and
fixed, point‑to‑point microwave. For the CARS, there are currently
145,281 fixed and 725 mobile links licensed in this band. The fixed
operations' bandwidths ranges are 6, 12.5, or 25 megahertz, while the
mobile operations use 25 megahertz channel bandwidths. The average path
length for fixed operations is 20 km (12.4 miles). The band
12.7‑13.25 GHz also supports 2,069 fixed and 2,779 mobile links for BAS,
and 636 fixed and 988 mobile links for LTTS. For BAS, the fixed
bandwidths are 10 and 20 megahertz channels, and the mobile bandwidth is
25 megahertz, with a 250 megahertz separation between transmit and
receive operations. The average path length for fixed operations is
15 km (9.3 miles). The LTTS uses bandwidths of 16, 17, or 25 megahertz
for both fixed and mobile operations and an average path length of 21 km
(13.0 miles). The band 12.7‑13.25 GHz provides 116 uplinks for the 10
GSO satellites mentioned above in the 10.7‑11.7 GHz discussion. The
channel loading and the geographical distributions of licensed links in
this band are shown in maps in Appendix 6.4.

> **Table 6.6: Band Usage 10.7‑13.25 GHz**

+-------------------------+------------+------------+----+------------+
| FSS (downlink)          | FSS        | Direct     | F  | FSS        |
|                         | (downlink) |            | SS | (uplink)   |
| International Sat. only |            | Broadcast  |    |            |
|                         | VSATs      |            | (u | Int        |
|                         |            | Satellite  | p) | ernational |
|                         |            |            |    |            |
|                         |            |            |    | Sat. only  |
+-------------------------+------------+------------+----+------------+
| FIXED                   | Secondary  | FIXED      | FI |            |
|                         |            |            | XE |            |
| Point‑to‑Point          | mobile     | Poin       | D/ |            |
| Microwave               |            | t‑to‑Point | MO |            |
|                         |            |            | BI |            |
| LTTS                    |            | Microwave  | LE |            |
|                         |            |            |    |            |
|                         |            |            | Po |            |
|                         |            |            | in |            |
|                         |            |            | t‑ |            |
|                         |            |            | to |            |
|                         |            |            | ‑P |            |
|                         |            |            | oi |            |
|                         |            |            | nt |            |
|                         |            |            |    |            |
|                         |            |            | M  |            |
|                         |            |            | ic |            |
|                         |            |            | ro |            |
|                         |            |            | wa |            |
|                         |            |            | ve |            |
|                         |            |            |    |            |
|                         |            |            | BA |            |
|                         |            |            | S, |            |
|                         |            |            | C  |            |
|                         |            |            | AR |            |
|                         |            |            | S, |            |
|                         |            |            | LT |            |
|                         |            |            | TS |            |
+-------------------------+------------+------------+----+------------+
|                         |            |            |    | Secondary  |
|                         |            |            |    | TV         |
|                         |            |            |    |            |
|                         |            |            |    | T          |
|                         |            |            |    | ranslators |
+-------------------------+------------+------------+----+------------+
| Federal Agency Testing  |            |            |    | NASA space |
| (10.7‑11.7 and          |            |            |    |            |
| 12.2‑13.25 GHz)         |            |            |    | research   |
|                         |            |            |    | at         |
| Radio Astronomy         |            |            |    |            |
| (passive sensing        |            |            |    | Goldstone, |
| 12‑14 GHz)              |            |            |    | CA         |
+-------------------------+------------+------------+----+------------+
|                         |            |            |    |            |
+-------------------------+------------+------------+----+------------+

> \| \| \| \| \| \|

10.7 11.7 12.2 12.7 12.75 13.25

**Assessment for ITFS/MDS Operations (10.7‑13.25 GHz)**

The technical characteristics in the 10‑13 GHz spectrum range are
significantly different from that experienced at the 2500‑2690 MHz band.
Consequently, relocation of the ITFS/MDS systems from the 2.5 GHz band
to 10‑13 GHz would require major changes to ITFS/MDS equipment and
network design.

*[10.7‑11.7 GHz (1000 megahertz)]{.underline}*. Accommodation of
ITFS/MDS in the band 10.7‑11.7 GHz would be extremely difficult due to
the heavy use of FS and the international nature of FSS operations. As
noted earlier, this band currently supports over 31,000 FS links and
almost 600 FSS downlinks. Sharing between ITFS/MDS and the incumbent
users is not feasible because ITFS/MDS are ubiquitous, wide‑area systems
using broad‑beam and omnidirectional antennas, which are not compatible
with other operations in the same geographical markets. Segmenting the
band into 202 megahertz for ITFS/MDS and 798 megahertz also is
impractical due to the heavy use by the incumbent services. Thus,
relocating ITFS/MDS into the band 10.7‑11.7 MHz would require
reaccommodating a portion of the incumbent users into other higher
frequency bands. This would be very disruptive to the FS due to the
varied bandwidths and the paired operations used by the FS operations.
Relocation of the FSS would also need to accommodate the cross‑band
pairing of this band with the FSS 14 GHz band and would have a
significant cost impact to deploy new satellites and earth stations.

*[11.7‑12.2 GHz (500 megahertz)]{.underline}* Accommodating ITFS/MDS in
the band 11.7‑12.2 GHz would be very disruptive to the fixed‑satellite
services. As mentioned above, this downlink band supports the VSAT, DTH,
and NGSO FSS services and the wide‑area, ubiquitous nature of ITFS/MDS
services are not compatible with the broad deployment of FSS terminals.
If 202 megahertz of spectrum were to be cleared for ITFS/MDS, the
incumbent services would have to be relocated into the remaining
298 megahertz of spectrum or be reaccommodated in higher frequency
bands. For FSS purposes, this band is paired with the band
14.0‑14.5 GHz. Therefore, relocating the FSS operations either into the
remaining 298 megahertz of spectrum or relocating into higher bands
would require a full realignment of this spectrum. This would create
considerable disruption to the incumbent services. Additionally,
consideration would have to be made regarding the Commission's recent
decision to allow NGSO FSS service downlinks in this spectrum range (ET
98‑206). Finally, although not protected, some accommodation of the
secondary mobile use in the band 11.7‑12.2 GHz band would need to be
examined further.

*[12.2‑12.7 GHz (500 megahertz)]{.underline}*. This band supports the
deployment of the DBS operations. (*See* discussion above.) Relocation
of ITFS/MDS services into the 12.2‑12.7 GHz band would be a severe
hardship to the current and future deployment of DBS in this country.
Again, sharing of this band between ITFS/MDS and broadcasting‑satellites
is not feasible due to the inability to coordinate ubiquitous DBS use
with a two‑way service. Further, we note that segmentation of this band
or relocation of the incumbents into higher bands is fraught with
difficulty due to the international nature of the broadcasting‑satellite
services. Recently, there has been considerable growth in the DBS
services. Relocation of these incumbent DBS services would require a
reconfiguration of the satellites and millions of home terminals.
Additionally, further consideration is needed regarding the NGSO FSS
downlink proceeding ET 98‑206.

*[12.7‑13.25 GHz (550 megahertz)]{.underline}* Reaccommodation of
ITFS/MDS into the 12.7‑13.25 GHz band is impractical due to the band's
heavy use by fixed, fixed‑satellite, and mobile services. With regard to
mobile operations, BAS, CARS, and LTTS pose particular difficulties to
sharing between these incumbent services and ITFS/MDS. As discussed in
Section 4 above, sharing between ITFS/MDS and mobile operations in the
same geographic area is not feasible. Because the incumbent mobile
services are dispersed throughout the country, ITFS/MDS could not share
with these incumbent operations. Segmentation of the band into
202 megahertz for ITFS/MDS and the remainder for the incumbent services
also is not reasonable due to the extensive use of the entire spectrum
band by the incumbent services. The band 12.7‑13.25 GHz supports
approximately 148,000 fixed and 4,500 mobile links licensed in this
band. Thus, relocating ITFS/MDS into this band would require
reaccommodating a large portion of the incumbent users into higher
frequency bands. Due to the propagation characteristics at these higher
frequencies (18 GHz or above), the relocated fixed services would
require additional facilities to provide the equivalent service ranges.
The mobile services would be severely impacted and may not be
operational at all due to multipath and signal fading. Such action also
would exacerbate current difficulties that already exist with relocating
fixed links from the 2 GHz band as laid out in ET Docket 92‑9, and those
fixed services relocating from the DBS band 12.2‑12.7 GHz as noted
above. (*See* the maps in Appendix 6.5.)

*[Other matters]{.underline}*. In addition to the points discussed
above, there are several Federal Government operations that operate on a
non‑interference basis. Specifically, NASA operates downlink telemetry,
on a non‑interference basis, during launch and emergencies in support of
the NASA Advanced Communications Technology Satellite Space Program. In
the bands 10.7‑11.7 and 12.2‑13.25 GHz, federal agencies use this
spectrum on a non‑interference basis for experimental testing for such
studies as millimeter wave propagation studies. For radio astronomy, the
FSS and FS that operate in the 10.7‑11.7 GHz band are urged to take all
practicable steps to protect the passive sensing and radio astronomy
studies of quasars that are conducted in the adjacent band
10.68‑10.7 GHz. Further, the band 12.75‑13.25 GHz also is allocated on a
primary basis to space research for reception only at NASA's Goldstone,
California facility.

**Summary (10.7‑13.25 GHz)**

As described above, ITFS and MDS is not compatible with the incumbent
services in the 10.7‑13.25 GHz spectrum. The extensive deployment of
fixed point‑to‑point operations in the band 10.7‑11.7 GHz poses
particular problems to relocation in this band. The growing deployment
of VSATs and DBS terminals throughout the country also creates
difficulties with relocating ITFS/MDS in either the 11.7‑12.2 GHz or
12.2‑12.7 GHz bands. The mobile and fixed operations of BAS, CARS, and
LTTS also create problems with relocating operations in the band
12.7‑13.25 GHz as well. Due to the technical characteristics of ITFS/MDS
services, sharing with the incumbent services is not possible in most
geographic areas. Therefore, to provide for ITFS/MDS, 202 megahertz of
spectrum will have to be cleared by relocating or segmenting all of the
incumbent users in that portion of the spectrum. As discussed above,
reaccommodating these services in higher bands would severely impact the
incumbent users. Moreover, the spectrum in the 10‑13 GHz range cannot
provide functional equivalency for the ITFS/MDS services due to the
considerable technical differences from the 2.5 GHz spectrum range.
Therefore, we believe the 10.7‑13.25 GHz spectrum is not practical as an
alternate band for ITFS/MDS services.

MIGRATION SCHEDULE (2003, 2006, 2010)

If the ITFS/MDS services are relocated to any of the Non‑Federal
Government bands except the 50 megahertz in the band 7075‑7125 MHz, a
substantial amount of time would be needed to relocate incumbent
satellite operations.[^154] Any relocation of FSS or BSS will entail the
design, construction, and launch of new satellites at higher satellite
frequency bands, which, alone, would take a number of years. GSO
satellites are constructed with an expected lifetime of 15 years, and
NGSO satellites have a life expectancy of 7 years. Once the satellites
are launched, however, there is no way to "relocate" them to different
frequency bands. It is therefore not possible to meet a migration
schedule that is less than the expected lifetime of the currently
operating satellites. Otherwise an existing and valuable resource would
be wasted.

On the other hand, relocation of the FS point‑to‑point operations could
start as early as 2003 because each facility could be relocated on an
individual, as needed, basis. This is similar to the process being used
for the 2 GHz fixed microwave point‑to‑point operations that are being
relocated for emerging technologies, such as PCS, but as fixed
operations are forced to higher frequencies the technical impact and
challenges increase substantially. Mobile operations also could be
relocated on an individual as needed basis; however, the technical
challenges for mobile communications at higher frequencies is even
greater than fixed services and it is highly unlikely that suitable
spectrum in nearby frequency bands could be located for these incumbent
services.

## SECTION 7

## ANALYSIS OF COSTS AND BENEFITS

The Study Plan states that for each band option being analyzed (*i.e.*,
sharing, segmentation and relocation), the study will estimate and
describe the costs to implement each option and any associated
assumptions. The estimates should address implementation of the options
in 2003, 2006, 2010 or at times where there is a potential cost
advantage to do so (*e.g.*, if costs can be mitigated by ceasing further
deployment of incumbent systems in the band under study, thereby
reducing costs to relocate incumbent systems to alternate bands). The
Study Plan also states that the study should estimate and describe the
benefits (including assumptions), if any, including potential auction
receipts that could be realized as a result of making spectrum available
for 3G systems in the frequency band under study. Finally, the study
should include a cost and benefit analysis for each option and
implementation timeframe under consideration.

In this section, we describe the costs and benefits for ITFS/MDS and
future 3G systems if spectrum were made available for 3G systems either
through segmentation of the 2500‑2690 MHz band or relocation of ITFS/MDS
systems to alternate bands, as addressed in Sections 5 and 6,
respectively. We identify the types of cost and benefit factors that we
considered in our analysis, and we discuss some of these factors in more
detail vis‑à‑vis the segmentation and relocation options that we
considered in this study. The analysis in this section is based on
information received in response to the *Advanced Wireless Services
NPRM*[^155]and our independent study. We do not analyze the cost and
benefit of making spectrum available for 3G systems by sharing the
2500-2690 MHz band with ITFS/MDS, because, as discussed in Section 4, we
conclude that sharing the band among these services would be extremely
problematic.

# COST AND BENEFIT FACTORS

We have identified certain cost and benefit factors that could
reasonably be included in this study, and these are discussed below.

In considering the cost impact to ITFS/MDS to implement any of the
segmentation or relocation options under study, we focused primarily on
prospective costs to maintain functionality and services. We note, for
example, that the relocation policy used to accommodate new PCS entrants
in the 1850‑1990 MHz bands requires that the new entrants provide
incumbent users, who are being moved out of the band, with comparable
facilities, which are evaluated in terms of throughput, reliability and
operating costs.[^156] This approach assumes a continuing public benefit
by maintaining ITFS/MDS functionality and services, and focuses on the
costs necessary to maintain this benefit. We did not analyze what
benefits, if any, might accrue to ITFS/MDS entities under the
segmentation or relocation options. For example, we considered the cost
to deploy additional cell sites to maintain a desired service area and
the cost to acquire new equipment, which may not yet be available, at
higher frequency bands. To the extent possible, we considered costs for
analog and digital, one‑way and two‑way systems. If functionality could
not reasonably be maintained (*e.g.,* segmentation of the 2500‑2690 MHz
band), we considered lost opportunity costs from fewer customers or
fewer services. In the segmentation and relocation discussions that
follow, we explain in more detail the cost factors used in analyzing
those options.

We recognize that by focusing on prospective costs to maintain
functionality and services, our analysis does not include certain costs
incurred by ITFS/MDS entities for the current and planned deployment of
services in the 2500‑2690 MHz band. For example, the auction of MDS
wide‑area licenses in 1995‑1996 generated winning net bids of
\$216.2 million. Sprint and WorldCom have spent over \$2 billion to
acquire numerous incumbent MDS licenses after the FCC decided to allow
the deployment of two‑way systems in the 2500‑2690 MHz band.[^157] MDS
entities also have numerous lease arrangements with ITFS licensees. If
these lease arrangements are not maintained, ITFS licensees could lose
significant revenues and in‑kind compensation to support their
educational missions.[^158] These cost factors present legal and policy
issues that are beyond the scope of this proceeding and estimates of the
costs cannot reasonably be made at this time. Therefore, we do not
include them in our analysis for purposes of this study.

Our analysis did not consider the costs to deploy 3G systems in the
2500‑2690 MHz band nor the potential benefits to prospective providers
of 3G services. At this time, we do not have a record on which to base
cost estimates for different types of systems or different types of
services that may be deployed. Further, we can only speculate on the
potential public benefits that could be realized as a result of making
spectrum available for 3G systems in the 2500‑2690 MHz band. For
example, we assume that if spectrum in the 2500‑2690 MHz band were made
available for 3G use, the spectrum would be licensed under competitive
bidding processes. The amount of revenue that might be generated by any
auction depends on a number of factors, including the amount of spectrum
made available, the state of technology, the extent to which the
spectrum is encumbered, and volatility in capital markets. Other factors
also may affect the proceeds generated by a spectrum auction.

We have not attempted to estimate the amount of revenue that might be
generated if spectrum in the 2500‑2690 MHz band were made available for
3G use, but some information is available that suggests auctions of
spectrum for 3G use could generate significant revenue. The
Congressional Budget Office (CBO), for example, has provided projections
of receipts from FCC spectrum auctions[^159] likely to occur between now
and 2007 when the FCC's statutory authority to conduct spectrum auctions
expires.[^160] The CBO's recent projections, which are based on past
auctions and private sales of comparable licenses, were recently revised
upward based on higher prices paid recently for spectrum licenses.[^161]
The CBO projects that spectrum auctions will bring in \$1 billion in
2001, between \$4 billion and \$10 billion each year from 2002 to 2004,
and smaller amount in subsequent years. These projections assume that
some of the auctions will be for spectrum for 3G use. We also note that
the FCC recently completed an auction for certain PCS spectrum, which
could be used for 3G systems, and a total of \$16.8 billion in net high
bids was received.[^162] Thus, this auction alone exceeded the CBO
projection for 2001.

Finally, both advanced wireless mobile and fixed services have the
potential to provide numerous benefits to the public. The FCC noted in
its *Fifth Competition Report* on commercial mobile services[^163] that
although only about two percent of mobile traffic is currently data,
substantial growth is expected in the future. The *Fifth Competition
Report* pointed to one forecast that wireless data subscribers will
outnumber wireline data subscribers by 2002 and another that predicts at
least \$35‑\$40 billion in revenues by 2007---an annual growth rate of
25 to 30 percent---and 100 million subscribers using some form of mobile
data.[^164] An October 2000 Council of Economic Advisers' Report
estimates the annual consumer benefits of 3G services to be in the range
of \$53‑111 billion.[^165]

The potential market for fixed wireless services also is promising. We
noted in the Interim Report that available evidence indicates that over
the next several years the demand for affordable broadband services in
the United States will far outpace the ability of incumbent local
exchange carriers and cable operators to provide those services.[^166]
The U.S. market for fixed wireless broadband services is expected to
increase from \$767 million in 1999 to \$7.4 billion by 2003,[^167] with
the total number of fixed wireless broadband subscribers predicted to
increase from 200,000 this year to 9.4 million in 2005.[^168]

# SEGMENTATION

In Section 5, we analyzed the effect on ITFS/MDS of segmenting the
2500‑2690 MHz band if 90 megahertz of spectrum were reallocated for 3G
systems use. We considered three optional band plans for making this
spectrum available for 3G systems. Our analysis shows that each of the
optional band plans would have significant impacts on ITFS/MDS if the
90 megahertz of spectrum were not replaced with spectrum from another
band, and ITFS/MDS entities had to operate on no more than 100 megahertz
of remaining spectrum in the band. First, incumbent one‑way ITFS/MDS
systems, both analog and digital, would have to be accommodated in the
remaining 100 megahertz of spectrum. Second, segmentation would have one
of two results for two‑way ITFS/MDS systems: either ITFS/MDS deployment
would be significantly constrained with substantial reductions in
customers served or services provided, or additional cell sites would
have to be deployed to maintain service areas. Our analysis is
consistent with views expressed by several commenters in response to the
*Advanced Wireless Services NPRM.*[^169]

As we have noted throughout this study, the current use of the
2500‑2690 MHz band by ITFS/MDS is very complex and is not uniform from
one geographic area to another. Consequently, each of the segmentation
options considered in this study would have different impacts on
ITFS/MDS, depending on the geographic area under review. Thus, it is not
possible to provide one cost estimate to implement each of the
segmentation options considered. Rather, we have looked at several
specific cost factors, which would apply in most cases, and in each
geographic area the implementation costs would reflect the types of use
that exist.

Under each of the segmentation options, some traditional one‑way ITFS
and MDS operations would have to be moved into the remaining spectrum.
We noted in Section 5 that approximately 60,000 transmitters would be
affected by the segmentation options studied. Generally, these systems
transmit using standard 6 megahertz composite NTSC video/audio
modulation. ITFS licensees may use a 125 kHz response station
transmitter at receive sites, which operate using wideband FM
modulation. Based on information provided by one commenter to the
*Advanced Wireless Services NPRM*, the cost to relocate this type of
facility could be approximately \$500,000.[^170] We also noted in
Section 5 that if some ITFS/MDS operators using multiple channels
converted their systems to digital modulation, spectrum use in the band
would be more efficient. Digital modulation may be a viable option only
for those operators using multiple channels, so the ability to compress
these uses into the least number of channels will vary from one
geographic area to another. Of course, converting one‑way systems to
digital modulation would entail another cost to ITFS/MDS operators.

The relocation of incumbent one‑way systems into the remaining spectrum
is only one factor that would exacerbate the difficulty of operators of
two‑way digital systems in the band finding sufficient spectrum. Each of
the segmentation options also would require guardbands between ITFS/MDS
and 3G operations, further reducing the amount of spectrum available for
two‑way ITFS/MDS systems.[^171] As noted in Section 5, the amount of
spectrum available for two‑way systems would vary depending on the size
and number of guardbands. Taking into account accommodation of incumbent
one‑way systems (which would vary depending on geographic area) and
guardbands, the amount of spectrum available for two‑way systems would
range from 52‑82 megahertz for option 1, 64‑94 megahertz for option 2,
or 58‑88 megahertz for option 3.

Guardband requirements themselves impose additional equipment costs on
both manufacturers and service providers, since manufacturers would have
to modify, for example, channel filtering, duplexers, and cellular reuse
patterns.[^172] In addition to the costs to manufacturers to reengineer
equipment for use in the band, operators would be penalized by the one
or more years needed to redesign and deploy new equipment.[^173] This
would delay the introduction of new broadband services in many markets
and to many educational users. At a time when the provision of
high‑speed data services to residential and business users is expected
to increase rapidly, MDS entities may lose the opportunity to enter some
markets as a competitor to DSL and cable modem services.[^174]

The significant reduction in spectrum available to deploy two‑way
systems in the band would impair the ability of ITFS/MDS operators to
deploy service as planned. Operators would either have to accept the
reduction in system capacity and thus serve fewer customers or provide
fewer services, or increase system capacity by adding additional cells.
With reduced spectrum and system capacity, operators may not be able to
offer data services at speeds sufficient to compete with alternative
technology such as DSL or cable modem service.[^175] If the number of
subscribers is significantly reduced, operators would not have a
sufficient revenue source to make the systems profitable. For example,
Cisco studied the impact on two markets if 90 megahertz of spectrum were
no longer available for two‑way ITFS/MDS systems. In one large market,
the system would experience nearly a 71 percent loss of capacity,
reducing the number of subscribers reached from 84,000 to 24,000
households; in a small market, system capacity would be reduced by
one‑half, with subscribers reached decreasing from 7,500 to 3,800
households.[^176]

As already noted, an ITFS/MDS two‑way system could add cells in order to
maintain functionality and services under any of the segmentation
options. As noted in Section 3, two‑way ITFS/MDS systems have been
designed to use a variety of network configurations. Generally,
operators intend to use one supercell in small markets or rural areas,
and sectorized cells or additional cells in large markets. System
capacity can be increased in most markets to meet increased demand by
sectorized cells or additional cells. Several commenters to the
*Advanced Wireless Services NPRM* addressed the costs, both to ITFS/MDS
operators and to the public, to add additional cells to address spectrum
reduction rather than increased demand.[^177] The consensus of these
commenters is that the deployment of additional cells would increase
operators' costs significantly, reduce profitability, and jeopardize the
ability to introduce broadband services in rural or smaller markets.

The HAI Study presents analysis developed from an engineering‑economic
model that calculated capital investment requirements, operating
expenses and revenue projections for a "normalized" two‑way ITFS/MDS
operation in a given market over a ten‑year study period. The HAI Study
examined the impacts for five sample markets of varying sizes[^178]
using a generic business case. The key drivers for the model were
investment costs, market size as measured by households in the sample
markets; 10^th^ year subscriber penetration targets (the demand
function); subscriber service levels and pricing; and the amount of
spectrum available in the market.[^179] The penetration targets drive
subscribership and capacity requirements, which in turn generate
investment requirements and operating expenses.

The HAI Study reached the following conclusions. Except for the smallest
sample market, all sample markets had to be multi‑cell markets to have
enough capacity to meet subscriber targets, and in larger markets the
number of cell sites increased by a factor of 2.7.[^180] Capital
investment requirements increased in all sample markets, and the total
capital requirement for the industry would increase from \$2.705 billion
to \$8.975 billion, a threefold increase. Operating expenses also would
increase significantly, so that over a 10‑year period cumulative
operating expenses would rise from \$5.3 to \$6.5 million in the
smallest sample market and from \$43.3 to \$74.9 million in the largest
sample market. Further, the 10‑year rate of return on investment for all
sample markets would be negative.[^181] Finally, the net present value
of costs that would be incurred by ITFS/MDS operators over the ten‑year
period as a result of a 90‑megahertz spectrum reduction would be about
\$19 billion.[^182]

Cisco performed a cost analysis for one large market, estimating the
increased capital and operational expenses over a five year period, and
extrapolated these figures to the top 100 Metropolitan Statistical Areas
(MSAs). Cisco states that the capital and operational expenses to deploy
broadband fixed wireless in the top 100 MSAs would increase by
\$5.19 billion over the first five years, from \$12.15 billion to
\$17.34 billion.[^183]

These studies have significant implications for future deployment of
two‑way ITFS/MDS in the 2500‑2690 MHz band if the band was segmented and
spectrum made available for 3G systems. In the remaining spectrum,
two‑way systems would not likely be deployed in most small markets or
rural areas, and, depending on the circumstances, two‑way systems may
not be profitable in some large markets as well. By and large, two‑way
systems have not yet been deployed in the 2500‑2690 MHz band, although
operators have plans to begin deployments later this year once the
initial application processing for two‑way systems is complete. If the
band was segmented and new two‑way system applications were limited to
certain portions of the band, the relocation expenses that new entrants
in the band would have to pay would be mitigated. Under the Commission's
current relocation policy, incumbents are entitled to relocation costs
only for those links that pose an interference problem, and thus
incumbents would not receive compensation for future systems for which
they have not applied or which have not been licensed.[^184] On the
other hand, if it were not profitable for incumbents to assume the costs
to deploy two‑way systems in the remaining spectrum, the public would
lose the benefits that could be realized by introducing competitive
broadband services, especially in many small markets or rural areas.

# RELOCATION

In Section 6, we identified and analyzed potential alternate frequency
bands for ITFS/MDS: 3700‑4200 MHz, 5925‑6425 MHz, 6425‑7125 MHz,
7125‑8500 MHz, and 10.7‑13.25 GHz. Our analysis shows that each of these
bands is already heavily utilized by other services, and that relocating
ITFS/MDS operations anywhere in this spectrum would be highly
problematic. Relocating ITFS/MDS to any of these alternate bands would
require that incumbent operations in these bands also would have to be
relocated. This secondary relocation, plus the time needed to develop
ITFS/MDS equipment for use in any of the alternate bands, would add
costs and delays to implementation of the relocation option.

Few comments filed in response to the *Advanced Wireless Services NPRM*
addressed ITFS/MDS relocation cost issues, and only one provided cost
estimates for relocating traditional ITFS facilities. The National ITFS
Association ("NIA") estimates that relocation costs for traditional ITFS
facilities, which are generally one‑way analog systems used for distance
learning, would be approximately \$19 billion over 15 years.[^185]
Although NIA's cost estimates are not band‑specific, NIA assumes that
any ITFS relocation band would be above 3 GHz and, because of
differences in propagation characteristics as compared to the
2500‑2690 MHz band, numerous additional transmitter sites would be
needed. NIA also assumes that equipment would have to be developed to
operate in a higher band, and that the cost of this equipment would be
significantly higher than current equipment for video/data transmission
and reception.

NIA breaks its estimates into facility replacement costs, increased
operation and maintenance costs, and lost lease revenues. With respect
to facility replacement costs, NIA assumes that at least three
transmitter sites would be required to replicate current ITFS coverage
at 2500‑2690 MHz, thus increasing all costs related to transmitter
sites, as well as adding new tower and backhaul costs. NIA further
assumes that equipment costs would be higher due to the technical
challenges of the higher band and the lack of opportunity of joint
development with MDS operators. Finally, NIA assumes that substantial
costs would be involved for removal and reconstruction of existing
sites, including engineering, shipping and insurance, and removal and
installation of transmitters. NIA estimates the total cost of replacing
2400 existing ITFS stations[^186] as \$3.7 billion.[^187]

Unlike our relocation analysis in Section 6, NIA assumes that any
relocation would result in the termination of the ITFS/MDS partnership,
thereby increasing ITFS licensees' costs and decreasing their
revenues.[^188] With respect to ITFS operation and maintenance costs,
NIA assumes that ITFS licensees would have to bear several costs that
are now being borne by their MDS partners such as transmitter site
rental costs, utilities, and other non‑personnel and depreciation costs
for transmitter sites. NIA estimates that these costs would total about
\$7.9 billion over the 15‑year lease period that typically exists at
present between ITFS licensees and MDS operators.[^189] NIA also assumes
that, over the typical 15‑year lease period, ITFS licensees would lose
significant revenues, which are used to support ITFS operations and
other educational endeavors. NIA assumes that ITFS licensees would
collect 5% of the revenues of broadband wireless systems in the
2500‑2690 MHz band, and if those lease revenues are foregone, NIA
estimates the loss to ITFS licensees over 15 years to be
\$7.2 billion.[^190]

In addition to NIA's cost estimates for relocating traditional ITFS
systems, we make the following general observations about the potential
costs to implement the relocation option for ITFS and MDS in any of the
frequency bands studied.

If relocation of ITFS/MDS incumbents were attempted, it is likely that
relocation costs would be lowest in the 3700‑4200 MHz band, but they
still could be significant. Both Cisco and the HAI Study note that the
ITFS/MDS equipment for two‑way systems now being used in the
2500‑2690 MHz band has been adapted from designs used in the 1.9 GHz and
2.4 GHz bands, and could not be used beyond 3 GHz, thereby requiring
equipment reengineering above 3 GHz.[^191] Cisco considered the impacts
on equipment reengineering and deployment if ITFS/MDS lost 100 megahertz
of spectrum in the 2500‑2690 MHz that was replaced with 100 megahertz in
the 3700 MHz band.[^192] This switch to dual‑band operation would impose
costs on equipment manufacturers and service providers, as well as delay
market entry by one to two years. Cisco notes that the RF components for
both the base stations and subscriber units would have to be
reengineered, and, for example, that the cost of customer premises
equipment ("CPE") would rise by about 25 percent.[^193] Cisco further
contends that because of changes in signal propagation, the coverage
area of a cell with a 20 mile radius at 2500‑2690 MHz, would shrink to
less than a 14 mile radius at 3700 MHz.[^194] This reduction in coverage
would negatively affect provision of service in smaller markets and
rural communities.

The HAI Study provides cost estimates for some of the above functions in
the 2500‑2690 MHz band.[^195] While that study did not examine the costs
of relocating ITFS/MDS users from the 2500‑2690 MHz band, we believe the
study has some relevance since costs for some of the following
representative items would likely be more at higher frequency bands.

-   Supercell fixed site investment for upstream sectorization:
    \$700,000 for omnidirectional antennas, \$1.1 million for four
    sectorized antennas, and \$1.7 million for ten sectorized antennas
    (does not include radios).[^196]

-   Multicell fixed site investment: \$850,000 (plus another \$150,000
    per market for Internet Protocol switching/routing).[^197]

-   Backhaul microwave system (dedicated) between the hub site and the
    local exchange carrier ("LEC"): \$145,000 for a DS‑3 system with
    hot‑standby redundancy.

-   Backhaul system (leased): monthly lease of \$3000 per DS‑3, and a
    monthly charge of \$20,000 per high‑speed (OC‑3) connection between
    the LEC and the Internet Service Provider.

-   Residential subscriber acquisition cost: \$700 for CPE initially,
    declining to \$350 in the tenth year; and \$350 for installation,
    declining to \$200 in the tenth year.

-   Commercial subscriber acquisition cost: \$700 for CPE initially,
    declining to \$350 in the tenth year; and \$500 for installation,
    declining to \$300 in the tenth year.

While it is not possible to estimate what the above costs would be in
other bands, it is likely that in general they would be higher in the
3700‑4200 MHz band, and significantly higher above 6 GHz. Because of
poorer propagation in higher bands, more cells would have to be added to
maintain the same quality of service, and such an addition would cause
investment costs to be multiplied by however many additional cells were
required. Additionally, subscriber acquisition costs would likely be
higher in each of the candidate relocation bands.

Further, since all of the candidate relocation bands are heavily
utilized, secondary relocation costs would have to be taken into
account, *i.e.,* incumbents in the relocation bands would themselves
have to be relocated to accommodate ITFS/MDS users. We believe that
these secondary costs can be very roughly estimated by looking at past
and anticipated future relocation costs for fixed, mobile, and GSO
satellite systems. We estimate these costs as follows: for fixed
point‑to‑point systems, we use a cost of \$250,000 per link; for fixed
point‑to‑multipoint systems, we use a cost of \$3,500 per link; for
mobile systems, we use a cost of \$150,000 per link; and for GSO
satellite systems, we use a cost of \$450 million per satellite.[^198]
These cost assumptions result in the following total relocation cost
estimates for each band, except for the 7125‑8500 MHz band, which is
used by Federal Government systems.

> *3700‑4200 MHz band*:

Total relocation estimate is approximately \$10.625 billion.

-   Fixed Systems (approximately 11,000 point‑to‑point
    links)‑‑\$2.75 billion;

-   Satellite Systems (35 GSO satellites)‑‑\$15.75 billion, including
    companion 5925‑6425 MHz band, or \$7.875 billion per band.

> *5925‑6425 MHz band*:

Total relocation estimate is approximately \$17.5 billion.

-   Fixed Systems (approximately 38,500 point‑to‑point
    links)‑‑\$9.625 billion;

-   Satellite Systems (35 GSO satellites)‑‑\$15.75 billion, including
    companion 3700‑4200 MHz band, or \$7.875 billion per band.

> *6425‑7125 MHz band*:

Total relocation estimate is approximately \$10.2 billion.[^199]

-   Fixed Systems (approximately 32,000 point‑to‑point
    links)‑‑\$8 billion;

-   Mobile Systems (approximately 2,800 links)‑‑\$0.4 billion;

-   Satellite Systems (4 satellites) ‑\$1.8 billion.

> *10.7‑13.25 GHz band*:

Total relocation estimate is approximately \$30.4 billion.

-   Fixed Systems (approximately 34,000 point‑to‑point links at
    \$8.5 billion and approximately 145,000 point‑to‑multipoint links at
    \$0.5 billion)‑‑\$9.0 billion;

-   Mobile Systems (approximately 4,500 links)‑‑\$0.7 billion;

-   Satellite Systems (46 GSO satellites)[^200]‑‑\$20.7 billion.

# SUMMARY

Deployment of both 3G and fixed wireless broadband systems will provide
considerable benefits to prospective users and the national economy.
Implementation of either the segmentation or relocation options analyzed
in this band study, however, would significantly affect ITFS/MDS
deployment and impose considerable costs on both private entities and
the public. Segmentation would require considerable time and costs to
reengineer and deploy systems utilizing much less spectrum than is now
allocated. Furthermore, delivery of fixed wireless broadband services to
the public and educational users would be delayed and, in rural areas or
smaller markets, may never be realized. Relocation also would require
considerable time and costs to reengineer and deploy systems in
alternate frequency bands. Again, delivery of service would be delayed
or never realized. The relocation option also would require other
services to relocate, and the time and costs to move those additional
services would be significant.

[^1]: FCC Staff Releases Its Interim Report on Spectrum Study of the
    2500‑2690 MHz Band (ET Docket No. 00‑232), Public Notice, DA 00‑2583
    (rel. Nov. 15, 2000); *See* *Federal Operations in the 1755‑1850 MHz
    Band: The Potential for Accommodating Third Generation Mobile
    Systems, Interim Report*, NTIA Special Publication 01‑41 (rel. Nov.
    15, 2000). The NTIA report is available on the internet at
    <http://www.ntia.doc.gov/osmhome/reports/imt2000/>.

[^2]: The Cellular Telecommunications & Internet Association, Personal
    Telecommunications Industry Association, and Telecommunications
    Industry Association, which represent a majority of the United
    States wireless industry established the Industry Association Group.
    *See* Industry Association Group Comments at ii.

[^3]: *Id.*

[^4]: *Amendment of Part 2 of the Commission's Rules to Allocate
    Spectrum Below 3 GHz for Mobile and Fixed Services to Support the
    Introduction of New Advanced Wireless Services, including Third
    Generation Wireless Systems* (ET Docket No. 00‑258), Notice of
    Proposed Rulemaking, FCC 00‑455 (rel. January 5, 2001) (hereinafter
    *Advanced Wireless Services NPRM*).

[^5]: Other international organizations that have worked with and
    through the ITU have proved instrumental in beginning to establish
    characteristics of 3G systems. These organizations include the
    Telecommunications Industry Association (TIA), the Third Generation
    Partnership Project (3GPP), the Third Generation Project 2
    Partnership (3GPP2), the Internet Engineering Task Force (IETF), the
    Universal Wireless Consortium (UWC), the CDMA Development Group
    (CDG), the European Telecommunications Standards Institute (ETSI)
    and others.

[^6]: We note that IMT‑2000 is intended to encompass both terrestrial
    and satellite services. For purposes of this study we are only
    considering terrestrial services. Also, we have taken the liberty to
    use the terms IMT‑2000 and 3G synonymously, although we recognize
    that 3G terrestrial wireless systems include those terrestrial
    wireless systems identified by the ITU as IMT‑2000 systems.

[^7]: *See, e.g.,* *Vocabulary of Terms for International Mobile
    Telecommunications‑2000 (IMT‑2000)*, Recommendation ITU‑R M.1224
    (1977), International Telecommunications Union, and *Key
    Characteristics for the IMT‑2000 Radio Interfaces*, Recommendation
    ITU‑R M.1455(2000), International Telecommunications Union.

[^8]: *See* *Detailed Specifications of the Radio Interfaces of
    IMT‑2000*, Recommendation ITU‑R M.1457 (2000), International
    Telecommunication Union. A more comprehensive list of the technical
    characteristics for each of these interfaces is included in Appendix
    2.1, which repoduces the 3G Industry Association Group's Report on
    3G Characteristics.

[^9]: *See* Report ITU‑R M.2023, *Spectrum Requirements for
    International Mobile Telecommunications‑2000 (IMT‑2000)*.

[^10]: The WRC adopted two key resolutions concerning the terrestrial
    component of IMT‑2000: Resolution 223 (WRC‑2000), "Additional
    frequency bands Identified for IMT‑2000," which addresses frequency
    bands above 1 GHz; and Resolution 224 (WRC‑2000), "Frequency bands
    for the terrestrial component of IMT‑200 below 1 GHz," which
    addresses frequency bands below 1 GHz. *See* Resolutions 223 and
    224, Final Acts of WRC‑2000, 2^nd^ ed., Istanbul, Turkey, June 2000.

[^11]: *See* Resolution 223, Final Acts of WRC‑2000, Istanbul, Turkey,
    June 2000.

[^12]: Due to the fact that the terms "MDS" and "MMDS" are often used
    interchangeably, some clarification is necessary with respect to use
    of those terms in this Report. In fifty markets in the country,
    Multipoint Distribution Service or "MDS" utilizes two 6 megahertz
    channels (Channel Nos.1 and 2) in the 2150‑2162 MHz band (in the
    rest of the country, the 6 megahertz No. 2 channel is replaced by a
    4 megahertz No. 2‑A channel (2156‑2160 MHz)). The shared spectrum
    between 2500 and 2690 MHz is referred to as the Multichannel
    Multipoint Distribution Service or "MMDS." For purposes of this
    Report, the term "MDS" will not only refer to the Nos. 1, 2, and 2‑A
    channels located in the 2150‑2162 MHz spectrum, but also the
    channels located in 2500‑2690 MHz spectrum. When the terms \"MDS
    systems\" or \"ITFS/MDS systems\" are referenced throughout this
    paper, licensees may be using the MDS channels in the 2150‑2160 MHz
    spectrum.

[^13]: In addition to ITFS and MDS use, thirty‑eight fixed stations are
    licensed to two entities in this band under the Fixed Microwave
    Service rules in Part 101. Although the band also is allocated to
    Fixed Satellite and Broadcasting Satellite Services, there are no
    users of this band in those services. Finally, the Radio Astronomy
    service is allocated on a secondary basis and there are a few
    stations in use around the country.

[^14]: An ITFS licensee is required to be an educational institution or
    governmental body engaged in the formal education of enrolled
    students. In addition, nonprofit organizations formed to provide
    instructional material to enrolled students and entities eligible to
    be licensees of noncommercial educational broadcast television
    stations are eligible to become ITFS licensees.

[^15]: *See In the Matter of the Request for Declaratory Ruling on the
    Use of Digital Modulation by Multipoint Distribution Service and
    Instructional Television Fixed Service Stations,* 11 FCC Rcd 18839
    (1996).

[^16]: *See The Mass Media Bureau Implements Policy for Provision of
    Internet Service on MDS and Leased ITFS Frequencies*, 11 FCC Rcd
    22419 (1996).

[^17]: *See Two‑Way Order,*13 FCC Rcd 19112 (1998), *recon.*, 14 FCC Rcd
    12764 (1999), *further recon.*, FCC 00‑244 (released July 21, 2000).
    In the *Two‑Way Order*, the Commission decided to: (1) permit both
    MDS and ITFS licensees to provide two‑way services on a regular
    basis; (2) permit increased flexibility on permissible modulation
    types; (3) permit increased flexibility in spectrum use and
    channelization, including combining multiple 6 megahertz channels to
    accommodate wider bandwidths, dividing 6 megahertz channels into
    smaller bandwidths, and swapping licensed MDS and ITFS channels; (4)
    adopt a number of technical parameters to mitigate the potential for
    interference among service providers and to ensure interference
    protection to existing MDS and ITFS services; (5) simplify and
    streamline the licensing process for stations used in cellularized
    systems; and (6) modify the ITFS programming requirements in a
    digital environment.

[^18]: *See Public Notice*, Report No. 148 (MMB November 29, 2000).

[^19]: *See Public Notice*, Report No. 164 (MMB February 1, 2001).

[^20]: *See* *Public Notice*, DA 01‑751 (MMB March 26, 2001).

[^21]: *See* Sprint Comments at 3. Throughout this Final Report,
    references to comments refer to those received in response to the
    *Advanced Wireless Services NPRM*, unless otherwise noted.

[^22]: *Id.* at 8.

[^23]: *Sprint Rolls Out Wireless DSL in Phoenix*, [Communications
    Daily]{.smallcaps}, May 9, 2000.

[^24]: *See* Worldcom Comments at 6. *See also*, *Annual Report and
    Analysis of Competitive Market Conditions With Respect to Commercial
    Mobile Services*, *Fifth Report*, FCC 00‑289, rel. Aug. 18, 2000 at
    E‑5 (*Fifth Report*).

[^25]: *See* Worldcom Comments at 6.

[^26]: *See* Worldcom Comments at 6. *See also*, Greg Keizer, *E‑Goals
    for '01*, Small Business Advisor from ZDWire, Dec. 28, 2000,
    available in 2000 WL 31553911.

[^27]: *Id. See also*, Matt Moore, *WorldCom Seeking Licenses for
    Fixed‑Wireless Services*, Associated Press Newswires, Aug. 15, 2000.

[^28]: Paul Kagan Associates, Inc., [Wireless/Private Cable
    Investor]{.smallcaps}, Mar. 9, 2000, at 1. WorldCom has stated that
    its capital expenditures for rolling out MMDS services are
    approximately \$2000 per square mile. *Telephony*, [Communications
    Daily]{.smallcaps}, Mar. 8, 2000.

[^29]: *Nucentrix Broadband Networks Announces Effectiveness of Shelf*,
    [Business Wire]{.smallcaps}, Dec. 17, 1999.

[^30]: Vector Orthogonal Frequency Division Multiplexing supports
    non‑line of sight operation, which can significantly improve signal
    coverage in a market.

[^31]: *Nucentix and Cisco Extend Broadband Wireless Trial in Amarillo*,
    News Release, Nucentrix Broadband Networks, Feb. 2, 2001.

[^32]: *Nucentix and Cisco Extend Broadband Wireless Trial in Amarillo*,
    News Release, Nucentrix Broadband Networks, Feb. 2, 2001.

[^33]: *Nucentrix Broadband Networks Announces FCC Notice of Fixed
    Wireless Applications*, News Release, Nucentrix Broadband Networks,
    Inc., Nov. 30, 2000.

[^34]: *See* LMA web page at http://www.lmasys.com/homepage.htm.

[^35]: *See*
    http://www.microtimes.com/newsfeeds/julyfeeds%2000/july10.html.

[^36]: *See* <http://www.cabledatacomnews.com/wireless/cmic12.html> for
    a listing of wireless broadband trials and deployments.

[^37]: *See* 47 C.F.R. § 21.901. *See* *also* footnote Error: Reference
    source not found, *supra*.

[^38]: Subchannelization is the division of a standard channel of fixed
    bandwidth into multiple, although not necessarily equal, channels of
    lesser bandwidth. Superchannelization is the aggregation of multiple
    contiguous channels of standard bandwidth into channels of larger
    bandwidth.

[^39]: *See* 47 C.F.R. § 74.939 (providing that the 2686‑2690 MHz is
    divided into 31 narrowband (125 kHz) response station channels).

[^40]: *See* 47 C.F.R. §§ 74.990, 74.991, 79.992; *Amendment of Parts
    21, 43, 74, 78, and 94 of the Commission's Rules Governing Use of
    the Frequencies in the 2.1 and 2.5 GHz Bands*, 6 FCC Rcd 6792,
    6801‑06 (1991). The rules provide that an MDS operator may be
    licensed on ITFS frequencies in areas where at least eight other
    ITFS channels remain available in the community for future ITFS use.
    In addition, no more than eight ITFS channels per community may be
    licensed to MDS operators. To be licensed on ITFS channels, an MDS
    applicant must hold a conditional license, license or a lease; must
    have filed an unopposed application for at least four MDS channels
    to be used in conjunction with the facilities proposed on the ITFS
    frequencies; and must show that there are no MDS channels available
    for application, purchase or lease. Finally, ITFS entities have the
    right to demand access to ITFS channels licensed to MDS operators.

[^41]: Basic Trading Areas (BTAs) are based on the *Rand McNally 1992
    Commercial Atlas & Marketing Guide*, 123rd Edition, at pages 38‑39,
    with the following additions: American Samoa (492), Guam (490),
    Northern Mariana Islands (493), San Juan, Puerto Rico (488),
    Mayagüez/ Aguadilla‑Ponce, Puerto Rico (489), and the United States
    Virgin Islands (491). For extensions and revisions by the Federal
    Communications Commission, *see* 59 FR 46195 (September 7, 1994);
    *see also*, http://www.fcc.gov/oet/info/maps/areas/.

[^42]: Since the auctions concluded in 1996, there have been bankruptcy
    defaults for 4 of the auctioned BTAs. In 1997, the Commission
    adopted default orders for two of the BTAs, Hickory, NC and
    Hagerstown, MD. Commission action for two additional BTAs, York, PA
    and Reading, PA, is pending.

[^43]: As explained above, all receive sites within 56.3 kilometers
    (35 miles) of the main station transmitter are protected from
    interference whether they are 'registered' or 'unregistered.'
    Receive sites that are further than 56.3 kilometers from the main
    transmitter site are only protected from interference if they are
    'registered.'

[^44]: Cable Datacom News^®^ presents an overview of wireless broadband
    technology and serices and wireless broadband network diagrams on
    their web site at http://www.cabledatacomnews.com/wireless/.

[^45]: Sue O Keefe, MMDS: From Back Burner to Center Stage,
    Telecommunications, Sept. 1, 1999.

[^46]: *Wireless OnLine Adds Vice President of Product Management*, [PR
    Newswire]{.smallcaps}, Jan. 5, 2000.

[^47]: NextNet, Inc., *Products* (visited Jan. 20, 2000)
    http://www.netwnetworks.com/products_prod_botton.html.

[^48]: Regional Wireless Operators Select Hybrid Networks' 2‑Way Today
    Solution to Launch Multiple Markets, PR Newswire, Jan. 10, 2000.

[^49]: Cliff Edwards, *Cisco Hopes Advances New Wireless Technology for
    Internet*, [AP Newswires]{.smallcaps}, Dec. 2, 1999.

[^50]: *Id*.

[^51]: *Nucentrix Files for FCC Approval to Launch Broadband
    Fixed‑Wireless Services*, News Release, Nucentrix Broadband
    Networks, Inc., Aug. 21, 2000; *Nucentrix Successfully Completes
    Initial Field Trial of Cisco Broadband Fixed‑Wireless Solution*,
    News Release, Nucentrix Broadband Networks, Inc., Aug. 15, 2000.

[^52]: *MCI WorldCom Adds Dallas to 'Fixed Wireless' Service Trials*,
    News Release, WorldCom, Inc., Apr. 5, 2000.

[^53]: *See* 47 C.F.R. §§ 21.902, 21.909, 21.913, 21.933, 21.937 and
    21.938.

[^54]: *See* 47 C.F.R. §§ 74.903, 74.939, 74.949 and 74.985.

[^55]: *See* Appendix D, Report and Order on Reconsideration In the
    Matter of Amendment of Parts 1, 21 and 74 to Enable Multipoint
    Distribution Service and Instructional Television Fixed Service
    Licensees to Engage in Fixed Two‑Way Transmissions, MM Docket
    97‑217, 14 FCC Rcd 12764 (2000) (hereinafter "Methodology") for
    details. The Methodology is periodically refined to accommodate
    real‑world technical concerns. *See, e.g.,* *Public Notice*,
    *Commission Amends Methodology Used for Calculation of Interference
    Protection and Data Submission for MDS and ITFS Station Applications
    for Two‑Way Systems*, DA 00‑938, released April 27, 2000. A copy of
    the most recent version of the Methodology can be found at
    <http://www.fcc.gov/mmb/vsd/files/methodology.doc>.

[^56]: *Id.*

[^57]: *See* 47 C.F.R. §§ 21.902, 21.909, 21.913, 74.903, 74.939, and
    74.985. *See* also, Section 3 *supra* regarding ITFS/MDS
    Interference Protection Standards.

[^58]: ITFS/MDS receivers, for purposes of this interference analysis
    include not only response station receivers located at commercial
    customer premises and registered ITFS receive sites, but also the
    main station receivers associated with the main station
    transmitters. Main station receivers receive signals on
    125 kilohertz response channels associated with each 6 megahertz
    channel.

[^59]: The Industry Association Group 3G Technical Characteristic Report
    is included as Appendix 2.1. There are only minor differences
    between the characteristics listed in the ITU documents and those
    presented in the Industry Association Group Report.

[^60]: Because mobile units could potentially operate at any location at
    any time, a complete analysis of the effect of multiple 3G mobile
    stations would require assumptions regarding their level of
    deployment within an area. Such assumptions are beyond the scope of
    this Final Report. For example, such assumptions may include
    statistics regarding how many mobile units may be operating in any
    given area at any one time and the calling patterns of users.

[^61]: ITFS/MDS services in the 2500‑2690 MHz band tend to fall within
    one of four distinct architectures: 1) downstream analog video; 2)
    downstream digital video; 3) downstream digital data; and 4)
    downstream/upstream digital data. Although variations exist, a
    substantial number of technical characteristics are consistent
    across the four different architectures.

[^62]: 47 C.F.R. §§ 21.904 and 74.935.

[^63]: *See* 47 C.F.R. §§ 21.902, 21.909, 21.913, 74.903, 74.939, and
    74.985.

[^64]: The minimum distance separation is rounded to the
    nearest kilometer. Additional data is available in Tables 4‑C -- 4‑E
    of Appendix 4.1.

[^65]: *See* 47 C.F.R. §§ 21.902 and 74.903.

[^66]: *Id.*

[^67]: The minimum distance separation is rounded to the
    nearest kilometer. Additional data is available in Tables 4‑F‑4‑H of
    Appendix 4.1.

[^68]: George W. Harter, MSI, "Feasibility Study on Spectrum Sharing
    between Fixed Terrestrial Wireless Services and proposed Third
    Generation Mobile Services in the 2500‑2690 MHz Bands" October 2000.
    *See* Appendix 4.2.

[^69]: For example, ITU‑R Recommendaiton 1457, Detailed Specifications
    of the Radio Interfaced of International Mobile
    Telecommuications‑2000 (IMT‑2000).

[^70]: For example, the value for receiver sensitivity for CDMA‑2000 1x
    used in the Interim Report was --107 dBm and the Industry
    Association Group updated this value to ‑104 dBm total received
    power in a fully loaded system. The updated Report also shows that
    the value of this parameter is --119.6 dBm for a single 9600 bit per
    second (bps) traffic channel in additive white gaussian noise (AWGN)
    for 1% frame error rate (FER).

[^71]: *See e.g.,* Sprint Comments at 17‑18; Verizon Comments at 19.

[^72]: George W. Harter, MSI, "Interference to 3G Systems from ITFS/MDS
    Systems Sharing the Same Frequencies." *See* Appendix 4.3.

[^73]: The study used the center city coordinates and list of cities
    currently in the FCC rules for Part 90 licensees. *See* 47 C.F.R. §
    90.741. We also confirmed that the list of 50 most populated cities
    had not changed significantly by comparing this list with 1999 data
    from the United States Bureau of the Census.

[^74]: The exception is Salt Lake City where 5 channels currently are
    not licensed, although applications have been tendered for 4 of the
    5 channels.

[^75]: Our analysis reflected the 56.3 kilometer (35 mile) radius
    protected service area provided for in the FCC's rules, rather than
    a minimum distance separation zone as shown in tables 4.1 and 4.2.
    Maintaining the standard protected service areas set by our rules
    provides a very conservative estimate of the potential unencumbered
    geographic areas for the 2500‑2690 MHz band and recognizes the
    potential for engineering solutions that might permit sitings closer
    than the separation distances calculated above.

[^76]: Partitioning is the assignment of a portion of a geographic
    service area to another entity. The partitionee becomes the licensee
    for the spectrum in the partitioned area.

[^77]: The circles are drawn with radius 217 kilometers (135 miles)
    rather than 161 kilometers (100 miles) to ensure that receivers
    located at the edge of the 56.3 kilometer (35 mile) protected
    service area are protected.

[^78]: A guard band ensures interference free operations between
    adjacent services by providing a buffer zone in which out‑of‑band
    emissions can attenuate to a point where their liklihood of
    producing adjacent channel interference is minimized.

[^79]: *See* Verizon Comments at 23.

[^80]: *Id.* at 25.

[^81]: *See* VoiceStream Reply Comments at 4.

[^82]: A duplexer is a device that permits simultaneous transmission and
    reception with a common antenna.

[^83]: An estimate of the amount of spectrum needed for a guard band is
    presented later in this Section.

[^84]: An architecture which uses a single main transmitter, sometimes
    referred to as a super‑cell, uses a single base station to provide
    service over the entire service area. It is usually characterized by
    a tall tower and relatively high power. A cellular configuration,
    sometimes referred to as a mini‑cell system, uses many cells to
    serve a geographic area. They will often use low towers and low
    power.

[^85]: We note that the Interim Report incorrectly concluded that the 3G
    spectrum under this option could not be paired for FDD operation.

[^86]: *Id*.

[^87]: The database showed that on average over 4,000 transmitters are
    licensed nationwide on any given 6 megahertz ITFS/MDS channel. Since
    15 channels equates to 90 megahertz of spectrum, over 60,000 (15
    channels \* 4, 000 transmitters per channel) transmitters would be
    affected.

[^88]: The limit on the number of customers that a two‑way MDS system
    can accommodate cannot readily be estimated. It depends on the
    amount of spectrum available, the level of service each individual
    customer contracts for as well as the usage patterns in any specific
    area.

[^89]: MPEG is the Motion Picture Experts Group, which has been working
    to produce standards for digital compression of video signals.

[^90]: *See*, *e.g.*, *Advanced Television Systems And Their Impact Upon
    The Existing Television Broadcast Service*, MM Dockt No. 87‑268,
    *Fourth Report and Order*, 11 FCC Rcd. 17,771 (1996) at ¶ 5.

[^91]: In general, the compression ratios for program material such as
    sports for which high quality is desired and which has lots of
    action and constantly changing video content is much less than what
    can be achieved for a talk show, where the background does not
    change much and picture quality is not as important.

[^92]: *See* Footnote Error: Reference source not found, *supra*.

[^93]: *See* Nucentrix Comments at 11.

[^94]: *See* Cisco Comments at 5. *See* also, Footnote Error: Reference
    source not found, *supra*.

[^95]: *See* Worldcom Comments at 17‑18. Station downconverter overload
    was explained in the Interim Report. ITFS receive stations are
    vulnerable to interference from digital MDS response stations. Such
    interference, intermittent and noise‑like in nature, could occur if
    a transmit site is located nearby an ITFS receive site regardless of
    the frequency separation between the stations. This situation was
    addressed in the *Two‑Way Order* and certain coordination
    requirements were placed on MDS licensees to minimize this
    possibility. *See* *Two‑way Order* at 45‑47 and 56. The effect of
    this situation on 3G systems is that under the contemplated
    segmentation options, even if there is frequency separation between
    3G and ITFS stations, this type of interference could occur from the
    3G system to the ITFS system and render it unusable.

[^96]: *See* Worldcom Comments at 18.

[^97]: *See* WCA Comments at Appendix B, page 5. Sprint concurs that
    this is an accurate estimate. *See* Sprint Comments at 22.

[^98]: *See* Cisco Comments at 7.

[^99]: *See* Appendix 2.1 for IMT‑2000 technical characteristics.

[^100]: *See* 47 C.F.R. §§ 21.902, 21.909, 21.913, 74.903, 74.939, and
    74.985.

[^101]: *See* 47 C.F.R. §§ 21.904(b) and 74.935(b). Additionally, for
    completeness, we assume 125 kilohertz bandwidth for the hub receiver
    bandwidth because many stations continue to use these channels for
    voice channels on the path. Analysis of these stations using the
    maximum 6 megahertz allowed under the rules (to accommodate two‑way
    systems) would produce results similar to the results shown for the
    6 megahertz response stations.

[^102]: A more detailed table is provided in Table 5‑A in Appendix 5.3.

[^103]: In the planning factors tables, we assume, that the interference
    immunity attainable by greater frequency separation is 40 dB
    per megahertz (based on FCC Laboratory measurements of television
    receivers). Because received power is proportional to ,
    each megahertz reduces the distance by 20 dB or a factor of 100.

[^104]: A more detailed table is provided in Table 5‑B in Appendix 5.3.

[^105]: More detailed tables are provide in Tables 5‑C and 5‑D in
    Appendix 5.3.

[^106]: *See* Verizon Comments at 14 and Appendix A.

[^107]: *See* Cisco Comments at 9‑10.

[^108]: *Id*.

[^109]: *See* Worldcom Comments at 18.

[^110]: *See* Verizon Comments at Appendix A. *See also*, 47 C.F.R. §
    21.908(d) for a description of the emission limitaitons.

[^111]: *See* Cisco Comments at 10.

[^112]: *See* WCA Comments at Appendix B, Page 17. These are the data
    rates offered to each customer. The channel can support higher data
    rates. Data rates for commercial customers are higher: 1,024 kbps
    downstream and 512 kbps upstream.

[^113]: *See* *Deployment fo Advanced Telecommunications Capability:
    Second Report*, Federal Communications Commission, rel. August 2000
    at C‑1. This report is available on the internet at:
    <http://www.fcc.gov/broadband>.

[^114]: *Id*. at C‑2.

[^115]: *Id*. at C‑5.

[^116]: *Id*.

[^117]: This figure was provided by Worldcom in a presentation to the
    FCC on October 11, 2000. It has been used with the permission of
    Worldcom.

[^118]: In this case, the MDS operator needs appoximately 160 MHz total
    (32 miles x 32 miles x =3217 square miles x
    0.05 megahertz/square mile) to serve customers in this cell. The
    160 megahertz compares favorably with the commenters statements that
    approximately 156 megahertz of spectrum is needed.

[^119]: 160 megahertz is used for our analysis rather than the full
    202 megahertz available to ITFS/MDS serivces (190 megahertz
    available in the 2500‑2690 MHz band and 10‑12 megahertz available in
    the 2150‑2160/62 MHz band). According to commenters this is typical
    of the amount of spectrum they have available in each market.

[^120]: This assumes leaving the existing transmitter in its current
    location. However, it may be possible to reduce this to 2‑3
    additional transmitter sites, if the existing transmitter is
    relocated. HAI, in its study, determined that a 90 MHz reduction in
    spectrum available to MDS would increase the number of cell sites by
    a factor of 2.7 for the larger markets. *See* WCA Comments at
    Appendix B, page 25.

[^121]: *See* Cisco Comments at 10.

[^122]: *Id.*

[^123]: *Id.*

[^124]: *See* "ITFS/MDS Channel Licensing" on page
    [32](#itfsmds-channel-licensing).

[^125]: *See* *Amendment of Section 2.106 of the Commission\'s Rules to
    Allocate Spectrum at 2 GHz for Use by the Mobile Satellite Service*,
    ET Docket No. 92‑9, *Second Report and Order*, 8 FCC Rcd 6495 (1993)
    (\"*Emerging Technology Proceeding*\").

[^126]: ITFS/MDS currently occupies a total of 202 megahertz of spectrum
    (12 megahertz from 2150‑2162 MHz and 190 megahertz from
    2500‑2690 MHz).

[^127]: *See* 47 C.F.R. § 2.106.

[^128]: There are also proposals to use Fixed‑satellite networks to
    provide internet services to rural and un‑served areas directly to
    end users. *See FWCC Request for Declaratory Ruling on Partial‑Band
    Licensing of Earth Stations in the Fixed Satellite Service that
    Shared Terrestrial Spectrum*, IB Docket No. 00‑203, *Notice of
    Proposed Rule Making*, 15 FCC Rcd. 23127 (2000). ("*FWCC/ONSAT
    NPRM*")

[^129]: The purpose of registration is to receive protection from
    interference from terrestrial Fixed service operations. Receive‑only
    earth stations used for cable head‑ends and feeds to terrestrial
    broadcast networks are registered particularly in congested urban
    areas to avoid the possibility of receiving interference that would
    result in disruption of service to their end users.

[^130]: *See Emerging Technology Proceeding*.

[^131]: *See Request of Declaratory Ruling and Petition for Rule Making*
    filed on May 5, 1999 by the Fixed Wireless Communication Coalition,
    RM‑9649; *see also*, *Notice of Proposed Rule Making*, IB Docket No.
    00‑203, 15 FCC Rcd 23127 (2000).

[^132]: The greatest impact of using higher frequencies would be on the
    return link from the subscriber location, particularly in rural
    deployments where longer distance communication is necessary. We
    note that the higher frequency bands support various fixed services
    that are different from the residential and educational services
    provided by ITFS/MDS, especially in rural areas and smaller markets.

[^133]: *See Emerging Technology Proceeding*.

[^134]: *See* 47 C.F.R. § 2.106.

[^135]: *See Emerging Technology Proceeding*.

[^136]: *See Amendment of Parts 2,25, and 97 of the Commission's Rules
    with Regard to the Mobile Satellite Service above 1 GHz*, ET Docket
    No. 98‑142, *Notice of Proposed Rule Making,* 13 FCC Rcd 17107
    (1998). ("*MSS FeederLlinks*")

[^137]: *See* Assessment for bands 3700‑4200 and 5925‑6425 MHz, as
    discussed above.

[^138]: *See MSS Feeder Links.*

[^139]: *Id.*

[^140]: *See* NTIA Report 00‑378, *Spectrum Usage for the Fixed
    Services*, March 2000.

[^141]: *See* 47 C.F.R. § 2.106.

[^142]: *See* Appendix 6.3, footnote NG41.

[^143]: *See Amendment of Part 2 and 25 of the Commission's Rules to
    Permit Operation of NGSO FSS Systems Co‑Frequecy with GSO and
    Terrestrial Systems in the Ku‑Band Frequency Range, et al,* ET
    98‑206, *First Report and Order and Further Notice of Proposed Rule
    Making,* 66 Fed. Reg. 10601 (February 16, 2001). ("*NGSO FSS
    Proceeding*")

[^144]: *See* 47 C.F.R. § 2.106, footnote NG104.

[^145]: The GSO FSS operations in the 10.7‑10.95 GHz and 11.2‑11.45 GHz
    bands must adhere to the requirements specified in Appendix 30B of
    the ITU Radio Regulations and are referred to as \"planned band\"
    operations. GSO FSS operations are typically less extensively
    deployed in the Appendix 30B planned bands, as compared to
    non‑planned bands. *See* 47 C.F.R. § 2.106 of the Commission\'s
    Rules, footnote 792 A; and ITU RR Footnote No. S5.441 and Appendix
    30B of the ITU‑R Radio Regulations *Provisions and Associated Plan
    for the Fixed‑Satellite Service in the Frequency Bands
    4500‑4800 MHz, 6725‑7025 MHz, 10.70‑10.95 GHz, 11.20‑11.45 GHz and
    12.75‑13.25 GHz*. Use of these frequency bands is also governed by
    Resolution 130 (WRC‑97).

[^146]: The GSO FSS operations in this band perform TT&C communications
    to provide data on the spacecraft\'s functions via a two‑way
    telemetry link between the satellite and the controlling earth
    station. TT&C communications are used throughout the satellite\'s
    life, including the launch and deployment phase. The TT&C function
    allows the earth station to control both the physical orbital
    position and internal functioning of the spacecraft.

[^147]: *See* *NGSO FSS Proceeding*.

[^148]: *See* *Amendment of Section 2.106 of the Commission\'s Rules to
    Allocate Spectrum at 2 GHz for Use by the Mobile Satellite Service*,
    ET Docket No. 92‑9, *Second Report and Order*, 8 FCC Rcd 6495 (1993)
    (\"Emerging Technology proceeding\"). *See also* *First Report and
    Order & Further Notice of Proposed Rule Making*, ET Docket No.
    95‑18, 12 FCC Rcd 7388 (1997) (\"2 GHz MSS allocation proceeding\").

[^149]: *See* 47 C.F.R. § 101.147(p).

[^150]: *See* *NGSO FSS Proceeding*.

[^151]: *See also Petition for Rulemaking To Amend Eligibility
    Requirements in Part 78 Regarding 12 GHz Cable Television Relay
    Services*, CS Docket No. 99‑250, *Notice of Proposed Rule Making*,
    14 FCC Rcd 11,967.

[^152]: *See* ITU Radio Regulations, Appendix 30B and 47 C.F.R. § 2.106
    footnote NG104. We note that there is one licensee using the U.S.
    Appendix 30B assignment in this band for domestic feeder links for a
    GSO MSS system.

[^153]: Our database indicates that there are 9 authorizations issued
    for GSO FSS earth stations in the 12.75‑13.25 GHz band. These
    authorizations do not indicate the actual number of earth stations
    or antennas that a licensee might deploy. Additionally, this number
    may not include several international earth station authorizations
    issued before 1995 when the IBFS database was created.

[^154]: All the bands studied have a satellite allocation (*i.e.,*
    fixed‑satellite or broadcasting‑satellite), except the band
    7075‑7125 MHz. *See* Table 6.1, *supra*.

[^155]: *See* Section 1, *supra*.

[^156]: *See, e.g.,* 47 C.F.R. §§ 101.69‑101.83.

[^157]: Sprint has spent \$1.24 billion to acquire MDS licenses in 90
    markets; WorldCom has spent \$1.1 billion to acquire licenses in 78
    markets.

[^158]: The National ITFS Association (NIA) estimates that typical lease
    arrangements between ITFS licensees and MDS operators could generate
    earning of approximately \$7.2 billion over the next 15 years for
    ITFS licensees. *See* NIA Supplemental Comments (filed March 20,
    2001) at 6‑7.

[^159]: This information is available at the CBO's webpage,
    [www.cbo.gov.](http://www.cbo.gov./)

[^160]: *See* 47 U.S.C. § 309(j).

[^161]: *See* "Military, Industry Not In Lockstep On 3G Spectrum Issue"
    *Communications Daily*, February 16, 2001. The article states that
    the "Senate Budget Committee bulletin this week said Congressional
    Budget Office (CBO) had 'dramatically' raised its estimate of
    spectrum auction receipts by \$10 billion over previous baseline.
    CBO increased baseline 55% to \$28 billion over 2002‑2007. It
    attributed change to 'market enthusiasm' for 3G and cited
    \$17 billion generated by FCC\'s C‑block auction last month."

[^162]: This auction was for C and F Block broadband PCS licenses that
    were in default. The auction began on December 12, 2000 and closed
    on January 26, 2001. *See* http://www.fcc.gov/wtb/auctions/

[^163]: *See* *Annual Report and Analysis of Competitive Market
    Conditions with Respect to Commercial Mobile Services*, *Fifth
    Report* (*Fifth Competition Report*), FCC00‑289, released August 18,
    2000.

[^164]: *Id.* at 34‑35.

[^165]: *See The Economic Impact of Third‑Generation Wireless
    Technology.*

[^166]: Analysts estimate that for a variety of technical, financial and
    operations reasons, cable modem and xDSL services cannot or will not
    meet the increasing demand for broadband by themselves. *See, e.g.,
    The Wall Street Journal*, "\[t\]he cable industry's rush to wire up
    America with high‑speed Internet access is running into a serious
    problem: Too many heavy Internet users are crowding online at once,
    in some cases creating major bottlenecks and slowdowns." Cauley,
    "Heavy Traffic is Overloading Cable Companies' New Internet Lines,"
    *The Wall Street Journal*, at B1, B16 (Mar. 16, 2000). In addition,
    the need for cable operators to upgrade their plant for two‑way
    capability (particularly in less densely populated areas) and the
    business strategies of the large cable MSOs suggest that cable modem
    service will not be ubiquitously available. *See* *Broadband! ‑ A
    Joint Industry Study by Sanford C. Bernstein & Co., Inc. and
    McKinsey & Company, Inc.*, at 25‑26 (January 1999). ("The nature of
    smaller and more rural systems ‑‑ often with less access to capital;
    less threat of competition; and less dense and, therefore, more
    expensive plant to upgrade ‑‑ keeps our forecast for \[non‑MSO\]
    systems at about 15% upgraded. . . It's worth pointing out that many
    of the cable upgrades to date appear to be targeted at the most
    attractive neighborhoods (*i.e.*, high densities and high household
    incomes). On a homes‑passed basis, we estimate that about 60%
    (12 million) of all high‑income households in the U.S. are passed by
    upgraded cable plant.") (the "Bernstein/McKinsey Study"). Ubiquitous
    xDSL services are unavailable due to factors that include "loop
    length (if loops are too long), presence of non‑DSL compatible
    remote terminal technology (such as nearly all the legacy variety of
    digital loop carrier systems) as well as other aspects of deployed
    line electronics, such as load coils and bridge taps."
    Bernstein/McKinsey Study at 25. Indeed, it has been estimated that
    existing telephone plant is "DSL capable" in only 44% of the
    residential market. *Id.* at 26. *See also* *Next‑Generation
    Networks Exploit Last‑Mile Bandwidth*, *TR's Last‑Mile Telecom
    Report* (Feb. 24, 2000)
    \<http://www.tr.com/newsletters/lmtr/sample.html\> (quoting officer
    of Bell Atlantic Network Services as referring to DSL as an "interim
    strategy"); Cauley, "For Phone Companies Wiring the Web, a
    Surprising Speed Bump," *The* *Wall Street Journal*, at B1 (Feb. 17,
    2000).

[^167]: "The Broadband Fixed Wireless Services Market Gains Momentum,
    According to IDC," *PR Newswire* (Dec. 13, 1999). All totaled, it
    has been estimated that by the year 2005, seventy percent of the
    nearly 10 million estimated fixed wireless broadband subscribers
    will be served via ITFS/MDS.

[^168]: Smith, "Wireless Rides To The Rescue," *Wireless Week*, at 16
    (Feb. 7, 2000).

[^169]: *See, e.g.,* Comments filed by The Wireless Communications
    Association, Inc. (WCAI), Sprint Corporation (Sprint), Cisco
    Systems, Inc. (Cisco). WCAI submitted a study prepared by HAI
    Consulting, Inc. titled "MDS/MMDS/ITFS Two‑Way Wireless Broadband
    Service; Spectrum Requirements and Business Case Analysis" (HAI
    Study).

[^170]: The Association of American Public Television Stations ("APTS")
    states that WITF, a public television ITFS licensee in Pennsylvania
    with 16 ITFS channels and 4 sites, calculates that its total costs
    to relocate would be \$420,500. This includes the cost of
    transmitters, combiners, feed lines, antennas, and receive
    equipment. APTS states that because these costs represent only
    replacing certain analog equipment, they do not necessarily provide
    a complete assessment of the equipment costs that would be incurred
    upon relocation of an ITFS licensee to some other band where
    equipment has not yet been developed and propagation characteristics
    and other engineering factors may be different. Also, APTS states
    that there may be additional relocation costs attributable to
    professional or other personnel costs; securing additional
    transmitter sites, transmission equipment and backhaul links, or
    more expensive receive site equipment; loss of operational and
    maintenance support; lost revenues from the invalidation of excess
    capacity agreements that would otherwise be used to support a
    station's educational mission; and costs related to the impairment
    of the station's educational services during the time of transition
    and thereafter. *See* APTS *ex parte* communication, ET Docket
    00‑258, March 20, 2001.

[^171]: Cisco estimates that guardbands could reduce spectrum
    availability for ITFS/MDS by up to 54 megahertz.

[^172]: *See, e.g.,* Cisco Comments at 9‑11. Cisco states that its
    equipment, which was designed without taking into account adjacent
    mobile operations, would need 18 megahertz of guardband and thus
    would have to be reengineered.

[^173]: *See, e.g.,* Cisco Comments at 10. Cisco cites the need to
    redesign both hardware and software; revisit component supply chains
    and partner agreements; duplicate lab and field trials; and
    reinitialize manufacturing plants.

[^174]: *See, e.g.,* Cisco Comments at 11.

[^175]: *See, e.g.,* HAI Study at 6.

[^176]: *See* Cisco Comments at 11‑13.

[^177]: *See, e.g.,* Comments filed by WCAI, Cisco, Sprint and WorldCom.

[^178]: The sample markets, based on BTA population, ranged in size from
    100,000 to 18,750,000 POPS and from 38,206 to 7,156,489 households.

[^179]: As noted in Section 5, HAI assumed that 158 megahertz of
    spectrum (26 six megahertz channels, plus an additional 2 megahertz)
    would be available to each ITFS/MDS two‑way system. Reducing the
    amount of available spectrum by 90 megahertz reduces the available
    spectrum to 11 six megahertz channels. *See* HAI Study at 5‑6. Cisco
    states that its network design assumed 162 megahertz of spectrum
    available in dense urban markets using a micro‑cell architecture,
    and 132 megahertz in small markets using a single super‑cell
    configuration. *See* Cisco Comments at 7.

[^180]: In the large market they studied, Cisco found that base station
    deployment would triple. *See* Cisco Comments at 12.

[^181]: *See* HAI Study at 24‑28.

[^182]: *See* WCA Supplemental Comments, March 21, 2001, at 4‑5.

[^183]: *See* Cisco Comments at 12.

[^184]: *See, e.g.,* 47 C.F.R. § 101.75. *See also* 47 C.F.R. § 101.79,
    which specifies sunset provisions for incumbent licensees in the
    1850‑1990 MHz, 2110‑2150 MHz, and 2150‑2160 MHz bands. In those
    bands, emerging technology licensees are not required to pay
    relocation costs to incumbents ten years after the voluntary
    negotiation period begins for the first emerging technology
    licensees.

[^185]: *See* NIA Supplemental Comments of March 20, 2001, at 4.

[^186]: NIA states that 2400 existing ITFS stations account for 8000
    licensed ITFS channels with 8000 transmitters, 2000 combiners (one
    for every four channels), and 1200 transmission lines and antennas
    (two for each site). NIA also states that there are approximately
    700,000 ITFS receive sites. *Id.*

[^187]: *Id*.

[^188]: *Id.* at 3‑4.

[^189]: *Id.* at 5‑6.

[^190]: *Id.* at 6‑7.

[^191]: *See* HAI Study at 9; Cisco Comments at 14.

[^192]: Cisco Comments at 13.

[^193]: *Id.* at 13‑14.

[^194]: *Id.* at 15.

[^195]: *See* HAI Study at 19‑22.

[^196]: This estimate includes towers, antennas, transmission lines,
    transmitter combiners, receive multicouplers, duplexers, backup
    power, network management and monitoring equipment, and IP
    switching/routing. *Id*. at 19.

[^197]: This estimate includes towers, antennas, transmission lines,
    transmitter combiners, receive multicouplers, duplexers, backup
    power, network management and monitoring equipment, and fixed
    investment for the radio system. *Id*. at 20.

[^198]: For fixed point‑to‑point links, we use the \$250,000 per link
    figure specified for Personal Communications Services relocation;
    *see* 47 C.F.R. § 24.243(b). For fixed point‑to‑multipoint links,
    our research indicates that the cost of approximately 70‑72
    point‑to‑multipoint links equals the cost of one point‑to‑point
    link, and \$250,000 divided by 70‑72 equals about \$3,500. For
    mobile links, our research indicates that such links are generally
    about \$100,000 less expensive than fixed point‑to‑point links;
    therefore, we use a figure of \$150,000 per mobile link. For GSO
    satellite systems, our research indicates that an average system
    costs about \$400‑500 million to construct and launch; therefore, we
    use a figure of \$450 million per GSO satellite. All of these
    figures are rough approximations that we feel are adequate for the
    purposes of this report, but that should not be used in other
    contexts where greater accuracy is required.

[^199]: This estimate does not include an estimated cost of a number of
    low‑earth orbit and digital audio radio satellite services feeder
    links that operate in the 6700‑7075 MHz band, which would be
    significant.

[^200]: We note that this number includes 25 satellites that operate in
    the 11.7‑12.2 GHz band, which is paired with the 14.0‑14.5 GHz band.