9 FCC Red No. 24 Federal Communications Commission Record FCC 94-213
Before the
Federal Communications Commission 
Washington, D.C. 20554
In the Matter of
Report to
Ronald H. Brown
Secretary, U.S. Department of Commerce
Regarding the
Preliminary Spectrum Reallocation Report
By the Commission: 
Adopted: August 9, 1994; Released: August 9, 1994
TABLE OF CONTENTS
I. INTRODUCTION 2
II. BACKGROUND 3
III. ANALYSIS OF COMMENTS 4
IV. ANALYSIS OF SPECTRUM IDENTIFIED
FOR REALLOCATION 12
V. DISCUSSION 21
VI. RECOMMENDATIONS 30
I. INTRODUCTION
1. One year ago, Congress directed the Secretary of Com 
merce to identify at least 200 megahertz of spectrum 
currently allocated on a primary basis for Federal Govern 
ment use which is not required for present or identifiable 
future use by the Federal Government, and which is most 
likely to have the greatest potential for productive uses and 
public benefit if allocated for non-Federal use. On Feb 
ruary 10, 1994, the Secretary of Commerce released its 
Preliminary Spectrum Reallocation Report (Preliminary 
Report) 1 identifying spectrum for reallocation from Federal 
Government use to private sector, including local govern 
ment, use. The public was then afforded an opportunity to 
comment on the Preliminary Report. In general, parties 
filing comments praised NTIA for its efforts in preparing
the Preliminary Report, but stated that the proposals re 
quire modifications to better satisfy the public's spectrum 
requirements. This report provides an analysis of the com 
ments, a discussion of possible alternative bands of spec 
trum, and a supplemental spectrum reallocation plan that 
we believe would enhance dramatically the viability of the 
reallocated spectrum for commercial and local governmen 
tal use.2
2. Although the Department of Commerce has complied 
with the requirements enacted by Congress, we believe that 
considering possible changes to the reallocation plan pre 
sented in the Preliminary Report could result in even 
greater benefits to the public. In preparing its final report 
we request NTIA to seek to provide the large blocks of 
spectrum required to accommodate high volumes of com 
munications and the wide bandwidths necessary to transmit 
communications such as video. The private sector would 
also benefit from access to blocks of spectrum that can be 
readily paired and used to accommodate emerging technol 
ogies such as mobile satellite service.
II. BACKGROUND
3. The Omnibus Budget Reconciliation Act of 19933 
(Reconciliation Act), which was signed into law on August 
10. 1993. requires that the Secretary of Commerce identify 
at least 200 megahertz of spectrum currently allocated for 
use by Federal Government agencies, for transfer to the 
FCC for use by the private sector.4 All of the 200 
megahertz of spectrum recommended for reallocation must 
be located below 5 gigahertz, with at least 100 megahertz of 
this being below 3 gigahertz.5 The Reconciliation Act re 
quired that the Secretary of Commerce issue a report 
within six months of the date of its enactment that makes a 
preliminary identification of reallocable bands of frequen 
cies that meet criteria established by the Act. The Rec 
onciliation Act further required the Secretary of 
Commerce to identify 50 megahertz of the 200 megahertz 
of spectrum that can be made available for reallocation 
immediately upon issuance of the preliminary report.6 At 
least one-half of the 50 megahertz identified for immediate 
reallocation must be below 3 gigahertz and all of it must be 
identified for exclusive non-Federal use. The President 
must withdraw the assignment to a Federal Government 
station of any frequency recommended for immediate 
reallocation within 6 months of release of the preliminary 
report so that the spectrum is then available for exclusive 
non-Federal use.7
1 NTIA Special Publication 94-27.
2 This report satisfies Title VI, Section 113(d)(3) of the Om 
nibus Budget Reconciliation Act of 1993, which requires that 
the Federal Communications Commission submit to the Sec 
retary of Commerce an analysis of comments, along with any 
comments or recommendations it deems appropriate, filed in 
response to the Department of Commerce's preliminary report 
identifying spectrum for reallocation from Federal Government 
use to private sector use.
3 Omnibus Budget Reconciliation Act of 1993, Pub. L. No. 
103-66, Title VI,  6001(a)(3), 107 Stat. 312 (approved August 10, 
1993); see also H.R. Rep. No. 103-213, 103rd Cong., 1st Sess. 
(1993).
The Communications Act of 1934 authorized the FCC to 
assign frequencies to all radio stations in the United States 
except those belonging to the Federal Government. Use of the 
term "private sector" refers to commercial entities, private en 
tities, local governments, and public safety organizations. Sec 
tion 305 of the Communications Act, 47 U.S.C.  305, 
authorizes the President to assign frequencies to Federal Gov 
ernment stations. This authority has been delegated to the 
Assistant Secretary of Commerce for Communications and In 
formation (who is also the Administrator of the National Tele 
communications and Information Administration). See Pub. 
Law 102-538, 106 Stat. 3533 (1992).
5 The Reconciliation Act permits up to 100 megahertz of the 
spectrum recommended for reallocation to be retained for some 
use by Federal Government stations provided that the Govern 
ment use is limited to substantially less than the potential use 
to be made by non-Government stations (this would be consid 
ered "mixed use" spectrum). Reconciliation Act  113(b).
6 Reconciliation Act  113(e)(2)(A).
' i.e., by August 10, 1994. The Reconciliation Act does contain
a provision whereby the President can substitute alternative
6793
FCC 94-213 Federal Communications Commission Record 9 FCC Red No. 24
4. In compliance with the timing requirements of the 
Reconciliation Act, on February 10, 1994, the Department 
of Commerce released its report making a preliminary 
identification of spectrum for reallocation.8 The frequency 
bands, including conditions on use, that Commerce has 
identified for reallocation are listed in Table 1.
5. The Reconciliation Act provided a 90 day period from 
the release of the Preliminary Report during which inter 
ested parties could file comments with the Secretary of 
Commerce regarding the report and its recommendations. 
That 90 day period ended May 11, 1994. A total of 47 
comments were filed, copies of which were provided to the 
FCC by the Department of Commerce.9 The Reconciliation 
Act requires that, 90 days from the end of the public 
comment period, the Commission submit to the Secretary 
of Commerce an analysis of the public comments, along 
with any comments or recommendations it deems appro 
priate. The Department of Commerce is to consider the 
public comments and the Commission's report and, is 
required to submit to the President and Congress a final 
report identifying and recommending spectrum for 
reallocation by February 10, 1995. 10
HI. ANALYSIS OF COMMENTS
6. A total of 47 parties filed comments in response to the 
Preliminary Report. These comments can be divided into 
four general groups; 1) federal agencies, 2) amateur radio 
service licensees and organizations, 3) manufacturers and 
users of equipment authorized under Part 15 of the Com 
mission's rules, and 4) other commercial and local govern 
ment interests. A list of commenters is attached as 
Appendix A. The commenters discussed the frequency 
bands proposed for reallocation as well as the process 
NTIA followed to arrive at the proposals.
frequencies if he determines that: 1) the reassignment would 
jeopardize the national defense interests, 2) the frequency pro 
posed for reassignment is uniquely suited to meeting important 
governmental needs, 3) the reassignment would seriously jeop 
ardize health or safety, 4) the reassignment will result in costs 
in costs the Federal Government that are excessive in relation 
to the benefits that may be obtained from commercial or other 
non-Federal uses, or 5) the reassignment will disrupt the exist 
ing use of a Federal Government band of frequencies by ama 
teur radio licensees. See Reconciliation Act  114.
8 Preliminary Spectrum Reallocation Report, U.S. Department 
of Commerce, NTIA Special Publication 94-27, February, 1994 
(Preliminary Report).
Five of the commenters, the Florida Department of Trans 
portation, the U.S. Department of Justice, the Maine Turnpike 
Authority, the National Hydrologic Warning Council, and the 
Department of Energy, filed comments after the May 11, dead 
line. These comments will, however, still be considered. 
10 See Reconciliation Act  113.
6794
9 FCC Red No. 24 Federal Communications Commission Record FCC 94-213
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6795
FCC 94-213 Federal Communications Commission Record 9 FCC Red No. 24
Government Agencies
7. Comments were received from sixteen Government 
agencies. They focused on the impact that would result 
from reallocation of the spectrum identified in the Prelimi 
nary Report. No agency opposed reallocation of the pro 
posed bands. However, a number of agencies noted that 
imposition of conditions on non-Government use of cer 
tain bands is critical to protect Government operations on 
adjacent bands. This is especially true for agencies perform 
ing space services, such as the National Aeronautics and 
Space Administration (NASA), the National Research 
Council (NRC). and Cornell University and The National 
Astronomy and Ionosphere Center (Cornell). One or all of 
these organizations stressed the need to prevent use of the 
1390-1400 MHz, 1427-1432 MHz, 1670-1675, MHz, 
1710-1755 MHz. 2390-2400, and 2402-2417 MHz bands for 
Space-to-Earth links or aeronautical applications. 11 Agen 
cies also stressed the need to maintain the delayed 
reallocation schedule for certain frequency bands and the 
need to continue use of some Government facilities as 
proposed in the Preliminary Report. 12 Some agencies that 
will be affected by reallocation of the proposed spectrum 
provided estimated costs associated with the requirement to 
move operations to other bands or to find alternate meth 
ods of meeting the agency's requirements (e.g., commu 
nicate via leased lines, or obtain service from a commercial 
provider). 13 No Government Agencies proposed alternative 
bands for reallocation.
Amateur Service
8. Fifteen comments were received by licensees and or 
ganizations associated with the amateur radio service. These 
commenters uniformly oppose reallocation of the 
2300-2310 MHz. 2390-2400 MHz, and 2402-2417 MHz 
bands because of the potential impact on amateur oper 
ations. These bands are currently allocated for use by the 
amateur radio service on a secondary basis to government 
services. Although commenters concur with the Prelimi 
nary Report's assertion that these bands are not as heavily 
used as lower frequency bands available to the Amateur 
service, they also contend that use of these bands is increas 
ing and that there are a number of existing operations that 
will be affected by reallocating the spectrum.
9. Current amateur service uses of this band include 
amateur television repeaters. The Chief of Police of the 
City of Martinez, California, states that an amateur televi 
sion repeater in the San Francisco region currently serves 
emergency agencies and argues that reallocation of the
spectrum in the 2.4 GHz band from the amateur service 
would have a negative impact on public safety. 14 In addi 
tion, commenters state there are a number of amateur 
radio point-to-point microwave links operating in these 
bands in the southwestern United States 15 and that these 
links provided vital communications during the Los 
Angeles earthquake earlier this year when normal tele 
phone service was disrupted. 16 Commenters also indicate 
that there are more than 200 weak-signal amateur radio 
stations in operation in the United States. 17 These stations 
receive very weak signals that are transmitted over long 
distance using a variety of propagation methods and are 
extremely susceptible to interference.
10. Entities filing comments dispute the Preliminary Re 
port's contention that amateur service requirements could 
be accommodated in the remaining 35 megahertz of spec 
trum in the 2400-2402 MHz and 2417-2450 MHz bands 
that would still be available to the amateur service on a 
secondary basis to Federal Government operations. Most 
amateur service microwave links use frequencies in the 
2300-2310 MHz band paired with frequencies in the 
2390-2400 MHz band in accordance with a band plan 
adopted by SCRRBA. Commenters state that continued 
point-to-point microwave operations require paired fre 
quencies separated by at least 40 megahertz but less than 
140 megahertz, and that under the Preliminary Report's 
reallocation plan it would not be possible to accommodate 
such use. 18 In addition, weak signal operations require 
approximately 1 megahertz of uncluttered spectrum. Under 
the SCRRBA band plan, these operations are currently 
located in the 2303.75-2304.75 MHz band. SCRRBA states 
that weak signal operations require uncluttered spectrum 
and that these operations cannot share spectrum with the 
Amateur-satellite service operations in the 2400-2402 MHz 
band and cannot operate in the noisy 2417-2450 MHz band. 10
11. Commenters also state that the 2400-2402 MHz band 
is insufficient to accommodate planned Amateur service 
satellite operations. They point out that, because the Ama 
teur satellite service generally uses low earth orbit satellites, 
effective development of Amateur satellite operations re 
quires world-wide allocations. Modifying the allocation in 
the U.S. could, therefore, have a negative impact on Ama 
teur-satellite service operations around the world.20 
Commenters further contend that at least 10 megahertz of 
spectrum is needed at 2400-2410 MHz to provide a 
matched downlink band to the 10 megahertz uplink band 
in the 1260-1270 MHz band. Additional downlink spec 
trum may also be required in this band to match uplink
11 NASA comments at Attachment 2, NRC comments at 5 and 
11-14, Cornell comments at 3-5. It is unclear from these com 
ments whether NRC and Cornell seek to prevent use of the 
entire 1710-1755 MHz band for Space-to-Earth links and aero 
nautical applications. Both commenters single out the 
1718.8-1722.2 MHz band, which contains the fourth transition of 
the ground state of the OH radical, for protection, but state that 
airborne and space-to-Earth stations should be prohibited in 
this band and "adjacent bands." NRC at 13, Cornell at 5. 
12 See comments of the National Oceanic and Atmospheric 
Administration regarding use of the 1670-1675 MHz, and 
1710-1755 MHz bands, and comments of the National Commu 
nications System at 3-4 regarding delayed reallocation of the 
1710-1755 MHz band.
13 See comments of the National Aeronautics and Space Ad 
ministration, Department of the Army, Department of the
Treasury, Department of the Interior, National Oceanic and 
Atmospheric Administration, Department of Agriculture. De 
partment of Justice, and Department of Energy.
City of Martinez, California, Chief of Police comment at 1-2.
15 The Southern California Repeater and Remote Base Associ 
ation (SCRRBA) database shows 22 conventional medium 
bandwidth point-to-point terminals and 10 Digital narrowband 
terminals. SCRRBA comments at 5.
16 San Bernardino Microwave Society, Inc. comments at 4, 
Southern California Repeater and Remote Base Association 
comments at 3, Amateur Radio Council of Arizona comments 
at 1.17 American Radio Relay League comments at 14.
18 SCRRBA comments at 8.
19 SCRRBA comments at 8.
20 Radio Amateur Satellite Corporation comments at 3-12.
6796
9 FCC Red No. 24 Federal Communications Commission Record FCC 94-213
spectrum in the 3400-3410 and 5650-5670 MHz bands.21 Fi 
nally, the commenting parties note that the proposed 
reallocation will crowd Amateur service users into the least 
desirable spectrum in the 2417-2450 MHz band.22 This 
spectrum is less desirable because, the 2417-2450 MHz is at 
the center of the 2400-2500 MHz band available for use by 
Industrial, Scientific, and Medical devices and is noisier 
than the 2400-2417 MHz band.23
12. Several Amateur service commenters provide sugges 
tions as to how the Department of Commerce could lessen 
the impact of reallocation on the Amateur service. The San 
Bernardino Microwave Society suggests identifying the 
2417-2422 MHz band for reallocation rather than the 
2300-2305 MHz band and giving the Amateur service pri 
mary status for use of the 2300-2305 MHz band.24 The 
SCRRBA requests that the reallocation proposal be modi 
fied to retain the 2303.75-2304.75 MHz band for weak 
signal use, and that amateur point-to-point operations dis 
placed by the spectrum reallocation be accommodated by 
allocating two 6-megahertz bands for amateur point-to- 
point use in the 2310-2390 MHz band. If the Department 
of Commerce reconsiders reallocating portions of the ama 
teur service bands identified in the Preliminary Report, 
SCRRBA proposes that, if necessary, the Department of 
Commerce could make up for a spectrum short-fall by 
substituting a like amount of spectrum between 2417-2425 
MHz.25 The ARRL proposes allocating spectrum in the 
2360-2390 MHz band to accommodate Amateur operations 
displaced by the proposed reallocation.26
Part 15 Manufacturers
13. Comments were filed by three companies that manu 
facture equipment used on an unlicensed basis as autho 
rized under Part 15 of the Commission's rules. These 
commenters focus on the 2402-2417 MHz band, which is 
already available for private use under Part 15 of our 
Rules.27 In 1985 the Commission amended Part 15 of the 
Rules to permit development and use of spread spectrum 
systems in the bands 902-928 MHz, 2400-2483.5 MHz, and 
5725-5850 8MHz with up to 1 watt transmitter output 
power.28 In 1990, to further encourage the development 
and implementation of this "exciting new family of tech 
nologies" the Commission modified Part 15 of its rules to 
maximize the flexibility and broaden the opportunities for 
spread spectrum devices.29 Our attempts to encourage this 
development have been successful and today millions of 
Part 15 spread spectrum devices provide a wide variety of 
communications services as well as services such as auto 
mated meter reading, inventory control, package tracking 
and shipping control, alarm devices, local area networks,
and cordless phones. Although the majority of Part 15 
spread spectrum devices currently operate in the 902-928 
MHz band, commenters point out that considerable invest 
ment has been made in developing equipment to operate 
in the 2400-2483.5 MHz band.30 Recently, spread spectrum 
equipment including wireless local area networks, a wire 
less intercom headset, and a new type of cordless phone 
have been approved for use in the 2400-2483.5 MHz band 
and it is likely that use of this band by spread spectrum 
devices will increase. Commenters contend that 
reallocation of the 2402-2417 MHz band will jeopardize the 
future of advanced communications systems that are being 
developed under Part 15.31
Other Manufacturers, Licensees, and Local Governments
14. Comments were filed by thirteen other entities, in 
cluding equipment manufacturers, satellite service provid 
ers, public safety and utility organizations, and local 
governments. A number of these commenters noted a need 
for the Government to provide larger blocks of spectrum 
below 3 GHz. These commenters state that blocks of spec 
trum wider than 5 or 10 megahertz and unimpeded by 
continued government use are required to support wide 
area communications systems and to support systems ca 
pable of providing telecommunications technologies such 
as full motion video and high speed transmission of high 
resolution graphics.32 These commenters also state that 
NTIA failed to adequately consider the needs of private 
radio users, particularly public safety entities, and that 
NTIA should do so in its final report.33
15. Parties with an interest in satellite services noted that 
some of the proposed spectrum, particularly the blocks 
above 3 GHz, would be useful for the fixed satellite service 
(FSS). These entities argue, however, that additional spec 
trum forsatellite services is required.34 Although the Rec 
onciliation Act requires that only spectrum below 5 GHz 
be considered toward fulfilling the 200 megahertz mini 
mum requirement, Loral/Qualcomm urges NTIA to look at 
reallocation of spectrum above 5 GHz, particularly the 
5000-5250 MHz band, for MSS feeder links.35
Comments on the Process
16. Commenters generally recognize the difficult task 
that NTIA faced in identifying spectrum for reallocation to 
the private sector. Several commenters commend and sup 
port NTIA in its efforts to reallocate spectrum. 36 A large 
number of non-Government commenters, however, express 
disappointment and concern that NTIA did not seek great 
er private sector input in identifying bands for
21 Radio Amateur Satellite comments at 2-3 and 10, ARRL 
comments at 18-19.
22 ARRL comments at 17.
23 See para. 36, infra.
24 San Bernardino Microwave Society comments at 5.
25 SCRRBA comments at 8.
26 ARRL comments at n.3.
27 See 47 C.F.R.  15.247.
28 First Report and Order, Gen Docket No. 81-413, 50 Fed Reg
25234 (June 18. 1985).
29 Report and Order, Gen Docket 89-354, 5 FCC Red 4123
(1990).
30 Larus Corporation comments at 1, GEC Plessey
Semiconductors Inc. at 1.
31 Larus Corporation comments at 1-2, GEC Plessey 
Semiconductors Inc. at 1-2, Western Multiplex Corporation at 1.
32 Association of Public-Safety Communications Officials-In 
ternational (APCO) comments at 3-7, Telecommunication In 
dustry Association (TIA) comments at 13-14, Motorola, Inc. 
(Motorola) comments at 3-10.
Motorola comments at 4-10, UTC comments at 5, APCO 
comments at 8.
34 Loral/Qualcomm Partnership, L.P. (Loral/Qualcomm) com 
ments at 1-3, COMSAT Corporation (COMSAT) comments at 2-8.
35 Loral/Qualcomm comments at 3-6.
36 See, e.g., comments of E.F. Johnson at 1-3. and comments of 
Digital Microwave Corporation.
6797
FCC 94-213 Federal Communications Commission Record 9 FCC Red No. 24
reallocation.37 The Telecommunications Industry Associ 
ation (TIA) lists several problems that it believes have 
resulted from the lack of private sector input prior to 
release of the Preliminary Report. These include 1) com 
plete lack of private sector input on the first 50 megahertz 
of spectrum, 2) NTIA identification of only the bare mini 
mum amount of spectrum necessary to comply with the 
Reconciliation Act rather than a broader selection of spec 
trum, and 3) NTIA provision of insufficient details of 
federal operations to allow the private sector to evaluate 
fully the potential usefulness of the spectrum. 38 39
17. Motorola, Inc. (Motorola), the Association of Public- 
Safety Communications Officials-International (APCO), 
and the Utilities Telecommunications Council (UTC) all 
believe that NTIA has not adequately considered the needs 
of private radio users in identifying spectrum for 
reallocation.40 These commenters note that Congress recog 
nized the importance of private spectrum users, especially 
public safety users, in the Reconciliation Act. APCO ques 
tions whether NTIA has met its obligation under the Rec 
onciliation Act because, claims APCO, it failed to consider 
adequately the immediate needs of the public safety com 
munity. 41 These commenters state that NTIA should more 
fully consider the needs of private radio users in its final 
report and selection of spectrum. Several commenters also 
note the importance of the Intelligent Vehicle Highway 
System in enhancing the capacity and efficiency of the 
Federal-highway infrastructure and urge that the future 
spectrum needs of this service also be considered during 
the final spectrum selection process.42
18. A number of commenters question whether the De 
partment of Commerce has fully met its obligations under 
the Reconciliation Act. considering the existing non-Gov 
ernment use in some bands identified for reallocation and 
the limited potential for private sector use of some bands. 
Most notably, several commenters point to the significant 
existing private use of the 2402-2417 MHz band by Indus 
trial, Scientific, and Medical equipment, particularly mi 
crowave ovens, as well as use of the band by the amateur 
radio service and by equipment authorized under Part 15 
of the Commission's rules. They view these factors as se 
verely restricting the potential for use of this band by the 
private sector and severely limiting the benefit to the pub 
lic of reallocating this band. For these reasons, TIA states 
that for all practical purposes, this band is already allocated 
exclusively to non-Federal use; and that, therefore, 
reallocation of this band "does not meet the letter or spirit 
of Title VI." TIA calls for NTIA to immediately reconsider 
proposing the 2402-2417 MHz band for reallocation.43
19. Finally, commenters in the amateur radio commu 
nity contend that the Department of Commerce has failed 
to meet its obligations because it did not conduct a study as 
to the feasibility of the amateur radio service to share with 
the commercial users as is required under Section 
113(c)(3)(C) of the Reconciliation Act.44
IV. ANALYSIS OF SPECTRUM IDENTIFIED 
FOR REALLOCATION
1390-1400 MHz
20. The Preliminary Report identified the 1390-1400 
MHz band as spectrum that can be made available for 
exclusive non-Government use in January, 1999 provided 
it is not used for space-to-Earth links. NTIA also recom 
mends that receiver standards for non-Government systems 
be adopted.45 As with most of the bands identified for 
reallocation below 3 GHz, commenters believe that the 
relatively small size of the 1390-1400 MHz band will limit 
its usefulness, especially for wide-area terrestrial commu 
nications.46 Commenters also note that adjacent channel 
use of FAA and DoD high-power radar systems will re 
quire development of equipment capable of tolerating in 
terference, thereby adding to the cost of equipment. 47 Fur 
ther, commenters note that, although this band is to be 
available on an exclusive basis for non-Federal use, the 
Department of Commerce has stated that the band is not to 
be used for space-to-Earth links and that some Government 
operations will continue in remote areas.48 Use of this band 
is further constrained by U.S. allocation footnote 311 
which limits fixed and mobile use of this band in thirteen 
areas of the U.S. and its territories. NTIA has recom 
mended a five year delay in reallocating this spectrum; 
however, non-Government use of this band will be affected 
by continued operations of Government facilities at 17 
locations, some of which are in or near major metropolitan 
areas, for ten years.49
21. Although located between cellular radio and personal 
radio services (PCS), we believe that the 1390-1400 MHz 
band is located too far from these services to be readily 
incorporated into either of them. In our recent Memoran 
dum Onion and Order in GENlDocket No. 90-314, where 
we finalized rules for PCS at 1830-1990 MHz, we found 
that equipment capable of operating in both the 1850-1990 
MHz and the 2110-2200 MHz bands would cost 25 percent 
more than equipment that only operates in the 1850-1990
37 See comments of Cactus Iruertie Systems/Cactus Radio Club, 
Inc. at 4, San Bernardino Microwave Society, Inc. at 1, Amateur 
Television Network at 2, SCRRBA at 6, Amateur Radio Council 
of Arizona, ARR1 at 8-11, TIA at 2-6.
38 TIA comments at 3-6.
3Q Although the Reconciliation Act did not specifically require 
the Department of Commerce to seek private sector input prior 
to issuing the Preliminary Report, it did set forth criteria to be 
used in identifying spectrum for reallocation, one of which is 
that the bands identified be "most likely to have the greatest 
potential for productive uses and public benefits under the 1934 
Act if allocated for non-Federal use." See Reconciliation Act 
Section 113(a)(5).
40 Motorola comments at 4-10, APCO comments at 2-8, UTC 
comments at 4-6.
41 APCO comments at 4.
42 IVHS America, Inc. comments at 1-3, Motorola comments at 
14-15, Florida Department of Transportation comments at 1-3, 
Maine Turnpike Authority comments.
43 TIA comments at 11-13.
44 American Radio Relay League (ARRL) comments at 5-6.
45 Preliminary Report at 5-4.
46 Motorola comments at 3, APCO comments at 5-6.
47 TIA comments at 14-15. In fact, in the Preliminary Report. 
NTIA states that receiver standards must be adopted to protect 
non-Government systems from interference from high-power 
government radar systems. In the past, the Commission has 
seldom adopted receiver standards, preferring instead to allow 
equipment manufacturers to determine an acceptable level of 
equipment performance to match the needs of their customers. 
^ TIA comments at 14-15. 
49 See Preliminary Report at 5-3, 4.
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9 FCC Red No. 24 Federal Communications Commission Record FCC 94-213
MHz band.50 Similar or greater costs could be expected in 
incorporating this band into either the cellular service or 
PCS.
22. This band is located in a desirable part of the spec 
trum where propagation is favorable for mobile services. 
Equipment for operation in this band could undoubtedly 
be developed quickly. We agree with commenters, how 
ever, that the small size of the proposed allocation will 
make it difficult to implement new technologies. The 
1390-1400 MHz band may not be sufficient to support a 
new service or to substantially promote development of 
new technologies.
1427-1432 MHz
23. The Preliminary Report identified the 1427-1432 
MHz band as spectrum that can be made available for 
exclusive non-Government use in January, 1999 provided 
it is not used for airborne or space-to-Earth links.51 As with 
the 1390-1400 MHz band, commenters cite the small size of 
the 1427-1432 MHz band as limiting potential uses.52 TIA 
notes that, although this band, is to be reallocated on an 
exclusive basis, the Department of Commerce has stated 
that the band can not be used for airborne or space- 
to-Earth links because of the need to protect adjacent 
channel radio astronomy operations, and that protecting 
these adjacent channel radio astronomy operations could 
make this band difficult to use.53 In addition, although 
NTIA has proposed that this band be reallocated within 
five years. Government operations will continue at 14 loca 
tions for 15 years. Such continued use could adversely 
affect the ability of non-Government entities to use this 
spectrum.
24. We agree with commenters that the small size of this 
proposed allocation, as well as its remoteness from existing 
non-Government services, will make it difficult to use this 
spectrum either as an adjunct to an existing service or to 
support a new service. The Preliminary Report's suggestion 
that this band be combined with the 1390-1400 MHz band 
would yield an unbalanced allocation of one 5-megahertz 
wide block with a 10-megahertz block that would not be 
conducive to channel pairing arrangements and that might 
still be too small to promote development of new technol 
ogies.
1670-1675 MHz
25. The 1670-1675 MHz band has been identified for 
reallocation on a mixed use basis and to be made available 
in January, 1999.54 The only Government operation iden 
tified by NTIA for continued operation is the Earth station 
operated by the National Oceanographic and Atmospheric 
Administration (NOAA) on Wallops Island, which receives 
data from NOAA's GOES weather satellite.55 NTIA states
that radiosondes operated by the Government in this band 
will be relocated to other frequencies.56 NTIA also states 
that in order to protect radio astronomy operations in 
adjacent bands, this band is not to be used for non-Govern 
ment airborne or space-to-Earth links.5 ' TIA agrees with 
NTIA that before non-federal users can use this band, 
meteorological services will have to be redesigned or re 
placed. TIA cautions that adjacent channel radio astronomy 
operations may make it difficult to use this band for non- 
Government operations.58
26. WARC-92 reallocated this band worldwide for mobile 
use, intending that it be used to implement aeronautical 
public correspondence -- a common carrier service. As 
noted in the Preliminary report, however, the U.S. has 
already stated that it will not use this band for aeronautical 
public correspondence.59
27. Again, we believe that 5 megahertz may be too small 
an allocation to support development of new broadband 
technologies or wide-area operations and that this band is 
not located near enough to current non-government oper 
ations for it to serve as an adjunct to them.
1710-1755 MHz
28. NTIA has identified this band for mixed use and to 
be available January 2004. The Preliminary Report states 
that the Government will continue to operate indefinitely 
fixed microwave stations authorized prior to February 10, 
1994, that are used by Federal power agencies or on which 
the majority of communications is for safety-of-life. The 
Government will also continue to operate fixed microwave 
facilities, tactical radio relay and aeronautical mobile sta 
tions authorized as of February 10, 1994, in 17 specific 
areas around the country.
29. Although the 1710-1755 MHz band is the largest 
block of spectrum identified for reallocation below 3 GHz, 
commenters state that the substantial continued Govern 
ment use of the band will limit its value for non-Govern 
ment service.60 These commenters question whether the 
Federal Government might be able to relocate some or all 
of its microwave operations to another spectrum band or to 
consolidate them within a portion of this band.61 In addi 
tion, commenters felt that, because of the substantial size of 
this band and critical need for spectrum for non-Govern 
ment use, NTIA should attempt to reallocate this spectrum 
earlier than the ten years proposed.62
30. The 1710-1755 MHz is a desirable band located rela 
tively close to the 1850-1990 MHz band allocated for PCS. 
The 1710-1755 MHz band is also the only band identified 
below 3 GHz where it might be feasible to support wide- 
area operations. We agree with commenters, however, that 
the amount of continued Government use of this band will 
severely limit its usefulness for non-Government oper-
50 Memorandum Opinion and Order, GEN Docket 90-314, re 
leased June 13, 1994, at para. 34, 9 FCC Red 1309 (1994).
51 Preliminary Report at 5-4.
52 Motorola comments at 3, APCO comments at 5-6.
53 TIA comments at 15.
54 Preliminary Report at 5-4.
55 GOES is NOAA's Geosynchronous Operational Environ 
mental Satellite that, the Preliminary Report states, consists of 
two geostationary satellites which include visible and infra-red 
imaging, space monitoring, a search and rescue subsystem, data 
collection platforms, and a relay of facsimile data between earth 
stations.
56 A radiosonde is generally a balloon-borne meteorological 
instrument consisting of sensors coupled with a radio transmit 
ter.
57 Preliminary Report at 5-7.
58 TIA comments at 15-16.
59 Preliminary Report at 4-19.
60 APCO comments at 6-7, Motorola comments at 7, GTE 
Service comments at 4, TIA comments at 16.
61 TIA comments at 16, Motorola comments at 10-11, UTC 
comments at 2-3.
62 TIA comments at 16-17, Motorola comments at 10-11, GTE 
comments at 4, UTC comments at 2-3, APCO comments at 6-7.
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FCC 94-213 Federal Communications Commission Record 9 FCC Red No. 24
ations. Some of the 17 specified areas for continued Gov 
ernment use are in or near major metropolitan areas and 
have radii of operation ranging from 50 to 160 km. Fur 
ther, NTIA has not indicated the locations and number of 
Federal power and safety-of-life microwave systems that 
must be protected. The lack of specific information on 
continued Federal Government use of this band makes it 
difficult to determine whether this band should be counted 
toward the minimum spectrum requirements under the 
terms of the Reconciliation Act. The Reconciliation Act 
states that a band of frequencies may only be counted 
toward the minimum spectrum requirement if the poten 
tial use of Federal Government stations is substantially less 
than the potential use to be made by non-Federal 
stations."3 We lack sufficient information as to the actual 
amount of continued Federal Government operations pro 
posed for this band to compare the amount of proposed 
Government use with potential non-Government use and 
to gauge its usefulness for future non-Government use.
2300-2310 MHz and 2390-2400 MHz
31. The Preliminary Report identifies the 2300-2310 
MHz and 2390-2400 MHz bands as being available for 
reallocation for exclusive non-Government use. The 
2300-2310 MHz band is identified as being available in 
January, 1996. provided that the band is not used for 
airborne or space-to-Earth links.64 The 2390-2400 Mhz 
band is identified for immediate availability. The Prelimi 
nary Report recommends that this band not be used to 
provide airborne or space-to-Earth links.65 As discussed 
above, amateur interests object to reallocation of these 
bands because of their current use by the Amateur service. 
Commenters state that NTIA failed to determine accurately 
the effect that reallocation of these bands would have in 
disrupting current use of Government bands by the Ama 
teur service, as required by the Reconciliation Act. Fur 
ther, commenters note that NTIA failed to determine to 
what extent commercial users could share this spectrum 
with the Amateur service, another requirement of the Rec 
onciliation Act. Commenters have indicated that sharing 
between amateur radio licensees and commercial radio us 
ers is not feasible.
32. We believe that several factors hamper the possibili 
ties for productive non-Government use of these bands. As 
with most of the spectrum identified for reallocation below 
3 GHz, these 10 megahertz-wide band segments may prove 
too small to support new services. The Preliminary Report 
notes the bands' proximity to the bands in the 1850-2200 
MHz range that the Commission has allocated for emerging 
technologies and contends that these bands could serve as 
adjuncts to technologies used in those bands. However, as 
we found in the PCS MO&O that equipment operating in 
multiple bands will cost approximately 25 percent more
than equipment operating in a single band, it is not appar 
ent that combining these bands with emerging technologies 
spectrum will be economically feasible.66
33. Non-Government use of these bands will also be 
restricted by the need to protect Government operations in 
adjacent bands. TIA and GTE caution that the presence of 
highly sensitive receivers and/or high power transmitters of 
NASA's deep space network in the adjacent bands may 
make it difficult to use these bands for non-Government 
operations.67 NTIA has stated that, to protect NASA's deep 
space network and interplanetary research radar operations 
in adjacent bands, reallocation of the 2300-2310 MHz band 
for airborne or space-to-Earth links must be avoided. NTIA 
also states that additional constraints on land-based non- 
Federal operations in the 2300-2310 MHz band near the 
Goldstone, CA deep space Earth station may be necessary, 
and the Preliminary Report also alludes to the need for 
similar constraints with respect to the 2390-2400 MHz band.68
34. The largest factor affecting future use of these bands 
is their existing availability for use by the Amateur 
service.69 Congress specifically sought to avoid disruption of 
existing use of Federal Government frequencies by amateur 
radio licensees.70 We agree with commenters that there is 
substantial likelihood that reallocation of the 2300-2310 
MHz and 2390-2400 MHz bands to commercial or local 
government use could cause serious disruption to Amateur 
service use of these bands.
2402-2417 MHz
35. The Preliminary Report identifies the 2402-2417 
MHz band for exclusive non-Government use to be made 
available immediately. 71 According to the comments, the 
2402-2417 MHz band is the most controversial band iden 
tified for reallocation. This band is also currently available 
for use on a secondary basis by the Amateur service and 
commenters raise the same concerns with respect to 
reallocation of this band as were discussed with respect to 
the 2300-2310 MHz and 2390-2400 MHz bands. In addi 
tion, amateur interests raise concerns about the future of 
the Amateur satellite service in this spectrum. In the Pre 
liminary Report NTIA states that it declined to identify the 
2400-2402 MHz band for reallocation because of existing 
use of this band by the amateur satellite service.72 However, 
amateur entities contend that this small 2-megahertz wide 
band is insufficient to accommodate planned future sat 
ellite requirements.
63 Reconciliation Act at (b)(2)(B).
64 Preliminary Report at 5-9.
65 Preliminary Report at 4-17.
66 Supra at note 50.
h/ TIA comments at 17. GTE comments at 4. 
68 Preliminary Report at 4-15. A number of Government agen 
cies commenting on the Preliminary Report also stress the need 
to prohibit airborne or space-to-Earth links in the 2390-2400 
MHz band and to limit terrestrial operations in Puerto Rico to 
protect the planetary research radar at Arecibo, Puerto Rico.
See, National Research Council comments at 14, Cornell Uni 
versity/National Astronomy and Ionosphere Center comments at 
5, and National Science Foundation at 1.
69 See paras. 8-12., Supra.
70 In the Reconciliation Act Congress required that bands of 
frequencies be identified that seek to avoid, "excessive disrup 
tion of existing use of Federal Government frequencies by ama 
teur radio licensees." Reconciliation Act at  113(c)(l)(C)(iii). 
'' Preliminary Report at 5-9.
72 Preliminary Report at 4-17.
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9 FCC Red No. 24 Federal Communications Commission Record FCC 94-213
36. Further, commenters state that reallocation of the 
band will also likely result in loss of millions of dollars 
already invested in developing spread spectrum systems 
designed to operate in the band under Part 15 of our Rules.73
37. Although the 2402-2417 MHz band is the only band 
below 3 GHz where non-Government use would not be 
restricted or where use of the band would not be on a 
mixed basis,74 we believe that this band provides the least 
potential for providing spectrum for new non-Government 
services.
38. The most problematic aspect of this band is its exist 
ing use by non-Government Industrial, Scientific, and 
Medical (ISM) devices and by devices authorized under 
Part 15 of our Rules. As discussed in the Preliminary 
Report, the 2400-2500 MHz band is occupied by over 80 
million microwave ovens, which are ISM devices. The 
Preliminary Report includes in its Appendix E an analysis 
of possibilities for sharing with microwave ovens. This 
analysis concludes that the high level of noise created by 
microwave ovens between 2425-2475 MHz renders success 
ful use of this frequency range by a licensed communica 
tion service unlikely. The analysis goes on to conclude, 
however, that the noise below 2425 MHz is significantly 
less and that advanced modulation techniques, such as 
spread spectrum, should be able to penetrate the noise 
below 2425 MHz. We disagree. An examination of the 
charts showing measurements for Green Mesa, near Boul 
der Colorado, and at Flagstaff, Arizona indicate that the 
noise in the 2400-2420 MHz range is only 10 to 15 dB 
below the noise at the center of the ISM band. Using 
NTIA's assertion that noise in the center of the band is 20 
to 40 dB above receiver threshold noise, the noise in the 
2400-2420 MHz band is still 5 to 30 dB above receiver 
threshold noise. This would make it extremely difficult for 
any licensed communication system to operate and would 
greatly reduce the advantages of using advanced technol 
ogies. The gain in capacity generally realized by advanced 
technology systems would have to be traded for providing 
resilience to interference from microwave ovens. TIA has 
submitted a study demonstrating that, because of the noise 
created by ISM devices that operate in this band, im 
plementing a communications systems in this band will 
cost up to 50 times as much as a system operating in a 
band without interference from ISM devices.75
39. Despite the noise in this band, manufacturers devel 
oping equipment operating under Part 15 of our Rules 
have begun to use this band successfully. In 1990 we 
encouraged development of advanced spread spectrum de 
vices in the 902-928 MHz, 2400-2483.5 MHz, and 
5725-5850 MHz bands. Today there are literally millions of 
Part 15 devices operating in the 902-928 MHz band, in 
cluding cordless phones, wireless alarm systems, computer
local area networks, automated meter reading systems, anti- 
shoplifting systems, inventory control systems, and auto 
matic vehicle identification systems. Although the 
2400-2483.5 MHz band is not as heavily used as the 
902-928 MHz band, there has recently been substantial 
development of, and investment in, equipment using this 
band. These include local area networks, wireless intercom 
systems, and cordless phones. It is unlikely that a licensed 
service would be able to share this band with these devices, 
which can operate with up to one watt of transmitter 
output power under Part 15 of our Rules.76 Accordingly, 
reallocation of this band would jeopardize the significant 
private sector investment already made in developing new 
technologies operating under Part 15.
40. Considering the potentially adverse effects on the 
amateur radio service and on use of the band by devices 
operating under Part 15. as well as the difficulties in using 
this band because of the amount of noise from ISM de 
vices, we believe that reallocation of this band presents less 
value to the private sector than any other band identified 
for reallocation in the Preliminary Report.
3650-3700 MHz
41. The Preliminary Report identified the 3650-3700 
MHz band as being available for reallocation on a mixed 
use basis in January 1999.77 The 3650-3700 MHz band is 
currently used by the non-Government fixed satellite ser 
vice for international systems. COMSAT states that it al 
ready has several customers using this service as part of 
INTELSAT. Although COMSAT supports the transfer of 
3650-3700 MHz, it notes that reallocating it for mixed use, 
as proposed by NTIA, would essentially maintain the status 
quo of existing Government/non-Government use.78 
COMSAT, requests that the entire 3600-3700 MHz band be 
reallocated for non-Government use, or, in the alternative, 
that the sharing arrangement that currently applies to the 
3600-3700 MHz band be extended to the 3500-3600 MHz band.79
42. Although this band is already used by non-Govern 
ment users, we believe that elimination of allocation foot 
note U.S. 245, which limits FSS satellite use to 
international inter-continental systems subject to a case- 
by-case interference analysis, would provide potential for 
increased non-Government use. As discussed below, how 
ever, we believe that the reallocation of additional spec 
trum adjacent to this band is justified for private sector use.
4635-4660 MHz and 4660-4685 MHz Bands
43. The Preliminary Report recommends that both the 
4635-4660 MHz and 4660-4685 MHz bands be reallocated 
for exclusive non-Government use. The 4660-4685 MHz 
band is recommended for immediate reallocation and the
' 3 Larus Corporation comments at 1-2, GEC Plessey 
Semiconductors Inc. at 1-2, Western Multiplex Corporation at 1. 
/J* Some Government agencies commenting on the Preliminary 
Report would, however, even place restriction on non-Govern 
ment use of this band. See National Science Foundation com 
ments at 1, and Cornell University/National Astronomy and 
Ionosphere Center comment at 5-6.
75 TIA comments at Appendix.
76 In the Preliminary Report, NTIA states that the shared use 
of the 902-928 MHz band between Federal Government systems 
and a wide-array of non-Government systems suggests that 
there is very efficient use of this band and it concludes that the
large number of existing non-Federal incumbents eliminates the 
band From consideration for reallocation. Preliminary Report at 
4-9. We expect that the situation with respect to the 2402-2417 
MHz band would become very similar even though we have not 
yet seen the high level of use in this band as in the 902-928 
MHz band.
77 Preliminary Report at 5-9.
78 COMSAT comments at 2-5.
79 COMSAT comments at 5-8.
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FCC 94-213 Federal Communications Commission Record 9 FCC Red No. 24
4635-4660 MHz band is recommended for reallocation in 
three years, although the report states that Government 
operations in 4635-4660 MHz will continue at three sites, 
each with an 80 km operating radius, for 15 years.
44. Loral/Qualcomm states that the 4635-4660 MHz and 
4660-4685 MHz bands would be useful for MSS feeder 
links. Loral/Qualcomm also notes, however, that an addi 
tional 150 MHz of adjacent spectrum would greatly help in 
implementing commercial MSS service. According to 
Loral, this spectrum would be useful on either a shared or 
exclusive basis.80
45. Although these bands are already allocated for non- 
Government use by the fixed satellite service (space-to- 
Earth) on a co-primary basis with Government fixed and 
mobile use, there is currently no non-Government use of 
these bands. Use of these bands by the fixed satellite service 
is constrained by two factors: 1) US footnote 245. which 
limits use to international inter-continental systems subject 
to an interference analysis, and 2) Appendix 30b of the 
international Radio Regulations, which contains a plan that 
allots only two orbital slots to the United States. In addi 
tion, a bilateral agreement with Canada requires that terres 
trial line-of-sight use of this band must coordinated with 
Canada.81
46. Provided that the domestic allocation footnote is 
eliminated for these bands, we believe that this spectrum 
would be useful in providing non-Government services 
although such use would still be constrained by the inter 
national allotment plan contained in Appendix 30b of the 
international Radio Regulations. As we discuss below, how 
ever, reallocation of substantially more spectrum in adja 
cent bands, even on a shared basis, could help realize the 
potential benefit to the public that this spectrum offers.
V. DISCUSSION
47. In requiring that at least 200 megahertz of spectrum 
be reallocated from Federal Government use to private 
sector use Congress sought to promote more efficient use 
of the spectrum, provide spectrum on which advanced 
communications technologies could be implemented, pro 
vide spectrum to satisfy the future needs of public safety 
organizations, and provide spectrum for use by biomedical 
telemetry devices. Congress included both the public and 
the FCC in determining what spectrum is most appropriate 
for reallocation to meet these goals.82 As evidenced by the 
instant Report, this process is a cooperative effort between 
NTIA and the FCC. 3 We look forward to building on this 
initial effort at satisfying the spectrum and communications 
needs of both Government and non-Government users.
48. We recognize that the task Congress set for the 
Department of Commerce was formidable and included a 
stringent time table for identifying and reallocating spec 
trum. Coordination with the Government agencies that use 
spectrum and quantification of the impact that spectrum
reallocation will have on the ability of those agencies to 
fulfill their mandated mission within the time allotted for 
preparing the Preliminary Report required an extraordi 
nary effort by NTIA. NTIA has risen to this task and has, 
in general, identified spectrum for reallocation that bal 
ances the needs of non-Government licensees with the 
impact that reallocation will have on Government agencies. 
After consideration of the comments filed in response to 
NTIA's Preliminary Report, however, we conclude that 
some modifications to the spectrum identified could more 
fully advance the goals set forth by Congress.
49. Congress intended that the spectrum identified have 
the greatest potential for productive uses and public bene 
fits if allocated for non-Government use.84 Generally, we 
believe that NTIA has developed a viable spectrum 
reallocation plan, however, as commenters have stated, 
there are a number of impediments that make commercial 
use of much of the spectrum identified for reallocation 
difficult. Much of the spectrum identified for reallocation 
is in band segments that are too small to accommodate the 
wide-area, high capacity communications systems of the 
future. Use of these bands will be further frustrated be 
cause they are generally located in a manner which makes 
it difficult to allocate paired channels or are scheduled for 
reallocation at different times. In addition, at least one of 
the proposed bands, at 2402-2417 MHz, is already heavily 
used by non-Government entities and reallocation presents 
limited gain to the public. Non-Government use of some 
bands is affected by continued in-band or adjacent-band 
Government use. Accordingly, we believe several changes 
to the NTIA reallocation plan would provide greater bene 
fits to the public.
50. One area of the reallocation plan presented in the 
Preliminary Report that needs to be addressed is the 
2402-2417 MHz band. Reallocation of the 2402-2417 MHz 
band presents little or no additional benefit to the public. 
This band is already used for non-Government services by 
the amateur radio community and by Part 15 devices. It 
will be extremely difficult to provide a licensed service in 
this band because of its heavy use by ISM equipment. 
Further, installing a licensed service in this band may 
result in a loss to the public of Part 15 spread spectrum 
communications equipment as well as possibly preventing 
use of this band for Amateur service operations. The bene 
fits of providing short-range communications via 
unlicensed low power devices is generally recognized, and 
interest in such devices is growing. Recently there have 
been dramatic developments in such equipment such that 
it now can provide a wide and versatile array of services 
including cordless phone, wireless local area networks, 
wireless PBX, point-to-point communications, inventory 
tracking systems, and IVHS-related systems. In fact, the 
Federal Government has recognized the value of Part 15 
devices and the benefits that such devices can offer its own 
agencies and its regulations permit Government use of 
unlicensed Part 15 devices.85 Noting the growing impor-
80 Loral/Qualcomm comments at 2-3.
81 This Bilateral agreement also requires that U.S. troposcatter 
systems in this hand must be coordinated with Canada if they 
are within 500 km of the U.S./Canadian border.
82 See Reconciliation Act at Sections 113(d)(2) and 113(d)(3).
83 The Reconciliation Act requires that the Assistant Secretary 
of Commerce and the Chairman of the FCC meet at least 
biannually to conduct joint spectrum planning, including dis 
cussion of the spectrum allocation actions necessary to accom 
modate the future requirements of users and action necessary to 
promote the efficient use of spectrum, including shared use. 
Reconciliation Act at Section 112.
84 Reconciliation Act at Sec. 113(a)(5).
85 Part 7.8 of the NTIA Manual of Regulations & Procedures 
for Federal Radio Frequency Management.
6802
9 FCC Red No. 24 Federal Communications Commission Record FCC 94-213
tance of unlicensed devices, we recently allocated 20 
megahertz of spectrum in the 1.8 GHz band for unlicensed 
PCS devices and indicated that we would pursue additional 
allocations for such devices.86
51. Considering the existing non-Government use of the 
2402-2417 MHz band by the Amateur service, ISM equip 
ment, and Part 15 devices, and the limited possibility for 
implementing a licensed commercial service in the band, 
we believe that the reallocation of this band will provide 
very little additional value to the public. Any future 
changes to this band could jeopardize significant private 
sector investments already made in this band and could 
result in a loss of benefits to the public and the Federal 
Government. Accordingly, we recommend that additional 
bands, possibly the 2300-2310 MHz and 1845-1850 MHz 
bands, be identified for immediate non-Government avail 
ability.
52. Although we believe that NTIA has established a 
foundation for a spectrum reallocation plan that greatly 
benefits the public, we suggest that NTIA consider a few 
changes to the process used in preparing the Preliminary 
Report. For instance, the Reconciliation Act requires that 
NTIA identify frequencies that span not less than 200 
megahertz below 5 GHz and sets forth further guidelines 
for identifying spectrum. 87 In the future, NTIA could iden 
tify spectrum in excess of the minimum requirements, and 
then provide government agencies and the public an op 
portunity to work together to construct a reallocation plan 
that provides the best balance of minimizing impact to 
government agencies while maximizing the benefit to the 
public.
53. The public had only one opportunity to comment on 
the spectrum proposed for reallocation. Accordingly, there 
has been little opportunity for the public to comment on 
alternatives. We believe that if NTIA were to seek greater 
input from both the public and the FCC in identifying 
spectrum to be reallocated, spectrum can be identified 
which would be more useful to the public without seri 
ously jeopardizing Government use thereof.
54. In revisiting its reallocation proposals, it would be 
helpful if bands could be identified that can be paired to 
provide full duplex service, are large enough to provide for 
development of new technologies, and sufficient to satisfy 
communications needs that have recently been identified. 
As evidenced by comments filed in response to NTIA's 
Preliminary Report, our recent PCS proceeding, and var 
ious other filings such as the petition filed by the Coalition 
of Private users of Emerging Multimedia Technologies,88 
modern and emerging technologies require large blocks of 
spectrum to accommodate high volumes of communica 
tions and the wide bandwidth necessary to transmit com 
munications such as video. In addition, the mobile satellite 
service will play a critical role in development of a na 
tional and global information infrastructure and additional 
spectrum is needed for this service. Applicants for mobile 
satellite licenses have sought multiple spectrum allocations 
to accommodate MSS service link and feeder link commu 
nications.89 To help satisfy both immediate and future com 
munications requirements, the private sector would benefit 
from large blocks of spectrum that can be paired and that 
can be used to accommodate emerging technologies. To 
meet some needs it would be beneficial to the public to 
have access to bands above 5 GHz, discussed above, and 
therefore we believe that the NTIA should include consid 
eration of such bands in its final report. Greater input 
from the public may allow NTIA to identify more spec 
trum than the 200 megahertz identified in the Reconcili 
ation Act.
55. A number of potential alternative frequency bands 
and their potential benefits that we have preliminarily 
identified are discussed below.
225-400 MHz
56. As recognized in the Preliminary Report, this band 
offers desirable propagation characteristics and availability 
of mature, economical radio technology. The propagation 
characteristics are ideal for creation of wide area networks 
in the land mobile service. Congestion in the VHF/UHF 
bands currently available for non-Government land mobile 
is high and reallocation of spectrum in this band would be 
of immediate benefit in relieving such congestion. We are 
currently considering methods of improving the efficiency 
of use of non-Government land mobile spectrum by divid 
ing the channel bandwidth of systems operating in the 
72-76, 150-174, 421-430, 450-470, and 470-512 MHz 
bands.90 Such channel splitting methods are difficult to 
implement in congested spectrum. Spectrum reallocated in 
the 225-400 MHz band could greatly facilitate our efforts 
by providing "green space" in which to begin implement 
ing spectrum efficient systems. This spectrum could also 
provide greater flexibility for accommodating applications 
that require wider bandwidth, such as transmission of data 
or images, in the in the bands, while still improving the 
efficiency of two-way land mobile radio. Spectrum in this 
band could also be very valuable in enhancing public 
safety communications and could possibly provide spec 
trum for use by biomedical telemetry devices, which manu 
facturers have indicated require spectrum below 1 GHz.91
86 Memorandum Opinion and Order, GEN Docket 90-314, 9 
FCC Red 1309 (1994). Unlicensed PCS applications would in 
clude, but not be limited to, high and low speed data links, 
cordless telephones, and wireless PBXs.
87 Reconciliation Act, Section 113.
88 This petition was filed with the Commission December 23, 
1993, and is included for consideration in our proceeding con 
cerning uses for the first 50 megahertz of spectrum to be 
reallocated from Federal Government to private sector use. ET 
Docket No. 94-32, 59 Fed Reg 25589 (May 17, 1994). 
89 We discuss the need for additional MSS and feeder link 
spectrum in our Notice of Inquiry to prepare for the Interna 
tional Telecommunication Union's 1995 World 
Radiocommunication Conference, Notice of Inquiry. 1C Docket 
No. 94-91, 59 Fed Reg 25873 (May 18, 1994).
90 See Generally, Notice of Proposed Rule Making, PR Docket 
No. 92-235, 7 FCC Red, 8105 (1992).
91 See comments of the Critical Care Telemetry Group 
(CCTG) filed in response to our Notice of Inquiry in ET Docket 
94-32. CCTG consists of Hewlett-Packard Company Medical 
Products Group, Marquette Electronics, Inc., Pacific Commu 
nications, Siemens Medical Systems, Inc. and SpaceLabs Medi 
cal, Inc. In its comments, CCTG states that it represents 
"essentially all of the companies located in the U.S. that are 
engaged in the production of low power, portable biomedical 
telemetry systems."
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FCC 94-213 Federal Communications Commission Record 9 FCC Red No. 24
57. The Preliminary Report describes the 225-400 MHz 
band as the "single most critical spectrum resource... with 
in the North Atlantic Treaty Organization (NATO)."92 
However, our NATO allies in Europe have found it appro 
priate to use portions of this band for non-military pur 
poses. CEPT countries are using the 225-230 MHz band, at 
least temporarily, for Digital Audio Broadcasting and are 
considering using spectrum in the 380-400 MHz portion of 
the band for terrestrial public safety use. In addition, 
WARC-92 allocated the 312-315 MHz and 387-390 MHz 
bands for the mobile satellite service (MSS) on a secondary 
basis. If these bands could be made available domestically 
for such use, it would increase the amount of spectrum 
available below 1 GHz for MSS by approximately 120 
percent. The Notice of Inquiry in 1C Docket No. 94-31 93 
notes that discussions between the FCC and NTIA are 
underway on use of the 312-315 MHz and 387-390 MHz 
bands for MSS; this proceeding presents an opportunity to 
act on these discussions.
58. Despite the complex use of this band for Govern 
ment operations, as discussed in the Preliminary Report, 
the benefits of reallocating the spectrum might be found to 
outweigh those needs. As noted in the Preliminary Report, 
interest in civilian use of this band in Europe is growing.94 
Although the Preliminary Report notes that the conven 
tional spectrum management process provides ample op 
portunity to explore shared or non-Government use of this 
band at a later date, we believe that prompt action to allow 
non-Government access to this band will further our ef 
forts to relieve congestion in the VHBUHF bands and to 
provide for advanced land mobile technologies.
1350-1400 MHz
59. This band is located between bands used for the 
cellular radio service and for personal communications 
service and we believe that equipment for use in this band 
could become quickly available. This band could offer 
additional spectrum to implement emerging technologies 
but it is sufficiently separated from the spectrum currently 
allocated for PCS and the cellular service that it could not 
readily be combined with either of those existing services. 
Non-Government users must have access to sufficient spec 
trum in this band to support new, independent services. 
Although use of this band by the radio astronomy service 
may limit the variety of non-Government uses, this band 
would be highly desirable for terrestrial services. Allocating 
only 10 megahertz of this band at 1390-1400 MHz would 
severely limit potential uses. We suggest NTIA reevaluate 
this band with a view toward making more of it available 
for non-Government use.
1492-1525 MHz
60. Except in the United States, WARC-92 allocated this 
band for use on a primary basis for the mobile satellite 
service in Region 2. MSS is an emerging service for which 
great demand is anticipated and which will benefit the 
nation's world-wide competitiveness. Full implementation 
of this service may. however, be hampered by a lack of
available spectrum. While we recognize the difficulties in 
reallocating this band that are described in the Preliminary 
Report, we do not believe they fully preclude the possibil 
ity of doing so. The American Mobile Service Corporation 
(AMSC), in its comments, has provided an evaluation of 
the possibility of shared Government/non-Government use 
of this band/5
61. This band is part of spectrum in the 1435-1525 MHz 
and 2360-2390 MHz bands used for aeronautical 
telemetering. Out of this total 120 megahertz of spectrum, 
the 1492-1525 MHz band contains only 33 MHz, or less 
than 28 percent of the available spectrum. In a September 
17, 1993, letter to the Department of State, the FCC and 
NTIA stated that discussions on use of the 1492-1525 MHz 
band for MSS are underway and would continue.96 We 
recommend that NTIA more closely the examine the pos 
sibility of reallocating this band for non-Government use, 
at least on a mixed use basis.
1675-1710 MHz
62. In the Preliminary Report's discussion of Federal 
Government Meteorological services, the 1670-1675 MHz 
band was identified for reallocation. The Report noted that 
WARC-92 allocated this spectrum for mobile use by ad 
ministrations wishing to implement aeronautical public 
correspondence. We note that WARC-92 also allocated the 
1675-1710 MHz band for MSS in Region 2. As with the 
1492-1525 MHz band, potential MSS operation in this band 
holds great promise to provide a wide variety of new 
communications services both domestically and interna 
tionally. AMSC has also provided an. analysis of how non- 
Government MSS systems could potentially share this band 
with Government meteorological services.97 The joint 
FCC/NTIA letter of September 17, 1993, also mentioned 
the 1675-1710 MHz band as a candidate for future MSS use 
and we request NTIA to further examine the reallocation 
of this band as well as the 1492-1525 MHz band.
1710-1850 MHz
63. The 1710-1850 MHz band is adjacent to the 
1850-1990 MHz spectrum allocated by the Commission for 
PCS, and reallocation of this band would greatly enhance 
our ability to provide adequate spectrum for new and 
advanced telecommunications technologies. In its Prelimi 
nary Report, NTIA recognizes the great potential for bene 
fit to the public that this band offers and recommends that 
the 1710-1755 MHz portion of the band be reallocated on a 
mixed basis. The Preliminary Report does not recommend 
reallocation of the 1755-1850 MHz portion of the band 
because of Federal use of the 1761-1842 MHz frequency 
range for tracking, telemetry and control of Government 
space systems. However, we are not convinced that non- 
Government use would be incompatible with Government 
use of the 1761-1842 MHz frequencies. The Preliminary 
Report refers to a study performed to evaluate the compati 
bility of high density land mobile operations with space 
operations in the 2025-2110 MHz and 2200-2300 MHz 
bands and applies the findings of that study to the
92 Preliminary Report at 4-23.
93 Preparation of International Union World 
Radiocommunication Conferences, Notice of Inquiry, 1C Docket 
No. 94-91, 59 Fed Reg 25873 (May 18, 1994).
94 Preliminary Report at 4-25. 
93 AMSC comments at Annex II.
96 December 17, 1993, joint letter to Mr. Richard C. Beaird, 
Acting U.S. Coordinator and Director, International Commu 
nications and Information Policy, Department of State, from 
Chairman, FCC and Assistant Secretary of Commerce for Com 
munications and Information.
97 AMSC comments at Annex I.
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9 FCC Red No. 24 Federal Communications Commission Record FCC 94-213
1761-1842 MHz band. Unlike the 2025-2110 and 2200-2300 
MHz bands, however, use of the 1761-1842 MHz band for 
Government operations is limited to Earth-to-space trans 
missions. Thus, it is not obvious that the study is directly 
applicable to the 1761-1842 MHz band. It also appears 
from the Preliminary Report that Government use is limit 
ed to less than 10 locations. These limited Government 
operations might be able to coexist with some non-Govern 
ment use. The Preliminary Report also does not describe 
why large "guard bands" are needed at either side of the 
1761-1842 MHz band. The 6 megahertz wide 1755-1761 
MHz frequency range and the 8 megahertz wide 1842-2850 
MHz frequency range appear to offer excessive protection 
for space operations.
64. In addition, to further investigation into the feasibil 
ity of non-Government use of 1755-1850 MHz, the possibil 
ity of relocating a greater number of Government fixed and 
mobile operations from the entire 1710-1850 MHz band. 
The Preliminary Report indicates that there are a number 
of stations that will indefinitely continue to use the band, 
including stations used by Federal power agencies, fixed 
microwave operations where the majority of communica 
tions involves safety-of-life, and stations in a list of 14 
operating areas as large as 160 km in radius, some of 
which encompass or are near major metropolitan areas.98 
The Preliminary Report notes that a list of specific Federal 
power agency facilities and safety-of-life facilities will be 
provided in the final report. However, at that stage, there 
will be no opportunity for the FCC to analyze and com 
ment on the impact of such operations on non-Govern 
ment use of the band.
65. We believe that the potential benefit to the public of 
access to this entire band, or at least a larger portion of the 
band than 1710-1755 MHz, is great. Every reasonable effort 
should be made to grant access to a greater portion of the 
1710-1850 MHz band if that can be accomplished without 
seriously impairing non-Government use by continuing 
wide-spread Government operations. In addition, every ef 
fort should be made to reallocate this spectrum in less than 
the 10 years proposed for the 1710-1755 MHz band.
3600-3700 MHz
66. The Preliminary Report identified the 3650-3700 
MHz portion of this band for reallocation. In the U.S. table 
of allocations, the entire 3600-3700 MHz band is currently 
allocated for the co-primary use of non-Government (FSS), 
but such use is limited to international inter-continental 
systems by US allocation footnote 245. As satellite commu 
nications systems become more wide-spread, the fixed-sat 
ellite service is growing in importance and additional 
spectrum will be needed. In addition, this band was iden 
tified in our negotiated rule making regarding MSS above 1 
GHz as one of the more likely candidates for MSS/RDSS 
feeder link spectrum." Reallocation of the entire 
3600-3700 MHz band for private sector use and elimination 
of footnote 245 could provide much needed spectrum for 
FSS. We believe it would be very useful to fully examine 
the possibility of reallocating the entire band for non- 
Government use.
4400-4990 MHz
67. The Preliminary Report has identified the 4635-4685 
MHz portion of this band for reallocation, and we believe 
that this spectrum will prove useful for non-Government 
operations. New technologies will, however, likely require 
greater than the 50 MHz identified for reallocation. From 
the general description of fixed and mobile applications 
described in Appendix D of the Preliminary Report, it 
appears that significant opportunities for additional non- 
Government use exist, considering that many of the Gov 
ernment operations appear to be in either remote areas or 
at sea. Accordingly, further consideration should be given 
to reallocating a significantly greater portion of the 
4400-4990 MHz band for exclusive non-Government use as 
well as to the potential for sharing all of this spectrum with 
non-Government services.
5000-5250
68. Although the 5000-5250 MHz band is located above 5 
GHz and would not count toward satisfying the 200 
megahertz minimum reallocation required by the Recon 
ciliation Act, reallocation of this band, or a portion of the 
band, would be useful for non-Government use. In its 
comments, Loral/Qualcomm states that it has been inves 
tigating possible use of this band for MSS feeder uplinks. 100 
In addition, some countries in Europe have proposed that 
the 5150-5250 MHz portion of this band be allocated for 
development of "Hiperlan" data transmission systems 
which will transmit 20 Mbps. Such systems could facilitate 
the rapid transfer of information between computers. 
Reallocation of this band for such an emerging technology 
could allow U.S. companies to be involved in the early 
development of such systems and could boost the ability of 
U.S. companies to compete in Hiperlan deployment.
5850-5925
69. As with the 5000-5250 MHz band, the 5850-5925 
MHz band is above 5 GHz and would not count toward 
satisfying the 200 megahertz minimum reallocation re 
quired by the Reconciliation Act. The 5850-5925 MHz 
band is currently allocated for primary use by the military 
for radiolocation operations. However, this band is also 
allocated for primary use for non-Government Fixed Sat 
ellite Service (Earth-to-Space) as well as for secondary use 
by the Amateur service. The 5850-5925 MHz band could 
be paired with the 3600-3700 MHz band, which currently 
has a primary allocation for use by the non-Government 
Fixed Satellite Service (space-to-Earth).
VI. RECOMMENDATIONS
70. Congress has recognized the critical role that private 
sector communications service providers play in advancing 
telecommunications technologies, in giving a competitive 
advantage to this nation's economy, and in ensuring the 
public's safety of life and property. Congress has also recog 
nized the need for providing these non-Government en 
tities with sufficient spectrum to permit development and 
deployment of new communications services. Congress
98 The Reconciliation Act states that frequencies assigned to 
Federal power agencies are only eligible to be reallocated on a 
mixed use basis and that assignments to those agencies shall not
be withdrawn. Reconciliation Act at Section 113(c)(4).
99 Report of the MSS Above 1 GHz Negotiated Rulemaking 
Committee released April 6, 1994. at 31.
100 Loral/Qualcomm comments at 5-6.
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FCC 94-213 Federal Communications Commission Record 9 FCC Red NO. 24
passed the Reconciliation Act to help satisfy these future 
spectrum needs. NTIA has established a viable foundation 
on which to provide useful spectrum for use by the private 
sector. However, some modifications to the bands identified 
by NTIA in its Preliminary Report could provide the pub 
lic even greater benefits. To assist identifying spectrum that 
would better serve the public, in this Report we have 
identified frequency bands that could provide a home for 
emerging and innovative communication technologies.
71. Table 2 provides a possible alternative plan for the 
spectrum reallocation. Although this plan significantly ex 
ceeds the 200 megahertz minimum required by the Rec 
onciliation Act, it provides options that would have 
numerous advantages to the public. As discussed above, 
reallocation of spectrum in the 225-400 MHz band is con 
sistent with actions under consideration in NATO coun 
tries and would enhance the options for implementing 
more efficient technologies in bands below 1 GHz. Spec 
trum in the 225-400 MHz band might also be used to 
implement a Federal Government/local Government public 
safety network to coordinate the activities of the Federal 
and local governments and could provide spectrum for use 
by biomedical telemetry devices.
72. Table 2 also adds the 1755-1760 MHz and 1845-1850 
MHz bands to the spectrum proposed in the Preliminary 
Report. The 1710-1755 MHz band is the largest band below 
3 GHz identified for reallocation and, we believe, one of 
the most potentially useful bands. We believe that the two 
5-megahertz wide band segments that we have identified 
can be reallocated while still providing a sufficient guard 
band to protect the space operations discussed in the Pre 
liminary Report. Reallocation of the 1755-1760 MHz band 
would provide a contiguous 50 megahertz block of spec 
trum located in a band for which equipment could be 
quickly developed. Further, moving the reallocation sched 
ule for this band from January 2004. as proposed in the 
Preliminary Report, to January 1999 would allow the pub 
lic to realize the benefits of this band much more quickly. 
The 1845-1850 MHz band is immediately adjacent to spec 
trum allocated for PCS and could serve as an adjunct to 
this service.
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9 FCC Red No. 24 Federal Communications Commission Record FCC 94-213
TABLE 2
Alternate Spectrum Reailocation Plan
Bands for 
Reailocation
225-230 MHz
380-400 MHz
1390-1400 MHz
1427-1432 MHz
1670-1675 MHz
1710-1760 MHz
1845-1850 MHz
2300-2310 MHz
2390-2400 MHz
2402-2417 MHz
3625-3700 MHz
4635-4660 MHz
4660-4685 MHz
5850-5925 MHz
Total
Amount 
(MHz)
5
20
10
5
5
50
5
10
10
15
75
25
25
75
335
Reailocation 
Status
Mixed
Mixed
Non-Government only
Non-Government only
Mixed
Mixed
Mixed
Non-Government only
Non-Government only
Non-Government only
Mixed
Non-Government only
Non-Government only
Non-Government only
Availability
Dependent on NATO 
agreement
Dependent on NATO 
agreement
January 1999
January 1999
Immediate
January 1999
Immediate
Immediate
Immediate
Immediate
January 1999
January 1997
Immediate
January 1999
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FCC 94-213 Federal Communications Commission Record 9 FCC Red No. 24
73. Our alternative plan also adds the 3625-3650 MHz 
and 5850-5925 MHz bands to the spectrum proposed in the 
Preliminary Report. These bands are both currently al 
located for use by the non-Government Fixed Satellite 
Service with one band allocated for use as an uplink and 
the other band allocated as a downlink. These bands might 
therefore be paired to provide more usable spectrum for 
the Fixed Satellite Service.
74. In addition, the reallocation plan in Table 2 advances 
the reallocation schedule for the 2300-2310 MHz band to 
match the schedule for the 2390-2400 MHz band. These 
bands are two of the few bands identified in the Prelimi 
nary Report that readily lend themselves to paired oper 
ations and simultaneous reallocation of the bands would 
greatly facilitate paired use of these bands.
75. We realize that advancing the reallocation schedule 
of some bands could be difficult because existing users will 
need to be relocated. To assist in a rapid reallocation of 
some of these bands we are willing to explore jointly with 
the Department of Commerce the possibility of non-Gov 
ernment entities compensating Government agencies for 
the cost of modifying or reallocating Government systems 
that are affected by the reallocation. Although it is prob 
ably not feasible to fully compensate agencies in all in 
stances, it is likely that compensation for some operations, 
such as fixed microwave systems, is feasible. Also, provid 
ing for compensation to Government agencies should en 
courage agencies to relocate some operations that are 
scheduled to continue in mixed use bands.
76. We have provided in this report an analysis of the 
comments to NTIA's Preliminary Report and a discussion 
of the spectrum identified by NTIA as well as recommen 
dations for spectrum that would better meet the needs of 
the public. We hope that, in preparing its final report. 
NTIA will consider the need for large blocks of spectrum, 
particularly below 3 GHz, that are unencumbered by con 
tinued Government operations in and around metropolitan 
areas. Such spectrum will provide great benefit to the 
public in providing for the introduction of new services, 
the expansion of existing services, and will provide much 
needed spectrum for the implementation of MSS. In addi 
tion, significant amounts of spectrum are required for the 
development of services above 3 GHz and even above 5 
GHz. Options for spectrum reallocation need not be limit 
ed to bands below 5 GHz. Since the Reconciliation Act 
does not foreclose reallocation of spectrum in excess of 200 
megahertz, NTIA and the FCC should also explore options 
available for sharing spectrum, thereby providing greater 
benefit to both Government and non-Government users 
and greatly expanding the efficient use of spectrum. We 
look forward to NTIA's final report, which we believe will 
be instrumental in providing fruitful options for advancing 
technological development and implementing a national 
and global information infrastructure.
APPENDIX A
List of Parties that Filed Comments on NTIA Report 
"Preliminary Spectrum Reallocation Report"
Number Party
01 United States Information Agency
02 City of Martinez. CA Police Department
03 GEC Plessey Semiconductors. Inc.
04 Larus Corporation
05 Department of Health & Human Services
06 National Science Foundation
07 Department of Veterans Affairs
08 Maine Turnpike Authority
09 CDR Gerald T. White, USN(ret)
10 George E. Dew
11 Richard M. Shappe
12 Cactus Radio Club, Inc.
13 San Bernardino Microwave Society, Inc.
14 Amateur Television Network
15 Palomar Amateur Radio Club
16 IVHS America
17 National Aeronautics and Space Administration
18 Department of the Army
19 Department of the Treasury
20 Western States VHF-Microwave Society
21 Southern California 'Repeater and Remote Base 
Association
22 James W. Tittle
23 Terry R. Young
24 National Research Council
25 Department of the Interior
26 Amateur Radio Council of Arizona
27 The National Astronomy and Ionosphere Center
28 Radio Amateur Satellite Corporation
29 Association of Public-Safety Communications Of 
ficials International, Inc.
30 Loral/Qualcomm Partnership
31 E.F. Johnson Company
32 National Communications System
33 American Mobile Satellite Corporation
34 Utilities Telecommunications Council
35 Motorola, Inc.
36 American Radio Relay League, Inc.
37 GTE Corporation
38 Telecommunications Industry Association
39 Communications Satellite Corporation
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9 FCC Red NO. 24 Federal Communications Commission Record FCC 94-213
40 National Oceanic and Atmospheric Administra 
tion
41 Department of Agriculture
42 Western Multiples Corporation
43 Digital Microwave Corporation
44 Florida Department of Transportation
45 U.S. Department of Justice
46 National Hydrologic Warning Council
47 Department of Energy
6809