**NATIONAL TELECOMMUNICATIONS AND INFORMATION ADMINISTRATION (NTIA)**

**An Assessment of the Viability of Accommodating**

**Advanced Mobile Wireless (3G) Systems in the**

**1710-1770 MHz and 2110-2170 MHz Bands**

**\[July 22, 2002\]**

**[SUMMARY]{.underline}**

Consideration for spectrum for advanced mobile wireless services started
with the World Administrative Radio Conference (WARC) in 1992 and was
further delineated at the World Radiocommunication Conference (WRC) in
2000. The quest for 3G spectrum in the U.S. began when the Federal
Communications Commission (FCC) released their Spectrum Policy statement
in 1999. In October 2000, the previous Administration directed that a
plan be developed to select spectrum for 3G by October 20, 2000 that
would result in the allocation of additional spectrum for 3G services by
July 2001 and the auction for licensing 3G wireless providers by
September 30, 2002. In December 2000, the FCC adopted a Notice of
Proposed Rulemaking (ET Docket No. 00-258) to amend Part 2 of the
Commission's rules to allocate spectrum below 3GHz for mobile and fixed
services to support the introduction of new advanced wireless services
including 3G based on the FCC's Spectrum Policy Statement and petitions
from the Cellular Telecommunications and Internet Association (CTIA).

The Administration's and FCC's attempt to identify spectrum for 3G in
2000 and early 2001 timeframe was unsuccessful. Meanwhile, a number of
countries in the rest of the world moved forward and allocated spectrum
for 3G (e.g., Europe, where 155 MHz of spectrum was set aside for the 3G
terrestrial component). According to the CTIA, wireless voice and data
usage has grown from 16 million subscribers using 20 billion total
minutes in 1993 to 130 million subscribers using 450 billion minutes in
2001. At the same time, the Department of Defense (DOD) has become much
more spectrum intensive since they have had to participate in a number
of defensive and offensive actions throughout the world, including
Eastern Europe, Mideast, Afghanistan, and the U.S. (Homeland Defense).

Secretary Evans and FCC Chairman Powell established a task force to
succeed where previous efforts had failed. The Commerce Department's
National Telecommunications and Information Administration (NTIA), in
conjunction with the FCC, DOD, and other federal government agencies,
studied the viability of making all or a portion of the 1710-1770 MHz
and 2110-2170 MHz bands available for advanced mobile wireless (3G)
services. This study concluded that 90 MHz of this spectrum can be
allocated for 3G services to meet increasing demand for new services
without disrupting communications systems critical to national security.
This 90 MHz would come from the 1710-1755 MHz band and a matching 45 MHz
from the 2110-2170 MHz band.[^1] Further information regarding the
results of the viability assessment and the steps necessary to clear the
identified spectrum is described below.

A. **1710-1755 MHz Band**

The 1710-1755 MHz band can be used for the accommodation of advanced
mobile wireless services, assuming certain actions are accomplished.
Specifically, the 1710-1755 MHz band would be substantially cleared of
federal systems. Except as provided below, federal users of this band
would relocate or modify their operations accordingly not later than
December, 2008, or sooner, depending on the nature of the
radiocommunications. In order to achieve this time line, the following
actions would be required:

1\. **Reimbursement Funds**: As required by the Strom Thurmond National
Defense Authorization Act for Fiscal Year 1999 ("NDAA 99\"), funds would
be made available by the private sector entity receiving the Government
spectrum (1710-1755 MHz band) for the cost of relocating or modifying
all Federal Government radiocommunications systems required to vacate or
modify their operations in the 1710-1755 MHz band after the auction has
taken place.

2\. **Federal Non-Military Systems**: The NTIA would direct the
relocation of federal non-military systems from the 1710-1755 MHz band
to other federal bands. Federal agencies that operate systems that are
required to relocate under OBRA-93 are entitled to reimbursement, and
would submit planning assignments to the Frequency Assignment
Subcommittee (FAS) in a timely manner. Federal agencies with protected
assignments have agreed voluntarily to relocate such assignments, if
reimbursed, and would also submit planning assignments to the FAS. All
such systems would be relocated two years after availability of
reimbursed funds, or sooner if practicable.

3\. **Department of Defense (DOD) Fixed Microwave Systems**: The DOD
would relocate its conventional fixed microwave systems from the
1710-1755 MHz band to other bands within two years after reimbursement,
but no later than December 2008, depending on the complexity of the
relocated systems.

4\. **DOD's 16 Protected Sites**:

a.  **DOD Airborne Telemetry & Video Systems**: Subject to the
    availability of reimbursement funds, DOD would relocate their
    airborne operations by December 2008 to other frequency bands, such
    as the 1755-1850 MHz band, 2360-2385 MHz or other telemetry bands;
    or the 2385-2395 MHz band under primary status provided as a result
    of FCC rulemaking for government mobile use. The NTIA will work with
    DOD to facilitate the introduction of new and relocated systems into
    the bands identified above.

b.  **DOD Ground Systems**: The FCC would accomplish the necessary
    rulemaking so that DOD ground systems in the 1710-1755 MHz band can
    remain on a secondary, coordinated basis at all sites, but on a
    primary basis at the Cherry Point, NC, and Yuma, AZ sites for
    operations used in a manner similar to current operations at these
    protected sites. DOD ground systems, other than Digital Wideband
    Transmission System (DWTS) operations at Cherry Point and Yuma, that
    cannot adjust their operations to prevent interference to commercial
    users in the 1710-1755 MHz band will operate in the 1755-1850 MHz
    band or on a non-interference, coordinated basis in the
    1350-2690 MHz band. DOD ground systems may operate in the 2025-2110
    MHz band on a secondary, coordinated basis in the Southwestern
    region[^2] of the U.S.

    **c.** **Future DOD Requirements in 1755-1850 MHz Band**:
    Considering that DOD has future requirements to satisfy in the
    1755-1850 MHz band plus the absorption of certain operations from
    the 1710-1755 MHz band, the FCC would conclude the necessary
    rulemaking by September, 2004 to permanently modify footnote US346
    of the U.S. Table of Allocations to allow DOD the use of the
    2025-2110 MHz band on a co-equal primary basis for DOD ground
    stations at selected sites[^3] that support DOD space operations.
    The relocation of satellite control frequencies would make more
    spectrum available in the 1755-1850 MHz band to satisfy future DOD
    spectrum requirements.

    **d.** **DOD Precision Guided Munitions (PGM) Operations**: PGM
    operations may continue in the 1710-1720 MHz band on a primary basis
    until inventory is exhausted or until December 31, 2008, whichever
    is earlier.

    **e.** **Other DOD Systems**: Other DOD systems[^4] would relocate
    to the 1755-1850 MHz band, or other bands as available.

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5.  **Implementing Coordination**: The NTIA, the FCC, and industry will
    establish a continuing process to facilitate sharing in the
    1710-1755 MHz band. It is anticipated that the FCC will complete the
    necessary rulemakings to address the above conditions for making the
    band essentially clear of DOD operations at the protected sites, as
    well as, reallocation of the band from government exclusive only to
    both government and non-government use on a mixed-use basis. It is
    expected that the early rollout of 3G will occur in the urban areas.
    Assuming reimbursed funds are available, every effort will be made
    to clear these areas first.

    B. **1755-1770 MHz Band**

    The 1755-1770 MHz band is not viable for use by 3G for three
    reasons. First, the impact to or constraints on DOD mobile
    radiocommunication system operations would be significant and
    unacceptable in light of DOD's extensive and critical operations in
    this band. Second, the sharing between 3G and DOD terrestrial
    systems in this band would not be possible in light of the large
    geographical separation distances required. Third, the DOD satellite
    ground control stations would interfere with 3G base stations at
    large geographical distances. In addition, it was determined that no
    suitable alternate federal and/or commercial spectrum could be
    identified for satisfactory relocation of DOD systems. A leap
    forward in technology may permit extensive sharing in all bands
    below 3 GHz in the future. Until that time, however, use of the
    1755-1770 MHz band for advanced wireless applications is not
    considered viable.

    C. **2110-2170 MHz Band**

    According to FCC's 3G working group[^5], 45 MHz in the 2110-2170 MHz
    band appears to be feasible for 3G use. It is anticipated that the
    FCC will initiate a rulemaking for allocation and service rules that
    will make 45 MHz available for advanced wireless services.

    **[VIABILITY ASSESSMENT]{.underline}**

    This NTIA document summarizes the findings of NTIA, the FCC's 3G
    Working Group, the DOD, and other members of the Intra-Government 3G
    Planning Group (IG3GPG).[^6] The IG3GPG assessed the 1710-1770 MHz
    and the 2110-2170 MHz bands to determine if those bands present
    viable options for accommodating advanced mobile wireless systems.
    The 1710-1770 MHz band is used by a number of Federal agencies for
    fixed microwave systems, airborne and land mobile systems, satellite
    command and control operations, radio astronomy, weapon control
    systems, and video surveillance systems. The 2110-2170 MHz band
    includes common carrier, multi-point distribution, paging,
    radiotelephone, local TV transmission, and private point-to-point
    service licensees. The 2110-2170 MHz band is also allocated to the
    mobile satellite service downlink. During earlier efforts, these
    particular bands had been identified as offering the greatest
    potential for additional spectrum for advanced mobile wireless
    services.[^7]

    As of December 2001, according to CTIA, the wireless industry
    employed approximately 203,000 employees, generated revenues of \$65
    billion for CY 2001, and served approximately 128 million wireless
    subscribers. Wireless subscribers are expected to grow to 237
    million in the next 3 years. The commercial wireless industry has
    forecast the need for significant increases in spectrum to support
    growing use of mobile phones as well as new mobile data and Internet
    applications (such as 3G) that will require more bandwidth than is
    currently available for first and second generation cellular
    wireless systems.

    The successful implementation of 3G is expected to enhance U.S.
    economic security by providing opportunities for telecommunications
    manufacturers, service providers, and businesses and consumers
    across the country. 3G holds the potential to make U.S. business
    management more efficient and effective and to expand economic
    opportunities available to all Americans. Based on models used by
    the International Telecommunication Union (ITU), the FCC estimated
    that approximately 300 MHz to 420 MHz of spectrum would be required
    within the United States for 3G services. In addition to current
    national allocations available for commercial mobile services, at
    least 120 MHz to 240 MHz of spectrum has been projected by industry
    as needed to meet future needs. These estimates were based on busy
    hour traffic in high-population-density urban areas.

    While the industry's case for additional spectrum for advanced
    wireless services is documented nationally and internationally, the
    spectrum needs of DOD are also increasing rapidly. The U.S. defense
    forces have greatly increased their wireless use in support of the
    war fighter and homeland defense. Telecommunications, including
    mobile, aeronautical mobile, and rapidly deployable fixed systems,
    are essential to the success of U.S. military operations around the
    world. At the same time, U.S. forces need to train as they expect to
    fight, including the use of spectrum resources at home and abroad.
    Further, military forces could be called on to provide security
    anywhere within the country during crisis. Because of international
    agreements and long-term development and acquisition projects, DOD
    needs spectrum that offers long-term use and security from future
    encroachment. Furthermore, DOD needs operational flexibility as its
    mission responds to changing threats. Accordingly, any sharing
    arrangements would need to protect DOD missions without creating
    conflicts with commercial mobile systems. If DOD systems are to be
    relocated, alternate, comparable spectrum must be identified, as
    required by statute.[^8]

# THE BANDS ASSESSED

Commerce Secretary Evans and FCC Chairman Powell mutually agreed in July
2001 that a final decision on allocation of spectrum for 3G should be
extended to ensure that any decision on additional spectrum for 3G be
the best one possible. As a result of this agreement, the Secretary
directed the NTIA to work with the FCC in coordination with the
Executive Branch agencies to develop a plan to assess spectrum for 3G. A
plan was developed to assess the 1710- 1770 MHz and 2110-2170 MHz bands
because they appeared to hold the greatest potential for possible use by
3G without significantly conflicting with Federal government operations.
The 1710-1770 MHz band is currently used by the Federal government while
the 2110-2170 MHz band is currently used by the private sector. It was
envisioned that the 2110-2170 MHz band could be use for the base station
part of 3G and the 1710-1770 MHz band for the hand-held units. It was
then determined that NTIA would assess the 1710-1770 MHz band and the
FCC would assess the 2110-2170 MHz band.

NTIA and the DOD assessed the 1710-1770 MHz band by splitting the
assessment into two key parts - the 1710-1755 MHz band and the
1755-1770 MHz band. The split was based upon previous decisions
resulting from the Omnibus Budget Reconciliation Act of 1993 (OBRA-93)
[^9], in which the Federal Government had identified *inter alia* the
1710-1755 MHz band for transfer to the FCC on a "mixed-use" basis
(included the maintenance of federal spectrum use at 16 specific DOD
sites and of certain critical federal fixed microwave links around the
country). Spectrum use in the 1755-1770 MHz band is currently exclusive
to the Federal Government. Therefore, a key difference in assessing
these bands is that there is already a presumed federal limitation to
the use of the 1710-1755 MHz band, while no such limitation exists for
the 1755-1770 MHz portion.

Despite the limitation on federal use in the 1710-1755 MHz band, this
band contained substantial challenges to accommodate 3G use. Because
current law^1^[^10] guarantees the continued operation of protected
Federal Power Administration systems in the 1710-1755 MHz band, unless
they voluntarily agree to relocate, any future 3G operations would have
to operate to protect them, thus limiting access. These, and other
federal protected fixed links are distributed around the country; many
supporting electrical power transmission or safety-of-life services. The
Federal Government frequency assignment distribution is shown in
Figure 1. The 16 DOD sites represent critical training and test
facilities for Army, Navy, Air Force and Marine Corps. Many of those 16
sites are used for aeronautical mobile systems, and the potential impact
of those operations extends to points within line-of-sight from high
altitude aircraft. The potential for interference to 3G systems extends
into high population areas in southern California, most of Nevada,
Seattle, much of the Gulf Coast, and major portions of the Eastern
seaboard. The protected site areas of operation and required distances
to prevent interference to 3G are shown in Figure 2.

**[Figure 1]{.underline}**

![](media/image1.wmf){width="5.875694444444444in" height="3.8875in"}

**[Figure 2]{.underline}**

![](media/image2.wmf){width="4.459027777777778in"
height="3.7993055555555557in"}

Many federal operations use the spectrum for short periods of time at
specific locations. Such uses may be able to share with private and
commercial services if prioritization mechanisms or signal response and
frequency flexibility capabilities can be incorporated in future
systems.

**[CONSIDERATIONS FOR ASSESSING THE VIABILITY]{.underline}**

**[OF ACCOMMODATING 3G USE]{.underline}**

To determine the viability of accommodating the use of advanced
commercial mobile services, the IG3GPG identified the spectrum
requirements of the incumbent users, analyzed the

possibility of relocating incumbent users to other bands (including
associated costs), and, where relocation of federal systems was not
possible, analyzed methods of sharing spectrum. During

the period of the assessment, NTIA and the FCC considered comments that
were filed during the FCC's 3G rulemaking.^1^[^11]

NTIA first determined that it could relocate all non-military operations
in the 1710-1770 MHz band to frequency assignments in other federal
bands. The DOD determined that it could relocate most conventional fixed
links (assuming that all systems relocated would be fully reimbursed) to
other federal bands, thereby clearing DOD fixed operations from the
band. However, the DOD could not relocate the remaining systems without
comparable spectrum that offered the spectrum characteristics needed to
support other DOD system requirements. Therefore, NTIA and DOD hosted
information exchanges with industry service provider/vendor engineers
who analyzed each of the 16 sites on an assignment-by-assignment basis,
considering the operational characteristics of the DOD systems.^1^[^12]
As a result of this analysis, the industry experts concluded that all
aeronautical mobile systems and all ground-based TRR systems must be
cleared from the 1710-1755 MHz band if the band is to be used for
advanced wireless services. The industry team noted that further
analysis might conclude that a few of the more remote areas might
require less spectrum, particularly in the earlier years of advanced
services deployment. However, the industry team expressed its desire
that the entire 1710-1755 MHz band would need to be cleared
eventually.^1^[^13]

With respect to the 1755-1770 MHz band, DOD operations are more varied
in location and function than in the 1710-1755 MHz band. Also, DOD and
other federal agencies currently have exclusive use of the band and have
looked to this band to accommodate their growing and evolving missions.
Once again, NTIA found that it could relocate federal non-military
conventional fixed links to other bands. However, in order to move DOD
systems, comparable spectrum that maintained flexibility of use and
comparable room for future growth was required. Moving to other Federal
Government exclusive bands below 3 GHz would merely serve to decrease
operational flexibility and growth potential. Similarly, none of the
non-Federal Government bands proposed by the FCC possessed the needed
propagation characteristics, tuning range, growth potential and
conflict-free operations needed by DOD.

**Incumbent User Spectrum Requirements**

[1710-1770 MHz Band]{.underline}.

The federal requirements for the 1710-1755 MHz band are defined by the
set of frequency assignments existing in the government master file
(GMF) for that band. This includes military and non-military fixed
systems, and military and non-military mobile systems, some of which are
airborne. As a result of the OBRA-93 mandates, systems in unprotected
areas have to vacate the band. Users of protected fixed links and
systems in protected areas may voluntarily accept reimbursement and
relocate. The 1755-1770 MHz band is available to federal agencies
nationwide on an exclusive basis.

NTIA researched federal operations via its GMF, the master list of
authorized federal frequency assignments (The GMF lists the assignments,
but does not specify the amount of equipment associated with each
assignment.). As of January 2002, there were 1,371 federal non-military
assignments in the 1710-1770 MHz band listed in GMF. The majority (99
percent) of non-military assignments are for fixed service, followed by
mobile, aeronautical-mobile, land mobile, and space services. There are
1,016 military assignments in the 1710-1770 MHz band. Of those
assignments, approximately 76 percent are for fixed or transportable
use. The GMF does not contain all the classified federal assignments.

The 1710-1850 MHz portion of the frequency spectrum possesses specific
attributes that make it a prime operating region for many DOD mobile and
aeronautical systems. These attributes include wide beamwidth antennas,
low transmit powers, large channel throughputs, high link reliability,
and extended link distances. No other band region to which DOD has
access can simultaneously support this unique set of attributes in
combination.

The DOD identified its incumbent systems operating in the 1710-1755 MHz
band at 16 protected sites, and DOD systems operating in the
1755-1770 MHz band across the United States. The major incumbent systems
include tactical radio relay (TRR), air combat training systems (ACTS),
the satellite control Space Ground Link System (SGLS), precision guided
munitions (PGMs), fixed point-to--point links, unmanned aerial vehicles
(UAVs), combat identification, and other military systems. According to
NTIA's reimbursement rules, reimbursed assignments in the 1710-1755 MHz
band are limited to those in existence up to and including 1998.

The DOD has in recent years experienced an increase in spectrum
requirements, especially for the 1710-1850 MHz band. The increase in DOD
spectrum needs within this band is driven both by the need to increase
the capabilities of existing systems as well as by the introduction of
newer advanced technology wireless systems. The characteristics of this
portion of the spectrum lends itself to the development and operation of
such systems as unmanned aerial vehicles, new identification systems to
prevent "friendly fire" situations, and individual wireless links to
soldiers to provide state-of-the-art data exchange to enhance
battlefield situational awareness. In addition, increased information is
being collected on the battlefield and must be rapidly transmitted to
higher decision-making levels. This increased information transmission
required improvements in existing system capability, primarily by
expanding capacity or throughput to support the information exchange
requirements of battlefield networks and expanding capacity on telemetry
links to support growing test range data requirements. In many cases
this increase in capacity requires wider transmission bandwidths.

[2110-2170 MHz Band]{.underline}.

The 2110-2130 MHz portion of the 2110-2170 MHz band supports 3,454
common carrier (Part 101) licenses, 56 paging and radiotelephone service
(Part 22) licenses, 47 local television transmission service (Part 101)
licenses, and one general aviation (Part 22) license. The 2130-2150 MHz
band supports 2,448 private point-to-point (Part 101) licenses, and two
common carrier (Part 101) licenses. Channels in the 2130-2150 MHz band
are paired with spectrum in the 2180-2200 MHz band. The 2160-2165 MHz
band supports 890 common carrier (Part 101) licenses, 13 paging and
radiotelephone service (Part 22) licenses, and 40 local television
transmission service (Part 101) licenses.

NASA uses the 2110-2120 MHz band for high power up-link transmissions at
its Deep Space Network (DSN) facility at Goldstone, California in order
to ensure link availability to deep space satellites.

**Potential for Relocation**

Funding and comparable spectrum are two key factors in examining the
possibility of relocating certain DOD systems. Because the participants
in the IG3GPG estimated that revenues to be obtained from auction of 3G
spectrum would be far greater than the costs of relocating incumbent
systems, costs were not considered critical to the viability of each
band. While current law does not mandate that all federal agencies have
to be provided comparable spectrum, it does require that comparable
spectrum be provided if DOD systems are relocated.

Certain DOD operations in the 1755--1770 MHz band are part of integrated
systems that operate throughout much of 1755--1850 MHz band. Therefore,
if the 1755-1770 MHz band were no longer available, DOD would need more
than 15 MHz to relocate existing systems because of the links with other
systems in the 1755-1850 MHz would be severed and would have to be
re-accommodated elsewhere. DOD also needs spectrum that offers
comparable opportunity to develop and deploy systems to meet
international and homeland defense missions. Because of international
agreements and long-term development and acquisition projects,
comparable spectrum must also provide predictability and certainty for
long-term availability. Furthermore, DOD needs operational flexibility
as its mission responds to changing threats. Therefore, to obtain joint
certification of comparability, any spectrum for relocation of DOD uses
would have to possess those characteristics.

The following bands were identified as potential candidate bands for
relocation of incumbents in the 1710-1770 MHz band: 930-950, 1910-1930,
1990-2025, 2025-2110, 2200-2290, 2360-2385, 2385-2390, 2390-2400,
2500-2690, 3650-3700, 4400-4940, 7125-8500, and 14500-15400 MHz. The
primary focus was on the 1770-1850, 2200-2290, 4400-4940, 7125-8500, and
14500-15400 MHz bands as these were Federal Government bands. The vast
majority of the fixed microwave systems could be accommodated in the
7125-8500, and 14500-15400 MHz bands using off-the-shelf commercial
equipment. However, bands above 3 GHz do not provide spectral
characteristics to accommodate DOD mobile capabilities. Individual bands
such as 930-950 MHz, 1910-1930 MHz, 2390-2400 MHz either do not offer
sufficient spectrum, or would create new interference issues with regard
to incumbent users, but may be useful when coupled with adjacent bands,
such as coupling the 2360-2385 MHz and 2385-2390 MHz bands. The
1990-2025 MHz and the 2025-2110 MHz bands offers the spectral
characteristics that could support many DOD requirements, but the bands
also have incumbents with no readily apparent band(s) to which they
could be relocated.

**Potential for Sharing**

To accommodate 3G sharing with incumbent DOD users, the IG3GPG needed to
establish first whether 3G use was generally compatible with the
incumbent users. If not, it would consider whether spectrum could be
shared through frequency, location or time separation and provide a
viable 3G service without diminishing the capabilities of the incumbent
users. To support an analysis of sharing, the FCC provided the most
recent technical parameters for the 3G systems.

**Relocation Costs**

In its report, "The Potential for Accommodating Third Generation Mobile
Systems in the 1710-1850 MHz Band",^1^[^14] released in March 2001, NTIA
estimated the costs associated with the various segmentation options
that would allow the 1710-1755 MHz and 1755-1850 MHz bands to be used
for 3G accommodation. For the 1710-1755 MHz band, NTIA is required to
submit estimates to the FCC regarding the relocation costs for federal
systems that must be relocated as a result of OBRA-93. NTIA is currently
preparing a separate report for future release on this subject, but has
previously estimated costs for this band, which appeared in the *NTIA 3G
Report*. The final costs for the 1710-1755 MHz band may be different
from the costs shown herein due to additional data received subsequent
to this assessment.

**[VIABILITY OF THE 1710-1755 MHz BAND]{.underline}**

**Potential Relocation of Fixed Systems**

To assess the viability of relocating federal non-military fixed systems
from the 1710-1755 MHz band, NTIA ran a computer program, Spectrum XXI,
which nominates frequencies for assignment based on the technical
parameters of the subject system. Many federal agencies use this
program, developed by NTIA and the DOD, to plan frequency assignments.
Spectrum XXI uses GMF assignments to create an electromagnetic
environment. Where spectrum was found in other frequency bands for the
systems currently assigned in the 1710-1755 MHz band using Spectrum XXI,
then relocation was deemed possible. Moving fixed links to other
government bands does not significantly limit the use of the bands to
which the fixed systems would be moved. Via this process, NTIA found
that it could relocate all conventional non-military fixed links from
the 1710-1755 MHz band to other federal bands. Although the Federal
Power Administration links and certain other links identified in the
NTIA Final Reallocation Report, are safety-of-life systems exempt from
relocation by statute, the user agencies have agreed to relocate these
systems pending reimbursement. Most of the fixed assignments in the
1710-1755 MHz and the 1755-1770 MHz bands have return links in the
1770-1850 MHz band. Accordingly, an added efficiency of the move to 3G
will be the relocation of virtually all federal non-military
conventional fixed links to other federal bands, freeing up spectrum in
the 1755-1850 MHz band for more efficient uses. The DOD determined that
it could relocate most of its conventional fixed microwave systems to
other bands.

**Potential Relocation of Mobile Systems**

Relocation of mobile assignments presents a more difficult situation
because potential interference is far greater from mobile systems to
incumbent operations in the bands to which systems might be relocated.
NTIA identified several non-military mobile systems for relocation.
These non-military mobile systems are not protected, and due to the
limited operations associated with these assignments, NTIA concluded
that relocation is possible.

[National Aeronautics and Space Administration (NASA)]{.underline}: NASA
has the following frequency assignments that require relocating:

\(1\) Aeronautical mobile operation in Virginia on 1720 MHz supporting
remotely piloted vehicle research. Relocation of operations to the
1770-1850 MHz band is possible since

equipment tunes between 1710-1850 MHz.

\(2\) Aeronautical mobile operation at Edwards AFB, California on 1727
MHz supporting data transfer from high performance aircraft. Relocation
of operations to the 1770-1850 MHz band is possible since equipment
tunes between 1710-1850 MHz.

\(3\) Aeronautical mobile operation at Pierre, South Dakota on 1735 MHz
supports lighter-than-air aircraft research. Relocation of operations to
the 1770-1850 MHz band is possible since equipment tunes between
1710-1850 MHz.

[Departments of Justice, Treasury and the U.S. Postal
Service]{.underline}: These three agencies have United States &
Possessions video surveillance operations in the 1710-1755 MHz and
1755-1770 MHz bands. Ongoing discussions have addressed moving their
operations to the 1770-1850 MHz band or another authorized band for this
type of operation. These federal users have requested that selection of
a new band and/or new equipment be made jointly due to the similarity of
operations. Discussions on a specific band and commonality of equipment
are ongoing.

[Department of Transportation (DOT)]{.underline}: The DOT has a land
mobile operation at Pueblo, Colorado in support of testing and
developing railroad vehicles and related railway systems. NTIA has asked
the DOT to identify an alternate band to continue their operations.

[Department of Defense (DOD)]{.underline}:

NTIA identified the 1770-1850 MHz and 2200-2290 MHz bands as potential
alternate government bands for the relocation of DOD mobile assignments.
The 2200-2290 MHz band supports 1629 aeronautical mobile frequency
assignments encompassing telemetry and telecommand. The band is the
consolidated downlink and crosslink band for Space Ground Link Subsystem
(SGLS) and NASA's Telemetry and Data Relay Satellite System (TDRSS) and
NASA's Ground Network (GN). The TDRSS is critical to the control of
commercial and government launches. It also supports communications with
space research and earth exploration satellites, and the Hubble
telescope. Given the ongoing difficulty in providing adequate spectrum
for satellite command and control and telemetry applications and the
fact that it would not be possible to find open channels in other bands
for these uses, no further consideration could be given to this band.
Other possible bands included the 2360-2385 MHz band, and the 2385-2390
MHz band identified for transfer to the FCC in 2005. The 2360-2385 MHz
band contains 229 federal aeronautical mobile assignments, one fixed and
one radar; the 2385-2390 MHz band contains 23 aeronautical telemetry
assignments.

In general, relocating all DOD systems from the 1710-1755 MHz band of
the 16 protected sites into the remaining 1770-1850 MHz band was not
feasible, given the existing and growing operations in the 1770-1850 MHz
band. Moving mobile, including aeronautical mobile operations into the
dense electromagnetic environment of the 1770-1850 MHz band will
restrict other potential deployments. The 1770-1850 MHz band currently
supports additional systems (such as the satellite control earth
stations and the air combat training systems) and must absorb the DOD
frequency assignments that will be displaced from the 1710-1755 MHz band
that are outside of the 16 protected areas. Although non-military
conventional fixed systems may be relocated from this band, they are not
generally located at or near military facilities and therefore do not
significantly relieve the frequency congestion at DOD sites. The limited
geographical areas of military facilities and the number of radio
systems currently operating in these areas produce highly dense
electromagnetic environments that are incapable of supporting the
additional assignments that would need to be relocated from the
protected areas, including the other systems currently operating in the
1755-1770 MHz band that would need to be relocated to these same
facilities. The tuning ranges of this equipment generally do not operate
beyond 1850 MHz. Therefore, the potential identification of comparable
spectrum outside this range or in small increments would require
redesign of the equipment in some cases.

Therefore, systems such as the tactical radio relay (TRR), precision
guided munitions, aeronautical mobile systems, and certain other systems
will require comparable spectrum for relocation, in addition to
reimbursement to maintain their current capabilities. However, no
comparable spectrum has been identified. These systems are operational
in many of the 16 protected areas as described in the NTIA Final
Reallocation Report. Technical analyses have indicated that operation of
these systems could cause interference to 3G base stations.

[Tactical Radio Relay]{.underline}:

TRR systems mostly consist of the AN/GRC-103, AN/GRC-226 and AN/GRC-245
(mobile subscriber equipment) systems for Army use, and the AN/MRC-142
and AN/SRC-57 for Navy/Marine Corps use. These systems tune from
1350-1850 MHz (the AN/GRC-245 tunes to 2690 MHz) and requires 50 MHz
(Army), 60 MHz (Marine Corp), and 88 MHz (Navy) for ship-to-shore links.
Much of the tuning range of these systems is not available in the United
States during peacetime.

TRR systems often have a large number of frequency assignments at
military facilities to give the local frequency manager adequate
spectrum resources to balance the requirements of TRR, mobile systems,
and other DOD equipment that all use the 1710-1850 MHz band. During
large exercises, the 1710-1850 MHz and other government bands are at
times insufficient to satisfy the requirements for these exercises. For
those exercises, no additional assignments can be made, and no
additional equipment can be supported in this spectrum. The DOD examined
relocating 1710-1755 MHz assignments to the 1770-1850 MHz band, but
found that sufficient channels would not be available for large
operations and that other operations in that band would be constrained.
These systems have been designed with a broad tuning range to support
large networks of multiple links that require significant co-site and
transmit/receive frequency separations. The full tuning range is not
able to be used in the United States because of

limitations of suitable federal frequency allocations in the tuning
range. Therefore, other comparable spectrum is necessary to accommodate
the TRR systems if relocated from the band.

The TRR equipment also cannot be redesigned to operate outside the
1710-1850 MHz band on a site-by-site basis, since the equipment operates
as part of a larger system. TRR equipment is transportable and is often
deployed to multiple locations to interoperate with other systems for
training exercises or operational missions. For example, TRR equipment
used by the Army National Guard in New York State may need to move with
the Guard unit to other geographical locations for training or
deployment, and must interoperate with other TRR equipment.

However, DOD ground systems in the 1710-1755 MHz band could operate on a
secondary, coordinated basis at the 16 protected sites with the
exception of Cherry Point, NC, and Yuma, AZ, where they would require
primary status because they cannot adjust their operations to prevent
interference to commercial users. Cherry Point and Yuma are critical for
conducting realistic Marine Corps training in amphibious operations and
aviation training, respectively. It may also be possible for DOD to
operate on a non-interference, coordinated basis in the 1350-2690 MHz
band at all locations and on a secondary, coordinated basis in the
2025-2110 MHz band in Southwestern region. DOD is already from
time-to-time coordinating frequencies on a temporary basis at the local
level in the 1350-2690 MHz band. The 2025-2110 MHz band is used
primarily by the electronic news gather services, space operations,
earth exploration-satellite operations and space research. NASA has very
effectively coordinated with other users of the band. The DOD
coordination would be similar in nature and since the ground operations
are usually in remote areas, it would appear to be feasible for DOD to
operate on a coordinated basis in this band. Use of the 2025-2110 MHz
band in support of DOD space operations at selected DOD ground station
sites would also be helpful to take the pressure off use of the
1755-1850 MHz band due to continued space operations use and absorption
of certain operations in the 1710-1755 MHz band. The coordination in
this band would be similar to that currently being done by NASA for its
space operations. The FCC would have to perform a rulemaking to modify
footnote US346 of the U.S. Table of Allocations to allow DOD the use of
the 2025-2110 MHz band on a co-equal primary basis for DOD ground
stations at selected sites that support DOD space operations.

[Aeronautical Telemetry]{.underline}:

Airborne telemetry operations take place in 10 of the 16 protected
sites. Telemetry downlinks operate from manned aircraft, unmanned aerial
vehicles (UAV), and missiles or other ordnance devices. Flight
characteristic data and video are transmitted to the ground for
analysis. Aircraft operations are expensive, and data lost from live
missile firings are irreplaceable, so telemetry signals are designed to
be robust to completely capture the downlink data. Because of the
operating altitude (up to 30,000 ft above mean sea level) of some of the
aircraft, a wide area may be illuminated by telemetry signals. These
systems were the least compatible with 3G systems.

Aeronautical telemetry assignments are often interleaved between
ground-based assignments, and scheduled so as not to interfere. Because
of the tight packing of frequency assignments and the complex scheduling
required for flight operations, the DOD has stated that relocation of
these assignments to the 1770-1850 MHz band, which is already heavily
used, may be difficult. If other spectrum such as the 2385-2395 MHz band
(adjacent to the existing telemetry band 2360-2385 MHz) could be made
available, DOD airborne operations could be relocated from the 1710-1755
MHz band at the 16 protected sites. The 2385-2390 MHz band was
identified by NTIA to be provided to the FCC under the Balanced Budget
Act of 1997. The FCC is in process of reallocating this spectrum. The
2390-2395 MHz band is currently used for amateur service on a primary
basis. FCC will have to perform a rulemaking to reallocate this spectrum
to include airborne telemetry.

[Precision Guided Munitions:]{.underline}

Both the Air Force and the Navy operate precision guided munitions
(PGMs) in the 1710-1850 MHz band. Although the technical characteristics
of these systems are classified, DOD has stated that their
characteristics prevent limiting full PGM operations to the 1770-1850
MHz band. Therefore, operations within the 1710-1755 MHz band cannot be
moved to the 1770-1850 MHz band. Because of the operational and physical
constraints involved in launching and guiding a missile to its target,
spectrum below 3 GHz is required for satisfactory operation of the
guidance system. Higher frequencies pose problems with respect to
antenna coverage, electrical (prime power) requirements, and transmitter
power output. No studies exist that show practical implementation above
3 GHz. Relocation of PGMs to the 2200-2290 MHz band has been examined,
but this band is heavily used by numerous RF systems critical to the
national defense and operation of the PGMs at desired test sites would
be problematic. There are no international frequency bands allocated for
military uses, so the use of any alternate frequency band would likely
conflict with commercial applications in bands allocated
internationally. No other comparable spectrum suitable for PGMs has been
identified. Although the bands cannot be stated in this assessment, it
should be noted that PGMs could not be operated in any band where threat
emitters are known to operate. Navy PGMs have slightly different
frequency plans, and could still operate with the loss of the 1710-1755
MHz band, with reduced capability.

Impact to DOD PGM systems will be minimized by allowing them to operate
on a primary basis in the 1710-1720 MHz band until the current inventory
of PGMs is exhausted or until December 2008, whichever occurs first.

**Relocation Costs**

Based on information provided by the federal agencies, costs associated
with the relocation of non-military systems from the 1710-1755 MHz are
estimated at \$410 million. The cost to relocate military systems
(non-protected) from the 1710-1755 MHz is estimated to be between
\$38-138 million, an amount currently being reassessed by DOD. The cost
to relocate and/or modify DOD radiocommunications at the 16 protected
sites will be determined at a later date, but not exceed the date
established by the NTIA reimbursement rules relative to the auction
date. As indicated above, these values are estimates and subject to
change.

**Potential Sharing**

Technical analyses of the potential for frequency sharing between
incumbent systems and 3G systems in the 1710-1755 MHz were made.
Previous analyses had shown that if operated on the same frequency, in
the same geographic area, at the same time, DOD operations in the
1710-1755 MHz band would interfere with 3G base stations. Protected DOD
operations are conducted within a circular area (operations area) drawn
around the designated 16 sites. Interference to 3G base stations is
possible outside these areas at distances that are a function of the
location of the transmitter within the given operations area, the system
altitude, power, and antenna gain. The results of the analyses indicate
that large separation distances would be required to prevent
interference between incumbent and 3G systems. However, while TRR
systems occupy most of the band during large-scale training operations,
these systems are located on the ground and, though portable, operate as
fixed microwave systems with the associated narrow beamwidths.
Aeronautical links, though having the widest potential reach, are
limited to periodic flights during a day, are limited in the number of
channels, and move rapidly across the operation area (which constantly
changes the potential zone of interference to the 3G base stations as
the aircraft move). Signals associated with guidance of PGMs are short
in duration during live firings; interference is only possible during
the time of flight of the munition. Captive carry PGM training flights
involving two or more aircraft will have a longer duration. In these
cases, 3G operators could take measures to overcome interference coming
from the known direction of the DOD operations.^1^[^15]

The analysis of the industry experts concludes that all aeronautical
mobile systems and all terrestrial TRR systems must be cleared from the
1710-1755 MHz band if the band is to be used for advanced wireless
services. The industry team noted that further analysis might conclude
that a few of the more remote areas might require less 3G spectrum,
particularly in the earlier years of advanced services deployment.
However, industry noted that the entire 1710-1755 MHz band would need to
be cleared eventually.

**[VIABILITY OF THE 1755-1770 MHz BAND]{.underline}**

**Potential Relocation of Fixed Systems**

The Spectrum XXI mechanism was again used to assess the viability of
relocating fixed systems from the 1755-1770 MHz band. Via this process,
NTIA found again that all conventional non-military fixed links in the
1755-1770 MHz bands could be relocated to other federal bands. The DOD
found relocation frequencies for most of its conventional fixed
point-to-point assignments.

**Potential Relocation of Mobile Systems**

[National Aeronautics and Space Administration (NASA)]{.underline}: NASA
requires relocation of space-to-space non-geostationary operations
supporting communications between the space shuttle and its payload.
Relocation of operations to the 1770-1850 MHz band is possible since the
current NASA frequency assignment allows for continuous selection of
frequency between 1763 and 1840 MHz.

[Department of Defense]{.underline}:

[DOD Mobile Systems]{.underline}: Some of the DOD mobile systems (e.g.,
unmanned aerial vehicles, combat identification systems, etc.) operating
in the 1755-1850 MHz range have recently been elevated in importance due
the war on terrorism, homeland defense, and possible requirements for
ballistic missile defense. The DOD also anticipates that the
1755-1850 MHz band will experience increased use due to growth in
military spectrum requirements to support mobile wireless applications.
The current tuning ranges of this equipment do not go beyond 1850 MHz.
Therefore, the potential identification of *comparable spectrum* outside
this range or in small increments, would require redesign of the
equipment.

[Tactical Radio Relay]{.underline}: The potential for the relocation of
tactical radio relay is the same as for the 1710-1755 MHz band.

[Aeronautical Telemetry]{.underline}: The potential for the relocation
of aeronautical telemetry is the same as for the 1710-1755 MHz band.

[Precision Guided Munitions:]{.underline} The relocation discussion on
PGMs provided for the 1710-1755 MHz band also applies for the 1755-1770
MHz band. In addition, the loss of this 1755-1770 MHz band would
severely constrain Navy PGM systems to the point of reducing training
effectiveness.

[Air Combat Training Systems]{.underline}: The Air Combat Training
Systems (ACTS) use two ground-to-air and two air-to-ground frequencies
above 1770 MHz. The ground-to-ground component of the system uses fixed
links in the 1764-1770 MHz range. The DOD has tentatively identified
alternate spectrum for the ground links in another federal band, but
relocation of these links to higher bands will require a significantly
increased infrastructure complexity.

[Land Warrior and ICIDS]{.underline}: These relatively new DOD systems
operate in the 1755-1850 MHz range. The Land Warrior system is a
wireless local area network enabling soldiers to send and receive voice,
video, map overlay information, operation plan diagrams, etc. It tunes
between 1772 MHz and 1822 MHz, with a bandwidth of 20 MHz with 5 MHz
channel increments for transmission. This overlaps the 1755-1770 MHz
band. Loss of the 1755-1770 MHz band would mean the loss of 2 (center
frequencies 1772 and 1777 MHz) out of 11 channels, or a loss of 18 per
cent of possible channels. The Individual Combat Identification System
(ICIDS) is an interrogate and response system designed to provide
identification of friendly force by individual and automatic weapons
users to a range of 1000 meters or more. ICIDS operates in the 1755-1850
MHz range. The loss of the 1755-1770 MHz band would mean the loss of 150
channels out of 950, or a loss of about 16 per cent of all possible
operating channels. Furthermore, moving all operations within a smaller
set of operating channels increases the likelihood of co-site
interference. Inter-system interference reduces the ability of ICIDS to
accurately identify friendly soldier, potentially leading to friendly
fire casualties. No acceptable alternate bands have been identified for
relocation of either Land Warrior or ICIDS.

**Potential Relocation of Satellite Systems**

The 1761-1842 MHz band segment supports the telemetry, tracking, and
command (TT&C) functions for the DOD satellites. It also supports North
Atlantic Treaty Organization (NATO) and British military satellites, and
various space and ballistic missile test programs. TT&C supports
automatic space vehicle acquisition and tracking, ranging, reception and
recording of vehicle telemetry data, and transmissions of commands to
the space vehicle.

The main system operating in this band segment that supports the TT&C
functions is the Air Force Space Ground Link Subsystem (SGLS). The band
plan for SGLS comprises 20 discrete frequencies beginning at
1763.721 MHz and ending with 1839.795 MHz. Each channel is 4.004 MHz
wide. Satellites generally are able to receive only on one pre-set
channel, and this channel cannot be changed once the satellite is
launched. Although most TT&C operations are provided by fixed sites, the
Air Force also uses transportable SGLS-compatible earth stations to
provide additional coverage during launches, early orbit operations,
anomaly resolution, and

critical orbit insertion maneuvers. These transportable stations are
moved as necessary to accomplish the mission.

In addition to supporting TT&C for military satellites, the
1761--1842 MHz band segment supports TT&C for the cooperative DOE/DOD
Proliferation Detection Technology (PDT) Program. The PDT Program will
demonstrate advanced system technologies for remotely monitoring nuclear
facilities and for identifying and characterizing undeclared and
clandestine nuclear facilities. Although this program is directed at
nuclear proliferation monitoring, the technology could potentially serve
a variety of other national security and civilian needs.

The operation of U.S. satellite control facilities internationally is
authorized by specific host nation agreements in those countries in
which the SGLS-compatible stations are deployed. The lack of spectrum
support for continued satellite control operations in the 1755--1850 MHz
band would have implications for U.S. allies as well, since both NATO
and the UK specifically depend on satellite control stations operating
in the 1755--1850 MHz band to provide military spacecraft TT&C support
for the NATO SATCOM IV and the UK SKYNET satellites, respectively.

The Air Force Satellite Control Network (AFSCN) consists of satellite
control centers, tracking stations and test facilities located around
the world. Satellite Operations Centers are located at Schriever Air
Force Base near Colorado Springs, Colorado and Onizuka Air Force Base,
Sunnyvale, California. These centers are manned around the clock and are
responsible for the command and control of their assigned satellite
systems. The operations centers are linked to remote tracking stations
(RTS's) around the world. The RTS's provide the link between the
satellite being controlled and the operations center. RTS's around the
world are needed to maintain frequent communications with the satellite.
The TRS's are required by the operations centers to contact a supported
satellite as needed while it's within the particular TRS's view. Some
satellites, especially those in geostationary orbit, are limited in
which TRS's can support them due to visibility constraints. Space
vehicle checkout facilities are used to test launch vehicles and
satellite platforms to ensure that the onboard systems operate within
specifications.

No comparable available spectrum has been identified for relocation of
the satellite control function. The physical relocation of a control
station is a major undertaking, involving acquisition of real estate in
the appropriate locations, funding, equipment procuring, and legal
implications regarding the Base Relocation and Closure Act. Relocation
of satellite remote tracking stations to minimize interference cannot be
accomplished in the near-term, if at all. Spectrum relocation for
satellite operations to the 2025-2110 MHz band has been considered, and
could free up frequencies in the 1755-1850 MHz band for other DOD usage.
New satellites to be launched could be set to operate in the 2025-2110
MHz band, but any major transition to this band could not be completed
within a decade. NTIA, in its Final Reallocation Report, noted that it
is not possible to change the frequencies for satellites which have
already been launched, and while it may be possible to change the
frequency of satellites which have yet to be launched, in the near term
this would be extremely expensive.^1^[^16]

**Relocation Costs**

NTIA identified current assignments via the GMF. However, given the
expanding and evolving DOD missions, flexibility and long-term growth
opportunity represented an essential characteristic of this band. The
cost to relocate non-military systems from the 1755-1770 MHz band is
estimated at \$210 million. The estimate to relocate military
assignments from the 1755-1770 MHz band has not been determined at this
time.

**Potential Sharing**

Technical analyses of the potential for frequency sharing between
incumbent systems and 3G systems in the 1755-1770 MHz bands were made.
The results of the analyses indicate that large separation distances
would be required to prevent interference between incumbent and 3G
systems. The FCC staff indicated that mitigation techniques resulting
from terrain shielding, deployment of base station antennas that avoid
main-beam coupling with interfering stations, and use of advanced
(adaptive) antenna systems, would significantly lessen the distance over
which a given DOD system would interfere with a given 3G system.
However, NTIA concluded that general frequency sharing is not feasible
in the 1755-1770 MHz band, given the hundreds of geographically
dispersed incumbent systems operating in that band, national coverage
requirements for 3G, and the separation distances required to prevent
interference. Further, implementation and protection of 3G in areas
where the 3G systems would not receive interference will only further
restrict DOD growth in the band. Additional system modifications may be
required, such as RF filtering, to limit adjacent band interference due
to the inherent disparity between Federal and 3G systems.

Satellite systems requiring access to any of SGLS channels 1 through 4
would be impacted by 3G operations in the 1755-1770 MHz band. While the
mobile component of 3G systems that 1710-1770 MHz band would not pose a
significant interference threat to satellites, the uplink transmissions
of the satellite control stations may interfere with the 3G base
stations receivers in the band for distances in excess of 200 km
depending on terrain. Satellite receiver frequencies are pre-set, and
cannot be changed from the ground. Both geostationary and
non-geostationary satellites are controlled in the 1755-1770 MHz band.
Satellites are scheduled for commanding, in advance, from those remote
tracking stations that will have the satellite in view during the
scheduled time. It is imperative that all remote tracking stations be
able to command every satellite, as operational requirements dictate.

**[VIABILITY OF THE 2110-2170 MHz BAND]{.underline}**

Fixed microwave incumbents in the 2110-2150 MHz and 2160-2165 MHz bands
are entitled to compensation for relocation to other frequency bands
under the policies adopted in the FCC's *Emerging Technologies*
proceeding for incumbent fixed users in the frequency bands reallocated
for broadband PCS. These incumbents are entitled to compensation for
relocation of any links that may pose an interference threat to new
fixed or mobile systems licensees, including compensation for all
engineering, equipment, site, and FCC fees.

The 2150-2162 MHz band supports Multi-point Distribution Service (MDS)
licensees as a return channel for transmissions in the 2500-2690 MHz
band. Channel (1) is 2150-2156 MHz, channel (2) is 2156-2162 MHz, and
channel (2a) is 2156-2160 MHz. Licenses are issued for geographic areas,
either on a protected basis within an area defined as a circle with a 35
mile radius, or within a Basic Trading Area (BTA) not including the
protected MDS areas (circles).

The FCC indicated that there may be viable replacement spectrum
available for the licensees to continue to offer two-way services.

**Potential Relocation of Fixed Systems**

The FCC has already established relocation procedures for fixed service
users in the 2110-2150 MHz and 2160/62-2165 MHz bands. For the
2165-2170 MHz band, the FCC has also established procedures for
mobile-satellite service providers to relocate incumbent fixed services.
Because it has not been determined whether this spectrum should be
reallocated for 3G wireless systems, the FCC has not addressed whether
there is a need for additional relocation procedures for incumbent
mobile-satellite service providers. In addition, because the FCC has not
decided whether to reallocate the 2150-2160/62 MHz band for 3G wireless
systems, there are no relocation procedures for this portion of the
band. The 2110-2130 MHz band is paired with the 2160-2180 MHz band, and
the 2130-2150 MHz band is paired with the 2180-2200 MHz band. As a
result, the FCC may also need to identify relocation spectrum for the
bands paired with any spectrum ultimately allocated for 3G wireless
systems.

For the bands under consideration, the FCC study reviewed various
options for relocation spectrum. Several years ago, in the *Emerging
Technologies* proceeding, the FCC reallocated certain bands to fixed
services for the purposes of relocating incumbents in the bands
designated for *Emerging Technologies* use, including spectrum at 4 GHz,
6 GHz, 10 GHz, and 11 GHz. Generally, it is believed that all of the
existing non-multi-point distribution system (MDS) operations in the
2110-2150 MHz and the 2160/62-2200 MHz bands can be accommodated
utilizing these relocation bands. For the 2150-2160/62 MHz band, the
current record in the FCC's ongoing rulemaking proceeding regarding
several options for relocation spectrum, including: unlicenced personal
communications systems (PCS) spectrum (1910-1930 MHz); amateur radio
service and unlicenced asynchronous voice (unlicenced PCS) device
spectrum (2390-2400 MHz); mobile-satellite service spectrum (1990-2025
MHz); and the upper multi-channel, multipoint distribution
system/instructional television fixed service (MMDS/ITFS) band
(2500-2690 MHz) appears to provide several viable alternatives for
relocation spectrum, and as such, adequacy of relocation spectrum should
not present an insurmountable challenge. For the 2110-2170 MHz band, and
any relevant paired spectrum, the FCC's report provides information that
will be helpful in determining the magnitude of the relocation issues.

The FCC plans to relocate fixed microwave incumbent licenses in the 4
GHz, 6 GHz, 10 GHz, and 11 GHz bands. Available data shows that it may
be possible for many incumbent operations to be relocated to frequencies
as high as 11 GHz, and technically, could be generally accommodated in
the lower bands due to the relatively short path lengths of the links.

Relocation issues, including identifying appropriate relocation
spectrum, will be addressed by the FCC in developing polices to
facilitate implementation of 3G services. Based on the current
information available, while acknowledging that some difficult tradeoffs
may need to be made, there is sufficient spectrum available for
relocation. Accordingly, should the FCC decide, based on the record in
the 3G proceeding, that such reallocation and re-licensing is in the
public interest, the entire 2110-2170 MHz band could be made available
for 3G wireless systems in an acceptable timeframe.

**Potential Relocation of Space Research**

The frequency associated with the NASA Goldstone facility cannot be
altered because space probes will continue to be commanded by Goldstone
for years to come.

**Potential Sharing with Fixed Systems**

Third Generation wireless systems cannot generally share spectrum with
nation-wide fixed service systems.

**Potential Sharing with Space Research**

Third generation mobile receivers will probably experience service
disruption in the 2110-2120 MHz band when attempting to operate in areas
surrounding the Goldstone site during uplink transmissions. The severity
and duration of such disruption will depend upon the frequency/channel
assigned to the mobile unit, as well as, time, power, and orientation of
the

transmitting antenna, distance, terrain, and weather between Goldstone
and the affected mobile unit.^1^[^17]

**APPENDIX**

**INDUSTRY ANALYSIS OF SHARING BETWEEN ADVANCED WIRELESS SYSTEMS**

**AND DOD OPERATIONS** **IN THE 16 PROTECTED SITES**

**[Introduction]{.underline}**

This appendix was prepared by the Cellular Telecommunications & Internet
Association ("CTIA") in conjunction with NTIA's ongoing study of "The
Potential for Accommodating Third Generation Mobile Systems in the
1710-1850 MHz Band." On October 5, 2001, NTIA announced a new plan to
identify spectrum for advanced mobile services that examines the
potential use of the 1710-1770 MHz and 2110-2170 MHz bands. This plan
includes the 1710-1755 MHz band, which was reallocated in 1995 in
accordance with the Omnibus Budget Reconciliation Act of 1993
("OBRA-93"). At the request of NTIA, technical experts from various
companies[^18] met with NTIA and DoD representatives on June 24-25, 2002
to discuss the potential for accommodating advanced wireless services in
the 1710-1755 MHz band including in areas identified by DoD as
"protected areas."[^19]

**[Technical Analysis]{.underline}**

NTIA advised the industry experts that all conventional fixed systems
that were previously exempt from relocation would be cleared from the
1710-1755 MHz band including those systems operating in the 16
"protected areas." However, DoD intended to continue to operate
aeronautical mobile and tactical radio relay ("TRR") systems operating
in these areas. As a result, the industry's analysis focused only on the
aeronautical mobile and TRR systems.

Industry studied the potential impact of the DoD systems on the future
operations of advanced wireless systems. Operation of these systems on
the same frequencies at the same time and over the same geographic area
would result in harmful interference to commercial systems. It was noted
that the DoD systems are operated for a significant portion of the day
and/or over a significant number of days per week. Consequently, we
concluded that the band could not be shared based on operational
criteria and that continued operations of the DoD systems would create
large interference contours ("exclusion zones") within which acceptable
commercial service would not be possible.

The aeronautical mobiles presented the worse case scenario. Aircraft
employing these systems fly within the identified "protected areas" at
altitudes up to 50,000 feet. The analysis showed that interference from
the airborne stations would occur over all areas that are line of sight
to the aircraft. The line of sight exclusion zone depends on altitude.
For a typical operation at an altitude of 25,000 ft, the line of sight
distance is approximately 300 km. At the maximum operational altitude of
50,000 ft, interference could occur over a distance of more than 400 km.
As a result, the exclusion zones created by the operation of these
systems may extend 300-400 km beyond the operational "protected area,"
blocking off large portions of the country from commercial service. For
example, aeronautical mobiles operating in and around the Patuxent
River, MD facility would create an exclusion zone that extends from
Baltimore, MD, through Washington, DC, and as far south as Norfolk and
Newport News, VA.

Interference from terrestrial TRR systems is also significant.
Terrain-based propagation models were used to analyze the potential
interference from the TRR fixed link systems. The results showed that
the exclusion zones are generally comparable to the identified
"protected areas" which range from 100 km to 240 km in diameter. Many of
these "protected areas" include, or are in close proximity to, cities,
major interstate highways, or other areas where wireless services would
be anticipated. The propagation analysis showed that continued operation
of the TRR systems in these areas would make commercial service
inaccessible in those areas.

**[Conclusions]{.underline}**

The analysis of the industry experts concludes that [all]{.underline}
aeronautical mobile systems and [all]{.underline} terrestrial TRR
systems must be cleared from the 1710-1755 MHz band if the band is to be
used for advanced wireless services. It was noted that further analysis
might conclude that a few of the more remote areas might require less
spectrum, particularly in the earlier years of advanced services
deployment. However, it is expected that the entire 1710-1755 MHz band
would need to be cleared eventually.

[^1]: 1 This 90 MHz would be in addition to the existing
    cellular/specialized mobile radio spectrum (806-821, 824-849,
    861-866, 869-894, 896-901, 935-940 MHz), 120 MHz of personal
    communications service spectrum (1850-1910 and 1930-1990 MHz which
    can also be used for 3G services as market and technology develop),
    and other bands currently under consideration (for example, licenses
    for the 746-764 MHz and 776-794 MHz bands (36 MHz) will be
    auctioned.) In addition, the FCC also recently added a mobile
    allocation to the 2500-2690 MHz band (190 MHz).

[^2]: 2 The Southwestern region includes operations in mostly remote
    areas and ranges, including China Lake, CA; Pacific Missile Test
    Range, Pt. Mugu, CA; Ft. Irwin, CA; Holloman AFB, NB; and Yuma, AZ.

[^3]: 3 These satellite control stations are: New Hampshire Tracking
    Station, New Boston AFS, NH; Vandenberg Tracking Station, Vandenberg
    AFB, CA; Eastern Vehicle Check-out Facility & GPS Ground Antenna &
    Monitoring Station, Cape Canaveral, FL; Buckley AFB, CO; Guam
    Tracking Station, Anderson AFB, Guam; Hawaii Tracking Station, Kaena
    Ptl, Oahu, HI; Kwajalein Atoll (GPS ground antenna); Camp Parks
    Communications Annex, Pleasanton, CA; Colorado Tracking Station,
    Schriever AFB, CO; Naval Satellite Control Network, Laguna Peak, CA;
    Naval Satellite Control Network, Prospect Harbor, ME; and Kirtland
    AFB, NM

[^4]: 4 Other systems include unmanned ground robotic systems, range
    timing distribution systems, and target scoring devices.

[^5]: 5 The views expressed by the FCC staff while participating in the
    IG3GPG are those of the Commission staff's 3G Working Group and do
    not necessarily represent the views of the Federal Communications
    Commission, any Commissioners, or other FCC staff.

[^6]: 6 This planning group consists of representatives of NTIA, the
    FCC, the Department of Defense, the Office of Management and Budget,
    the Office of Science and Technology Policy, and the Department of
    State.

[^7]: 7 A Presidential executive memorandum dated October 13, 2000,
    stated the need and urgency for the United States to select radio
    frequency spectrum to satisfy the future needs of citizens and
    businesses for mobile voice, high-speed data, and
    Internet-accessible wireless capability; the guiding principles to
    be used for the development of 3G wireless systems; and direction to
    the federal agencies to carry out the selection of spectrum. The
    executive memorandum directed the Secretary of Commerce to work
    cooperatively with the FCC to develop a plan to select spectrum for
    3G wireless systems, and to report on the current spectrum uses and
    the potential for reallocation or sharing of the bands identified at
    the ITU 2000 World Radiocommunication Conference (WRC-2000) that
    could be used for 3G systems. The executive memorandum also set
    forth a goal of completing the 3G spectrum decision by July 2001 to
    allow licenses to be auctioned by September 30, 2002. However, a 3G
    spectrum decision was not reached by July 2001, because of the
    difficulties associated with sharing the bands. As a result, the
    IG3GPG was established, and a new plan to select spectrum for 3G
    systems was developed that would require the examination of several
    additional spectrum options. After a thorough examination of many
    options for accommodating advanced mobile systems, the most viable
    option for further study was determined to be the 1710-1770 MHz
    band, paired with the 2110-2170 MHz band. The FCC agreed to study
    the viability of the 2110-2170 MHz band to accommodate advanced
    wireless systems, and the Federal Government would study the
    1710-1770 MHz band.

[^8]: 8 The term "comparable spectrum" used in this assessment is
    specified in Title X, Subpart G, Section 1062 of the National
    Defense Authorization Act for Fiscal Year 2000 and the NTIA Manual
    of Regulations and Procedures For Federal Radio Frequency
    Management, Section 2.3.13, paragraph 1. "the Department of Defense
    shall not surrender use of any band of frequencies in which the
    Department of Defense is a primary user for non-federal use, unless
    the following conditions are met.

    A. NTIA, in consultation with the FCC, has identified and made
    available to the Department of Defense for its primary use, if
    necessary, an alternative band or bands of frequencies with
    comparable technical characteristics as a replacement; and

    B. The Secretary of Commerce, the Secretary of Defense, and the
    Chairman of the Joint Chiefs of Staff have jointly certified to the
    Committee on Armed Services and the Committee on Commerce, Science
    and Transportation of the Senate; and the Committee on Armed
    Services and the Committee on Commerce of the House of
    Representatives, that the replacement band or bands of frequencies
    identified in (A.) above provides comparable technical
    characteristics to restore essential military capability that will
    be lost when the band of frequencies is surrendered."

    The essential components of this definition are that the *comparable
    spectrum* offers primary access, if necessary, and comparable
    technical characteristics (i.e., adequate bandwidth, signal
    propagation characteristics) to restore essential military
    capability. Furthermore, the evaluation of comparability would
    require certification of the Secretaries of Commerce and Defense as
    well as the Chairman of the Joint Chiefs of Staff.

[^9]: 9 Pub. L. No. 103-66, 107 Stat. 312 (1993)

[^10]: 010 *Id.*

[^11]: 11 Federal Communications Commission, Notice of Proposed
    Rulemaking, *Amendment of Part 2 of the Commission's Rules to
    Allocate Spectrum Below 3 GHz for Mobile and Fixed Services to
    Support the Introduction of New Advanced Wireless Services,
    including Third Generation Wireless Systems*, ET Docket No. 00-258.

[^12]: 212 FCC staff did not participate in the DOD/NTIA/industry
    sharing analysis of the 16 grandfathered sites and, hence, express
    no view as to the results set forth in the Appendix.

[^13]: 313 See Appendix for the details of the Industry analysis.

[^14]: 414 National Telecommunications and Information Administration,
    U.S. Department of Commerce, NTIA Special Publication 01--46, [The
    Potential for Accommodating Third Generation Mobile Systems in the
    1710-1850 MHz Band: Federal Operations, Relocation Costs, and
    Operational Impacts - Final Report]{.underline} (March 2001),
    (hereinafter referred to as the *NTIA 3G Report*)

[^15]: 515 The FCC staff indicated that mitigation techniques resulting
    from terrain shielding, deployment of base station antennas that
    avoid main-beam coupling with interfering stations, and use of
    advanced (adaptive) antenna systems, would significantly lessen the
    distance over which a given DOD system would interfere with a given
    3G system.

[^16]: 616 *See* National Telecommunications and Information
    Administration, U.S. Department of Commerce, NTIA Special
    Publication 95--32, [Spectrum Reallocation Final Report]{.underline}
    (1995), at 4--13.

[^17]: 717 *See* the *NTIA 3G Report*, Appendix A for more detailed
    information on possible interference from Goldstone to 3G systems.

[^18]: 1 Representatives from AT&T Wireless, Cingular Wireless,
    Ericsson, Lucent, Motorola, Nortel Networks, Verizon Wireless,
    VoiceStream, and CTIA participated in the June 24-25, 2002 meeting.

[^19]: 2 These "protected areas" include China Lake, CA, Eglin AFB, FL,
    Yuma, AZ, Cherry Point, NC, Pacific Missile Test Range, CA, Nellis
    AFB, NV, Hill AFB, UT, Patuxent River, MD, Holloman AFB, NM, Ft.
    Irwin, CA, Ft. Rucker, AL, Ft. Bragg, NC, Ft. Campbell, KY, Ft.
    Lewis, WA, Ft. Benning, GA, and Ft. Stewart, GA. However, DOD noted
    that there are no aeronautical mobile or tactical radio relay
    systems operating in the 1710-1755 MHz band at Ft. Rucker or Ft.
    Benning.