**INTERIM REPORT**

# November 15, 2000

**SPECTRUM STUDY OF THE**

**2500‑2690 MHz BAND**

**The Potential for Accommodating**

**Third Generation Mobile Systems**

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height="1.8006944444444444in"}

Federal Communications Commission

Staff Report Issued by:

Office of Engineering and Technology

Mass Media Bureau

Wireless Telecommunications Bureau

International Bureau

**ACKNOWLEDGEMENTS**

This Initial 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, Rebecca Dorch, Robert Eckert, Bruce
> Franca, Kathryn Hosford, Ira Keltz, Julius Knapp, Geraldine Matise,
> Fred Thomas

## Mass Media Bureau

Melvin Collins, Charles Dziedzic, Joe Johnson, Keith Larson, Brad
Lerner, David Roberts, Thomas Wilchek

## Wireless Telecommunications Bureau

Diane Cornell, Charles Rush

## International Bureau

Charles Breig, Richard Engelman, Ari Fitzgerald, Trey Hanbury, Henry
Straube

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

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)

2\. 3G SYSTEM DESCRIPTION [5](#section-2)

3\. INCUMBENT SYSTEMS IN THE 2500‑2690 MHz BAND [17](#section-3-1)

4\. STUDY ASSUMPTIONS AND METHODOLOGY [36](#section-4)

5\. EVALUATION OF SPECTRUM SHARING [39](#section-5)

6\. BAND SEGMENTATION ANALYSIS [54](#band-segmentation-analysis)

[Appendices]{.underline} [Page]{.underline}

APPENDICES FOR SECTION 1 A-1

APPENDICES FOR SECTION 2 A-21

APPENDICES FOR SECTION 3 A-33

APPENDICES FOR SECTION 5 A-56

## EXECUTIVE SUMMARY

This Interim Report describes the current uses of the 2500 -- 2690 MHz
band and analyzes the potential for sharing that band with third
generation (3G) wireless systems. This band is one of several frequency
bands identified at the 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 Interim Report examines the nature and technical characteristics of
planned 3G services, the current and planned use of this 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.

The Interim Report is consistent with a memorandum executed by the
President on October 13, 2000 (Presidential Memorandum) and a subsequent
Study Plan released on October 20, 2000 by the Department of Commerce.
The Presidential Memorandum articulates the need to select radio
frequency spectrum to satisfy the United States' future needs for mobile
voice, high speed data, and wireless Internet capability. The
Presidential Memorandum establishes for the Executive Agencies guiding
principles to be used in selecting spectrum that could be made available
for 3G wireless systems, and strongly encourages independent federal
agencies to follow the same principles in any actions they take related
to the development of 3G systems. Noting the joint spectrum management
responsibilities of the Executive Branch and the Federal Communications
Commission (FCC), the Presidential Memorandum directs the Secretary of
Commerce to work cooperatively with the FCC: (1) to develop a plan to
select spectrum for third generation wireless systems by October 20,
2000; and (2) to issue by November 15, 2000 an interim report on the
current spectrum uses and potential for reallocation or sharing of the
bands identified at WRC‑2000 that could be used for third generation
wireless systems. These actions are to enable the FCC to identify
spectrum for third generation wireless systems by July 2001 and auction
licenses by September 30, 2002.[^1]

In accordance with the Presidential Memorandum, the Department of
Commerce released a "Plan to Select Spectrum for Third Generation (3G)
Wireless Systems in the United States" (Study Plan) on October 20, 2000.
The Study Plan noted that although various frequency bands have been
identified for possible 3G use, the FCC and the National
Telecommunications and Information Administration (NTIA) needed to
undertake studies of the 2500‑2690 MHz and the 1755‑2850 MHz frequency
bands in order to provide a full understanding of all the spectrum
options available. The Study Plan calls for the FCC to complete an
Interim Report on the 2500--2690 MHz band and for NTIA to complete an
Interim Report on the 1755--1850 MHz band by November 15, 2000. A final
report will be issued by March 1, 2001 that will examine whether it may
be necessary to reallocate spectrum for incumbent services, and if so,
what spectrum may be made available and the costs.

The Interim Report represents the results of analyses by the 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 the Interim Report are as follows:

-   The 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 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 global consensus as to how the frequency bands
    identified at WARC‑92 and WRC‑2000 will be used to implement 3G, or
    whether 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 currently 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 and is 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; 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 initial 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 would cause
    extensive interference to incumbent ITFS and MDS systems. This is
    because the 2500‑2690 MHz band is either used or soon to be used by
    ITFS and MDS systems in most populated areas of the country. 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 as an interim
    measure.

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-   Segmenting the 2500 -- 2690 MHz band to enable third generation
    mobile wireless systems access to this spectrum would raise
    technical and economic difficulties for incumbents. While there may
    be long term options to segment the 2500-2690 MHz, segmentation
    could affect the economics of current and planned ITFS and MDS
    systems and their ability to provide service to rural areas. In
    addition, any segmentation option would have to account for the
    flexible service configurations and offerings that incumbent
    licensees are currently implementing.

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

## SECTION 1

## INTRODUCTION

This Interim Report addresses the current spectrum uses and the
potential for sharing or segmenting the 2500‑2690 MHz band for possible
third generation (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
International Telecommunication Union (ITU) and on information provided
by industry.

This Interim 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 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 will undertake
studies of two frequency bands identified by WRC‑2000 for possible 3G
use. NTIA will undertake the study of the 1755‑1850 MHz band, and the
FCC will study 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.

The Study Plan notes that the studies will be conducted in two phases.
An Interim Report on each band is to be released by November 15, 2000; a
Final Report on each band is to be released by March 1, 2001. The
Interim Report is to include a description of 3G systems, a description
of incumbent systems, and an evaluation of system sharing and band
segmentation options. The Final Report will 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, will initiate
the Department's outreach program to industry. The FCC also intends to
solicit industry input through its rulemaking and other procedures. The
purpose of these activities is to develop recommendations and plans for
identifying spectrum for 3G wireless systems. In addition to regular
government‑industry public meetings, industry will be able to comment on
the Initial Reports when they are released.

## 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. As already noted, the FCC has undertaken this
study of the 2500‑2690 MHz band, which is one of the bands identified by
WRC‑2000 for possible use by 3G systems. In addition, the FCC plans to
issue a Notice of Proposed Rulemaking (NPRM) before the end of the year
to examine and propose spectrum for allocation to the fixed and mobile
service that would be capable of being used to provide 3G wireless
service. As noted in the Study Plan, a number of frequency bands,
including those identified by WARC‑92 and WRC‑2000, are capable of
supporting third generation mobile wireless systems. The FCC will fully
explore the extent to which various frequency bands may be used to
provide spectrum for 3G services. This Interim Report on the
2500‑2690 MHz band will become part of the official record for the
rulemaking proceeding, and comments on this Initial Report will be
considered in the context of that proceeding. The rulemaking proceeding
also will invite comment on the Interim Report for the 1755‑1850 MHz
band that NTIA is preparing.

The FCC has generally expressed strong support for providing spectrum
opportunities for 3G services. For example, many of the decisions
reached in the FCC's reallocation of spectrum in the 700 MHz region for
fixed and mobile services are designed to enable that spectrum to be
used for 3G or other advanced communications services determined by the
market. In addition, the FCC's November 1999 Spectrum Policy Statement
announced that spectrum in the 1710‑155 MHz, 2110‑2150 MHz and
2160‑2165 MHz bands may be proposed for allocation for advanced mobile
and fixed communications services, such as 3G.[^2] The FCC's recent
report to Congress on competition in the commercial mobile radio
services also discusses generally the FCC's policies allowing 3G
services to be introduced in existing frequency bands.[^3]

## SCOPE OF INTERIM 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. 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 planned FCC rulemaking. The
assumptions made at this time are intended to facilitate initial
analyses and are not intended to prejudge or foreclose other future
options.

The Interim Report is organized in the following manner.

Section 2 describes 3G system requirements. In particular, this section
describes the proposed uses of 3G systems; the technical characteristics
for 3G systems developed by the ITU; and international spectrum
considerations for 3G systems.

Section 3 describes incumbent ITFS and MDS systems in the 2500‑2690 MHz
band. This section focuses on: (1) the nature of use, including the band
allocation and ITFS/MDS service descriptions; (2) spectrum usage,
including the ITFS/MDS band channel plan, leasing arrangements, and
flexible channel use; (3) ITFS/MDS geographic deployment; (4) ITFS/MDS
system characteristics, including both one‑way and two‑way systems; and
(5) ITFS/MDS interference protection standards.

Section 4 describes the assumptions that form the basis for this band
study, including spectrum requirements for 3G systems.

Section 5 evaluates the spectrum sharing options between ITFS/MDS and
potential 3G systems. In particular, it examines 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 6 describes possible options for segmenting the 2500‑2690 MHz
band to provide spectrum for 3G systems. This section does not address
whether it may be necessary or appropriate to reallocate additional
spectrum to compensate for the reduction in spectrum available for
incumbent systems, nor does it address the costs that would be incurred
if ITFS/MDS systems were relocated to other parts of the spectrum. These
matters will be addressed in the final report.

## SECTION 2

## 3G SYSTEM DESCRIPTION

The Study Plan calls for the FCC to provide a description of 3G system
requirements. This description is to 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 order to simplify the presentation of the material called for in the
Study Plan, we have combined the discussion of related items. For
example, the discussion on 3G technical characteristics also addresses
interference thresholds. The discussion on 3G spectrum requirements
addresses 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 is discussed in our
analyses of spectrum sharing and band segmentation in Section 5 and 6 of
this Initial 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).[^4] Therefore, for the purposes of
this Interim Report, we rely 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
initial 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 OF 3G SYSTEMS**

According to the ITU, IMT‑2000 systems are third generation mobile
systems that are scheduled to start service around the year 2000 subject
to market considerations. They will provide access, by means of one or
more radio links, 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;

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-   capability for multimedia applications, and a wide range of services
    and terminals.[^5]

#  

Table 2.1, shown below, 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                                     |
+-----------------------------------------------------------------------+

IMT‑2000 systems will support a wide range of services based on fixed
telecommunication networks and mobile networks. 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. Services will be
available in a variety of situations, both indoor and outdoor, and in a
range of environments including dense urban (including high intensity
office use), suburban, rural and remote areas. Land, maritime, and
aeronautical environments are to be included within IMT‑2000 systems so
that the user in a vehicle, on a ship, or in an aircraft will have
continuous availability of services.

Services will cover a wide range of offerings, including basic wide area
paging, voice telephony (probably the prime requirement of the personal
terminal), digital data services, and audio and visual communications.
The actual services obtained by a user will depend on their terminal
capabilities, a subscribed set of services, and the service offerings
provided by the relevant network operator. Services requiring high
transmission rates are most likely to be found in high density areas,
such as business centers. Many new applications will be developed for
IMT‑2000 systems, of a nature that cannot readily be forecast today.

A key objective of IMT‑2000 is to enable users of personal terminals to
go anywhere in the world and to have access to a minimum set of
services, such as voice telephony and a selection of data services.
IMT‑2000 also could provide services to fixed users and for any
circumstance where a rapid and economical implementation of fixed
communications is required. This capability is of particular interest to
developing countries.

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.

**TECHNICAL CHARACTERISTICS OF 3G SYSTEMS**

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.[^6] These are as follows:

(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 MHz 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 MHz
    and 3.75 MHz are supported at this time but the specification can be
    extended to bandwidths up to 15 MHz.

(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 MHz bandwidth and a chip rate of 3.84
    Mcps, and TD‑SCDMA that uses 1.6 MHz 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 MHz 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.

A more comprehensive list of the technical characteristics for each of
these interfaces is included in Appendix 2.1. As can be seen from above
and in the detailed specifications of these interfaces, 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 FOR 3G SYSTEMS

As indicated in the Study Plan, a number of frequency bands have been
identified for possible use by terrestrial 3G operations. For example,
the 806‑960, 1710‑1885 and 2500‑2690 MHz bands were identified for
possible use by terrestrial IMT‑2000 systems by WRC‑2000. 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 discussion below provides information on various international and
domestic developments concerning the identification of frequency bands
for possible use by future 3G systems.

# International Spectrum Developments

# At the 1992 World Administrative Radiocommunication Conference (WARC‑92), the 1885‑2025 MHz and 2110‑2200 MHz bands were identified for use by countries wishing to implement future public land mobile telecommunication systems (FPLMTS). WARC‑92 noted however that such use does not preclude the use of these bands for other allocated uses.[^7] At the 1997 World Radio Conference, FPLMTS became IMT‑2000.[^8] 

# 

# Like many nations in North and South America, and in Asia, the United States allocated to other uses portions of the bands that WARC‑92 identified for IMT‑2000 systems, recognizing that new commercial mobile services were needed long before the 2000 timeframe envisioned by the ITU for IMT‑2000. Shortly after WARC‑92, the FCC conducted auctions to license Personal Communication Services (PCS) in the 1850‑1910 MHz and 1930‑1990 MHz band pair. These extremely successfully PCS auctions not only prompted aggressive competition in the United States mobile telecommunications market, but also stimulated the demand for even more advanced wireless services. 

> 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.

*[WRC‑2000 Preparations.]{.underline}* During its preparations for
WRC‑2000, the United States, responding to the large anticipated demand
for IMT‑2000 systems and realizing that various countries around the
world use the same frequencies to support different spectrum‑consuming
services, identified three major goals for identifying future spectrum
for IMT‑2000 use. First, the United States wanted the ITU to identify
more than one band pair for IMT‑2000 use. The rationale for a multi‑band
approach was that not all countries in the world require equal amounts
of spectrum to support future wireless services. Identifying more than
one band pair for IMT‑2000 would allow countries to tailor their
domestic band plans to their economic development and domestic
priorities. Moreover, identifying a single band pair for IMT‑2000 use
would fail to consider the possibility that some nations already might
have encumbered the identified bands with equally vital services that
could not be displaced or relocated without significant strategic or
economic hardship.

Second, the United States sought to convince ITU members to allow
nations to choose freely among several, equally valid bands for IMT‑2000
use. While global roaming might be improved by elevating a single band
pair as the preferred band for IMT‑2000 use, such a mandatory
harmonization effort would just as likely stifle competition and
technological development. A policy of equality among bands identified
for IMT‑2000 use would allow nations to tailor their domestic band plans
to their specific needs and regulatory developments within a coherent
global framework.

Third, the United States wanted the ITU to adopt a technology‑neutral
approach in identifying frequency bands for possible 3G system use.
Industry decisions about which technology to deploy for third generation
wireless systems should rest on sound engineering, not on international
spectrum policies. A technologically neutral approach would allow
companies to compete based on price and quality, rather than for
spectrum allocations that favored particular interests.

Going into WRC‑2000, different regions of the world supported the
identification of different additional bands for IMT‑2000. The member
countries of the European Conference of Postal and Telecommunications
Administrations (CEPT), for example, proposed the 2500‑2690 MHz band as
the additional band for IMT‑2000 because in parts of Europe the
1710‑1885 MHz band is occupied by second generation mobile (GSM‑1800).
Most of the countries in the Western Hemisphere, by contrast, favored
the 1710‑1850 MHz band as the additional band for IMT‑2000 because the
2500‑2690 MHz is occupied in many countries by Multipoint Distribution
Systems (MDS). Meanwhile, the Asian‑Pacific countries split between
support for the 1710‑1850 MHz band and the 2500‑2700 MHz band.

During preparations for WRC‑2000, the United States committed to
studying the feasibility of using all or parts of the 1710‑1850 MHz and
2500‑2690 MHz bands for IMT‑2000 operations.[^9] The United States said
it would consider the impact of the operation of IMT‑2000 systems on the
systems already licensed to operate in these bands. The current study
represents a step toward determining which of the bands or portion of
the bands the ITU identified for IMT‑2000 will be made available for
such operations in the United States.

*[WRC‑2000 Results]{.underline}.* Despite competing national and
regional priorities, the United States achieved its three major goals at
WRC‑2000. Most ITU member nations agreed that the ITU should identify
multiple bands for IMT‑2000 use. Member nations also agreed that the ITU
should reject attempts to assign certain bands priority and to prescribe
certain technologies for exclusive use in those bands. Based in large
part on United States proposals, WRC‑2000 identified the bands listed in
the following Table as suitable for IMT‑2000 use[^10].

Table 2.2: WRC‑2000 Additional IMT‑2000 Bands

  -----------------------------------------------------------------------
  **Frequency Band**                  **Proposed by:**
  ----------------------------------- -----------------------------------
  806[^11]‑960 MHz                    United States

  1710‑1885 MHz                       United States; CITEL[^12]

  2500‑2690 MHz                       United States; CEPT[^13]
  -----------------------------------------------------------------------

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.[^14] The principles that are recognized in these resolutions
allowed international consensus on the three frequency bands listed in
the above table.

The key principles reflected in the WRC‑2000 resolutions are as follows:

-   the sharing implications between services sharing the bands
    identified for IMT‑2000 will need further study in ITU‑R;

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-   studies regarding the availability of the bands 1710‑1885 MHz and
    2500‑2690 MHz for IMT‑2000 are being conducted in many countries,
    the results of which could have implications for the use of those
    bands in those countries;

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-   due to differing requirements, not all administrations may need all
    of the IMT‑2000 bands identified at the conference, or, due to the
    usage by and investment in existing services, may not be able to
    implement IMT‑2000 in all of those bands;

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-   currently operating second‑generation mobile communication systems
    may evolve to IMT‑2000 in their existing bands;

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-   services such as fixed, mobile (second‑generation systems), space
    operations, space research and aeronautical mobile are in operation
    or planned in the band 1710‑1885 MHz, or in portions of that band;

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-   services such as broadcasting‑satellite, broadcasting‑satellite
    (sound), mobile‑satellite and fixed (including multipoint
    distribution/communication systems) are in operation or planned in
    the band 2500‑2690 MHz, or in portions of that band;

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-   the identification of several bands for IMT‑2000 allows
    administrations to choose the best band or parts of bands for their
    circumstances;

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-   flexibility must be afforded to administrations to:

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-   determine, at a national level, how much spectrum to make available
    for IMT‑2000 from within the identified bands;

-   develop their own transition plans, if necessary, tailored to meet
    their specific deployment of existing systems;

-   have the ability for the identified bands to be used by all services
    having allocations in those bands; and

-   determine the timing of availability and use of the bands identified
    for IMT‑2000, in order to meet particular market demand and other
    national considerations.

In summary, the WRC‑2000 results allow countries flexibility in deciding
how to implement IMT‑2000 systems. 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.

WRC‑2000 took no further action with regard to the frequency bands
identified for IMT‑2000 at WARC‑92. Thus, the frequency bands
1885‑2025 MHz and 2110‑2200 MHz bands may also be used to implement
IMT‑2000 systems.

**Further 3G Spectrum Studies**

In addition to identifying additional spectrum that should be considered
for implementing IMT‑2000 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[^15] 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. In response to this Resolution 223, ITU‑R generally will study
the following areas:

-   sharing implications and possibilities for all services having
    allocations in the identified frequency bands;

-   harmonized frequency arrangements for the implementation of IMT‑2000
    that take into account the services currently using the bands or
    planning to use the bands, the required compatible frequency
    arrangements of second‑generation systems, and the need to
    facilitate the evolution of current mobile systems to IMT‑2000;

-   means to facilitate global roaming across different regional band
    usage within the bands identified for IMT‑2000;

-   spectrum demand predictions related to traffic density and timing;
    and

-   study of the provision of a fixed wireless access using IMT‑2000
    technologies.

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.

**Current Use of Frequency Bands Identified for 3G**

The 1710--1850 MHz and 2500--2690 MHz bands are currently used in a
variety of ways around the world. The chart in Appendix 2.2 describes
some of the current uses that various nations have allocated to the
1710‑1885 MHz and 2500‑2690 MHz bands. The chart also include excerpts
from ITU‑R Report M.2024, which documents the comments of countries that
responded to an ITU survey on current usage within the 1710‑1885 MHz and
2500‑2690 MHz bands.

For example, many European nations use the 1710‑1885 MHz band for second
generation GSM mobile phone service and Digital Enhanced Cordless
Telecommunications (DECT). Similarly, several Asia nations (Malaysia,
Korea, China) and South Africa have allocated this band to terrestrial
mobile uses and/or DECT. Canada, Brazil and New Zealand have deployed
low capacity fixed services in these bands.

The 2500‑2690 MHz band is used principally for electronic newsgathering
in Europe, Australia and New Zealand. Many of the other countries,
including the United States, Canada, Brazil, Malaysia, China and South
Africa, use the 2500‑2690 MHz band principally for MDS services. Japan
and Korea indicated that they intend to rely heavily on this band for
Mobile Satellite Service while China and Malaysia indicated an intention
to use this band for satellite services.

Many countries, especially in Europe, have already identified spectrum
bands for IMT‑2000 systems and some have begun the licensing
process.[^16] In fact, all member countries of the European Union are
obligated to issue licenses for 3G systems by January 2001. To aid in
the planning for IMT‑2000 in the United States and to help facilitate
global roaming, it is beneficial to note the spectrum allocation
decisions that have been made by other administrations. A summary of
spectrum identified by ITU for IMT‑2000 near 2 GHz, and spectrum usage
in Europe and the United States near 2 GHz is provided in the figure
below. Additionally, the table in Appendix 2.3, which was compiled by
FCC staff using publicly available information, indicates specific
frequency plans of various countries.

**Figure 2.1: IMT‑2000 Spectrum Near 2 GHz**

![](media/image2.wmf){width="6.438194444444444in"
height="3.598611111111111in"}

**Domestic Spectrum Considerations for 3G Implementation**

The FCC plans to initiate a rulemaking in the near future to address
spectrum issues for 3G systems. It should be noted that the Commission
has generally sought to allow the marketplace to determine the
particular uses for spectrum. We anticipate that the Commission
rulemaking will identify a number of frequency bands that will provide
opportunities for implementation of 3G systems. For example, the
Commission has allocated spectrum in the 700 MHz region for both fixed
and mobile services. This spectrum is planned to be auctioned beginning
on March 6, 2001. Parties have expressed interest in using this spectrum
for either fixed or mobile systems, including 3G systems. The ultimate
use of this spectrum will be determined by the winners of the auction.

**TIMING OF 3G IMPLEMENTATION**

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. We expect to address timing issues in the final report of this
study.

**OPERATIONAL CONSIDERATIONS**

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. Further, the
incumbent and planned services in the 2500--2690 MHz band also are
ubiquitous. These operational considerations are considered in Section 5
on spectrum sharing.

## SECTION 3

## INCUMBENT SYSTEMS IN THE 2500‑2690 MHz BAND

The Study Plan states that one of the study information basic
requirements is to describe candidate band incumbent systems.
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. This section of the Report addresses this basic requirement.

This section organizes the information, called for in the Study Plan,
into the following categories: nature of use, spectrum usage, geographic
deployment, system characteristics, and interference protection
standards. Information on system life expectancy, planned replacement
systems, and a cost/benefit analysis will be provided in the Final
Report of the band study.

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).[^17] 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**

**Domestic Allocations**

The Table of Frequency Allocations (47 C.F.R. § 2.106) shows the
2500‑2690 MHz band to be allocated domestically for non‑Federal
Government use on a primary basis to the Fixed Service, the Fixed
Satellite Service (FSS) (2500‑2655 MHz -- space‑to‑earth and 2655‑2690
-- earth‑to‑space), and the Broadcasting Satellite Service (BSS). In
addition, there is an allocation for space research (passive) and earth
exploration‑satellite (passive) in the 2640‑2690 MHz portion of the band
for use on a secondary basis on a shared basis for Federal Government
and non‑Federal Government use. *See* Appendix 3.1, an excerpt from
Table of Frequency Allocations for the 2500‑2690 MHz band.

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. 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. One
licensee is a common carrier,[^18] and the other is a public safety
entity.[^19] Regarding the FSS and BSS, 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.

**ITFS/MDS Service Description**

ITFS and MDS share 190 megahertz of spectrum in the 2500‑2690 MHz band.
ITFS licensees are allotted 120 megahertz of spectrum, MDS licensees are
allotted 66 megahertz of spectrum, and 4 megahertz of spectrum is
allotted for response channels for each service. As discussed below,
these services share the spectrum through complex licensing and leasing
arrangements that have evolved over time and that are not uniform in all
geographic areas.

ITFS has approximately 1,275 entities holding over 2,175 ITFS licenses
in urban and rural locations throughout the United States. Over 70,000
locations serve as registered receive sites, 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. An ITFS
licensee is required to be an educational institution or governmental
body engaged in the formal education of enrolled students.[^20] 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. Distance learning via ITFS takes students
beyond the school walls by giving them access to experiences and
instructions in locations anywhere in the world. Videoconferencing
allows students and teachers to interact with presenters and ask
questions by telephone and e‑mail.[^21] ITFS has become a crucial part
of the curriculum of many educators. 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 the
ITFS service. *See* Appendix 3.2 for a detailed description of
traditional ITFS service throughout the nation.

MDS currently has 2,570 station licensees and conditional licensees
(*i.e.*, authorizations to construct or modify facilities). Although the
original MDS channels were intended for business data, the MDS spectrum
traditionally has been used to deliver multichannel video programming
service (known as wireless cable service since it is similar to cable
television) to residential customers. Through leasing arrangements with
ITFS licensees, MDS licensees have used excess capacity on ITFS channels
to provide a viable video programming service in many communities.
Approximately one million homes continue to receive multichannel video
programming service from approximately 250 ITFS/MDS‑based wireless cable
systems. These systems compete with cable and satellite providers of
broadcast and video programming services.

Although the ITFS/MDS spectrum traditionally was used for one‑way analog
video transmission, the communications industry is rapidly taking
advantage of Commission service rule changes to permit the use of the
2500‑2690 MHz band 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.[^22] 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.[^23]

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. 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.[^24] 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.

The *Two‑Way Order* provided increased flexibility to ITFS licenses that
will facilitate their ability to use licensed spectrum to take advantage
of broadband access. In the *Two‑Way Order*, the Commission expanded its
definition of educational usage requirements on the ITFS band, allowing
both voice and data services to fulfill ITFS programming requirements.
An analog, non‑two‑way ITFS licensee who leases excess channel capacity
to an MDS operator must provide a total of at least 20 hours per channel
per week of ITFS programming on its authorized channels. Such a licensee
retains the right to recapture an additional 20 hours per channel per
week for simultaneous programming on the number of channels for which it
is authorized. An ITFS licensee may also shift required educational
programming onto fewer than its authorized number of channels. For
example, a licensee with two authorized channels could carry 40 hours of
programming on one of those channels and satisfy the requirement. A
licensee may further agree to reservation of time on channels not
authorized to it but which are included in the MDS system with which it
has a leasing arrangement. In a digital environment, ITFS licensees must
maintain a minimum capacity of 5% of its channel capacity. Depending on
their curriculum needs, some ITFS licensees retain most or all of their
capacity for their own use. Under the flexibility allowed by the
*Two‑Way Order*, ITFS licensees can devise systems that provide
educational users with broadband access for a variety of video and data
applications, thereby establishing ITFS as an integral educational tool
for school districts across the country. Two‑way systems will provide
schools with Internet access at speeds far in excess of that available
with dial‑up service, as well as allow other users in the community to
access a wide variety of educational materials that ITFS licensees and
other educators can make available over the World Wide Web.

With the advent of two‑way technology, MDS has become a vehicle for
offering high‑speed Internet access and broadband services to
residential and small office/home office ("SOHO") customers. For
example, since 1998 WorldCom and Sprint have invested over \$2 billion
dollars in the acquisition (by purchase or lease) of MDS and ITFS
channel rights covering 60 million households. Using primarily the MDS
allocation at 2150‑2160/2 MHz, MDS entities have already begun to
provide high‑speed Internet access in 12 cities.[^25] In addition, MDS
providers such as WorldCom, Sprint, and Nucentrix, have worked with
manufacturers such as Cisco, ADC, and Adaptive Broadband to develop
technologies capable of delivering high speed, high capacity broadband
voice, video and data services to residential customers, small and
medium businesses and educational institutions. One industry analyst
estimated there were 12,000 MDS Internet access subscribers at the end
of 1999,[^26] and other analysts expect the market for this service to
grow substantially over the next 3 to 5 years.[^27] Approximately 25
companies are currently using MDS spectrum to offer high‑speed Internet
access in at least 43 markets and have announced plans to offer the
service in numerous additional markets. *See* Appendix 3.3 for a
description of current and planned deployment of MDS Internet access by
specific carriers.

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.[^28] The U.S. market for fixed wireless
broadband services is expected to increase from \$767 million in 1999 to
\$7.4 billion by 2003,[^29] with the total number of fixed wireless
broadband subscribers predicted to increase from 200,000 this year to
9.4 million in 2005.[^30]

One key objective of the Telecommunications Act of 1996 was to increase
choice and competition in all aspects of telecommunications.[^31]
Nationwide deployment of MDS systems will provide Americans with another
option for high‑speed access, which may include digital subscriber line
(DSL), cable modem, or satellite‑based service provided by the incumbent
telephone company, cable operators, or satellite operators. Indeed, in
rural or otherwise underserved markets in the country, ITFS/MDS may be
the sole provider of broadband service*.*

In its *Second Report on the Availability of High‑Speed and Advanced
Telecommunications Services*,[^32] the Commission identified rural
Americans, particularly those remote from major population centers, as
being particularly vulnerable to not receiving access to advanced
telecommunications services in a reasonable and timely basis. Thus, the
Commission has adopted a proactive role in the promotion of advanced
services for these particularly vulnerable groups "by encouraging
competition, promoting infrastructure investment and addressing the
affordability of advanced services."[^33] The growth of ITFS/MDS two‑way
service is intended to provide affordable service to those market
sectors that are more likely to be underserved and provide a competitive
choice to consumers in more urban and more affluent markets.

## SPECTRUM USAGE

**ITFS/MDS Band Channel Plan**

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). The additional spectrum used by MDS is
located in a lower band. In the largest fifty metropolitan areas in the
country,[^34] MDS utilizes two 6 megahertz channels in the 2150‑2162 MHz
band. 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). To the
extent that this Initial Report considers only spectrum sharing and band
segmentation of the 2500‑2690 MHz band, it will not address relocation
of the MDS service located in the 2150‑2162 MHz band; the issue of MDS
usage of the 2150‑2162 MHz band will be addressed in the Final Report
when relocation issues are considered. The channel plan is shown in
Figure 3.1.

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

![](media/image3.wmf){width="6.0in" height="4.290972222222222in"}

## Leasing Arrangements 

In 1983, the Commission reallocated eight of the then twenty‑eight ITFS
channels for MDS use, and also authorized ITFS licensees to lease excess
capacity on their systems to MDS operators.[^35] These actions allowed
for the development of a multichannel video distribution service that
could be competitive with cable television service. In 1991, the
Commission made additional channels available for MDS operators'
use.[^36] 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. The leasing of excess
ITFS channel capacity has been 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.

Flexible Channel Use

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 spectrum plans for two‑way data services call for either
the highest or lowest frequencies in the 2500‑2690 MHz band to be used
for "upstream" service from the user to the system's receiver.
Downstream voice data channels would occupy the remaining spectrum. This
type of band arrangement would allow operators to provide approximately
30 megahertz separation between upstream and downstream transmissions to
provide sufficient isolation of upstream and downstream signals in the
duplex switch.

Licensees are given flexibility to assign bandwidth as needed to meet
the asynchronous bandwidth needs of their customers, including offering
adjustable bandwidth "on demand" to meet specific customer needs.
Licensees can subchannelize and superchannelize the 6 megahertz main
channels and the I‑channels (125 kHz response channels)[^37] to permit
the maximum possible operating flexibility. (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.) 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. *See*
Appendix 3.4 for a pictorial representation of ITFS/MDS band plans.

Further, the Commission's rules allow MDS and ITFS licensees to swap
channels, subject to Commission approval. Channel swapping could be a
useful means to devise flexible band plans for two‑way systems. Finally,
it should be noted that 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.[^38]

**ITFS/MDS 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 which provided that receive sites
within a 24.1 kilometer (15 mile) radius of a licensed ITFS transmitter
was entitled to interference protection. Nonetheless, the Commission
allowed receive sites beyond the identified boundary to be registered
and protected from interference. With the adoption of the *Two‑Way
Order*, the Commission increased the PSA to 56.3 kilometers (35 miles)
and eliminated registration of receive sites. The Commission continued
to provide interference protection to numerous previously registered
receive sites that were beyond the new 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. Figure 3.2 below depicts current ITFS
channel usage.[^39]

# Figure 3.2: Current ITFS Channel Usage

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

MDS originally was licensed on a site‑specific and channel‑specific
basis as well. Because MDS was a point‑to‑multipoint service, the
Commission provided interference protection to receivers located within
a PSA of 24.1 kilometers (15 miles), later expanded to 56.3 kilometers
(35 miles), surrounding licensed transmit sites. In 1995, the Commission
decided to license all available MDS channels on a wide‑area basis. 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 BTA‑like geographic areas.[^40] The BTA
licensees are authorized to construct facilities to provide service over
any usable MDS channels within the BTA and have preferred rights to the
available ITFS channels.[^41] Today, some incumbent site‑specific MDS
licensees continue to provide service within PSAs that either overlap
with or lie within licensed BTAs. Figure 3.3 below depicts current MDS
channel usage.

# Figure 3.3: Current MDS Channel Usage

![](media/image5.png){width="5.25in" height="3.454861111111111in"}

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 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.

As a result of the 1998 *Two‑Way Order*, MDS and ITFS licensees are
modifying their facilities to add transmit paths and to modify channel
usage to accommodate the introduction of new two‑way services. MDS
entities have been able to provide two‑way service on MDS channels
located at 2150‑2160 MHz since 1998, but given the complex interference
environment in the 2500‑2690 MHz band, the Commission adopted a specific
authorization process in the shared band. To ease the transition to
two‑way service and allow time to resolve potential interference
conflicts, the Commission decided to announce an initial filing window
for two‑way modification applications for the 2500‑2690 MHz band.
Subsequent to this initial licensing process, two‑way applications will
be processed under a rolling one‑day filing window. The Commission
requires specific types of MDS and ITFS facilities be licensed,
including main stations, hub stations, and high and low power booster
stations. In addition, licensees will have to provide notice to other
users of the band of some high power receive sites because of potential
interference conflicts.

The initial filing window for two‑way service in the 2500‑2690 MHz band
occurred from August 14, 2000 until August 18, 2000. Applicants had to
certify that they met all requirements regarding interference protection
to existing and proposed facilities or had received the necessary
consent letters. In addition, applicants were required to serve all
potentially affected parties with copies of their application and
engineering materials. Any applications that do not certify that the
requirements have been met will be dismissed. The Commission will
conduct random audits prior to or after a license has been issued in
reliance on a certification. If an audit reveals that an application is
improperly certified, incomplete or contains a material error, the
Commission will dismiss the application or revoke the license. Even
after an application is approved, the licensee cannot cause unauthorized
interference to any protected facility. If such interference is
documented, the licensee must immediately cease operations. Figure 3.4
depicts current ITFS/MDS applications on file with the Commission.

**Figure 3.4: Current ITFS/MDS Applications**

![](media/image6.png){width="5.029166666666667in"
height="3.5131944444444443in"}

ITFS/MDS 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: analog video, digital video,
unidirectional digital data, and bi‑directional 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 3.5, 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 3.5, 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 omindirectionally) 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 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 (per 6 megahertz bandwidth)
> 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 up to a maximum of 33 dBW
> (per 6 megahertz bandwidth) EIRP.
>
> *Booster Station (low power):* Same as above except limited to a
> maximum power of --9 dBW (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.
>
> *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 2186‑2190 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 (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. In this way, the system service
area can be 'cellularized,' similar to cellular telephone systems, in
order to facilitate frequency reuse. 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.

While different providers use different types of equipment, two‑way
systems operate in generally the same way. Through a computer, a user
sends a request for data or a Web page to the MDS modem. The MDS modem
sends the data request to the receiver/transmitter on the user's roof.
The receiver/transmitter sends the data within the 2500‑2690 MHz band at
speeds up to 10 megabits per second to the MDS provider's
receive/transmit tower. The tower relays the data request through the
MDS provider's network to the Internet Service Provider (ISP) facility.
The ISP receives the request and retrieves data either from its servers
or from the Internet over its high‑speed backbone connection. The ISP
then returns the data via the MDS provider's network to the
receive/transmit tower. The transmit site sends the data within the
2500‑2690 MHz band at speeds up to 10 megabits per second to the
receiver on the user's roof. The roof‑mounted receiver relays
information to the MDS modem. The modem passes the information to a
stand‑alone PC or Macintosh computer, or to multiple users in
seconds.[^42] Figure 3.5 shows a pictorial representation of how an MDS
system works.[^43]

**Figure 3.5: How An MDS System Works**

![](media/image7.png){width="4.029861111111111in"
height="3.2715277777777776in"}

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.[^44] For example, Wireless Online utilizes an antenna
technology that enhances the coverage, quality, and capacity of MDS
networks.[^45] 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 spectrum allocated.[^46] Hybrid Network, Inc.'s equipment
allows carriers to split one 6‑megahertz channel into three 2‑megahertz
channels and thereby offer different levels of service using the
different 2 megahertz channels.[^47] Also, in December 1999, Cisco
Systems released a cellularization technology for MDS and unlicensed
spectrum called VOFDM ("Vector Orthogonal Frequency Division
Multiplexing").[^48] 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.[^49] 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.[^50] WorldCom is also testing VOFDM
in its Dallas trial.[^51] All of these innovations permit MDS licensees
to make ever more effective use of their spectrum.

**ITFS/MDS 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.[^52] 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.[^53] 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.[^54] Interference is calculated using undesired/desired (D/U)
signal ratios and field 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 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 desired to
undesired (D/U) signal ratios and field 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.[^55]

## SECTION 4

## STUDY ASSUMPTIONS AND METHODOLOGY

The Study Plan calls for an analysis of the ability of 3G systems to
share spectrum with incumbent services in the 2500 -- 2690 MHz band. The
Study Plan also calls for an analysis of the possible segmentation of
this spectrum to accommodate 3G systems. In order to perform these
analyses, certain assumptions about the technical characteristics of 3G
systems and incumbent systems must be made. The assumptions made for
purposes of these analyses are discussed in this section.

These analyses may need to be revised to take into account additional
information that may be gained through discussions with industry,
further international studies on 3G, and the planned FCC rule making.
The assumptions made at this time do not prejudge or foreclose
consideration of other options at a future date.

# SYSTEM TECHNICAL CHARACTERISTICS 

# Future 3G Systems

As an initial matter, it is not expected that the Commission will
mandate use of any particular standards for 3G systems and is likely
only to establish minimal requirements to control radio frequency
interference and to protect against human exposure to radio frequency
energy. However, in order to perform technical analyses of the ability
of 3G systems to share spectrum with incumbent systems certain
assumptions were made about 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. Where appropriate the ITU
technical standards for IMT‑2000 systems, which are described in Section
2, were used. Table 2-A in Appendix 2.2 describes the characteristics of
IMT‑2000 mobile stations, and Table 2-B describes the characteristics of
IMT‑2000 base stations.

# Incumbent ITFS and MDS Systems

Additionally, certain assumptions about the technical characteristics of
ITFS and MDS systems were made. For purposes of this Initial Report, the
technical characteristics currently employed by ITFS and MDS systems in
the 2500‑2690 MHz band were used. These system characteristics are
described in Section 3. Appendix 3.5 describes the technical
characteristics of one‑way base and receive stations and two‑way base
and response stations. It is recognized that some of the assumptions
about the technical characteristics of ITFS and MDS systems may have
limitations. For example, while the interference protection ratios that
currently apply between MDS and ITFS systems were used, the appropriate
interference protection ratio could vary where the source of
interference is a 3G signal. Additionally, current regulations provide
flexibility to MDS operators to design their systems as they see fit, so
the ability of these systems to reject interference from 3G systems may
vary. Thus, the assumptions regarding the appropriate interference
protection ratios must be examined further and may be modified for the
final report.

**SPECTRUM REQUIREMENTS FOR 3G SYSTEMS**

In order to perform an analysis of band segmentation options, certain
assumptions about the overall amount of spectrum that may be made
available for 3G systems in the 2500--2690 MHz band have been made.
Several factors are important in making this determination.

As an initial matter, the impact on incumbent services of any spectrum
that is made available for 3G systems must be made. While it may be
feasible to offset reductions in the spectrum available for incumbent
systems by improving spectrum efficiency, this has its limitations.
Further, it is anticipated that the options for replacement spectrum may
also be limited. Therefore, it has been assumed that a substantial part
of the 2500--2690 MHz band will continue to be required to support MDS
and ITFS operations.

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 that pairing this spectrum with other bands is
feasible. Therefore, for purposes of this Interim Report, it is assumed
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
choice in 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, it is assumed that 90 megahertz of spectrum
would be made available for 3G systems for purposes of this Interim
Report. This would continue to leave more than half of the current
spectrum available for ITFS and MDS. It would also provide sufficient
spectrum for multiple licenses. For example, an allocation of
90 megahertz could provide for three licenses of 30 megahertz each, or
three licenses of 20 megahertz each and three licenses of 10 megahertz
each.

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. It is also recognized that 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 have not been recognized in this Interim
Report, although they will be examined at a later time as specific
options become clearer and more information becomes available.

**STUDY METHODOLOGY**

As suggested in the Study Plan, this Interim Report examines spectrum
sharing and frequency band segmentation.

In the case of spectrum sharing, this Interim Report first evaluates
whether 3G systems could operate on a co‑channel basis with incumbent
ITFS and MDS systems. Next, the Interim Report examines whether there is
spectrum that is not currently used by ITFS and MDS systems that could
be used by 3G systems.

With regard to band segmentation, several options are considered for
making available 90 megahertz of spectrum for 3G systems in the
2500--2690 MHz band. The potential impact of these options on ITFS and
MDS is evaluated. The costs and operating impacts to incumbent users are
not examined at this time but will be considered in the Final Report.

## SECTION 5

## EVALUATION OF SPECTRUM SHARING

In this section a technical evaluation of options for sharing between 3G
and incumbent operations in the 2500‑2690 MHz band is presented.
Specifically, this section evaluates the ability of 3G systems to share
spectrum with current ITFS and MDS licensees. The technical feasibility
of co‑channel and adjacent channel sharing between licensed ITFS/MDS
stations and 3G base and mobile stations is examined by calculating
minimum distance separation requirements using the interference
protection criteria established in the Commission's rules for ITFS and
MDS.[^56] ITFS/MDS licenses within the spectrum band are examined to
assess where, in light of the minimum separation distances, 3G systems
could operate without causing harmful interference to ITFS/MDS systems.

**INTERFERENCE PROTECTION REQUIREMENTS**

The technical characteristics used in this analysis include the five ITU
IMT‑2000 radio interface standards[^57] and the FCC's rules for ITFS/MDS
interference protection.[^58] Specifically, the analysis calculates 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 determines the minimum distance separation
required to avoid harmful interference .[^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 is fairly straightforward to predict
the interference from a 3G base station into ITFS/MDS receivers. We also
analyze the effect that a single typical 3G mobile unit would have on
ITFS/MDS receivers. We note that 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 Interim Report.[^60]

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

Each system architecture can be implemented utilizing a single main
transmitter configuration. These systems typically have a single high
power 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).[^61] Typical EIRP for
analog systems are in the 100‑1000 watt 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 systems designs to overcome signal loss within a
protected service area.

In addition to single main transmitter designs, cellular architectures
are being developed and deployed for two‑way 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 EIRP, using the minimum
necessary to achieve path reliability. Interference is controlled within
the protected service area by careful frequency planning utilizing
polarization, sector geometry and receive antenna isolation.
Transceivers located at customer premises have downstream gains of 12 to
27 dBi, similar to that for single cell one‑way system, and also have
upstream gains of 10 to 24 dBi.

To determine co‑channel and first adjacent channel protection
requirements, technical characteristics specified in the FCC rules for a
typical ITFS/MDS station are used. Current FCC rules require co‑channel
ITFS/MDS licensees to maintain a desired signal to undesired signal
level (D/U) of 45 dB at all unobstructed areas within the 56.3 kilometer
(35 mile) radius protected service area of an incumbent station.[^62]
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 for co‑channel analysis is used. For the
adjacent channel analysis, FCC rules specify that a D/U ratio of 0 dB be
maintained. Tables 5‑A and 5‑B in Appendix 5.1 summarize the pertinent
provisions of the FCC rules for ITFS/MDS response stations and ITFS/MDS
main stations.

The analysis assumes 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 assumes the 3G mobile
station is operating with 100 milliwatts EIRP (‑10 dBW). The technical
characteristics of the five IMT‑2000 systems used in this analysis are
summarized in Tables 2‑A and 2‑B in Appendix 2.1.

Table 5.1 shows the minimum spacing required to prevent interference
between 3G base and mobile stations and ITFS/MDS hub and response
station receivers based on the planning factors set forth in Tables 5‑A
and 5‑B in Appendix 5.1.[^63] 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.[^64] 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.[^65] 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 5.1: Calculation of Co‑channel Separation Distances**

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

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<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 5.2 tabulates the minimum spacing
required to prevent interference between 3G base and mobile stations and
first adjacent ITFS/MDS main and response station receivers.[^66]

**Table 5.2: 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.[^67] Adjacent channel separation
requirements do not appear to be as limiting.

## ITFS/MDS CHANNEL LICENSING

In this section, the 2500‑2690 MHz band is examined to determine if
there are any vacant channels (*i.e.*, channels not currently licensed)
that could be made available for 3G use. This study looks at channel
availability in the 50 largest metropolitan areas in terms of
population.[^68] To determine whether there are any vacant channels, the
information in 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 the 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 indicates the number of channels licensed
per city. This analysis shows that in 49 of the 50 cities all 31
ITFS/MDS channels are licensed within 161 kilometers (100 miles). The
exception is Salt Lake City where 5 channels currently are not
licensed.[^69]

Maps have been drawn depicting the locations of hub and response
stations and the protected service areas for each of the of 31 ITFS and
MDS channels.[^70] Channel availability may be examined from both these
composite maps and the maps of the individual channels. Appendix 5.3
contains a map for each of the 20 ITFS and 11 MDS channels. By way of
example, close-up maps of one ITFS and one MDS channel in each of six
cities are shown in Figures 5.1 through 5.12. As is explained in the
sections below, the two channels shown (ITFS Channel A1 and MDS Channel
E1) are representative of each of the ITFS/MDS channels.

In the figures in this section, the diamonds surrounded by shaded or
white circles represent main transmit sites for MDS licenses and their
56.3 kilometer (35 mile) radius protected service areas.[^71] The
diamonds without circles represent MDS hub receivers and/or transmit
sites licensed prior to November 6, 2000 within auctioned Basic Trading
Areas (BTAs).[^72] Grandfathered point‑to‑point ITFS registered receive
sites are represented by the lines emanating from the centers of some
circles. Auctioned MDS channels by BTA are also shaded.

![](media/image8.png){width="3.002083333333333in"
height="1.94375in"}![](media/image9.png){width="3.002083333333333in"
height="1.94375in"}

![](media/image10.png){width="3.002083333333333in"
height="1.9479166666666667in"}![](media/image11.png){width="3.002083333333333in"
height="1.9479166666666667in"}

![](media/image12.png){width="3.002083333333333in"
height="1.9479166666666667in"}![](media/image13.png){width="3.002083333333333in"
height="1.9479166666666667in"}

![](media/image14.png){width="3.002083333333333in"
height="1.9479166666666667in"}![](media/image15.png){width="3.002083333333333in"
height="1.9479166666666667in"}

![](media/image16.png){width="3.002083333333333in"
height="1.9479166666666667in"}![](media/image17.png){width="3.002083333333333in"
height="1.9479166666666667in"}

![](media/image18.png){width="3.002083333333333in"
height="1.9479166666666667in"}![](media/image19.png){width="3.0180555555555557in"
height="1.9618055555555556in"}

**Geographic Distribution of MDS Systems**

As noted in Section 3, the entire 66 megahertz allocated to the MDS
service is encumbered throughout the entire United States. This is
because the rights to provide MDS service 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. Figure 5.13 is a nationwide
composite of all 11 MDS channel site specific licenses, protected
service areas and auctioned BTAs.

**Figure 5.13: MDS Composite**

![](media/image5.png){width="5.25in" height="3.5819444444444444in"}

In sum, Figure 5.13 illustrates that all MDS spectrum has been licensed
throughout the entire United States. The majority of sites shown on the
map denote incumbent MDS systems, however some sites (those shown
without protected service areas) depict locations of MDS systems that
have been built by geographic MDS licensees.

Recognizing that not all of the BTAs have been completely built‑out, we
next examine the actual occupancy of a sample MDS channel only where
licensed facilities exist. This analysis is conducted solely for the
limited purpose of this study and licensees and auction winners should
not assume any change in current policy or Commission rules by this
analysis. On the contrary, this analysis is being 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.
This analysis will also reveal whether MDS licensees might be positioned
to partition an area within their BTA to prospective 3G system
operators.[^73] By this we are simply recognizing the theoretical
possibility that a geographic MDS licensee that does not build its
system out in a portion of its BTA, could partition it to a 3G licensee
who could then offer 3G services in that limited area.

Using the information available in the Commission's database regarding
MDS Channel E1 (2596‑2602 MHz), for example, Commission staff have
assembled an occupancy profile that contains a static snapshot of
currently licensed MDS facilities. This profile is shown on the map in
Figure 5.14. The gray crosshatched area shows that the entire country
has been licensed on a geographic basis by BTAs. The white circles
reveal where incumbent MDS facilities have been licensed. Looking at
this from the perspective of Figures 5.1 through 5.12 above, this map
shows that even if the geographic licensees were not considered, Channel
E1 is currently licensed in each of the six cities shown on those maps.
Accordingly, the 6 megahertz associated with Channel E1 is not available
for 3G services in those cities. Additionally, analysis of the
Commission's licensing data and this map show that Channel E1 is already
licensed in most of the densely populated areas of the country. Indeed,
comparing Figure 5.14 with a population density map reveals that
protected service areas currently exist in virtually all densely
populated areas of the country. The relative population density map is
seen in Figure 5.15.

######### Figure 5.14: Single MDS Channel E1

![](media/image20.png){width="5.25in" height="3.4694444444444446in"}

# Figure 5.15: Relative Population Density[^74]

![](media/image21.png){width="5.246527777777778in"
height="3.722916666666667in"}

The gray crosshatched area in Figure 5.14 represents the area within
which a 3G system may be able to operate, assuming the partitioning of
the BTA and no further licensing of MDS Channel E1. However, as noted
above, the gray area shown on this map does not reflect the finding that
a co‑channel 3G system would need a minimum separation of 161 kilometers
(100 miles) -- rather, this map reflects the much smaller 56.3 kilometer
(35‑mile) protected service areas of licensed MDS stations. Accordingly,
the area available for co‑channel 3G systems is significantly less than
the area depicted. This can be seen in Figure 5.16 which reproduces 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 5.14.[^75] Only in the very limited white space of Figure 5.16
would it be possible to locate a 3G station and maintain the
161 kilometer (100 mile) base station separation requirement.

Figure 5.16: Single MDS Channel E1 With 217 kilometer (135 mile)
Protected Service Areas

![](media/image22.png){width="5.246527777777778in" height="3.73125in"}

The maps in Appendix 5.3 demonstrate that use and occupancy of the 11
MDS channels is not significantly different for any MDS channel. It is
apparent that each of the major metropolitan areas of the United States
is encumbered with incumbent MDS systems. Accordingly, Figure 5.14
represents a fair illustration of the geographic availability of
currently unoccupied MDS frequencies throughout the country.

**Geographic Distribution of ITFS Channels**

The same analysis as was done for the MDS channels is now done for the
ITFS channels. Figure 5.17 is a composite of ITFS licenses on all 20
ITFS channels. As can be seen in the map, some of the registered receive
sites extend beyond the protected service area; these sites are entitled
to the same protection as those receive sites that are located within
the protected service area. This composite of ITFS Channels A, B, C, D,
and G, a total of 120 megahertz, illustrates the areas of the country
currently encumbered by ITFS licenses. Similar to the results of the MDS
analysis, Figure 5.17 shows that most of the United States is covered by
at least one ITFS station.

######## Figure 5.17: ITFS Composite

![](media/image4.png){width="5.246527777777778in"
height="3.722916666666667in"}

Because the ITFS composite map only shows whether there is at least one
station on any one of the 20 ITFS channels, the occupancy of a single
ITFS channel is also examined. Figure 5.18 shows the occupancy for ITFS
Channel A1 (2500‑2506 MHz). Similar to MDS, it is clearly seen that the
United States is heavily encumbered by ITFS operators on this channel.
From the maps in Appendix 5.3, it is clear that each ITFS channel is
similarly encumbered. Therefore, the map shown in Figure 5.14 is
representative of each ITFS channel.

######## Figure 5.18: Single ITFS Channel A1

![](media/image23.png){width="5.25in" height="3.484027777777778in"}

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 5.18. 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 5.19 would it be possible
to locate a 3G station and maintain the 161 kilometer (100 mile) base
station separation requirement.

######## Figure 5.19: Single ITFS Channel A1 With 217 kilometer (135 mile) Protected Service Areas

![](media/image24.png){width="5.246527777777778in"
height="3.6458333333333335in"}

**Composite Nationwide ITFS/MDS Geographic Channel Occupancy**

Figure 5.20 is a composite of all encumbered area for the entire
2500‑2690 MHz band: including licensed stations, but excluding the
auctioned BTAs. The dark areas of the map are the ITFS/MDS protected
service areas. Again, as noted before, these circles do not reflect the
161 kilometer (100 mile) distance separation required for co‑channel
operations. Also, as addressed above the Commission has auctioned all of
the MDS channels nationwide on a BTA basis. Therefore these channels are
already licensed nationwide and are not available currently for sharing
with 3G operations.

######## Figure 5.20: Composite ITFS/MDS

![](media/image25.png){width="4.935416666666667in"
height="3.5131944444444443in"}

As this map reveals, ITFS and MDS channels are used in the major
metropolitan areas. And, similar to the previous maps, the area
available for possible 3G services within the 2500‑2690 MHz band is
significantly less than the white space shown when the 161 kilometer
(100 mile) minimum distance separation requirement is considered.
Accordingly, based on the assumptions used for this initial analysis,
sharing between 3G systems and ITFS/MDS operations is extremely
problematic. At this point, there does not appear to be enough spectrum
in the 2500‑2690 MHz band in the populated areas to support a viable 3G
service. Voluntary partitioning between incumbent users and 3G
operators, however, could offer some promise of sharing as an interim
measure.

## SECTION 6

## BAND SEGMENTATION ANALYSIS

This section describes possible band segmentation options for the
2500‑2690 MHz band. In this section, the analysis assesses the
feasibility of dividing the 2500‑2690 MHz band into segments or channels
to meet the radiocommunications requirements for 3G systems and ITFS/MDS
systems. Band segmentation would require a portion of the ITFS/MDS
spectrum to be cleared and made available for 3G systems.

As noted in Section 2, for the purposes of this study, our analysis will
assume that 90 megahertz of spectrum in the 2500‑2690 MHz band is to be
used for 3G service, and the remaining 100 megahertz of spectrum is to
be used for ITFS/MDS. The amount of spectrum assumed for 3G use in this
study 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, as described in Section 2, five radio interface
standards have been incorporated into the international standards for
the terrestrial component of IMT‑2000 by the ITU. As shown, these
standards incorporate both Frequency Division Duplex (FDD) and Time
Division Duplex (TDD) operation. Similarly, the architecture of planned
new two‑way MDS stations must also factor into our analysis. As
described in Section 2, 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.[^76]
Accommodations must also be made for TDD systems. 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.[^77]

Finally, when assessing the impact that any band segmentation option has
on 3G or ITFS/MDS systems, the operational environment of these systems
must be considered. Because 3G systems have not yet been implemented and
because under a band segmentation approach they would operate on cleared
spectrum, they have many options for their system design. ITFS/MDS
systems by contrast have developed over the last 30 years and the effect
of any band segmentation must consider the impact to how these systems
are implemented today and are planned to be implemented in the future.

Three band segmentation options, as well as their implications, are
discussed below.

TWO‑WAY ITFS/MDS SYSTEMS: BAND PLANS

As discussed in Section 3, ITFS and MDS services will be deploying
two‑way systems in the 2500‑2690 MHz band, subject to certain
limitations arising from how the spectrum is currently licensed in any
given geographic area. As noted, all MDS channels have been licensed on
a BTA basis through the competitive bidding process. Geographic MDS
licensees, in implementing their systems, must protect incumbent MDS
systems licensed on a site‑specific basis for thirty‑five 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
implementation 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 3.4 shows a pictorial representation of the various
band plans that MDS licensees are contemplating to accommodate the
individual needs of different geographic areas. The sample plans
presented in this figure are for study purposes only and do not reflect
the varied options that could be deployed by ITFS/MDS licensees in the
future. As seen in this figure, WorldCom has indicated three variations
based on actual situations. 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.[^78] 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**

Although the number of band segmentation options are extensive, three
band segmentation options, presented in Figure 6.1 below, were examined
as representative samples. In analyzing the impact that each of these
options will have on 3G and ITFS/MDS systems, the functional and
operational factors described in the previous section are included in
the assessment.

**Figure 6.1: Band Segmentation Options**

![](media/image26.wmf){width="5.990277777777778in"
height="4.495138888888889in"}

*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. As detailed above, this separation is necessary to implement
systems using FDD technology, which the IMT‑2000 radio standards as well
as the two‑way MDS implementations anticipate. Just as important, the
ability to implement TDD systems is not precluded by this segmentation
plan. An operator may implement FDD technology on any spectrum block for
which it is licensed. To accommodate this possibility, guard bands
between the 3G and ITFS/MDS 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 6.2, 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. Aside from the issues of finding suitable
spectrum on which to move these systems and the economic costs involved
in such an endeavor, the flexible nature of this band makes it extremely
difficult to assess the actual impact that this segmentation option
would have on currently 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
various lease arrangements and channel swaps.

**Figure 6.2: ITFS/MDS Stations Affected by Segmentation Option 1.**

![](media/image27.png){width="5.25in" height="3.5055555555555555in"}

*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 6.1, 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. The biggest drawback to this
option is that 3G and ITFS/MDS operators would not be able to implement
FDD technology unless suitable spectrum could be found with which to
pair their respective segments. On the other hand, this option lends
itself nicely to TDD technology for both 3G and ITFS/MDS systems.
However, in the absence of paired spectrum, flexibility for any
individual operator to implement the technology of its choice may be
lost.

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. And as described above, the actual impact to
any individual ITFS/MDS system due to clearing this portion of the
spectrum for 3G systems cannot be determined unless a detailed analysis
is undertaken for each geographic area.

**Figure 6.3: ITFS/MDS Stations Affected by Segmentation Option 2.**

![](media/image28.png){width="5.25in" height="3.473611111111111in"}

*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 inclusion of guard bands preserves the
ability of both 3G and ITFS/MDS operators to implement TDD technology.
The biggest drawback to this option is that it precludes the ability of
ITFS/MDS operators to implement FDD systems without finding suitable
paired spectrum. It is expected that most MDS operators contemplate
implementing FDD for their new two‑way systems.

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 below. And again, the
actual impact to any given ITFS or MDS system cannot be determined
without a detailed area by area analysis.

**Figure 6.4: ITFS/MDS Stations Affected by Segmentation Option 3.**

![](media/image29.png){width="5.25in" height="3.53125in"}

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

The impact of each segmentation option has been described above. In
addition, the impact of segmentation can be examined in more general
terms. Specifically, regardless of segmentation option, it is worthwhile
to examine the number of licensees that may be affected on any given
channel. A review of the Commission's licensing data as of November 6,
2000, indicates that each channel is similarly encumbered with a high
degree of use in and around the major United States markets. (The
figures in Appendix 5.3 depict the location of ITFS and MDS licenses for
each channel.) As can be seen from these thirty‑one figures, any band
segmentation option would entail the widespread relocation of a large
number of stations regardless of the segmentation option chosen.

Analyzing the licensing data currently shows that the number of licensed
transmitters per one 6 megahertz channel averages over 4000 nationwide.
Thus, within the framework of our assumption of 90 megahertz for 3G
services, over 60,000 transmitters would have to be accommodated. It is
important to note that these numbers are based on current ITFS/MDS
deployment and the majority of these stations are incumbent operators.
As geographic MDS licensees begin deploying two‑way service, the number
of stations will increase. This increase will be substantial because
with two‑way service, each subscriber's location becomes an additional
transmit site for upstream traffic. Therefore, for every transmitter
that a geographic MDS licensee currently has licensed, there is the
potential for many times that number to ultimately exist.[^79]
Additionally, educational institutions could continue to be licensed
ITFS stations where spectrum is available.

In light of the number of ITFS/MDS stations that need to be accommodated
regardless of segmentation option and the current lack of suitable
spectrum to which stations can move, options for increasing the spectrum
efficiency of ITFS/MDS operations must be explored. Such use would
entail the use of more spectrum efficient digital technologies through
digital compression techniques. It must be noted, however, that these
options, while possibly satisfying short term needs would hamper the
long‑term growth of this service. For example, if licensees were to
implement digital compression due to band segmentation, they would be
doing so on less total spectrum than they currently have available.
Thus, the upper limit on the number of channels they can provide is
reduced from what it would be if segmentation were not implemented. It
also must be noted that, while many operators have been or are planning
to implement digital technologies, there are still many operators who
provide analog TV service and have made no plans to change. Therefore,
digital techniques are not a panacea for the entire universe of
incumbent operators and any band segmentation option that may be
contemplated must account for all of the varied uses and implementations
of incumbent licensees.

Another issue that must be addressed under any segmentation option is
that of ITFS station downconverter overload. That is, 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.[^80] 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.

**IMPACT OF BAND SEGMENTATION ON CELL SIZE**

Another factor that must be examined under any band segmentation option
is the effect the reduction of available spectrum for ITFS/MDS has on
cell size (*i.e.*, the effect that squeezing ITFS and MDS stations into
less spectrum will have on the size of service areas). Figure 6.5
below[^81] indicates the amount of spectrum needed per cell site to
serve customers within a specified distance from that site. As
illustrated by the figure, it is evident that if the total amount of
spectrum available to an MDS licensee is reduced, that licensee, to
continue providing an acceptable grade of service to its customers, must
reduce the cell size. As cell size is reduced, the licensee must then
make a business decision to continue operating the site with reduced
coverage thereby reaching fewer customers or to add new sites to
maintain the same coverage as it had prior to the reduction in available
spectrum. The consequences of either of these options are clear. Either
the licensee ceases to provide service to its customers in the outlying
areas of its coverage area (most likely rural and underserved areas) or
it must build and maintain additional transmit sites to cover these
areas. For example, the figure shows that a single main transmitter
operating with its full complement of spectrum[^82] can serve a cell
with a 32 mile radius. If the total amount of spectrum for the ITFS/MDS
service is reduced from 190 megahertz to 100 megahertz or by 47.4%, it
is reasonable to assume that all operators are affected similarly
(*i.e.*, each operator must reduce its spectrum by 47%). Given this
reduction, the chart shows that for a 45% reduction in available
spectrum (55% of the total spectrum is available for the MDS licensee)
an MDS licensee must reduce its cell radius to 23 miles to maintain the
same bandwidth density or grade of service to its customers. Reducing
cell size in this manner reduces the cell area by half from 3217
square miles to 1662 square miles. In this situation, it is expected
that a licensee would require 3‑5 transmitter sites to cover the same
geographic area as the single main transmitter. Either option has
adverse effects. Namely, the MDS operator either incurs a significant
economic cost to build additional sites to continue serving its current
customer base or the customers in outlying areas will cease to be able
to receive service.

# Figure 6.5: Cell Size As A Function of Available Spectrum

![](media/image30.wmf){width="5.997222222222222in"
height="3.2944444444444443in"}

Based on our analysis of various segmentation options for the
2500--2690 MHz band, a few key findings can be made at this time. Any
segmentation option that may be pursued should account for the flexible
service configurations and offerings that incumbent and geographic
licensees are currently implementing. Further, no segmentation option
appears to be significantly better than another in terms of number of
licensees affected. That is, regardless of any option that is considered
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 their ability to provide service to
customers in outlying areas or add more transmitter sites may be
affected. Finally, because of the complex licensing scheme present in
this band due to the mix of auction winners, incumbent ITFS and MDS
licensees and the channel swaps and lease agreements that have been
implemented, blanket statements as to the effect of segmentation on any
specific market area cannot be made. To fully understand the
implications of any segmentation plan on the ITFS/MDS service, each
geographic area would need to be analyzed individually.

If spectrum were to be reallocated from ITFS/MDS, careful consideration
would need to be given to the options available to ensure the continued
viability of these services. For example, it would be necessary to
examine the extent to which service can be maintained in a reduced
amount of spectrum by improving spectrum efficiency. Alternatively, it
may be appropriate to identify additional spectrum in other bands. It
may also be possible to satisfy some communications requirements by
using alternative technologies, such as fiber optic communications.
These issues will be examined more fully in the Commission's planned
rule making proceeding on spectrum allocations that may be made
available for 3G services.

[^1]: ^\*^ NTIA, "Plan to Select Spectrum for Third Generation (3G)
    Wireless Systems in the United States," released October 20, 2000,
    [http://www.ntia.doc.gov/ntiahome/threeg/3g_plan14.htm](http://www.ntia.doc.gov/ntiahome/threeg/3g).
    *See* Appendix 1.1 attached.

[^2]: *Principles for Reallocation of Spectrum to Encourage the
    Development of Telecommunications Technologies for the New
    Millennium: Policy Statement*, FCC 99‑354, released November 22,
    1999.

[^3]: *Implementation of Section 6002(b) of the Omnibus budget
    Reconcilliation Act of 1993, Annual Report and Analysis of
    Competitive Market Conditions with Respect to Commercial Mobile
    Services: Fifth Report*, FCC 00‑289, released August 18, 2000.

[^4]: 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.

[^5]: *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.

[^6]: *See* "Detailed Specifications of the Radio Interfaces of
    IMT‑2000," Recommendation ITU‑R M.1457 (2000), International
    Telecommunication Union.

[^7]: *See* Footnote 764A to the international Table of Frequency
    Allocations, Final Acts of the World Administrative Radio Conference
    for Dealing with Frequency Allocations in Certain Parts of the
    Spectrum (WARC‑92), Malaga‑Torremolinos, 1992.

[^8]: Footnote 764A was renumbered to S5.388 and the reference to FPLMTS
    was changed to IMT‑2000. *See* Final Acts WRC‑97, World
    Radiocommunication Conference, Geneva, 1997.

[^9]: Although the United States proposed the 1710‑1885 MHz band for
    IMT‑2000 use, the United States noted that existing United States
    personal communication service (PCS) licensees operate in the
    1850‑1910 MHz band. In the United States, nothing prohibits PCS
    licensees from providing terrestrial IMT‑2000 services in spectrum
    in any bands allocated for the Commercial Mobile Radio Service
    (CMRS). Because the United States already permits IMT‑2000 services
    at 1850‑1885 MHz, no further study was deemed necessary for this
    portion of the internationally identified band.

[^10]: Provisional Final Acts of WRC‑2000, 2^nd^ ed., Istanbul, Turkey,
    June 2000.

[^11]: WRC‑2000 acknowledged that, in some countries, the 698‑806 MHz
    band is allocated to mobile service and that some administrations
    plan on using part of that band for IMT‑20000. *See* Resolution 224,
    Provisional Final Acts of WRC‑2000, 2^nd^ ed., Istanbul, Turkey,
    June 2000. The Study Plan noted that the 698‑746 MHz band could be
    considered in the United States for possible 3G use.

[^12]: CITEL is an organization of North and South American
    administrations in Region 2.

[^13]: CEPT is an organization of European administrations in Region 1.

[^14]: *See* Resolutions 223 and 224, Provisional Final Acts of
    WRC‑2000, 2^nd^ ed., Istanbul, Turkey, June 2000.

[^15]: *See* Resolution 223, Provisional Final Acts of WRC‑2000,
    Istanbul, Turkey, June 2000.

[^16]: In June, 1997, the European Radiocommunications Commission (ERC)
    designated 155 megahertz for IMT‑2000 in Europe. The frequency bands
    identified for terrestrial use are 1900‑1980 MHz, 2010‑2025 MHz, and
    2110‑2170 MHz. More specifically, the ERC plan pairs 1920‑1980 MHz
    (mobile) with 2110‑2170 MHz (base) and leave 1900‑1920 MHz and
    2010‑2025 MHz unpaired.

[^17]: 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
    Interim 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 and various channels in the WCS (2305 to 2360 MHz) spectrum
    as part of those systems.

[^18]: Nevada Bell is the licensee (WLL589‑WLL619 and WLU983‑WLU988) of
    a Time Division Multiple Access (TDMA) system providing telephone
    service to remote rural farms around Austin, NV. More than 50% of
    the subscribers on this system are Native Americans. The system
    operates on channels G3 and G4.

[^19]: The City and County of Denver is licensed (WHW35) to use channel
    D1 to transmit video training programs to fire stations metro‑wide.

[^20]: In addition, nonprofit organizations formed to provide
    instructional material to enrolled students may also be licensees.
    Furthermore, nonprofit organizations that would be eligible to be
    licensees of noncommercial educational broadcast television stations
    are eligible to become ITFS licensees.

[^21]: Because of the nonprofit nature of ITFS licensees and the
    licensees' limited resources, it is difficult to compile information
    about the exact nature and type of educational programs being
    offered by the licensees to the public.

[^22]: *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).

[^23]: *See The Mass Media Bureau Implements Policy for Provision of
    Internet Service on MDS and Leased ITFS Frequencies*, 11 FCC Rcd
    22419 (1996).

[^24]: *See Two-Way Order,*13 FCC Rcd 19112 (1998), *recon.*, 14 FCC Rcd
    12764 (1999), *further recon.*, FCC 00‑244 (released July 21, 2000).

[^25]: *See* *MCI WorldCom Announces 'Fixed Wireless' Service Trials*,
    [PR Newswire]{.smallcaps}, Mar. 7, 2000; *Sprint Launches Wireless
    High Speed Internet Access Service in Houston*, News Release, Sprint
    Corp., Oct. 4, 2000; *Sprint to Launch First Broadband Wireless
    Service for Residential and Small Business Customers in Bay Area*,
    News Release, Sprint Corp., Oct. 24, 2000.

[^26]: Andrew Backover, *Cable, DSL and Wireless Vie for Market
    Leadership*, [Denver Post]{.smallcaps}, Jan. 24, 2000, *available
    in* 2000 WL 4450560 (citing the Strategis Group).

[^27]: The Strategis Group predicts there will be 1.2 million
    residential and 300,000 business MDS broadband subscribers by 2003.
    *U.S. Wireless Broadband: LMDS, MMDS and Unlicensed Spectrum*, Peter
    Jarich and James Mendelson, The Strategis Group Inc., Feb. 17, 2000.

[^28]: 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. *See* *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).

[^29]: "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.

[^30]: Smith, "Wireless Rides To The Rescue," *Wireless Week*, at 16
    (Feb. 7, 2000).

[^31]: *See* § 706 Pub. L. 104‑104, Title VII, Feb. 8, 1996, 110 Stat.
    153, reproduced in the notes under 47 U.S.C. § 157.

[^32]: *See In the Matter of Inquiry Concerning the Deployment of
    Advanced Telecommunications Capability to All Americans in a
    Reasonable and Timely Fashion, and Possible Steps To Accelerate Such
    Deployment Pursuant to Section 706 of the Telecommunications Act of
    1996*, CC Docket No. 98‑146, FCC No. 00‑290 (released August 21,
    2000).

[^33]: *See* *Id*.

[^34]: *See* 47 C.F.R. § 21.901.

[^35]: *Report and Order in Gen. Docket No. 80‑112 and CC Docket No.
    80‑116*, 94 FCC2d 1203 (1983). The Commission reassigned eight
    channels in the E and F groups (2596‑2644 MHz) from the ITFS
    entities to the MDS service. The Commission also grandfathered
    interference protection to existing ITFS applicants, permittees or
    licensees on these eight E and F channels, resulting in twenty‑eight
    ITFS channels in some locales.

[^36]: The Commission reallocated the H group channels from the
    Operational Fixed Service to MDS and made MDS operators eligible for
    authorization on vacant ITFS channels with specified restrictions.
    *Second Report and Order in Gen. Docket No. 90‑54*, 6 FCC Rcd 6792,
    6793‑94, 6801‑06 (1991), *recon. denied*, 7 FCC Rcd 5648 (1992).

[^37]: *See* 47 C.F.R. § 74.939 (providing that the 2686‑2690 MHz is
    divided into 31 narrowband (125 kHz) response station channels).

[^38]: *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.
    Today, some MDS entities have licenses for ITFS channels.

[^39]: *See* Page [42](#itfsmds-channel-licensing) for an explanation of
    the symbols shown on the map.

[^40]: 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/\>.

[^41]: 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.

[^42]: Keith Ross, *Gearing Up for Two‑Way Wireless*, [Private Cable &
    Wireless Cable]{.smallcaps}, Oct. 1998.

[^43]: This figure was provided by and used with the permission of
    WorldCom, Inc.

[^44]: Sue O Keefe, MMDS: From Back Burner to Center Stage,
    Telecommunications, Sept. 1, 1999.

[^45]: *Wireless OnLine Adds Vice President of Product Management*, [PR
    Newswire]{.smallcaps}, Jan. 5, 2000.

[^46]: NextNet, Inc., *Products* (visited Jan. 20, 2000)
    \<http://www.netwnetworks.com/products_prod_botton.html\>.

[^47]: Regional Wireless Operators Select Hybrid Networks' 2‑Way Today
    Solution to Launch Multiple Markets, PR Newswire, Jan. 10, 2000.

[^48]: Cliff Edwards, *Cisco Hopes Advances New Wireless Technology for
    Internet*, [AP Newswires]{.smallcaps}, Dec. 2, 1999.

[^49]: *See* *Id*.

[^50]: *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.

[^51]: *MCI WorldCom Adds Dallas to 'Fixed Wireless' Service Trials*,
    News Release, WorldCom, Inc., Apr. 5, 2000.

[^52]: *See* 47 C.F.R. §§ 21.902, 21.909, 21.913, 21.933, 21.937 and
    21.938.

[^53]: *See* 47 C.F.R. §§ 74.903, 74.939, 74.949 and 74.985.

[^54]: *See* Appendix D, *Report and Order on Reconsideration In the
    Matter of Amendment of Parts1, 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) (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>\>.

[^55]: *See Id.*

[^56]: *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.

[^57]: See Appendix 2.1 for a summary of IMT-2000 technical
    characteristics.

[^58]: *See* 47 C.F.R. §§ 21.902, 21.909, 21.913, 74.903, 74.939, and
    74.985.

[^59]: 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.

[^60]: 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]: 47 C.F.R. §§ 21.904 and 74.935.

[^62]: *See* 47 C.F.R. §§ 21.902, 21.909, 21.913, 74.903, 74.939, and
    74.985.

[^63]: The minimum distance separation is rounded to the
    nearest kilometer. Additional data is available in Tables 5‑C, 5‑C,
    and 5‑D of Appendix 5.1.

[^64]: See 47 C.F.R. §§ 21.902 and 74.903.

[^65]: *See* *Id.*

[^66]: The minimum distance separation is rounded to the
    nearest kilometer. Additional data is available in Tables 5‑F, 5‑G,
    and 5‑H of Appendix 5.1.

[^67]: 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 5.2.

[^68]: 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.

[^69]: In Salt Lake City applications have been tendered for 4 of the 5
    channels.

[^70]: The circles depicted on the maps reflect 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
    the tables. Maintaining the standard protected service areas in the
    illustrations provides the reader 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.

[^71]: The differences in representation of the protected service area
    circles (gray on ITFS channels and white on MDS channels) is a
    function of the different licensing schemes used for these channels.
    Because MDS channels have been auctioned, the geographic licensee,
    subject to the interference rules, may place a station on any
    unencumbered area. Thus, all unencumbered area is shaded and white
    circles are overlaid on this area to show the location and protected
    service areas of incumbent MDS stations. In contrast, ITFS stations
    are only licensed on a site specific basis. Therefore, the location
    and protected service areas of these stations are shown as shaded
    circles on a white (no geographic licensees) background.

[^72]: We note stations operated by geographic MDS licensees are not
    subject to the same interference protection as incumbent stations
    and that maps shown below depict a 56.3 kilometer (35 mile) circle
    around station locations currently in our database for incumbent MDS
    licensees. Stations operated by geographic MDS licensees are shown
    as diamonds without circles around them.

[^73]: Partitioning is the assignment of a portion of a geographic
    licensees service area to another entity. This entity becomes the
    licensee for the indicated spectrum in the partitioned area of the
    service area.

[^74]: The lightest areas on the population density map represent
    population densities up to 28,000 people per square mile and the
    darkest areas represent population densities over 114,000 people per
    square mile.

[^75]: 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.

[^76]: A duplexer is a device that permits alternative transmission and
    reception with a common antenna.

[^77]: Although guard bands appear to be necessary to accommodate TDD
    operation, there is no data regarding how large they may need to be.

[^78]: 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. A system comprised of a single main transmitter cannot add
    more capacity, whereas a cellular configuration can grow by
    subdividing and adding cells.

[^79]: 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.

[^80]: *See* Two‑way Order at 45‑47 and 56.

[^81]: 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.

[^82]: In this case, the MDS operator needs appoximately 56 MHz total
    (32 miles x 32 miles =1024 square miles x 0.055 MHz/square mile) to
    serve customers in this cell.