Department of Defense

U.S. Department of

Agriculture 

Department of the

 Air Force

Department of the Army

U.S. Coast Guard

Department of

Commerce

Department of Energy

Federal Aviation

Administration

Federal Emergency

Management Agency

Department of Health

and Human Services

Department of the

Interior 

Department of Justice

National Aeronautics

and Space

Administration

National Science

Foundation

Department of the Navy

Department of the

Treasury

U.S. Postal Service 

THE POTENTIAL FOR

ACCOMMODATING THIRD

GENERATION MOBILE SYSTEMS

IN THE 1710–1850 MHZ BAND:

Federal Operations, Relocation Costs,

 and Operational Impacts 

Final Report

March 2001

U.S. DEPARTMENT OF COMMERCE

National Telecommunications and Information Administration

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

March 2001

U.S. DEPARTMENT OF COMMERCE

Donald L. Evans, Secretary

John F. Sopko, Acting Assistant Secretary

for Communications and Information, and

Administrator, National Telecommunications

and Information Administration

v

PROJECT MANAGEMENT

William T. Hatch

Associate Administrator

Office of Spectrum Management

Fredrick R. Wentland

Director, Spectrum Plans and Policies

TEAM LEADER

W. Russell Slye

Manager, Strategic Spectrum Planning Program

REPORT AUTHORS

Spectrum Engineering and 

Analysis Division

William T. Druhan, Jr.

Spectrum Policies

Joseph P. Camacho

Public Safety

Gary M. Patrick

Robert C. Wilson

CONTRIBUTORS

Spectrum Engineering and 

Analysis Division

Ernesto L. Cerezo

Spectrum Plans

Darlene A. Drazenovich

James T. Vorhies

vii

Table of Contents

Acronyms and Abbreviations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ix

Executive Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . xiii

I. Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-1

Background . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-1

Objectives . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-5

II. Third Generation System Description . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-1

Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-1

Spectrum Identified for IMT-2000 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-2

III. Federal Use of the 1710-1850 MHz Band . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-1

Overview . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-1

Satellite Control Systems . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-11

Conventional Fixed Systems . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-17

Tactical Radio Relay Equipment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-18

Air Combat Training Systems . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-20

Precision Guided Weapons . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-22

Other Systems . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-24

IV. Approaches for IMT-2000 Accommodation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-1

Sharing Potential Employing Protection Areas . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-1

1. Satellite Control (SGLS) Systems . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-1

2. Conventional Fixed Systems . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-4

3. Tactical Radio Relay . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-4

4. Air Combat Training Systems . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-7

5. Precision Guided Munitions (PGM) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-8

6. Other Systems . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-9

Band Sharing and Segmentation Options . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-9

Option 1: In-Band Pairing of the 1710-1850 MHz Band . . . . . . . . . . . . . . . . 4-10

Option 2: Dual-Band Pairing Using the 1710-1790 MHz Band . . . . . . . . . . . 4-16

Option 3: Migration From the 1710-1755 MHz Band. . . . . . . . . . . . . . . . . . . 4-20

Other Issues . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-26

International Concerns . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-26

National Defense Authorization Act of Fiscal Year 2000 . . . . . . . . . . . . . . . . 4-26

V. Estimates of Costs for Relocation of Federal Systems . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-1

Discussion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-1

Cost Estimates by Frequency Band . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-3

Cost Estimates by 3G Accommodation Option . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-7

Costs for Option 1 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-9

Costs for Option 2 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-11

Costs for Option 3 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-12
viii

Appendix A: Protection Contour Surrounding the Goldstone DSN Facility . . . . . . . . . . . . . A-1

Appendix B: Federal Agency Cost Submissions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . B-1

Appendix C: Frequency Assignment Tables by State/Location . . . . . . . . . . . . . . . . . . . . . . . . C-1

Appendix D: DOD Final Report . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . D-1
ix

Acronyms and Abbreviations

3G Third Generation

ACE Army Corps of Engineers

ACMI Air Combat Maneuvering Instrumentation

ACTS Air Combat Training Systems

ACUS Army Common User System

AFB Air Force Base

AFS Air Force Station

AFSCN Air Force Satellite Control Network

BBA-97 Balanced Budget Act of 1997 

BER Bit Error Ratio

CDMA Code Division Multiple Access

COTS Commercial-off-the-shelf

dB Decibel

dBi dB Referred to Isotropic

dBm dB Referred to 1 milliWatt

dBw dB Referred to 1 Watt

DMSP Defense Meteorological Satellite Program

DOD Department of Defense

DOE Department of Energy

DOI Department of the Interior

DOJ Department of Justice

DSN Deep Space Network

DSP Defense Support Program

DWTS Digital Wideband Transmission System

EAC Echelon Above Corps

EMC Electromagnetic Compatibility

ENG Electronic News Gathering

FAA Federal Aviation Administration

FCC Federal Communications Commission

FLTSATCOM Fleet Satellite Communications

FPA Federal Power Agencies

FSK Frequency Shift Keying

FY02 Fiscal Year 2002

GEO Geosynchronous

GFO GEOSAT Follow-On

GHz Gigahertz (109 Hertz)
x

GMF Government Master File

GPS Global Positioning System

GSM Global System for Mobile Communications

GSO Geosynchronous Orbit

HCLOS High Capacity Line-of-Sight

HEO Highly Elliptical Orbit

IAG Industry Association Group

IMT-2000 International Mobile Telecommunications-2000

I/N Interference-to-Noise Ratio

I+N Interference plus Noise

ITU International Telecommunication Union

ITU-R ITU Radiocommunication Sector

ITU-T ITU Telecommunication Standardization Sector

JTCTS Joint Tactical Combat Training System

kbps Kilobits per Second

kHz Kilohertz (103 Hertz)

km Kilometer

LEO Low Earth Orbit

LOS Line-of-Sight

m Meter

mbps Megabits per Second

MHz Megahertz (106 Hertz)

MILSTAR Military Strategic and Tactical Relay 

MSE Mobile Subscriber Equipment

NASA National Aeronautics and Space Administration

NATO North Atlantic Treaty Organization

NDAA National Defense Authorization Act

NGSO Non-Geostationary Orbit

non-GEO Non-Geostationary

NPRM Notice of Proposed Rulemaking

NSF National Science Foundation 

NTIA National Telecommunications and Information Administration

OBRA-93 Omnibus Budget Reconciliation Act of 1993 

PCS Personal Communications Service

PDT Proliferation Detection Technology
xi

RTS Remote Tracking Station

RTT Radio Transmission Technology

SATCOM Satellite Communication

SBIRS Space Based Infrared System

SCN Satellite Control Network

SGLS Space Ground Link Subsystem

SOCC Satellite Operations Control Center

STS Space Transportation System (Space Shuttle)

TACTS Tactical Air Combat Training System

TDD Time Division Duplex

TDMA Time Division Multiple Access

TRI-TAC Tri-Services Tactical Communications

TRR Tactical Radio Relay

TT&C Tracking, Telemetry, and Commanding

TVA Tennessee Valley Authority

TY$ Then Year Dollars

UAV Unmanned Aerial Vehicle

UFO UHF Follow-On

UK United Kingdom

USCG U.S. Coast Guard

USDA U.S. Department of Agriculture

US&P United States and Possessions

VHF Very High Frequency

W-CDMA Wideband Code Division Multiple Access

WARC-92 1992 World Administrative Radio Conference

WRC-97 1997 World Radiocommunication Conference

WRC-2000 2000 World Radiocommunication Conference

xiii

Executive Summary

Background

The National Telecommunications and Information Administration (NTIA) is the

Executive Branch agency principally responsible for developing and articulating domestic and

international telecommunications policy. Accordingly, NTIA conducts studies and makes

recommendations regarding telecommunications policies and presents Executive Branch views

on telecommunications matters to the Congress, the Federal Communications Commission

(FCC), and the public. NTIA also serves as manager of the Federal Government's use of the

radio frequency spectrum.

The President signed an executive memorandum dated October 13, 2000, that stated the

need and urgency for the United States to select radio frequency spectrum to satisfy the future

needs of the citizens and businesses for mobile voice, high-speed data, and Internet-accessible

wireless capability; the guiding principles to be used for the development of third generation

(3G) wireless systems; and the direction to the Federal agencies to carry out the selection of

spectrum. The President 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

International Telecommunication Union (ITU) 2000 World Radiocommunication Conference

(WRC-2000) that could be used for 3G systems.

Objectives

The objectives of this study were to document the Federal Government use of the 1710-

1850 MHz band, and to address other issues relevant to the possible accommodation of 3G

mobile systems in this band. These issues include sharing options, continuity of Federal

operations, time lines for relocation, and the estimated costs related to any relocation of Federal

users from the band.

Spectrum Under Consideration

The 1710-1885 MHz and 2500-2690 MHz bands were two bands, among others,

identified by the WRC-2000 as additional bands for 3G mobile systems, also called International

Mobile Telecommunications-2000 (IMT-2000). The United States is planning for the

introduction of IMT-2000 services by commercial providers, but unused spectrum to

accommodate such services is currently not available. Both NTIA and the FCC are examining

these candidate frequency bands (1755-1850 MHz and 2500-2690 MHz, respectively) identified

by the conference that are under their respective jurisdictions, with a view towards

accommodating IMT-2000 systems. Since the WRC-2000 identified these candidate bands for

IMT-2000 operations, promoting worldwide harmonization of spectrum is a desired long-term

goal.
xiv

 The 1710-1755 MHz band will be transferred to the FCC on a mixed-use basis pursuant

to the requirements of the Omnibus Budget Reconciliation Act of 1993 (OBRA-93), and the

National Defense Authorization Act (NDAA) for Fiscal Year 1999, but Federal operations can

continue in the band within 16 protected areas. The Federal Power Agencies and public safety

fixed links will also be protected. The 1850-1885 MHz band is under FCC regulatory

jurisdiction and is currently used for personal communications services (PCS). The remaining

1755-1850 MHz band, which is the focus of this study, is under the jurisdiction of NTIA. Within

the United States, the 1755-1850 MHz band is allocated on an exclusive basis to the Federal

Government for fixed and mobile services. Footnote G42 to the National Table of Frequency

Allocations provides for the co-equal accommodation of Federal space command, control, and

range and range-rate systems for earth station transmission in the 1761-1842 MHz band. The

Department of Defense (DOD) is the predominant user of the 1755-1850 MHz band. However,

13 other Federal agencies operate extensive fixed and mobile systems in this band throughout the

United States.

In addition to the above two bands identified by the conference, other bands that could be

considered in the United States are: 698-746 MHz, 747-762 MHz, 777-792 MHz, 806-960 MHz,

1850-1990 MHz, 2110-2150 MHz, and 2160-2165 MHz.

Schedules

The FCC, in conjunction with NTIA, is expected to identify spectrum by July 2001, and

auction licenses to competing applicants by September 30, 2002. The following report provides

NTIA’s assessment of the potential for accommodating 3G mobile systems in the 1710-

1850 MHz band, including the feasibility of sharing the band, operational impacts to incumbent

users, and estimated relocation costs in the event that incumbent users would be required to

relocate to alternate spectrum. The FCC report on the 2500-2690 MHz band, addressing similar

issues, will be released concurrently by the FCC.

Analysis Approach

This report examines the technical feasibility of accommodating 3G systems in the 1710-

1850 MHz band, and develops the estimated costs associated with any relocation of Federal

systems. In this report, the 1710-1850 MHz band will be considered in two parts: the 1710-

1755 MHz portion, and the 1755-1850 MHz portion. As noted above, the 1710-1755 MHz band

was identified by NTIA to be reallocated and transferred to the FCC under OBRA-93 as a

mixed-use band. The 1755-1850 MHz band is a vital national asset to support Federal

operations, particularly national defense, the control of electrical power transmission, and law

enforcement. The Federal use of the 1755-1850 MHz band can be categorized into several broad

classes of systems, 1) tracking, telemetry, and commanding for Federal space systems,

2) medium-capacity, conventional fixed microwave communications systems, 3) military tactical

radio relay (TRR) systems, 4) air combat training systems (ACTS), 5) precision guided munitions

(PGMs), 6) high resolution airborne video data links, and various other aeronautical mobile

applications, and 7) land mobile video functions such as robotics, surveillance, etc.
xv

NTIA examined the Federal use of the 1710-1850 MHz band for possible accommodation

of advanced mobile telecommunications systems, such as IMT-2000. To aid in NTIA’s

evaluation of accommodating IMT-2000 services in the 1755-1850 MHz band, the DOD

provided to NTIA on February 15, 2001, a report that detailed the electromagnetic compatibility

(EMC) between major DOD systems in the 1755-1850 MHz band and IMT-2000 systems,

relocation costs and operational impacts as a result of any potential DOD migration from the

band, and an examination of time requirements should DOD systems move from the band. NTIA

did not perform independent technical analyses on DOD systems. Data from those analyses

furnished by the DOD in its final report were incorporated into this report.

If possible, sharing the spectrum would allow for a more efficient use of this resource

than would relocating incumbent users. It is recognized that some systems will not be able to

share with a nationwide build out of 3G mobile systems. These systems will have to be moved to

another frequency band if accommodation is to occur.

Results

General. This NTIA Final Report examines the feasibility of accommodating IMT-2000

systems by sharing the 1710-1850 MHz band with incumbent Federal users, or segmenting the

band. In the 1755-1850 MHz band, predicted interference to both IMT-2000 and incumbent

systems would preclude compatible operation at a large number of metropolitan areas and over

large geographic areas of the country. Unacceptable operational restrictions would be required

on DOD systems in order to mitigate the interference with IMT-2000 systems. Therefore, it was

concluded that full-band sharing was not feasible.

This report also examines whether Federal agencies can fully vacate the 1755-1850 MHz

band to accommodate IMT-2000 systems. The most optimistic estimates, based on funding

being available in Fiscal Year 2002, indicate that all Federal agencies will be unable to fully

vacate this band until well beyond the time lines established for this study (i.e., 2003, 2006, and

2010). The examination revealed that regardless of funding, vacating the band could not be

accomplished for most DOD non-space systems until 2010 and beyond. Legacy space systems

would require continued protected access to the 1761-1842 MHz band until 2017, and possibly

as late as 2030 for some satellites. Migration prior to these dates would require premature

satellite loss, which would have extremely serious implications to Federal agencies’ abilities to

effectively accomplish their missions.

Moreover, for DOD systems, total relocation from any band requires alternate spectrum

that is technically comparable, with the same degree of regulatory protection that currently exists

in the 1755-1850 MHz band. NTIA has found, however, that comparable spectrum may not be

available.

The DOD EMC analyses showed that all major DOD systems will encounter serious

challenges in accommodating IMT-2000 systems, and could face significant operational

restrictions in any frequency sharing situation.
xvi

Space Operations. Federal satellite control is an essential function and is authorized to

use the 1761-1842 MHz portion of the band. This function could not be completely relocated

until all satellites using this band have expired, which could be as late as 2030. The DOD

analysis indicated that co-channel sharing between satellite control uplinks and transmitting

IMT-2000 base stations would result in excessive interference to the uplink signal, and is not

feasible due to the potential for harmful interference to satellite control signals at the orbiting

satellites.

The DOD analysis showed that co-channel sharing with transmitting IMT-2000 mobile

stations in a fully built-out scenario results in less interference to the uplink signals. The

potential for sharing the satellite control uplinks with IMT-2000 mobile units seems to be

technically feasible, and the potential interference is within the range of prudent risk

management. Interference to IMT-2000 systems from satellite control station transmissions

could be mitigated by either IMT-2000 systems operating outside of the interference distances

calculated for each satellite control station, or some real-time means for the IMT-2000 system to

avoid assigning channels on frequencies that satellite control stations are using.

Therefore, with regard to possible near-term use of the band for IMT-2000 systems,

sharing considerations with the satellite control systems presents a fundamental go/no-go

decision, since near-term replacement or changing frequencies in orbiting satellites is not

possible. All satellites supported in this band use receivers that are set to specific channels and

cannot be re-tuned after launch. The lifetimes of these satellites can exceed 10 years. Uplink

sharing is further complicated by the fact that transportable satellite control stations will be

operated at deployed locations when necessary to accomplish the satellite control mission. The

2025-2110 MHz band could possibly accommodate satellite control functions in the future. 

However, it would take several years to fund, develop, acquire, test, and qualify space flight

hardware, and frequency allocations for the band would need to be revised via an FCC

rulemaking process for space services that provides comparable regulatory protection.

The satellite control stations can potentially cause interference to co-channel IMT-2000

stations at significant distances, depending on the terrain surrounding the satellite control station. 

Near-worst-case interference distances in excess of 300 km were calculated using a smooth-Earth

propagation model. Actual interference distances will generally be less because of terrain

shielding.

Tactical Radio Relay Operations. Loss of significant spectrum to support TRR training

would lead to the requirement for replacement of the military TRR systems. An examination of

the spectrum below 3 GHz did not yield any available frequency band comparable to the 1710-

1850 MHz band for accommodation of the DOD use of TRR and other DOD spectrumdependent systems in support of test and training or large-scale military exercises. Therefore,

lacking comparable spectrum, the TRR systems cannot be relocated.

Air Combat Training Operations and Precision Guided Munitions. For the ACTS,

the 2010 time frame may allow for an accelerated Joint Tactical Combat Training System

program to provide replacements for the current ACTS systems. Modifications to current ACTS
xvii

systems could also be complete by that time. The point-to-point fixed links could be relocated to

the 4400 MHz or 7/8 GHz bands. However, compatibility issues with incumbent systems in the

air/ground alternate bands (2200-2290 MHz and 4400-4940 MHz bands) could prevent

successful relocation of the air/ground links.

Under any frequency sharing scenario, ACTS and PGMs will require modifications to

relocate to alternate bands. Sharing frequencies between these airborne systems and IMT-2000 is

not feasible because interference can occur over very large areas.

Fixed Services. Conventional fixed systems are also a cause for concern because of their

widespread use. NTIA concluded that general sharing of IMT-2000 operations with the current

nationwide fixed service systems would not be feasible

Other Government Systems. Other systems operating in the band, such as PGMs,

unmanned aerial vehicles, advanced data links, and electronic identification of friendly forces,

were studied to determine if they could share with IMT-2000 systems, or be relocated. 

Generally, sharing was found to be problematic, and the systems would need to be re-designed to

work in other frequency bands.

Options

The DOD EMC analyses further indicated that the extensive use of the 1755-1850 MHz

band by DOD, coupled with the projected build out of IMT-2000 systems, would make

uncoordinated sharing with IMT-2000 systems infeasible. However, three sharing and

segmentation options were considered in this report as shown below.

Option 1: In-Band Pairing. In this sharing option, the 1710-1850 MHz band is

considered as divided into three segments, 1710-1755 MHz, 1755-1805 MHz, and 1805-

1850 MHz. In this approach, mobile (handset) IMT-2000 units would share and transmit in the

1710-1755 MHz segment, the Federal Government would retain exclusive use of the 1755-

1805 MHz segment, and the IMT-2000 base stations would share and transmit in the 1805-

1850 MHz segment. This segmentation might make up to two 45-MHz segments available for

IMT-2000 services (i.e., 1710-1755 MHz paired with 1805-1850 MHz), under certain conditions. 

IMT-2000 operators would coordinate their operations within protection areas, defined by

separation distances from major Federal systems required to reduce mutual interference to an

acceptable level. However, since both mobile and base stations transmit (and receive) in the

1710-1850 MHz band, simultaneous coordination of both base and mobile frequencies may be

necessary. These factors, plus sharing satellite control uplinks with IMT-2000 base stations,

would preclude sharing under these conditions. Since sharing was shown not to be feasible, this

is not a viable option.

Option 2: Out-of-Band Pairing. A second sharing option would provide for IMT2000 mobiles to share and transmit in the 1710-1790 MHz range, in phases, with the base

stations transmitting in frequency bands above 2110 MHz, e.g., 2110-2150 MHz and 2160-

2165 MHz. The Federal Government would retain exclusive use of the 1790-1850 MHz
xviii

segment. This segmentation option would have three phases, the first phase allowing IMT-2000

mobile operations to share in the 1710-1755 MHz band, then adding shared use in the 1755-

1780 MHz band, and finally in the 1780-1790 MHz band, if required. As described above, IMT2000 mobile operators would coordinate their operations with DOD users whenever they operate

within protection areas, which are defined by separation distances from major Federal systems

that would reduce mutual interference to an acceptable level. These protection areas would be in

addition to the current 16 protected sites, and would include satellite control sites. This

coordination of the mobile terminals might be technically implemented in the IMT-2000 base

stations by the receiving base station not assigning mobile stations to a channel that was occupied

by a Federal user.

This option presents certain advantages compared to the in-band pairing option from an

interference standpoint, because only half of the IMT-2000 system needs to be coordinated, and

IMT-2000 base stations would not operate co-channel with satellite control uplinks. Co-channel

sharing with mobiles shows less interference potential to the satellite uplink, and may be feasible. 

In this case, satellite control uplinks would share with IMT-2000 mobiles in the 1761-1790 MHz

band. This option could, in the long-term, make up to 80 MHz available for mobiles in the 1710-

1790 MHz band to be paired with equivalent spectrum in a higher frequency band. The

alternatives to sharing would be for IMT-2000 services to be implemented in other frequency

bands, or, Federal systems in the band segments required for IMT-2000 to be relocated to

comparable spectrum. IMT-2000 operators would reimburse Federal operators if relocation,

modification, or re-tuning of the systems is necessary. Essential Federal Government capabilities

must be maintained.

Option 3: Out-of-Band Pairing & Federal Migration From Band. The third

approach considers that the 1710-1755 MHz band might be vacated by Federal operations, in

stages. IMT-2000 systems, paired with spectrum above 2100 MHz, would then have unrestricted

operation nationwide. Until replacement systems are funded and deployed, the 16 protected

areas would be replaced by new protected areas, selected to allow for full training on DOD

systems in the 1710-1755 MHz band. When deployed, new DOD TRR equipment, designed to

operate up to 2690 MHz, would then be authorized to operate in the new protected areas in

45 MHz of comparable replacement spectrum somewhere below 2690 MHz. As with any option

that may necessitate the relocation of existing Federal users, reimbursement guidelines,

appropriate time lines and access to comparable spectrum are issues that will need to be resolved.

Costs

In order to evaluate options associated with possible relocation of Federal systems to

alternate frequency bands, a determination of estimated relocation costs, operational impacts, and

time schedules for moving were developed. Estimated costs for DOD systems were submitted to

NTIA in the DOD Final Report. Costs for Federal civil agencies’ systems were submitted in

writing by each agency. Costs for DOD systems were submitted as “budget-year” amounts

(called “then-year” dollars (TY$) in the DOD Final Report), while other Federal agencies’ costs

are given in Fiscal Year 2002 (FY02) dollars. Direct addition of these amounts will yield an

inconsistent value. A deflator factor of 1.102 was used to equate TY$ to FY02 dollars. NTIA
xix

has relied on the cost data furnished by the Federal agencies as being representative of estimated

total system replacement costs, realizing that there are some unknown factors that will affect the

final costs.

The total cost to relocate Federal operations from the 1755-1850 MHz band is estimated

to be $4,640 million (FY02), if the time line specified by DOD and the other Federal agencies is

accommodated and alternate spectrum is made available. Although all relocation options have

an estimated total cost, this does not mean that relocation of all Federal systems is possible. For

example, no adequate alternate spectrum was found for the DOD TRR system.

 NTIA is developing rules for private sector reimbursement for relocating to other

frequency bands Federal systems currently operating in certain frequency bands (including the

1710-1755 MHz band) identified for reallocation. This reimbursement process is similar in some

respects to the procedures used in clearing the commercial PCS band. NTIA has released a

Notice of Proposed Rulemaking, and is in the process of establishing rules for private sector

reimbursement for relocating Federal systems. The procedures established by NTIA’s

rulemaking will be used as a basis for reimbursement for the relocation of Federal systems,

where necessary, from parts of the 1755-1850 MHz band.

Sharing Versus Options

Sharing is proposed for two options (Options 1 and 2). If sharing could be accomplished,

the government reimbursement costs incurred would be minimal, since the responsibility for

coordination would be borne by the commercial IMT-2000 service providers. However, under

the condition that sharing is not feasible, total costs are presented for complete relocation of

Federal systems. If some sharing is possible, then the costs would be less. These cost estimates

are appropriate only as guidelines in determining what the final relocation expenses might be. 

Estimated costs are based on very specific assumptions and schedules. Departures from these

assumptions would substantially change the cost of relocation. Some cost factors, such as final

selection of alternative frequency bands, are unknown at this time, and could influence the final

cost. The DOD indicated that under any circumstance they would not be able to vacate portions

of the 1755-1850 MHz band until beyond 2010. Support in the 1755-1850 MHz band for

Federal space assets would need to continue until at least 2017, and possibly until 2030 for some

satellites.

Costs versus Options

Total estimated relocation costs in FY02 dollars for the three options as described in this

report are as follows:

C Option 1 - $3,448 million

C Option 2 - $4,548 million 

C Option 3 - $2,192 million
xx

Reallocation Considerations

In implementing any of the options involving band segmentation, many Federal systems

in the 1755-1850 MHz band would need to be either relocated to different frequency bands or

modified to operate in the remaining portions of the band. Major performance, compatibility,

funding, and regulatory issues would have to be thoroughly addressed before any relocation

could begin. A major uncertainty with the concept of large-scale relocation is that critical issues

regarding the costs, risks, and engineering efforts to assure the incumbent systems in the alternate

bands are protected are not addressed. In the aggregate, this would be a complex, costly, and

lengthy process. The major risk in relocating major national defense systems is the uncertainty of

future successful mission accomplishment.

Specifically, there are several issues that must be resolved before any spectrum can be

made available in the 1755-1850 MHz for reallocation, including continuity of essential

government operations, interference, and regulatory protection of Federal Government systems

during any migration period; assurance of comparable spectrum available to which Federal

Government systems can relocate; and timely resolution of any regulatory actions necessary to

make such spectrum available.

Note that the NDAA for Fiscal Year 1999 also requires that Federal Government agencies

required to relocate or modify their radiocommunications systems to accommodate private sector

use of the spectrum be reimbursed for the costs associated with such relocation or modification. 

NTIA is in the process of developing and implementing rules for reimbursement. These rules

will be applicable to relocation costs associated with the 1710-1755 MHz band and any spectrum

that is or would be reallocated in the 1755-1850 MHz band.

Further, with respect specifically to surrender of spectrum in which the DOD is a primary

user, the NDAA for Fiscal Year 2000 also requires that:

 “(A) the National Telecommunications and Information Administration, in consultation

with the Federal Communications Commission, identifies and makes available to the

Department for its primary use, if necessary, an alternative band or bands of frequencies

as a replacement for the band to be so surrendered; and

(B) the Secretary of Commerce, the Secretary of Defense, and the Chairman of the Joint

Chiefs of Staff jointly certify 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 such

alternative band or bands provides comparable technical characteristics to restore

essential military capability that will be lost as a result of the band of frequencies to be so

surrendered.”
xxi

Findings

NTIA finds that unrestricted sharing of the 1755-1850 MHz band is not feasible, and any

other sharing options would require considerable coordination by IMT-2000 operators when

operating in the presence of Federal systems. In the event of Federal relocation resulting from

sharing/segmentation options, issues involving comparable spectrum, reimbursement, and the

time required for Federal entities to either modify or replace equipment would need to be

addressed.

Three sharing/segmentation options were examined for 3G accommodation. Option 1,

which included in-band pairing and sharing with both IMT-2000 mobiles and base stations, was

found not to be viable because of sharing difficulties. Option 2, which considered sharing and

out-of-band pairing, was found to be on option that could be further considered, but sharing

problems with some Federal systems remain to be solved. Option 3 considers migrating Federal

users out of the 1710-1755 MHz band in the long-term, and pairing this with spectrum in the

2110-2150 MHz and 2160-2165 MHz bands. This option may be possible if, along with

considerations of reimbursement and appropriate time lines, 45 MHz of comparable replacement

spectrum can be allocated to Federal use to accommodate the military training requirements for

TRR systems.
This page is left intentionally blank.
1-1

I. Introduction

Background

The National Telecommunications and Information Administration (NTIA) is the

Executive Branch agency principally responsible for developing and articulating domestic and

international telecommunications policy. Accordingly, NTIA conducts studies and makes

recommendations regarding telecommunications policies and presents Executive Branch views

on telecommunications matters to the Congress, the Federal Communications Commission

(FCC), and the public. NTIA’s responsibilities include fostering new technology and

encouraging the expansion of domestic wireless services, while ensuring that the Federal

agencies have adequate access to the spectrum to perform their critical missions.

NTIA is also responsible for managing the Federal Government's use of the radio

frequency spectrum. The FCC is responsible for managing spectrum used by the private sector,

including state and local governments. 

In support of these responsibilities, the NTIA has undertaken numerous spectrum-related

studies. The objectives of these studies were to assess spectrum utilization, feasibility of

reallocating government spectrum or relocating government systems, identify existing or

potential compatibility problems between systems, provide recommendations for resolving any

compatibility conflicts, and recommend changes to promote efficient and effective use of the

radio spectrum and to improve spectrum management procedures.

Over the past decade, there has been enormous worldwide growth in the use of

cellular-type personal mobile communications systems. Many countries initially introduced

analog systems and are now transitioning to digital systems. Studies in the International

Telecommunication Union (ITU) and elsewhere indicate that this growth in personal

communications is likely to continue.

Third generation (3G) wireless systems will provide terrestrial and satellite-based

broadband and multi-media capabilities, and represent a path for the evolution of existing cellular

and personal communications services (PCS). Discussions relative to spectrum for 3G advanced

mobile telecommunications systems are vital for administrations to plan their spectrum use, and

for industry to plan how it will meet the marketplace requirements of the future.

The International Mobile Telecommunications-2000 (IMT-2000) is an advanced mobile

communications standard, and is considered to be a 3G wireless system. Key features of the

IMT-2000 include a high degree of design commonality worldwide, compatibility of services

within IMT-2000 and other fixed networks, and high-quality worldwide use and roaming

capability for multi-media applications (e.g., video-teleconferencing and high-speed internet

access). The ITU established an agenda item for the 2000 World Radiocommunication

Conference (WRC-2000), which considered the “review of spectrum and regulatory issues for

advanced mobile applications in the context of IMT-2000, noting that there is an urgent need to

provide more spectrum for the terrestrial component of such applications and that priority should
1

 Resolution 721 (WRC-97) Agenda for the 1999 World Radiocommunication Conference, International

Telecommunication Union Radio Regulations, Volume 3, (Geneva: ITU 1998) at 319.

2

 Presidential Memorandum, Subject: Advanced Mobile Communications/Third Generation Wireless Systems,

The White House, October 13, 2000.

1-2

be given to terrestrial mobile needs, and adjustments to the Table of Frequency Allocations as

necessary.”1

The 1710-1850 MHz and 2500-2690 MHz bands were two of the candidate bands that

WRC-2000 considered for IMT-2000 terrestrial systems. The U.S. position for this conference

was negotiated by U.S. industry and government representatives, resulting in a proposal that the

United States believed could be the basis for a compromise at the conference, given the

conflicting positions of many of the other administrations. The United States suggested three

possible bands for IMT-2000, including the 1710-1885 MHz band (favored by the Americas), the

2500-2690 MHz band (favored by Europe), and the 698-960 MHz band. At the conference, the

United States stated that it would study these bands domestically. Since the WRC-2000

identified these candidate bands for IMT-2000 operations, promoting worldwide harmonization

is a desired long-term goal.

In addition to the 1885-2025 MHz and 2110-2200 MHz bands already identified

internationally for IMT-2000, the United States proposed and the WRC-2000 adopted regulatory

flexibility, giving each administration the right to determine which bands or part of the three

bands it may want to identify for IMT-2000. Also, the United States proposed to keep bands

identified for IMT-2000 open to any technology rather than specifying a technology or standard

for use in the spectrum.

Such national and international activities emphasize the need to investigate the

accommodation of IMT-2000 wireless systems in several candidate frequency bands to include

all or parts of the 698-746 MHz, 747-762 MHz, 777-792 MHz, 806-960 MHz, 1710-1850 MHz,

1850-1990 MHz, 2110-2150 MHz, and 2500-2690 MHz bands.

Subsequent to the WRC-2000, the Assistant Secretary of Commerce for Communications

and Information, the Chairman of the FCC, and representatives of the State Department and the

Department of Defense (DOD) met with White House staff to define the process by which

spectrum would be identified for advanced mobile telecommunications systems, such as IMT2000, in the United States. It was decided that studies would be performed by NTIA (on the

1755-1850 MHz band) and the FCC (on the 2500-2690 MHz band) to determine if either or both

of these bands would be viable candidates for accommodation of future 3G mobile systems. 

President Clinton signed an executive memorandum dated October 13, 2000, that stated

the need and urgency for the United States to select radio frequency spectrum to satisfy the future

needs of the citizens and businesses for mobile voice, high-speed data, and Internet-accessible

wireless capability; the guiding principles to be used for the development of advanced wireless

systems; and the direction to the Federal agencies to carry out studies to identify spectrum that

could be used by 3G wireless systems.2

 In summary, the President directed that the Secretary of

Commerce, in cooperation with the FCC:
3

 Department of Defense, IMT-2000 Technical Working Group, Interim Report, Investigation of the Technical

Feasibility of Accommodating the International Mobile Telecommunications (IMT) 2000 Within the 1755-

1850 MHz Band, IMT-2000 Technical Working Group, Department of Defense, (Oct. 27, 2000) [hereinafter DOD

Initial Report], available at <http://www.ntia.doc.gov/osmhome/reports/dodreport>.

4

 See 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, FCC 00-455, NPRM and Order, 66 Fed. Reg. 7438 (Jan. 23, 2001) [hereinafter

FCC 3G NPRM].

1-3

! Develop a plan by October 20, 2000, for the identification and analysis of possible

spectrum bands for 3G services that would enable the FCC to select specific

frequencies by July 2001 for 3G and complete the auction for licensing advanced

wireless providers by September 30, 2002;

! Issue interim reports by November 15, 2000, on the current spectrum uses and the

potential for reallocation or sharing the bands identified at the WRC-2000 that

could be used for advanced wireless systems, in order that the FCC can identify,

in coordination with NTIA, spectrum by July 2001, and auction licenses to

competing applicants by September 30, 2002; and

! Develop an outreach program to work with government and industry

representatives through a series of public meetings to develop recommendations

and plans for identifying spectrum for advanced wireless systems.

The DOD released to NTIA on October 30, 2000, an initial report detailing the

electromagnetic compatibility (EMC) interactions between major DOD radiocommunications

systems operating in the 1755-1850 MHz band and IMT-2000 systems. That report, entitled,

Department of Defense IMT-2000 Technical Working Group - Interim Report - Investigation of

the Technical Feasibility of Accommodating the International Mobile Telecommunications (IMT)

2000 Within the 1755-1850 MHz Band,

3

 was used by NTIA for preliminary evaluation of the

potential for sharing the 1710-1850 MHz band with IMT-2000 systems. The above work led to

the issuance of an NTIA interim report that described the potential for the 1755-1850 MHz band

to be used for advanced wireless applications.

Subsequent to the release of the NTIA and FCC interim reports, the FCC issued a Notice

of Proposed Rulemaking (NPRM)4 that requested comments regarding the accommodation of

advanced mobile wireless systems. The FCC listed three options for possible pairing of

frequency bands for the introduction of advanced wireless systems. These options are:

C FCC’s Option 1 - 1710-1755 MHz paired with 2110-2150 MHz and 2160-2165 MHz

(A variation to this option would be the addition, in phases, of the bands 1755-

1790 MHz. This is similar to the NTIA Option 2);

C FCC’s Option 2 - 1710-1755 MHz paired with spectrum in the 1755-1850 MHz band;

and
5

 Memorandum from Michael Altschul/Cellular Telecommunications Industry Association, Robert L.

Hoggart/Personal Communications Industry Association, and Grant E. Seiffert/Telecommunications Industry

Association to Assistant Secretary Rohde/NTIA and Chairman Kennard/FCC, establishing the Industry Association

Group, December 8, 2000.

6

 Dept. of Defense IMT-2000 Technical Working Group, Final Report, Investigation of the Technical Feasibility

of Accommodating the International Mobile Telecommunications (IMT) 2000 Within the 1755-1850 MHz Band

(Feb. 9, 2001) [hereinafter DOD Final Report], available at <http://www.ntia.doc.gov/osmhome/reports/>.

7

 U.S. Department of Commerce, Plan To Select Spectrum for Third Generation (3G) Wireless Systems in the

United States (Oct. 20, 2000), available at <http://www.ntia.doc.gov/ntiahome/threeg/3g_plan14.htm>.

1-4

C FCC’s Option 3 - 2110-2150 MHz and 2160-2165 MHz paired with spectrum in the

2500-2690 MHz band.

Since the Presidential Memorandum directed the Secretary of Commerce to work with

government and industry representatives to develop recommendations and plans for identifying

spectrum for 3G wireless services, NTIA has convened several government-industry outreach

meetings. These meetings have been held to provide an open dialog to address various issues

and concerns pertaining to accommodation of 3G wireless systems in the 1755-1850 MHz band

and 2500-2690 MHz bands. It was recommended by the participants at the initial governmentindustry outreach meeting that to address the numerous complex technical issues regarding the

accommodation of 3G systems in a timely manner, smaller subgroups would be required. These

subgroups would consist of technical experts from both government and industry.5

To that end, the Industry Association Group (IAG) was formed, with five subgroups, each

chaired by industry personnel. The subjects of the subgroups include: 1) 2500-2690 MHz, 2) 3G

Characteristics, 3) Satellite Group, 4) Fixed and Tactical Radio Group, and 5) Air Combat

Training Group. The main topics that were addressed in each subgroup include: technical

sharing analysis between 3G systems and existing systems, mitigation options, and migration

strategies to alternative bands. As of March 30, 2001, there have been four meetings of the

subgroups with both government and industry personnel in attendance. A final report of the

IAG, including the outputs of these subgroups, was forwarded to NTIA.

The DOD released to NTIA on February 15, 2001, a final report entitled, Department of

Defense Investigation of the Feasibility of Accommodating the International Mobile

Telecommunications (IMT) 2000 Within the 1755-1850 MHz Band,

6

 which refined the analyses

of the DOD Initial Report, and included operational impacts that would occur under sharing

scenarios or if DOD systems were to be relocated, and the associated relocation costs. Data from

that DOD Final Report are extracted and included here, and the complete report, minus

Attachment 1, is included as part of this report as Appendix D.

According to the Secretary of Commerce’s Spectrum Plan,7 this NTIA final report would

consist of the information contained in the NTIA Interim Report, plus relocation costs and

operational impact data as submitted by the DOD and other Federal agencies.
1-5

Objectives

The objectives of this study are:

1. To document Federal Government use of the 1710-1850 MHz band, and to address

issues relevant for possible use of the 1710-1850 MHz band to accommodate advanced mobile

telecommunications systems, such as IMT-2000, in the United States relative to:

(A) the current and emerging Federal uses, 

(B) an examination of sharing options between Federal systems and IMT-2000 systems,

(C) operational impacts to Federal agencies if Federal systems were to be relocated, and

(D) the estimated costs for relocation of these systems.

2. To compile information on the Federal use of the 1710-1850 MHz band for use as a

response to the FCC’s 3G NPRM on advanced mobile telecommunications. This report

specifically addresses paragraphs 41 through 49 of the NPRM.
This page is left intentionally blank.
8

 Material for this section was initially furnished by the Federal Communications Commission, and has been

updated with data furnished by the IAG via contributions in various meetings with NTIA and the FCC.

9

 ITU-R Recommendation M. [IMT.SPEC], ITU-R Radiocommunication Assembly, Istanbul, Turkey (May

2000).

10 ITU-T Draft Recommendation Q.1701, Geneva.

11 United States Talking Points for World Communication Conference 2000 on IMT-2000 spectrum requirements.

12 Id.

2-1

II. Third Generation System Description8

Introduction

Third generation, or IMT-2000 services, are the names commonly used to refer to the

next generation mobile wireless telecommunications services. The 3G family of services, and

the systems that will provide them, are intended to reflect a high degree of commonality and to

be compatible with each other. These services will support mobile and fixed users employing a

wide range of devices, including small pocket terminals, handheld telephones, laptop computers,

and fixed-receiver equipment. Third generation services are envisioned to be ubiquitous

throughout the world, as available in a remote part of a developing country as they are in an

urban area in a highly developed country. Seamless roaming is a key attribute, and access to

services is expected to be uniform. Furthermore, the user will be able to roam from an urban to a

suburban and into a rural setting without loss of basic services.

The ITU has been fostering the development of the underlying radio and network

standards for what is now defined as IMT-2000 services for over 15 years. The radio

transmission technologies (RTTs) providing for standardized 3G air-interfaces adopted in

November 1998 were the culmination of many years of effort under the auspices of the ITU’s

Radiocommunication Sector (ITU-R) Task Group 8/1. These RTTs form the basis for

connecting the user’s mobile or portable device to the physical infrastructure supporting IMT2000 services. ITU-R Task Group 8/1 also developed methods that can be used to assess the

amount of additional spectrum needed to accommodate the expected future growth in demand for

3G mobile services.9

 The ITU’s Telecommunication Standardization Sector (ITU-T) is actively

working to develop 3G signaling and communication protocols, network requirements needed to

support expected 3G services, and service definitions for IMT-2000 applications. Table 2-1

below, derived from ITU-T Draft Recommendation Q.1701,10 describes selected essential

capabilities of IMT-2000 systems.

Consumer demand for services available at any place, coupled with the expectation of

high quality and increased transmission speed, are key drivers in the effort to establish

commonality and compatibility of 3G terrestrial telecommunication systems. It is estimated that

by the year 2010 there will be 1 billion wireless subscribers worldwide on 3G networks.11 At the

present time, the worldwide penetration of wireless service is approximately 71⁄2 percent and it is

expected to exceed 30 percent by the end of the first decade of the new millennium.12 There are

over 1,300 cellular and second-generation terrestrial mobile service networks currently operating
2-2

worldwide, each with limited geographic coverage. It becomes increasingly important to

harmonize spectrum allocations for 3G services if companies are to provide uniform services and

seamless roaming on a regional or global scale.

Table 2-1

IMT-2000 Services/Capabilities

Capabilities to support circuit and packet data at high bit rates:

- 144 kbs or higher in high mobility (vehicular) traffic

- 384 kbs or higher for pedestrian traffic

- 2 mbs or higher for indoor traffic

Interoperability and roaming among IMT-2000 family of systems

Common billing/user profiles:

- Sharing of usage/rate information between service providers

- Standardized call detail recording

- Standardized user profiles

Capability to determine geographic position of mobiles and report it to

both the network and the mobile terminal

Support of multimedia services/capabilities:

- Fixed and variable rate bit traffic

- Bandwidth on demand

- Asymmetric data rates in the forward and reverse links

- Multimedia mail store and forward

- Broadband access up to 2 mbs

Spectrum Identified for IMT-2000

The ITU concluded that IMT-2000, or 3G, systems will require use of spectrum that

extends beyond that already encumbered by first and second generation mobile systems. A major

issue in the global debate regarding 3G system design, standards, and services that must be

resolved is the amount of common or “harmonized” spectrum that will be available on a global

and regional basis to support 3G systems. For ease in roaming, to help stimulate commonality in

services and economies of scale, proponents of 3G services believe it is important to identify as

much contiguous, harmonized spectrum to support worldwide 3G operations as is practical. This

will stimulate the development of global and regional coverage of 3G systems by reducing the

cost and complexity for system development, thus providing users with more cost-effective

services.

WARC-92. At the 1992 World Administrative Radio Conference (WARC-92), 230 MHz of

spectrum at 1885-2025 MHz and 2110-2200 MHz was identified for use by countries wishing to

implement 3G systems. Shortly after WARC-92, the FCC conducted auctions for licenses in the

paired 1850-1910/1930-1990 MHz band, which led to the rapid deployment of advanced mobile

wireless communications services throughout the United States. The success of the PCS rollout

has done much to increase competition in the provision of mobile telecommunications services in

the United States, and, at the same time has stimulated the demand for even more advanced

wireless services. Recently, countries around the world have started to license 3G systems within
13 Provisional Finals Acts of WRC 2000, 8 May-2 June 2000, Istanbul, Turkey, International Telecommunication

Union.

2-3

paired frequency bands identified at WARC-92: 1920-1980/2110-2170 MHz. The United

Kingdom (UK) and Germany have, for example, conducted auctions for IMT-2000 spectrum. 

The United States and the European experience indicates that the demand for advanced mobile

services is projected to continue to grow for some time to come.

WRC-2000. At the WRC-2000, additional spectrum to support IMT-2000 services was

identified.13 Three frequency bands, consistent with those proposed by the United States to the

conference, were identified for use by administrations wishing to implement IMT-2000 services

in addition to those adopted at WARC-92.

IMT-2000 System Characteristics. During preparations for WRC-2000, the United States

committed to studying the feasibility of using the 1755-1850 MHz and 2500-2690 MHz bands

(or parts thereof) for IMT-2000 operations. Such a study would involve determining the impact

of the operation of IMT-2000 systems on the systems already licensed to operate in these bands. 

The 1755-1850 MHz band is used in the United States to support critical Federal Government

services. The 1710-1755 MHz portion of the 1700/1800 MHz band identified at WRC-2000 is

currently in the process of becoming available for commercial use. The 1850-1885 MHz portion

of the same IMT-2000 band is already used to support PCS operations in the United States. The

2500-2690 MHz band is used to provide instructional television fixed services and multi-point

distribution services throughout the United States.

Because of the physical processes governing the propagation of radio waves in the

frequency range below 3 GHz, these frequencies can be efficiently transmitted and received by

small, compact, relatively lightweight user terminals. This feature, coupled with the ability to

support high-data rates, makes them ideally suited for uses requiring mobility and portability of

telecommunications services. Any 3G service that is targeted to mobile users is most effectively

provided by taking advantage of the properties of radio waves operating below 3 GHz. Those 3G

applications where the data rates are so high that fixed terminals are needed, or terminals that

require antennas so large that they can only be employed in a stationary configuration, are better

provided using frequencies above 3 GHz that can more effectively support higher data rate

systems. It is the problem of identifying the spectrum bands that can and cannot be used to

support 3G services that forms the crux of the effort to assess the degree to which IMT-2000

services can be included in bands already encumbered by services operating at 1755-1850 and

2500-2690 MHz.

In order to determine the impact of operating IMT-2000 systems in bands that are

encumbered, it is necessary to assess to what degree the proposed and incumbent systems can

co-exist in the same band. Stated in simple radio engineering terms, it is necessary to determine

whether or not harmful interference is generated into one of the systems (incumbent or proposed)

by the operation of the other(s). Furthermore, if it is determined that harmful interference is

likely to occur, it is desirable to isolate the conditions under which it occurs and whether or not

there exist means to mitigate its effects and costs associated with implementing such mitigation

techniques.
2-4

The interference assessment mentioned above requires values of the technical

characteristics for the systems being studied and the ability to quantify the systems’ performance. 

For the case of the incumbent systems in the bands 1755-1850 MHz and 2500-2690 MHz, it is

reasonable to assume that the pertinent parameters required for interference analysis studies are

readily available to the individuals tasked with performing the studies. This is not the case,

however, for all the parameters that are required to characterize IMT-2000 systems. These

systems, many of which are in the planning or development stage, do not have well-defined or

universally accepted values associated with every system parameter. Thus, we assume values for

certain IMT-2000 system parameters that are to be used in the conduct of the interference studies. 

When assumptions had to be made concerning values to be used in characterizing IMT-2000

systems, an attempt was made to adopt values that are consistent with values documented in

readily available material such as the reports and recommendations of the ITU-R, reports and

findings of industry-led working groups addressing IMT-2000 issues. In addition to values for

the technical parameters themselves, it is also necessary to assume certain characteristics of the

rollout of proposed IMT-2000 services, such as when they are likely to occur, whether there will

be a time-phasing of the rollout, what regions of the world are likely to support rollout earlier

than others, and within a region, whether there will be a geographical preference, i.e., urban

versus suburban versus rural, for the rollout. These assumptions also were based on as readily

available material and information as possible.

Tables 2-2 through 2-5 provide information on the various IMT-2000 system parameters

and rollout characteristics that are to be used in undertaking the studies being addressed here. 

These are the most recent industry-approved characteristics, but actual 3G systems may have

different parameters. If these parameters change, additional analyses will be required.

Table 2-2.

Characteristics of IMT-2000 Mobile Stations

Parameter CDMA-2000

1X

CDMA-2000

3X

UWC-136

(TDMA)†

EDGE

TD-CDMA

[21,22,23,24]

W-CDMA

[23]

Carrier Spacing 1.25 MHz 3.75 MHz 30 kHz [14] 200 kHz [7] 5 MHz

(nominal)

5 MHz +/-

n*0.2MHz [6]

Duplex Method FDD FDD FDD FDD TDD FDD

Transmitter

Power, (typical) 100 mW 100 mW 100 mW 100 mW 100 mW 100mW

Transmitter

Power,

(maximum)

250mW 250mW 1 W [15] 1 W [8] 250 mW 250 mW or

125mW [1]

Antenna Gain 0 dBi 0 dBi 0 dBi 0 dBi 0 dBi 0 dBi

Antenna Height 1.5 m 1.5 m 1.5 m 1.5 m 1.5 m 1.5 m

Access

Techniques CDMA CDMA TDMA [15] TDMAm TDMA/CDMA CDMAj
Table 2-2.

Characteristics of IMT-2000 Mobile Stations

Parameter CDMA-2000

1X

CDMA-2000

3X

UWC-136

(TDMA)†

EDGE

TD-CDMA

[21,22,23,24]

W-CDMA

[23]

2-5

Data Rates

Supported

153.6 kbps

(standard

supports up

to 625.35

kbps on

forward link

and up to

433.35 on

reverse

link)kbps

 460.8 kbps

(standard

supports up

to 2084.55.

kbps on

forward link

and up to

1354.95 on

reverse

link)kbps

13.0 kbps

(π/4 DQPSK)

19.95 kbps

(8-PSK

downlink)

18.6 kbps

(8-PSK

uplink)

144 kbps [9]

384 kbps

Pedestrian:

144 kbps

Vehicular: 384

kbps

Indoors: 2

Mbps

 Pedestrian:

144 kbps

Vehicular:

384 kbps

Indoors: 2

Mbps

Modulation Type QPSK/BPSK QPSK/BPSK π/4-DQPSK

8-PSK

GMSK

8-PSK QPSK HPSKo

Emission

Bandwidth

1250 < |f - fc|

< 1980 kHz,

-42 dBc in 30

kHz;

1980 < |f - fc|,

-50 dBc in 30

kHz;

2,5 MHz < |f -

fc| < 2.7 MHz,

-14 dBm in 30

kHz; 2,7 MHz

< |f - fc| <

3.5 MHz, 

-(14+15(f-fc-2

.7 MHz)) dBm

in 30 kHz; 

3.5 MHz < |f -

fc| < 7.5 MHz, 

-(13+(f-fc-3.5 

MHz)) dBm in

1 MHz; 

7.5 MHz <

|f - fc| <

8.5 MHz, 

-(13+10(f-fc-7

.5 MHz)) dBm

in 1 MHz;

8.5 MHz < |f -

fc| 

-27 dBm in

1 MHz

See [17] cf. Section 6.6

of [21] See [4]

-3 dB

0.12 MHz

[10],

0.12 MHz

[11]

-20 dB

0.18 MHz

[10],

0.18 MHz

[11]

-60 dB

0.40 MHz

[10],

0.60 MHz

[11]

Receiver Noise

Figure, (worst

case)

9 dB 9 dB 9 dB 9 dB 9 dB 9 dB
Table 2-2.

Characteristics of IMT-2000 Mobile Stations

Parameter CDMA-2000

1X

CDMA-2000

3X

UWC-136

(TDMA)†

EDGE

TD-CDMA

[21,22,23,24]

W-CDMA

[23]

2-6

Antenna

Temperature,

(kTb)g

-128 dBm b -121 dBm b

-108 dBm in

3.84 MHz -108 dBmi

Receiver Thermal

Noise Level

-125 dBma

-113 dBm 

-104 dBmb

-125 dBma

-108 dBm

-99 dBmb

-119 dBm -112 dBm -99

dBm/3.84 MHz

-99 dBm

Receiver

Bandwidth See [18] See [12] Unavailable, <5 MHz See [5]

Eb/No for Pe = 10-3

4 dB for 1%

FER for 9600

bps speech

services

1.9 dB for

1%FER in

AWGN

3.9 dB for 5%

FER in slow

fading

channel

(nominal

supported

rate)

performance

not available 7.8 dB 8.4 dB

3 dB (single

antenna,

equivalent rate

1⁄2 code)

3.1 dB*

Receiver

Sensitivityc

-104 dBm

Total

received

power in fully

loaded

system. 

Single 9600

bps traffic

channel is at -

119.6 dBm in

AWGN for 1%

FER

-99 dBm

Total

received

power in fully

loaded

system

Single 9600

bps traffic

channel is at -

119.6 dBm in

AWGN for 1%

FER

-113 dBm

[19] -102 dBm [9]

-105 dBm (cf.

Table 7.2,

[21])

-106 dBm

See [3] k 

Interference

Threshold 1d

-110 dBm in

1.25 MHz

-105 dBm in

3.75 MHz

No

equivalent See [13] -111 dBm in3.84 MHz -105dBmf

Interference

Threshold 2e

-94 dBm in

1.25 MHz

-90 dBm in

3.75 MHz

No

equivalent See [13] -92 dBm in3.84 MHz -89 dBmf

Notes: 

† UWC-136 consists of three components: enhancements to the 30 kHz channels (designated as

136+) for advanced voice and data capabilities, a 200 kHz carrier component for high speed data (384

kbps) accommodating high mobility (designated as 136HS Outdoor), and a 1.6 MHz carrier component

for very high speed data (2 mbps) in low mobility applications (designated as 136HS Indoor). The

combined result constitutes the IMT-2000 Radio Interface referred to as UWC-136.

a

 In bandwidth equal to data rate : for 1x and 3x CDMA2000, values are given for 9600 bps speech

services and nominal supported rate (153.6 kbps) for data services.

B

 In receiver bandwidth

c

 For a 10-3 raw bit error rate, theoretical Eb/No
2-7

d

 Desired signal at sensitivity, I/N = -6 dB for a 10 percent loss in range. This data was furnished by the

IAG, but data furnished by the FCC was used in the analysis.

e

 Desired signal 10 dB above sensitivity, S/(I+N) for a 10-3 BER. This data was furnished by the IAG, but

data furnished by the FCC was used in the analysis.

f

 Let N = receiver thermal noise = -99 dBm for WCDMA. Let S = receiver sensitivity = -106 dBm for

WCDMA. See also explanatory note f in Table 2. g 10Log(kTb) + 30 (dBm), where k = Boltzman’s constant = 1.38e-23, T = reference temperature =

average Earth temperature = 277 K, b = noise equivalent bandwidth (Hz).

h

 The above antenna temperature plus the worst-case receiver noise figure.

i

 b = chip rate = 3.84e6 chips/sec.

j

 Chip rate = 3.84e6 chips/sec.

k

 Reference sensitivity for bit error ratio (BER) not to exceed 10-3 for specified values of energy per chip

(Ec) = -117 dBm and received power spectral density (Ior) = -107 dBm measured at mobile station

antenna connector.

l

 A nominal operational frequency band of 1900 MHz is assumed.

m TDMA, comprising 8 time slots (577 us) per single TDMA frame (4.615 ms). For user packet data

service, 1-4 time slots per frame may be used by mobile stations having multi-slot classes that do not

require simultaneous transmission and reception, i.e., classes for which a duplexer is not required.

n

 Data rate on a per-time slots basis.

o

 Hybrid Phase Shift Keying: a method peculiar to UMTS WCDMA in which the peak to average ratio is

reduced in comparison to a QPSK signal by mixing the orthogonal variable spreading factor (OSVF) with

both information sources as real signals, i.e., those destined for I and Q modulation components, and

then shifting one component by 90 degrees to produce an equivalent imaginary signal and then utilizing

gain control on the Q channel to preserve orthogonality.

* Assumes Eb/No for Pe = 10-6 without diversity.

Table 2-3.

Characteristics of IMT-2000 Base Stations

Parameter CDMA-2000

1X

CDMA-2000

3X

UWC-136

(TDMA)

EDGE

TD-CDMA

[21,22,23,24]

W-CDMA

[23]

Operating 

Bandwidth 1.25 MHz 3.75 MHz 30 kHz 200 kHz 5 MHz (nominal)

5 MHz

+/- n*0.2MHz

Duplex Method FDD FDD FDD FDD TDD FDD

Transmitter Power 10 W 10 W 10 W 10 W 10 W 10 W

Antenna Gain 17 dBi per 120

deg. sector

17 dBi per 120

deg. sector

17 dBi per

120 deg.

sector

17 dBi per

120 deg.

sector

17 dBi per

120 deg.

sector

17 dBi per

120 deg.

sector

Antenna Height 40 m 40 m 40 m 40 m 40 m 40 m

Tilt of Antenna 2.5 degs down 2.5 degs down 2.5 degs

down

2.5 degs

down

2.5 degs

down

2.5 degs

down

Access Techniques CDMA CDMA TDMA TDMA TDMA/CDMA CDMA

Data Rates

Supported

153.6 kbps

(standard

supports up to

625.35 kbps on

forward link and

up to 433.35 on

reverse link)

460.8 kbps

(standard

supports up to

2084.55. kbps

on forward link

and up to

1354.95 on

reverse link)

30 kbps

44 kbps 384 kbps

Pedestrian:

144 kbps

Vehicular:

384 kbps

Indoors: 2

Mbps

 Pedestrian:

144 kbps

Vehicular:

384 kbps

Indoors: 2

Mbps

Modulation Type QPSK/BPSK QPSK/BPSK π/4-DQPSK

8-PSK

GMSK

8-PSK QPSK QPSK
Table 2-3.

Characteristics of IMT-2000 Base Stations

Parameter CDMA-2000

1X

CDMA-2000

3X

UWC-136

(TDMA)

EDGE

TD-CDMA

[21,22,23,24]

W-CDMA

[23]

2-8

Emission Bandwidth

885 < |f - fc| <

1250 kHz, -45

dBc in 30 kHz;

1250 < |f - fc| <

1980 kHz, min

(-45 dBc in 30

kHz, -9dBm in

30 kHz);

1980 < |f - fc| <

2250 kHz, -55

dBc in 30 kHz;

2250 < |f - fc,

-13 dBm in

1 MHz

cf. Section

6.6.2 of [22]

-3 dB 0.03 MHz 0.18 MHz 3 GPP

-20 dB 0.03 MHz 0.22 MHz TS25.104

-60 dB 0.04 MHz 0.24 MHz

Receiver Noise

Figure, (worst case) 5 dB 5 dB 5 dB 5 dB 5 dB 5 dB

Receiver Thermal

Noise Level

-129 dBm

-117dBma

-108 dBmb

-129 dBm

-112 dBma

-103 dBmb

-125 dBma -117 dBma -113 dBm at

384 kbps

-113 dBm in

384 kbps

Receiver Bandwidth Unavailable,

< 5 MHz 

-3 dB 0.03 MHz 0.18 MHz Reference 

-20 dB 0.04 MHz 0.25 MHz Reference 

-60 dB 0.09 MHz 0.58 MHz Reference 

Eb/No for Pe = 10-3

6.0 dB for 0.3%

FER for 9600

bps speech

services in

AWGN.

4.9 dB for 2.4%

FER in AWGN,

4.3 dB for 2.5%

FER in slow

fading for

nominal

supported rate 

performance

not available 7.8 dB 8.4 dB

3 dB (single

antenna,

equivalent 1⁄2

rate code)

3.4 dB*

Receiver Sensitivityc

-119 dBm for

Fundamental

channel in

AWGN

-119 dBm for

Fundamental

channel in

AWGN

-117 dBm -108.Bm

-109 dBm (cf.

Table 7.1 of

[22])

-110 dBm

Interference

Threshold 1d

-114 dBm in

1.25 MHz

-109 dBm in

3.75 MHz -131 dBm -123 dBm -115 dBm in3.84 MHz See note f

Interference

Threshold 2e

-98 dBm in

1.25 MHz

-93 dBm in

1.25 MHz -115 dBm -107dBm -96 dBm in3.84 MHz See note f

Notes:

a

in bandwidth equal to data rate : for 1x and 3x CDMA2000, values are given for 9600 bps speech

services and nominal supported rate for data services.
2-9

b

 In receiver bandwidth

c

For a 10-3 raw bit error rate, theoretical Eb/No d

Desired signal at sensitivity, I/N = -6 dB for a 10 percent loss in range. This data was furnished by the

IAG, but data furnished by the FCC was used in the analysis.

e

Desired signal 10 dB above sensitivity, S/(I+N) for a 10-3 BER. This data was furnished by the IAG, but

data furnished by the FCC was used in the analysis.

f

 The thermal noise figure for a W-CDMA receiver is -108 dBm based on kTf where k is Boltzmann’s

constant (1.38E-23), T is the temperature in Kelvin and f is the bandwidth in Hertz. For a noise figure of

4dB (typical value for a base station receiver), the thermal noise becomes -104dBm. However receiver

sensitivity depends on the service (voice, packet etc.). For example, the voice (DTCH 32) sensitivity for

the base station receiver is -121 dBm for BER < 0.001.

* Assumes Eb/No for Pe = 10-6 without diversity.

Table 2-4.

 IMT-2000 Traffic Model Characteristicsa

Parameter Value

Traffic Environments

Rural

Vehicular

Pedestrian

In-building (Central business district)

Maximum Data Rates

Rural - 9.6 kbps

Vehicular - 144 kbps

Pedestrian - 384 kbps

In-building - 2 Mbps

Cell Size

Rural - 10 km radius

Vehicular - 1000 m radius

Pedestrian - 315 m radius

In-building - 40 m radius

Users per cell during busy hour

Rural - not significant

Vehicular - 4700

Pedestrian - 42300

In-building - 1275

Percent of total uplink traffic >64 kbps during busy hour

Rural - not significant

Vehicular - 34%

Pedestrian - 30%

In-building - 28%

Percent of total downlink traffic >64 kbps during busy hour

Rural - not significant

Vehicular - 78%

Pedestrian - 74%

In-building - 73%

Average number of users per cell per MHz during busy hour

assuming frequency duplex operation

Rural - not significant

Vehicular 

< 64 kbps - 16

> 64 kbps - 4

Pedestrian

< 64 kbps - 150

> 64 kbps - 64

In-building

< 64 kbps - 4

> 64 kbps - 2

Note: a Values in the table are for a mature network.
2-10

Table 2-5.

Rate of IMT-2000 Network Developmenta

Local Environment

Calendar Year

2003 2006 2010

Urban 10% 50% 90%

Suburban 5% 30% 60%

Rural 0% 5% 10%

Note: a

 For some interactions the potential for interference will be influenced by the degree to which

IMT-2000 networks are built out. Table 2-4 identifies assumptions that will be used in the assessments with

respect to the degree to which US IMT-2000 networks are developed following the granting of licenses. 

The levels of aggregate emissions for a fully mature IMT-2000 environment will be taken from ITU-R 687.2

or other reference material as appropriate.

References:

[1] “3rd Generation Partnership Project; Technical Specification Group Radio Access Networks; UE Radio

Transmission and Reception”, (3G Technical Specification 25.101), clause 6.2.1. User equipment (UE) power

specified for power class II and III.

[2] “3rd Generation Partnership Project; Technical Specification Group Radio Access Networks; UE Radio

Transmission and Reception”, (3G Technical Specification 25.101), clause 8.3.1.

[3] “3rd Generation Partnership Project; Technical Specification Group Radio Access Networks; UE Radio

Transmission and Reception”, (3G Technical Specification 25.101), clause 7.3.1.

[4] “3rd Generation Partnership Project; Technical Specification Group Radio Access Networks; UE Radio

Transmission and Reception”, (3G Technical Specification 25.101), clause 6.6.2.1.1:

[5] “3rd Generation Partnership Project; Technical Specification Group Radio Access Networks; UE Radio

Transmission and Reception”, (3G Technical Specification 25.101), clause 7.6.1:

The BER shall not exceed 0.001 for the parameters specified in Table 7.6 and Table 7.7. For Table 7.7 up to (24)

exceptions are allowed for spurious response frequencies in each assigned frequency channel when measured

using a 1 MHz step size.

[6] “3rd Generation Partnership Project; Technical Specification Group Radio Access Networks; UE Radio

Transmission and Reception”, (3G Technical Specification 25.101), clause 5.4.1.

[7] “RF Minimum performance requirements 136HS Outdoor and 136HS Indoor Bearers”, (TR45 technical

specification, TIA/EIA-136-290), clause 2.

[8] “RF Minimum performance requirements 136HS Outdoor and 136HS Indoor Bearers”, (TR45 technical

specification, TIA/EIA-136-290), clause 4.1.1.2. Refers to Power Class II mobile station.

[9] “RF Minimum performance requirements 136HS Outdoor and 136HS Indoor Bearers”, (TR45 technical

specification, TIA/EIA-136-290), clause 6.2. Specifies data rates and reference sensitivity. Reference sensitivity

listed for 144 kb/s at a 10% block erasure rate (BLER).

[10] “RF Minimum performance requirements 136HS Outdoor and 136HS Indoor Bearers”, (TR45 technical

specification, TIA/EIA-136-290), Table A3a: Modulation and noise spectrum mask due to GMSK modulation. 

Measurement bandwidth is 30 KHz.

[11] “RF Minimum performance requirements 136HS Outdoor and 136HS Indoor Bearers”, (TR45 technical

specification, TIA/EIA-136-290), Table A3b: Modulation and noise spectrum mask due to 8-PSK modulation. 

Measurement bandwidth is 30 KHz.

[12] “RF Minimum performance requirements 136HS Outdoor and 136HS Indoor Bearers”, (TR45 technical

specification, TIA/EIA-136-290), clause 5.1:
2-11

[13] “RF Minimum performance requirements 136HS Outdoor and 136HS Indoor Bearers”, (TR45 technical

specification, TIA/EIA-136-290), clause 6.3:

[14] “Mobile Station Minimum Performance”, (Technical Specification TR45, SP-4027-270b), clause 2.3.1.3.1.

[15] “Mobile Station Minimum Performance”, (Technical Specification TR45, SP-4027-270b), clause 1.4 and clause

3.2.2. Refers to Power Class II mobile station.

[16] “Digital Traffic Channel Layer 1”, (Technical Specification, TR45, TIA/EIA 136-131), clause 1.3.

[17] “Mobile Station Minimum Performance”, (Technical Specification TR45, SP-4027-270b), clause 3.4.1.1.3.

[18] “Mobile Station Minimum Performance”, (Technical Specification TR45, SP-4027-270b), clause 2.3.2.4.3:

[19] “Mobile Station Minimum Performance”, (Technical Specification TR45, SP-4027-270b), clause 2.3.1.1.3.

[20] Body Loss Expectation is that values are similar for all technologies. Footnote retained for information

purposes“3rd Generation Partnership Project; Technical Specification Group Radio Access Networks; RF System

Scenarios”, (3G Technical Specification 25.942), clause 4.1.1.2.

[21] “3rd Generation Partnership Project; Technical Specification Group Radio Access Networks; UTRA (UE) TDD;

Radio Transmission and Reception (Release 1999)”, (Technical Specification 3GPP TS 25.102 v3.4.0 (2000-10)

[22] “3rd Generation Partnership Project; Technical Specification Group Radio Access Networks; UTRA (BS) TDD;

Radio Transmission and Reception (Release 1999)”, (Technical Specification 3GPP TS 25.105 v3.4.0 (2000-10)

[23] The “TD-CDMA” and “W-CDMA” air interfaces referred to in this document are standards developed by the 3G

Partnership Project (3GPP). 3GPP’s official designations for these air interfaces are UTRA-TDD and UTRA-FDD,

respectively.

[24] TD-CDMA differs from the other air interfaces in the table in that it uses time division duplexing 3⁄4 uplink and

downlink transmissions occur in the same spectrum, alternating in time 3⁄4 rather than frequency division duplexing in

which uplink and downlink transmissions occur in distinct frequency blocks. In other respects, such as in-band and

out-of-band emissions levels, modulation formats, etc., it is substantially similar to the other air interfaces and

essentially identical to W-CDMA. TD-CDMA’s coexistence behavior with a given incumbent government system (or

class of systems) can therefore be assessed through the uplink and downlink coexistence behavior of W-CDMA with

those system(s). It can be well approximated for coexistence calculations by treating it as a system which has the

combined (worst case from a coexistence perspective) uplink and downlink coexistence behavior of W-CDMA in a

single spectrum block (i.e., by combining the uplink coexistence behavior of W-CDMA in frequency block “A” with an

incumbent system in block “B”, and the downlink coexistence behavior of W-CDMA in frequency block “A” with an

incumbent system in block “B”). At such time as the FCC may choose to make some or all of the spectrum under

consideration available for commercial use, additional analyses will be required to develop a sound band plan

incorporating allocations for both FDD and TDD systems. These analyses are already underway in various

segments of the industry including 3GPP.
This page is left intentionally blank.
3-1

Figure 1. Pictorial Representation of Major Systems in the 1710-1850 MHz Frequency Band.

III. Federal Use of the 1710-1850 MHz Band

Overview

The entire 1710-1850 MHz frequency range is heavily used by the Federal Government. 

In the 1755-1850 MHz portion alone 4,782 Federal Government assignments are registered in

the Government Master File (GMF), as of January 2001. Internationally, the 1755-1850 MHz

band falls in the 1710-1930 MHz band allocated on a primary basis to the fixed and mobile

services for all three ITU Regions. Nationally, the 1710-1850 MHz band is allocated on a

exclusive basis to the Federal Government for fixed and mobile services. Footnote G42 to the

National Table of Frequency Allocations provides for the co-equal accommodation of Federal

space command, control, and range and range-rate systems for earth station transmission in the

1761-1842 MHz band. The band supports many Federal functions: (1) tracking, telemetry, and

commanding (TT&C) for Federal Government space systems; (2) medium-capacity,

conventional fixed microwave communications systems; (3) military tactical radio relay (TRR)

systems; (4) air combat training systems (ACTS); (5) precision guided munitions (PGM);

(6) high resolution video data links, and various other aeronautical mobile applications; and

(7) land mobile video functions such as explosive ordnance disposal and other robotics,

surveillance, etc. The radio systems supporting these functions are located across the United

States. Figure 1 is a pictorial representation of the functions of major Federal systems supported

in the 1710-1850 MHz band.
14 “Mixed Use” is a term defined in the Omnibus Budget Reconciliation Act of 1993, Pub. L. 103-66, 107

Stat. 312, for frequency bands reallocated from Federal to private use in accordance with this Act, which are

partially retained for continued use by Federal stations.

15 See Balanced Budget Act of 1997 (BBA-97), Pub. L. No. 105-33, 111 Stat. 251 (1997).

16 See National Defense Authorization Act for 2000, Pub. L. No. 106-65, 113 Stat. 512 (1999).

17 See Mandatory Reimbursement Rules for Frequency Band or Geographic Relocation of Federal

Spectrum-Dependent Systems, NPRM, 66 Fed. Reg. 4771 (Jan. 18, 2001) [hereinafter NTIA NPRM].

3-2

The 1710-1755 MHz portion of the band was identified to be transferred to the FCC

under the Omnibus Budget Reconciliation Act of 1993 (OBRA-93) as a mixed-use band.14

Certain military facilities, safety-of-life, and power transmission fixed links were exempted from

the reallocation. Protection Areas were established around certain military facilities as shown in

the NTIA Final Reallocation Report. The Balanced Budget Act of 1997 (BBA-97)15 required

NTIA to accelerate the availability of the 1710-1755 MHz band for commercial use, and required

the FCC to grant licenses by competitive bidding after January 1, 2001. The National Defense

Authorization Act (NDAA) for Fiscal Year 199916 required reimbursement for Federal systems

relocated from the 1710-1755 MHz band and other bands transferred to the FCC. NTIA has

issued an NPRM to compile and review comments prior to making rules for the reimbursement

process.17

Satellite control is one of the major services, and is carried out in the 1761-1842 MHz

portion of the band. The Air Force is responsible for controlling DOD, allied, and certain other

Federal satellites. These satellites are used for many purposes, including navigation, missile

warning, surveillance, weather, communications, and civil functions, all of which contribute

significantly to the defense and well being of the American civilian population. Although the

Air Force owns and operates the Air Force Satellite Control Network (AFSCN), it is a national

asset that serves many organizations in addition to the military. The satellite control stations

transmit to the satellites in the 1761-1842 MHz band from several stations in the United States,

and stations in host nations.

Fixed microwave networks in the 1755-1850 MHz band support backbone

communications systems for many of the Federal agencies. Fixed links are operated by Federal

agencies for voice, data, and/or video communications where commercial service is unavailable,

excessively expensive, or unable to meet required reliability. Applications include law

enforcement; emergency preparedness; support for the national air space system; military

command and control networks; and control links for various power, land, water, and

electric-power management systems. Other fixed links include data relay, timing distribution

signals, video relay, video surveillance systems, and robot video systems for hazardous material

response in support of explosive and forensic investigations.

As an example of DOD fixed systems, the U.S. Army Corps of Engineers (ACE) uses

this band extensively for its fixed microwave radio systems serving backbone communications

for the engineering districts in the continental United States. The Corps also uses this frequency

band for various purposes such as operating remotely-controlled hydro-electric generating

stations; providing communications support for emergency civilian relief, flood control and
3-3

sensor telemetry; temporary communications in each district; and maintenance and traffic control

of approximately 48,000 kilometers of inland waterways, including harbors, locks, and dams.

Federal civil agencies also have extensive fixed service links in the band to support the

various missions of the government. For example, the U.S. Department of Agriculture (USDA)

owns and maintains microwave systems operating in the 1755-1850 MHz band throughout the

United States. These microwave systems are used primarily in the Forest Service as backbone

links to interconnect land mobile radio system mountaintop repeaters and remotely-controlled

base stations. The land mobile systems are installed to 1) support the health and safety of

employees and the public on and around public lands, 2) provide communications in the fighting

of wildfires and responses to other natural disasters, and 3) aid in the protection of property. All

of the installations are standard commercial off-the-shelf (COTS) analog microwave

transmitters, receivers, and associated equipment.

Transportable radio relay systems are used by the military for nodal communications

stations that support tactical communications for a wide area. These systems operate in the fixed

service. The most common system is called the Mobile Subscriber Equipment (MSE). This

system is used extensively in the United States by warfighters to establish tactical

communications supporting command and control for wide-area networks. Several thousand

TRR systems are in the military inventory and used at many military establishments throughout

the country. The propagation characteristics of the band permit excellent tactical nodal

connectivity. Radio relay systems link various subordinate, lateral and strategic headquarters,

functional and component nodes, into an integrated area-wide network. Congestion and use of

the band are heavy in proximity to military bases and training areas. Naval task forces (Navy

and Marine Corps) use a variant of this system known as the Digital Wideband Transmission

System (DWTS), which are ship- and vehicular-mounted, point-to-point systems used for

ship-to-shore and ship-to-ship communications. There are approximately 600 of these systems

currently deployed.

One of the most difficult training missions is the training of air combat crews. Current

air combat training involves actual air-to-air encounters, with a network of ground stations

monitoring the training activity. Information regarding the aircraft’s flight parameters are

relayed to ground stations, and other information is sent to the aircraft from the ground stations. 

Several systems are in use by the military services, and are variations of the ACTS. These

systems currently operate in the 1755-1850 MHz band, and new systems will be coming online

soon.

The National Science Foundation (NSF) and the National Aeronautics and Space

Administration (NASA) conduct radio astronomy observations in the 1718.8-1722.2 MHz band

under authority of Footnote US256 to the National Table of Frequency Allocations. Continued

use of this band is very important to the scientific community.

Additionally, the Federal law enforcement agencies use this band to employ undercover

low-power video surveillance devices during criminal investigations. These devices may be

authorized throughout the United States and Possessions (US&P) for both protective operations

and criminal investigations. The video footage obtained during these investigations is critical for
18 The number of assignments in the 1710-1755 MHz band has been decreasing because of the migration of

Federal agencies from the band as a result of OBRA-93.

3-4

providing rapid response support to undercover officers and agents, and is used as evidence

during criminal trials and procedures.

In this report, the 1710-1850 MHz band will be considered in two parts: the 1710-

1755 MHz portion, and the 1755-1850 MHz portion. There are 1,825 frequency assignments for

Federal stations in the 1710-1755 MHz band listed in the GMF as of January 2001. The GMF is

the Federal Government’s master list of frequency assignments authorized by NTIA, but does

not necessarily represent the number of equipments associated with each assignment. In

addition, the GMF does not contain all of the classified Federal frequency assignments. Also,

there may be many pieces of radio equipment operating under a single frequency assignment. 

Table 3-1 shows the GMF summary count of assignments by station class per agency and radio

service in the subject band as of January 2001 A plot of the location of these assignments is

shown in Figure 2. Appendix C contains a table of 1710-1755 MHz assignments categorized by

state/location, agency, and station class.

Table 3-1

Number of Frequency Assignments In the 1710-1755 MHz Band18

Agency Total

Number

Fixed

Service

Mobile

Service

Aeronautical 

Mobile Service

Land Mobile

Service

No Specific

Service

Army 541 513 11 1 2 14

USDA 430 430 0 0 0 0

DOE 244 239 1 2 2 0

Navy 156 65 40 25 25 1

DOJ 113 113 0 0 0 0

FAA 89 89 0 0 0 0

Air Force 64 40 5 7 1 11

DOI 64 64 0 0 0 0

TVA 34 34 0 0 0 0

USCG 33 33 0 0 0 0

Treasury 20 18 1 1 0 0

Other

Agencies 37 32 5 0 0 0

Totals 1,825 1,670 63 36 30 26
3-5

1710-1755 MHz

Figure 2. Plot of Frequency Assignments in the 1710-1755 MHz Band.

Note: The symbols may indicate multiple assignments at a geographic location, assignments may cover multiple

emitters, and assignments authorized on a US&P basis are not reflected.

There are 4,782 frequency assignments for Federal stations in the 1755-1850 MHz band

listed in the GMF as of January 2001. Some assignments listed may be for nationwide use. The

majority of these assignments are in the fixed service (80 percent), followed by mobile, space,

land mobile, and aeronautical-mobile services. The five categories of radio services (plus

experimental stations) support the four main functions that are carried out in this band. 

Presently, 25 Federal entities are authorized to operate in the 1755-1850 MHz band. The major

users are: Army, Air Force, Navy, USDA, the Department of Energy (DOE), the Department of

Justice (DOJ), the Federal Aviation Administration (FAA), and the Department of the Interior

(DOI). Table 3-2 shows the GMF summary count of assignments by station classes per agency

and radio service in 1755-1850 MHz band as of January 2001 A plot of the location of these

assignments is shown in Figure 3. Appendix C contains a Table of 1755-1850 MHz assignments

categorized by state/location, agency, and station class. Tables 3-3, 3-4, 3-5, and 3-6 (with

accompanying figures) provide a summary count of assignments by station class for the 1755-

1780 MHz, 1780-1790 MHz, 1790-1805 MHz, and 1805-1850 MHz sub-bands, respectively. 

These sub-bands other than the 1790-1805 MHz segment have been identified for various

segmentation options described in Section IV.
3-6

1755-1850 MHz

Figure 3. Plot of Frequency Assignments in the 1755-1850 MHz Band.

Note: The symbols may indicate multiple assignments at a geographic location, assignments may cover multiple

emitters, and assignments authorized on a US&P basis are not reflected.

Table 3-2

Number of Frequency Assignments in the 1755-1850 MHz Band

Agency Total

Number

Fixed

Service

Mobile

Service

Aeronautical

Mobile

Service

Land

Mobile

Service

Maritime

Mobile

Service

Radiolocation

Service

Space

Services

No

Specific

Service

Agriculture 671 671 0 0 0 0 0 0 0

Air Force 893 378 170 16 23 0 0 224 82

Army 1177 1124 17 3 8 0 5 0 20

USCG 71 71 0 0 0 0 0 0 0

Energy 503 480 0 2 19 0 0 1 1

FAA 212 212 0 0 0 0 0 0 0

Interior 133 133 0 0 0 0 0 0 0

Justice 241 235 0 0 6 0 0 0 0

Navy 714 353 274 17 23 7 0 40 0

NASA 20 3 8 7 1 0 0 1 0

TVA 64 64 0 0 0 0 0 0 0

Treasury 34 31 0 3 0 0 0 0 0

Other

Agencies 49 45 0 0 3 0 0 1 0

Totals 4782 3800 469 48 83 7 5 267 103
3-7

1755-1780 MHz

Figure 4. Plot of Frequency Assignments in the 1755-1780 MHz Sub-Band.

Note: The symbols may indicate multiple assignments at a geographic location, assignments may cover multiple

emitters, and assignments authorized on a US&P basis are not reflected.

Table 3-3

Number of Frequency Assignments in the 1755-1780 MHz Sub-Band

Agency Total

Number

Fixed

Service

Mobile

Service

Aeronautical

Mobile

Service

Land

Mobile

Service

Maritime

Mobile

Service

Radiolocation

Service

Space

Services

No

Specific

Service

Agriculture 166 166 0 0 0 0 0 0 0

Air Force 180 76 23 3 2 0 0 56 20

Army 378 355 6 2 4 0 5 0 6

USCG 27 27 0 0 0 0 0 0 0

Energy 135 126 0 1 6 0 0 1 1

FAA 60 60 0 0 0 0 0 0 0

Interior 40 40 0 0 0 0 0 0 0

Justice 51 50 0 0 1 0 0 0 0

Navy 138 68 45 8 4 3 0 10 0

NASA 5 1 3 0 0 0 0 1 0

TVA 15 15 0 0 0 0 0 0 0

Treasury 10 9 0 1 0 0 0 0 0

Other

Agencies 14 14 0 0 0 0 0 0 0

Total 1219 1007 77 15 17 3 5 68 27
3-8

1780-1790 MHz

Figure 5. Plot of Frequency Assignments in the 1780-1790 MHz Sub-Band.

Note: The symbols may indicate multiple assignments at a geographic location, assignments may cover multiple

emitters, and assignments authorized on a US&P basis are not reflected.

Table 3-4

Number of Frequency Assignments in the 1780-1790 MHz Sub-Band

Agency Total

Number

Fixed

Service

Mobile

Service

Aeronautical

Mobile

Service

Land

Mobile

Service

Maritime

Mobile

Service

Radiolocation

Service

Space

Services

No

Specific

Service

Agriculture 49 49 0 0 0 0 0 0 0

Air Force 60 13 13 0 0 0 0 25 9

Army 151 151 0 0 0 0 0 0 0

USCG 2 2 0 0 0 0 0 0 0

Energy 31 27 0 0 4 0 0 0 0

FAA 19 19 0 0 0 0 0 0 0

Interior 11 11 0 0 0 0 0 0 0

Justice 16 16 0 0 0 0 0 0 0

Navy 51 24 23 0 0 0 0 4 0

NASA 3 2 0 1 0 0 0 0 0

TVA 3 3 0 0 0 0 0 0 0

Treasury 3 2 0 1 0 0 0 0 0

Other

Agencies 440 0 0 0 0 0 0

Total 403 323 36 2 4 0 0 29 9
3-9

1790-1805 MHz

Figure 6. Plot of Frequency Assignments in the 1790-1805 MHz Band.

Note: The symbols may indicate multiple assignments at a geographic location, assignments may cover multiple

emitters, and assignments authorized on a US&P basis are not reflected.

Table 3-5

Number of Frequency Assignments in the 1790-1805 MHz Band

Agency Total

Number

Fixed

Service

Mobile

service

Aeronautical

Mobile

Service

Land

Mobile

Service

Maritime

Mobile

Service

Radiolocation

Service

Space

Services

No

Specific

Service

Agriculture 100 100 0 0 0 0 0 0 0

Air Force 138 68 5 1 2 0 0 45 17

Army 183 173 2 0 1 0 0 0 7

USCG 11 11 0 0 0 0 0 0 0

Energy 91 89 0 0 2 0 0 0 0

FAA 23 23 0 0 0 0 0 0 0

Interior 13 13 0 0 0 0 0 0 0

Justice 44 44 0 0 0 0 0 0 0

Navy 70 48 10 0 3 1 0 8 0

NASA 6 0 2 4 0 0 0 0 0

TVA 18 18 0 0 0 0 0 0 0

Treasury 7 7 0 0 0 0 0 0 0

Other

Agencies 15 12 0 0 2 0 0 1 0

Total 719 606 19 5 10 1 0 54 24
3-10

1805-1850 MHz

Figure 7. Plot of Frequency Assignments in the 1805-1850 MHz Sub-Band.

Note: The symbols may indicate multiple assignments at a geographic location, assignments may cover multiple

emitters, and assignments authorized on a US&P basis are not reflected.

Table 3-6

Number of Frequency Assignments in the 1805-1850 MHz Sub-Band

Agency Total

Number

Fixed

Service

Mobile

Service

Aeronautical

Mobile

Service

Land

Mobile

Service

Maritime

Mobile

Service

Radiolocation

Service

Space

Services

No

Specific

Service

Agriculture 356 356 0 0 0 0 0 0 0

Air Force 515 221 129 12 19 0 0 98 36

Army 465 445 9 1 3 0 0 0 7

USCG 31 31 0 0 0 0 0 0 0

Energy 246 238 0 1 7 0 0 0 0

FAA 110 110 0 0 0 0 0 0 0

Interior 69 69 0 0 0 0 0 0 0

Justice 130 125 0 0 5 0 0 0 0

Navy 455 213 196 9 16 3 0 18 0

NASA 6 0 3 2 1 0 0 0 0

TVA 28 28 0 0 0 0 0 0 0

Treasury 14 13 0 1 0 0 0 0 0

Other

Agencies 16 15 0 0 1 0 0 0 0

Total 2441 1864 337 26 52 3 0 116 43
19 U.S. Department of the Army, Army Training and Doctrine Command, Army Space Reference Text, Chapter 7,

Space Systems, at Section 7-1: Control Segments (Telemetry, Tracking and Commanding), (visited Sept. 13, 2000),

htt;://<www.tradoc.army.mil/dcscd/spaceweb/chap07a.htm>.

3-11

Satellite Control Systems

Introduction. Satellites orbit the Earth in either geostationary satellite orbits (GSO) or

non-geostationary satellite orbits (NGSO). Satellites operated by the DOD include both GSO

and NGSO, and are used for such functions as communications, navigation, surveillance, missile

early warning and attack characterization, weather monitoring, and research and development. 

The critical nature of the Satellite Control Network (SCN) functions is such that DOD satellites

can neither be launched nor operated without the SCN. These satellites must be supported by the

SCN to achieve proper orbit, be initialized for operations, maintain orbit and configuration,

perform emergency recovery operations following on-orbit failures, and be used for disposal

operations at end-of-life. Satellites are controlled to maintain proper orbit, and must be

commanded to perform certain functions. This is the control function. The satellite controller

must know the location of the satellite to determine its present orbit. This is called a tracking

function. The operators also need to know the “health” of the satellites, so a telemetry link sends

back to the ground station information relating to the status of all platform functions such as

electrical, stabilization, temperature, and propulsion systems onboard the satellite. This is the

telemetry function. The combination of these functions for satellite control is termed TT&C. 

The uplink TT&C function is performed in the 1761-1842 MHz band for military satellites. The

associated downlink for these satellites is in the 2200-2290 MHz band.

Tracking, Telemetry, and Commanding. The 1761-1842 MHz band segment supports

the TT&C for the DOD satellites, in addition to the North Atlantic Treaty Organization (NATO),

UK 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 TT&C subsystem monitors and controls all of the other systems on the spacecraft,

transmits the status of those systems to the control segment on the ground, and receives and

processes instructions from the control segment. Telemetry is the data collected by sensors

throughout the satellite that determine the status of various system components, including

transmitters and antennas. This information is then transmitted to the ground segment.19 The

SCN is critical to launch and early orbit functions and emergency recovery for most U.S.

government satellites.

Telemetry also includes data on the operation and status of the satellite’s payload. For

example, on a communications satellite, telemetry would include data on power output of

transponders, pointing direction of antennas, and antenna and transponder switch configurations. 

Tracking involves determining a satellite’s position, altitude and other orbital parameters. Many

satellites carry a beacon that transmits a signal to help ground tracking receivers locate the

satellite. Onboard sensors, such as star trackers, horizon scanners, and inertial navigation

sensors provide other tracking data. Tracking information is essential to determine a satellite's

orbital parameters so that accurate predictions can be made of where the satellite will be in the
20 See National Telecommunications and Information Administration, U.S. Department of Commerce, NTIA

Special Publication 95-32, Spectrum Reallocation Final Report (1995), at 4-13 [hereinafter NTIA Final

Reallocation Report].

3-12

future. In this way, the satellite's orbital position can be adjusted so that it will be in its proper

position at the proper time.

Commanding is the act of controlling a satellite. Commanding a satellite is

accomplished by sending signals to it that initiate an action or change the configuration in some

way. Commands may be executed by the satellite immediately upon receipt, or stored for later

execution. Some commands are part of onboard software that allows the satellite to execute

certain functions autonomously when a predefined condition exists. Commands may direct the

thrusters to fire to change the orbit, or may reconfigure the payload to meet the needs of users.

The major system operating in this band segment that supports the TT&C functions is the

Space Ground Link Subsystem (SGLS). The band plan for SGLS comprises 20 discrete channels

within the 1761-1842 MHz band segment beginning at 1763.721 MHz and ending with

1839.795 MHz. Each channel is 4.004 MHz wide. 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. It is not possible to change the TT&C frequencies for satellites that

have already been launched. While it may be possible to change the frequencies of satellites that

are yet to be launched, this would be expensive, time consuming, and could impact scheduled

launch dates of critical national space assets, thus affecting the government’s ability to meet

satellite replacement requirements.

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.20 The

civilian and commercial communities also derive significant benefit from the Global Positioning

System (GPS), which is controlled and supported through the use of the 1761-1842 MHz band.

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 1761-1842 MHz

band would have implications for U.S. allies as well, since both NATO and the UK depend on

satellite control stations operating in the 1761-1842 MHz band to provide military spacecraft

TT&C support for the NATO SATCOM IV and the UK SKYNET satellites, respectively.

Air Force Satellite Control Network. The Air Force is the designated service

responsible for platform control of most DOD satellites. The organizations and facilities

involved are organized into the AFSCN. The principal organization in the AFSCN is the 50th
3-13

Space Wing of the Air Force Space Command, with headquarters at Schriever Air Force Base

(AFB), Colorado.

The AFSCN provides support for the operation, control and maintenance of a variety of

DOD and some non-DOD satellites. This involves continual execution of the tasks involved in

TT&C. In addition, the AFSCN provides pre-launch simulation, launch support, and early orbit

support while satellites are in initial or transfer orbits and require maneuvering to their final

orbit. The AFSCN provides tracking data to help maintain the catalog of space objects and

distributes various data such as satellite ephemeris, almanacs, and other information.

The AFSCN consists of satellite control centers, tracking stations, and test facilities

located around the world. Satellite Operations Centers are located at Schriever AFB near

Colorado Springs, Colorado, and Onizuka AFB, Sunnyvale, California. These centers are

staffed around the clock and are responsible for the command and control of their assigned

satellite systems. The control centers are linked to remote tracking stations (RTSs) around the

world. The RTSs provide the link between the satellite being controlled and the control center. 

A similar relationship exists for dedicated networks. RTSs around the world are needed to

maintain frequent communications with the satellite. Without RTSs, the control centers would

only be able to contact a satellite when it came into the control center's view. Some satellites,

especially those in geostationary orbit, never come within view of their control center (most

control centers do not have antenna capabilities to communicate directly with satellites in this

band). Space vehicle checkout facilities are used to test launch vehicles and satellite platforms to

ensure that the onboard systems operate within specifications. 

Remote Tracking Stations. Each RTS performs essential mission operations on a 24-

hours/day, 7-days/week basis. The AFSCN performs approximately 400 satellite contacts per

day. The operations are driven by the requirements to support U.S. national security space

operations, as well as by NATO, and the UK. Each RTS has one to four antennas used for

transmitting in the 1761-1842 MHz band. On the occasion of major maintenance or antenna

replacement, transportable assets are deployed to the RTS sites to ensure continuity of

operations. The antennas used are typically 60, 46, and 33 feet (18, 14, 10 meters) in diameter. 

They are supported by transmitters operating between 250 and 7,000 Watts, depending on the

required mission operation. Filters are employed to limit out-of-band radiation. The antennas

may be pointed low on the horizon to communicate with low-altitude satellites which have very

short visibility times. Low-angle radiation will also occur at Vandenberg AFB, California, and

Cape Canaveral Air Force Station (AFS), Florida, to conduct open loop check-out of satellites on

launch pads and to verify communications links prior to launch. For other satellite contacts, the

antennas are typically pointed at higher elevation angles. The infrastructure at each RTS has

evolved over the last 40 years and is extensive and sophisticated with regard to facility power,

emergency power, and connectivity to commercial terrestrial communications. For the most

part, the RTSs are located on U.S. military or host nation military/government facilities. RTSs

are located as follows:
3-14

1. Vandenberg Tracking Station, Vandenberg AFB, California.

• Three antennas

• Missions: satellite operations, space launch, and ballistic missile test launch

2. New Hampshire Tracking Station, New Boston Air Station, New Hampshire.

• Three antennas

• Missions: satellite operations and space launch

3. Thule Tracking Station, Thule Air Base, Greenland. 

• Four antennas

• Mission: satellite operations

4. Guam Tracking Station, Andersen AFB, Guam.

• Two antennas

• Mission: satellite operations

5. Hawaii Tracking Station, Kaena Point, Oahu, Hawaii. 

• Two antennas

• Missions: satellite operations and ballistic missile test launch

6. Colorado Tracking Station, Schriever AFB, Colorado.

• One antenna

• Mission: satellite operations

7. Oakhanger Telemetry and Command Station, Borden, Hampshire, England. 

• Two antennas

• Mission: satellite operations

8. Diego Garcia Tracking Station, British Indian Ocean Territory, Diego Garcia.

• One antenna

• Mission: satellite operations

9. Camp Parks Communications Annex, Pleasanton, California.

• Two antennas

• Mission: satellite operations

10. Eastern Vehicle Checkout Facility, Cape Canaveral AFS, Florida.

• One antenna

• Mission: pre-launch spacecraft compatibility testing

11. Onizuka AFS, California.

• One antenna

• Mission: satellite operations
21 Some of the satellite systems are for the Defense Support Program (missile warning), GPS (navigation),

Nuclear Detonation Detection System, DMSP (weather and environmental monitoring), Defense Satellite

Communications System (communications), MILSTAR (communications), Fleet SATCOM (communications), and

the UHF Follow-on (communications).

3-15

The AFSCN sites at Vandenberg, Thule, New Hampshire, Camp Parks, and at Onizuka

AFS include a data link terminal antenna, which provides communications functions using

SGLS.

Other Transmitting Sites. Other than the AFSCN stations, certain satellites are

controlled through dedicated sites to support specific programs. Typical examples of these sites

follow. The Defense Meteorological Satellite Program (DMSP) has a dedicated network

operated by the Suitland Satellite Operations Control Center (SOCC) in Suitland, Maryland. The

SOCC performs all primary TT&C functions for the DMSP through the use of AFSCN assets. 

The SOCC has a back-up facility at Schriever AFB, Colorado. The GPS has a Mission Control

Center at Schriever AFB operated by the Air Force Space Command, 50th Space Wing, 2nd

Satellite Operations Squadron. There are also dedicated GPS monitoring stations at Ascension

Island, Diego Garcia, Kwajalein, and Cape Canaveral tracking stations.21

In addition to the AFSCN, the GMF lists the following facilities that are authorized to

transmit on SGLS frequencies:

1. Blossom Point, Maryland

2. Buckley Air National Guard Base, Colorado

3. Fairbanks, Alaska

4. Laurel, Maryland

5. Kelly AFB, Texas

6. Kirtland AFB, New Mexico

7. Quantico, Virginia

The Navy operates additional sites at:

1. Prospect Harbor, Maine

2. Laguna Peak, California

Further, the Air Force also has transportable tracking facilities that are relocated

worldwide to satisfy immediate requirements for TT&C, such as anomaly resolution, that cannot

be accomplished at the fixed facilities. Under those conditions, the transportable terminals

usually operate on Federal land (e.g., military bases and installations). Figure 8 shows the

locations of SGLS-compatible uplink stations in the United States.
3-16











 Onizuka AFB

Vandenberg AFB

Laguna Peak



Oahu

Fairbanks

Schriever AFB

Buckley AFB

Kirtland AFB

Kelly AFB







1761-1842 MHz

AFSCN

SGLS



Figure 8

Cape Canaveral

Prospect Harbor

Quantico

Laurel

Blossom Point



New Boston





Philadelphia

Baltimore

Pittsburgh New York

Virginia Beach

Washington

Charlotte

Cleveland

New Orleans

San Antonio

Houston

San Diego

Oakland

San Jose

Sacramento

Fresno

Columbus

Cincinnati

Nashville

Los Angeles

El Paso

Albuquerque

Oklahoma City

Indianapolis

St. Louis

Chicago

Milwaukee

Minneapolis

Detroit

Kansas City

San Francisco

Atlanta

Austin

Boston Buffalo

Dallas

Denver

Jacksonville

Memphis

Miami

Omaha

Phoenix

Portland

Seattle

Tucson

Tulsa

 Guam

Figure 8. Satellite Control Network Sites.

Satellites Supported. The following is an unclassified summary of typical satellite

systems supported by DOD.

Unclassified Summary of Typical Satellites Supported by DOD

Short Name Orbit* Short Name Orbit*

USGCSS PH 2/3/3B GEO USGCSS PH5 GEO

FLTSATCOM GEO USOBO GEO

MILSTAR Inclined GEO DMSP Non-GEO

UFO GEO GPS Non-GEO

Skynet (UK) GEO STS (Shuttle) Non-GEO

NATO III/IV GEO GFO Non-GEO

DSP P-Series Non-GEO

SBIRS (Planned) GEO USAPEX Non-GEO

USGAE GEO OTF Non-GEO

USGBS GEO Various R&D Non-GEO (LEO,

HEO)

* Note: Geostationary Orbit (GEO), Highly Elliptical Orbit (HEO), Low Earth Orbit (LEO)
22 Conventional fixed systems as used herein refer to point-to-point systems using commercial off-the-shelf, or

equivalent equipment.

3-17

Conventional Fixed Systems22

The military services are extensive users of conventional fixed microwave relay systems

in the 1755-1850 MHz band. As mentioned earlier in this report, the ACE operates fixed

microwave systems throughout the country. All of the military services employ fixed microwave

systems on military installations and test and training ranges to support a variety of functions. 

These functions include general purpose communications to remote areas, relaying radar data

from remote range areas back to control centers, relaying video data from remote bombing and

gunnery ranges, sending command and control data to tethered aerostat radars, and relaying radar

data from tethered aerostats to ground control facilities.

The Forest Service of the USDA is one of the Federal Government’s largest users of

fixed microwave radio sites. These sites provide backbone communications support to land

mobile radios in national forests and lands managed by USDA for the public. The backbone

links provide primary radio interconnection between mountaintop radio repeaters and the base

stations, which further interconnects with either mobile or portable handheld radios. Some

USDA microwave links are shared with other agencies such as the DOJ. These systems are

essential for law enforcement, firefighting, and emergency preparedness disaster control (e.g.,

earthquake, volcanic eruption, and hurricane) communications.

The DOI manages its natural resources programs using fixed microwave links to

accomplish congressionally mandated missions. These microwave operations support a variety

of functions including: firefighting, law enforcement, disaster control within national forest and

parks, communications services to Native American Tribal lands, and earthquake monitoring. 

Operations are spread throughout the United States in suburban, urban, and rural areas, some of

which are remote and almost inaccessible so that commercial service is not available or reliable.

As a result of the 1710-1755 MHz band being identified for reallocation under the

OBRA-93, the FAA and U.S. Coast Guard (USCG) are in the process of procuring fixed

microwave links in the 7/8 GHz band. The FAA uses fixed microwave links as part of a

nationwide network to interconnect the nation’s air traffic control facilities. The USCG uses are

for vessel traffic control and safety operations, communications support of the national distress

system, and remote distress and safety communications.

The DOJ uses a nationwide network of fixed point-to-point links to connect its land

mobile users. Bureaus within the DOJ have also begun the transition to higher frequency bands

(e.g., 7/8 GHz band). These Federal law enforcement systems require secure communications to

prevent monitoring, which could disrupt investigations and/or cause life-threatening situations

for law enforcement personnel.

The DOE has fixed microwave operations in support of the National Defense and

Petroleum Reserve Programs with a variety of functions such as remote keying of high-frequency
3-18

transmitters, backbone communications and security, and remote control of robots, cranes and

alarms.

Other specific agency applications of the fixed microwave wide-area network systems

include the following: the FAA remote data transmission in support of aviation safety systems;

the USDA and the DOI backbone links for control of land mobile radio systems necessary in

firefighting, law enforcement, and disaster control within national forests, and for provision of

voice data connections between sites where commercial service is not available; and the

Department of the Treasury and DOJ microwave links related to law enforcement. This band is

also used by the USCG for vessel traffic safety systems, for communications support of the VHF

national distress system, and remote distress and safety communications and control networks.

One example of a wide-area network is the DOE and Tennessee Valley Authority (TVA)

use of this band for supervision, control, and protection of electrical power transmission. The

channels are used for high speed data relaying, supervisory control, load control, telemetering,

data acquisition, land mobile radio dispatching, operations and maintenance. The present system

connects, via wireline and radio, all Federal Government power marketing control facilities in

the western half of the United States and TVA region. Common equipment exists with the

non-Federal sector allowing interconnectivity for critical communications dealing with all

aspects of generating and transmission of power.

The U.S. Customs Service currently operates and maintains an analog microwave system

in Hawaii, commonly referred to as the Rainbow Microwave System, that provides a common

backbone system servicing Federal, state, and local agencies. The Rainbow system was included

in the list of Federal stations that are protected from interference under the mixed-use criteria

established by Title VI of the OBRA-93 due to the high priority, public safety missions it

supports. This system currently employs frequencies throughout the entire 1710-1850 MHz

band. There is no digital equipment available to replace the aging analog microwave system in

this band; therefore, any replacement digital microwave system must operate in higher frequency

bands at a higher cost to the users.

Tactical Radio Relay Equipment

The DOD uses TRR for command and control of military forces. The majority of TRR in

the band is supported by the MSE. Primary areas of operations for MSE in the United States are

shown in Figure 9. Some training areas for National Guard and Army Reserve units are not

shown.

The AN/GRC-103, AN/GRC-226, and A/N GRC-245 Radio Sets are line-of-sight (LOS)

trunk radios used to link nodes (switching centers) in the Army’s tactical telecommunications

system or the Army Common User System (ACUS). These radios operate in the 1755-

1850 MHz band. 
3-19

 ̈

 ̈

 ̈

 ̈

 ̈

1755-1850 MHz

Fixed and Mobile

Assignments

 Army MSE

 Navy DWTS

 USMC DWTS

San Antonio

Houston

Fresno

Los Angeles

Long Beach

San Jose

San Diego

Austin

New York

Philadelphia

Baltimore St. Louis Cincinnati

Indianapolis

Seattle

Minneapolis

Milwaukee

Pittsburgh

Virginia Beach

Washington

Oklahoma City

Albuquerque

New Orleans

Sacramento

San Francisco

Oakland

El Paso

Columbus

Nashville Charlotte

Chicago Cleveland

Detroit

Kansas City

Atlanta

Boston

Buffalo

Dallas

Denver

Jacksonville

Memphis

Miami

Omaha

Phoenix

Portland

Tucson

Tulsa

Figure 9. Concentrations of Fixed and Mobile Sites in the 1755-1850 MHz Band.

The ACUS is a seamless, tactical communications system that provides secure, highly

reliable voice and data communications for both mobile and static subscribers in a tactical

environment. The ACUS operates from the maneuver battalion to the theater rear boundary. 

This communication system is also known as the MSE and the Tri-Services Tactical

Communications (TRI-TAC) system. The MSE system is deployed at Echelons Corps and

Below and the TRI-TAC system is deployed at Echelons Above Corps (EAC). 

There are over 4,000 AN/GRC-226 Radio Sets fielded of which about 2,800 operate from

1350 MHz to 1850 MHz, and the balance operate from 225 MHz to 400 MHz. There are 872

AN/GRC-103 Radio Sets fielded at EAC. The AN/GRC-103 only operates from 1350 MHz to

1850 MHz. The AN/GRC-245 Radio Set, also known as the High Capacity Line of Sight

(HCLOS) Radio is the planned replacement for both the AN/GRC-103 and AN/GRC-226. 

Fielding of the AN/GRC-245 Radio Set began this past summer to the 124th Signal Battalion at

Fort Hood, Texas. To date 90 HCLOS radios have been fielded. The HCLOS radio has an

expanded operating frequency range over both the AN/GRC-103 and AN/GRC-226 in that it

operates from 1350 MHz to 2690 MHz (called Band III+), but the tuning range from 1850-

2690 MHz is rarely available for MSE operations. The spectrum efficiency of the AN/GRC-245

is more than twice that of its predecessors, enabling it to better handle the growing information

requirements of today’s Army.

These LOS radios use directional antennas mounted on top of portable masts 15 to 30

meters in height separated by distances of up to 40 km from each other to connect the Army’s

tactical communications or switching centers. The radio sets with ancillary equipment are
23 See DOD Final Report, supra note 6.

3-20

installed in shelters mounted on trucks providing the mobility needed to meet tactical

requirements.

The DWTS used by the Navy and Marine Corps is a surface-based, frequency modulated,

point-to-point and mobile communications system that carries 9, 18, or 36 voice channels or

digital data, and can be carried on a high mobility multipurpose wheeled vehicle. The DWTS is

used at Camp LeJeune, North Carolina; Twentynine Palms, California; Oahu, Hawaii; and at

other military installations and proving grounds where training exercises are conducted. This

system is fully deployed with approximately 600 units in the field. The DWTS consists of two

systems: the AN/MRC-142 operating in the fixed service at land-based facilities and the

AN/SRC-57 operating in the mobile service for ship-to-ship and ship-to-shore communications

(with land-based AN/MRC-142 units). The key feature of these systems is their transportability. 

These TRR systems are designed to be set up and disassembled rapidly to support the

communications needs of maneuvering troops.

Air Combat Training Systems

The ACTS are used extensively in the 1755-1850 MHz band. ACTS are complex by the

nature of their operations because both fixed and aeronautical mobile equipment are used. 

ACTS that operate in this band segment include the Air Force's Air Combat Maneuvering

Instrumentation (ACMI), and the Navy's Air Combat Maneuvering Range and Tactical Air

Combat Training System (TACTS). Two types of currently deployed ACTS systems are

described in the DOD Final Report: the current ACMI and TACTS (both called ACTS, herein).23

ACTS is a “system of systems” in that specific ACTS-equipped ranges may implement different

ACTS frequencies depending on the surrounding electromagnetic environment. These systems

provide critical training for, and evaluation of, aircrews in air combat tactics and performance. 

These systems are in operation at test and training ranges as well as other bases including

Reserve and Air National Guard locations that may include civilian airports. Recent information

indicates that the original program to replace these systems with a follow-on system called Joint

Tactical Combat Training System (JTCTS) is currently in the process of being restructured. A

new JTCTS contract is expected to be awarded within about a year.

Figure 10 represents permanent Air Force and Navy training sites in the United States. 

Air Force and Navy ACTS employ factory-preset frequencies throughout the 1761-1842 MHz

band segment that are used to transmit information to and from aircraft. The DOD has stressed

that training support systems such as these are key elements in the military's effort to provide

realistic simulation and combat preparedness for pilot training in a peacetime environment. 
3-21

Air Combat

Training Centers

Air Force ACMI

Navy TACTS

Fresno

New Orleans

Nashville Charlotte

Houston

Los Angeles

El Paso

Albuquerque

Oklahoma City

San Diego

San Antonio

Milwaukee

Chicago

Detroit

Virginia Beach

Washington Baltimore

Sacramento

San Francisco

Oakland

San Jose

Pittsburgh Columbus

Philadelphia

New York

Cincinnati

Indianapolis

St. Louis

Minneapolis

Cleveland

Kansas City

Atlanta

Austin

Boston

Buffalo

Dallas

Denver

Jacksonville

Memphis

Miami

Omaha

Phoenix

Portland

Seattle

Tucson

Tulsa

Figure 10. Air Combat Training Center Sites.

The U.S. Air Force ACMI/ACTS, the U.S. Navy TACTS, and its several variants,

provide training associated with aircraft missions ranging from squadron level up to and

including joint force missions. The Navy and Air Force use these systems for daily proficiency

training and as the final readiness training prior to deployment to combat areas around the world. 

ACTS provides real-time monitoring of aircraft combat operations and maneuvering, such as

gun-scoring, no-drop bombing training, and evasion and intercept tactics and electronic warfare

during exercises and training. It also records and plays back aircraft maneuvers for mission

analysis and debriefing. Most systems are composed of the ground-based tactical

instrumentation subsystem (ground-to-air) and the aircraft instrumentation subsystem

(air-to-ground) mounted internally or via a pod on the aircraft. The two-way data link between

these two subsystems is the only means by which they interact and allow the overall system to

function.

On the ground, there are remote stations that receive the aircraft downlink signal and

transmit commands to the aircraft, and relay the received aircraft data to a master station. Six

frequencies are used in the 1755-1850 MHz band for remote stations, and one frequency for the

master station to transmit to the remote stations. There are two ground-to-air frequencies, and

two air-to-ground frequencies.

During a mission, active Aircraft Instrumentation Subsystem pods are sequentially

interrogated on a periodic basis using the same frequency, and each responds when addressed by

its unique digital address code. The Aircraft Instrumentation Subsystem transmits both ranging

signals and stored digital data over a single channel. A typical training range uses a minimum of
3-22

10 frequencies within the 1755-1850 MHz band. A typical ACTS range is configured with more

than one master station and more than six remote stations that may require additional frequency

assignments, depending on spatial separation and radio frequency line-of-sight interference

considerations.

ACTS is employed at ranges in United States, Canada, Taiwan, Thailand, Egypt,

Okinawa, Korea, the UK, and Italy. Canadian F-18 fighter aircraft are fitted with an internal

ACTS box (and dedicated 1710-1850 MHz antenna) for use on the ranges similar to the U.S.

Navy F-18's. The Royal Netherlands Air Force uses ACTS with the Arizona Air National Guard

at Goldwater Air Field, Arizona. This system is fully deployed and includes approximately 120

tracking instrumentation systems and 1,400 aircraft instrumentation systems.

Some ACTS configurations are not reliant on an air-to-ground or ground-to-air data link,

and are not restricted to any particular geographic location. Therefore, these systems can operate

anywhere over the United States (or the world) in airspace set aside for military operations.

The JTCTS will operate in the same band and perform the same function/mission as the

ACTS. However, the JTCTS will differ from the current ACTS equipment in several important

respects. From the spectrum management aspect, the most significant of these are the

dual-bandwidth operation capability, and the spread spectrum nature of the signal. The JTCTS is

designed to tune throughout the 1710-1850 MHz band in 5 MHz increments for a total of 27

possible channels. The second major difference is that the JTCTS does not require a dedicated

range with numerous ground stations. This mode of operation, called “rangeless,” operates in a

air-to-air configuration, and therefore, can be used anywhere over the United States or the world

in airspace set aside for military operations.

The JTCTS has host nation coordination and permanent frequency assignments for Japan. 

The United States has also requested host nation coordination for several other countries.

Both the Tracking Instrumentation Subsystem and the Aircraft Instrumentation

Subsystem have planned replacements. The Aircraft Instrumentation Subsystem began

upgrading to the AN/ASQ-T31 in June of 1996. The AN/ASQ-T31 is portable and includes

provisions for data encryption. The Tracking Instrumentation Subsystem will be replaced by the

JTCTS, which is being developed by the Navy and is becoming operational. Most of the combat

training ranges will be upgraded to JTCTS within a 10-18 year period.

Precision Guided Weapons

Other critical DOD systems, such as PGM and high resolution video links, operate in this

band and are vital to national defense. Precision munitions include a number of weapons

systems that employ communications in this band between a launched weapon and a controlling

platform allowing for precision delivery of the weapon’s payload. These advanced systems are

normally employed against high-value and hardened enemy targets. DOD PGMs (e.g.,

AGM-130 and GBU-15) were designed for employment against fixed, high-value targets. These

weapons, in the 2,000-pound class, are launched from tactical aircraft from either low or high
3-23

altitude at ranges from 5 to in excess of 30 nautical miles. Equipped with television or infrared

sensors, and aided by GPS, these weapons provide operators the ability to attack targets in all

weather conditions, day or night. These weapons can be controlled from either the launch

aircraft or a standoff aircraft at a range of more than 100 nautical miles. Weapons operators

require access to a video and a command link frequency at any time during the mission,

including ground operations, post take-off pre-launch operations, and post-launch weapon flight

operations. Access to frequencies is critical during all training operations—these operations

require use of the frequencies for two hours at a time. The Navy currently operates similar

PGMs against fixed and relocatable land targets as well as ships.

The weapon control data link systems provide operators with the ability to control the

precision guided weapons. Video from the weapon seeker is transmitted to a weapon systems

officer who identifies the target and manually controls the bomb to the designated impact point. 

The AGM-130 provides a longer range, compared to the GBU-15, because its flight is assisted

by use of a rocket motor. Both data link systems associated with these munitions, the AXQ-14

and ZSW-1, use multiple frequencies within the 1710-1850 MHz band for both video and

command links. The AXQ-14 and ZSW-1 weapon control pods carried on the centerline station

on the aircraft, receive the weapon video for display, and transmit weapon guidance signals

through the command link.

If the weapon control data link system could not be used on its current frequencies in

2003, there would be an immediate loss of combat capability to the warfighter. The AGM-130

and GBU-15 could not be used to their full potential. These systems provide precision attack

capability from fighter aircraft, and they represent the majority of the total man-in-the-loop

precision capability from all military aircraft. Without this system, last-minute target

identification and the ability to minimize collateral damage would be lost.

Figure 11 depicts the contours of nominal radio line-of-sight distances surrounding the

many operational training areas where PGM-equipped aircraft operate. Because of the large

geographic areas involved, establishing protection areas for these operations is not feasible.
3-24

Figure 11. Line-of-Sight Distances from Precision Guided Munitions Operational Areas.

Other Systems

In addition to precision munitions and high resolution video links, the 1755-1850 MHz

band also supports deployable emergency communications systems, combat identification

systems, mobile tactical voice and data systems (Land Warrior), robotic control functions, and

target scoring systems. Appendix E of the DOD Final Report contains data on these systems.
24 National Telecommunications and Information Administration, U.S. Department of Commerce, NTIA Special

Publication 94-27, Preliminary Spectrum Reallocation Report (1994).

25 International Telecommunication Union, Use by the Mobile Service of the Frequency Bands 2025-2100 MHz

and 2200-2290 MHz, Resolution 211, WARC-92 (Malaga-Torremolinos, 1992).

4-1

IV. Approaches for IMT-2000 Accommodation 

Sharing Potential Employing Protection Areas

One potential method for accommodation of IMT-2000 would be for these systems to

share Federal and commercial frequency bands that are currently occupied. Co-channel sharing

is generally accomplished either by geographical separation, time separation, or by transmitting

waveforms that are designed specifically to reduce interference to other systems in shared bands. 

The discussion in this section will focus on the potential for geographical and time separation as

the main mechanisms to reduce interference, but one segmentation option is also included. The

DOD Final Report concluded that unrestricted, full-band sharing was not feasible in the 1755-

1850 MHz band. The discussion in this section references the DOD Final Report, based on

considerations of only the 1.25 MHz and 3.75 MHz IMT-2000 bandwidths with minimal

interference thresholds, as listed in the DOD Final Report. The 1.25 MHz and 3.75 MHz

bandwidths were selected to only represent the typical technical characteristics for evaluating the

EMC between IMT-2000 systems and selected DOD systems, and not as a forecast of future

IMT-2000 technology. Different technical parameters (e.g., other data rates, powers, or modes,

such as TDMA) will change the results accordingly.

1. Satellite Control (SGLS) Systems

In the 1994 Preliminary Spectrum Reallocation Report, NTIA noted the extensive studies

conducted on the possible interference to space research and space operations from terrestrial

systems.24 Various studies of interference to satellite uplinks generally concluded that "... the

introduction of ... land mobile systems in the frequency bands used by the space service would

cause unacceptable interference to the space services."25 Although those studies were focused on

the 2025-2110 MHz (uplink) and 2200-2290 MHz (downlink) bands, the results would apply

equally for the 1761-1842 MHz band segment.

Satellite support requires that the SGLS stations transmit to the space vehicle during the

time of its visibility. Some LEO satellites have only a short (approximately 10 minutes) window

of visibility. The goal is to acquire the satellites as close to the horizon as possible. Acquiring

satellites at angles between 5-10 degrees above the horizon begins to have operational impacts to

the satellite’s mission. The SGLS station will want to acquire the satellite as soon as possible,

and may start the acquisition process with the antenna pointed at the horizon point where the

satellite will appear. The SGLS antenna will track the satellite through its arc of visibility, which

could be up to 180 degrees. For non-geostationary satellites, the main beam of the antenna will

be pointed in any given direction for a relatively short time.
26 DOD Final Report at Appendix B (Potential Interference to and From Satellite Operations), supra note 6.

27 Link closure is the successful receipt of an expected downlink signal as a result of an uplink command.

28 DOD Final Report at Appendix B (Potential Interference to and From Satellite Operations) at B-14, supra

note 6.

29 Id. at B-41 through B-44.

4-2

The DOD Final Report contains an analysis of the potential for interference between

these operations and IMT-2000 systems.26 The potential for interference is analyzed as a result

of (1) interference to orbiting satellites caused by the aggregate transmissions from IMT-2000

transmitters, and (2) the potential interference to IMT-2000 receivers from SGLS transmitters.

A finding in the DOD Final Report summarizes the problem of SGLS sharing with IMT2000: “Operational impact to TT&C uplinks from IMT-2000 emissions is expected in the time

period 2006 and beyond when IMT-2000 system build-out has exceeded 50 percent of ITU

estimates for full capacity. In 2003, it is not expected that IMT-2000 build-out will be sufficient

to impact satellite operations uplink operations. These results are based upon realistic uplink

parameters. It should be noted that if uplinks were conducted from worst-case disadvantaged

(size, power, restricted viewing, etc.) terminals using antennas smaller than 33 feet (10 meters)

or lower transmitter powers, there is a potential for impact to link closure reliability27 in 2003. 

The degree of operational impact will vary as a function of the degree to which link closure is

affected. It is expected that impact would occur for a subset of systems and operating conditions,

although at critical junctures such as launch or anomaly resolution, such impact would be

critical.”28 This impact could increase if contributions from 3G emitters outside metropolitan

areas are considered.

Interference to the satellite receivers is a limiting factor in sharing the 1761-1842 MHz

band, since the frequencies on the satellites cannot be changed to avoid interference, and the

satellites continually “see” a large portion of the Earth. IMT-2000 transmissions will be received

by the satellites and can interfere with uplink signals sent by the SGLS sites. The DOD analysis

indicates that the link margin (the amount of signal in excess of that minimally required) would

be increasingly degraded as the build-out of IMT-2000 systems progresses. The study finds that

mobile IMT-2000 units would degrade the link margin (for a satellite altitude of 833 km) by up

to 4 dB in 2003, up to 11 dB in 2006, up to 13 dB in 2010, and by 14 dB when full build-out is

accomplished. For transmitting IMT-2000 base stations, the degradation in link margin would

be up to 21 dB in 2003, up to 28 dB in 2006, up to 30 dB in 2010, and up to 31 dB for full

build-out.29 Under this scenario, sharing with base stations would not be feasible, but sharing

with mobile stations may be possible. Increasing SGLS transmit power to provide an adequate

signal-to-interference ratio at orbital distances will have the detrimental effect of increasing the

level of interference to IMT-2000 receivers from SGLS transmitters, thereby increasing the

required separation distances.

To protect IMT-2000 systems on co-channel operations, protection areas around SGLS

sites could be determined based on the distance from an SGLS transmitter such that interference

would not be caused to an IMT-2000 receiver. Within the protection areas, some method of

coordination is necessary to achieve sharing. Using smooth-Earth propagation analyses, Tables
30 Id. at B-23 through B-32.

4-3

4-1 and 4-2 list the nominal radii of protection areas around SGLS sites that would be necessary

to reduce SGLS signals to the interference threshold of IMT-2000 mobile and base stations. The

DOD Final Report also includes sample plots of received signal levels as a function of SGLS

transmitter power and antenna elevation angles.30 The propagation prediction used in the DOD

Final Report was based on actual terrain surrounding sample SGLS stations. The interference

distances using terrain data are generally less than distances derived from smooth-Earth data for

the same signal level. As can be seen from Tables 4-1 and 4-2 using smooth-Earth data, the

combination of low SGLS power and mobile IMT-2000 systems receiving produces the smallest

protection areas. However, SGLS cannot always use the low power setting, as some satellites

because of age, system degradations, and/or orbit, require higher power. Further, as the number

of IMT-2000 transmitters increase, SGLS may need to increase power to maintain the required

carrier-to-interference ratio at the satellites.

If sharing/relocation is implemented to reach an accommodation between IMT-2000 and

the essential military capability as identified in the NDAA for Fiscal Year 2000, attention will

need to focus on a realistic transition schedule. This schedule must preserve the essential

military capability based on satellite lifetimes, satellite replenishment time lines and launch

constraints. There is a need to quickly obtain Fiscal Year 2002 (FY02) funding (one of the key

cost assumptions in the DOD Final Report), to allow sufficient time to design, engineer, acquire,

test and implement satellite modifications, time to perform engineering and environmental

impact studies, and fully fund if it is necessary to relocate ground facilities.

Table 4-1

Protection Distance in Kilometers for CDMA Carrier Spacing of 1.25 MHz 

Using Smooth-Earth Propagation

IMT-2000

Station Type

SGLS 

Antenna Elevation

SGLS Transmitter Power

250 Watts 2000 Watts 7000 Watts

Mobile 3 degrees 46 km 59 km 88 km

Mobile 5 degrees 41 km 48 km 59 km

Base 3 degrees 206 km 301 km 355 km

Base 5 degrees 164 km 238 km 298 km
31 International Telecommunication Union, Geneva, Switzerland, ITU-R Recommendation F.1334 [hereinafter

ITU-R F.1334].

4-4

Table 4-2

Protection Distance in Kilometers for CDMA Carrier Spacing of 3.75 MHz 

Using Smooth-Earth Propagation

IMT-2000 

Station Type

SGLS

Antenna Elevation

SGLS Transmitter Power

250 Watts 2000 Watts 7000 Watts

Mobile 3 degrees 41 km 49 km 62 km

Mobile 5 degrees 37 km 44 km 49 km

Base 3 degrees 171 km 243 km 307 km

Base 5 degrees 134 km 193 km 242 km

Table 4-3

AFSCN Transmit Parameters

AFSCN Transmitter Power 250 W, 2000 W, 7000 W

AFSCN Antenna Gain Towards Horizon

(49 dBi main beam gain)

23.4 dBi (3o elevation angle)

17.7 dBi (5o

 elevation angle)

AFSCN Antenna Height 15 meters

2. Conventional Fixed Systems

As a result of OBRA-93, some systems that were in the 1710-1755 MHz band were

retuned to the remaining 1755-1850 MHz portion of the band. For example, the Forest Service

of the USDA, determined the feasibility of this option based on the scarcely populated and

remote geographical areas of its operations.

Recommendation ITU-R F.1334 concludes “in order to cover all possible sharing

scenarios-separation distances on the order of 70-120 kilometers are needed for co-channel

sharing between the fixed service in the 1-3 GHz and IMT-2000 stations.”31 Because of the

number and distribution of Federal fixed service stations in the United States, co-channel sharing

with IMT-2000 systems does not seem to be feasible. The IAG also found that general sharing

with nationwide fixed stations was not feasible.

3. Tactical Radio Relay

The TRR system in use is generally the MSE for the Army, and the DWTS for the

Navy/Marine Corps. The MSE is a multi-band, multi-channel, tactical LOS trunk radio system

composed of several components. The part of the MSE that operates in the 1755-1850 MHz

band (and in the 1710-1755 MHz band) is the AN/GRC-226 (V)2 radio. This radio is capable of

tuning from 1350 to 1850 MHz, transmitting from 0.5 to 5.0 Watts, and using a 20 dBi gain

antenna. The system is capable of 16 kbps per channel with 16, 32, or 64 channels per trunk, at
32 See NTIA Final Reallocation Report at F-4, supra note 20.

33 The NTIA interim report cited 17 protected areas. There are 17 facilities, but two of them are co-located,

resulting in 16 protected areas.

34 See ITU-R F.1334, supra note 31.

4-5

Figure 12. Federal Sites Operating Fixed Microwave, Tactical Radio Relay, and Aeronautical

Mobile Stations in the 1710-1755 MHz Band Will Be Retained Indefinitely per OBRA-93.

256, 512, and 1,024 kbps total capacity. A 50 MHz separation is required between transmit and

receive frequencies. The system is designed to support the rapid set-up and disassembly required

to meet the needs of maneuver warfare.

As a result of OBRA-93, operation of TRR in the 1710-1755 MHz band will be restricted

to the 16 protected sites listed in Appendix F of the NTIA Final Reallocation Report32 shown in

Figure 12.33 Operations at other training areas will be limited to the 1350-1390 MHz and 1755-

1850 MHz bands, and in some locations, the 1432-1435 MHz band.

The analysis in the DOD Final Report addresses the potential for interference between

IMT-2000 systems and the Army’s AN/GRC-226, the Tri-Services Tactical radio

(e.g., AN/GRC-103) and also the AN/MRC-142 and AN/SRC-57 as part of the Navy’s DWTS. 

The use of military radio relay, employing relatively broad beamwidth antennas, is unique to

military operations, and hence is chosen for specific analysis in the DOD Final Report. 

Recommendation ITU-R F.1334 addresses the sharing situation between fixed point-to-point

microwave links using high gain, directive antennas.34 The potential for interference is analyzed

as a result of (1) interference to fixed service systems, such as TRR, caused by the aggregate
4-6

 ̈

 ̈

1755-1850 MHz

Fixed and Mobile

Assignments

 Army MSE

 Navy DWTS

 USMC DWTS

 ̈

 ̈

 ̈ San Antonio

Houston

Fresno

Los Angeles

Long Beach

San Jose

San Diego

Austin

New York

Philadelphia

Baltimore St. Louis Cincinnati

Indianapolis

Seattle

Minneapolis

Milwaukee

Pittsburgh

Virginia Beach

Washington

Oklahoma City

Albuquerque

New Orleans

Sacramento

San Francisco

Oakland

El Paso

Columbus

Nashville Charlotte

Chicago Cleveland

Detroit

Kansas City

Atlanta

Boston

Buffalo

Dallas

Denver

Jacksonville

Memphis

Miami

Omaha

Phoenix

Portland

Tucson

Tulsa

Figure 13. Protection Areas of 75 Kilometers Around TRR Sites.

transmissions from IMT-2000 transmitters, and (2) the potential interference to IMT-2000

receivers from TRR transmitters.

Co-channel sharing of TRR and IMT-2000 systems is not feasible based on the

significant distance separations required to prevent interference. To ensure compatible

operations between TRR and IMT-2000 systems on co-channels, protection areas around TRR

sites would require separation distances similar to the 75 kilometer radii example shown in

Figure 13. If IMT-2000 systems were required to operate only outside of the protected areas, this

approach would be unrealistic in that it would deny use of IMT-2000 services to numerous

sizeable segments of the population.

Table 4-4

AN/GRC-226 (MSE) Parameters

Transmitter Power -3 dBw or 7 dBw

Antenna Gain 20 dBi main beam, 11 dBi (20E-90E), 2 dBi (90E-180E)

Antenna Height 30 meters

Receiver Bandwidth 0.85 MHz (-3 dB) 

Receiver Noise Figure 8 dB

Receiver Noise Power Level -137 dBw

Allowed Interference Power -143 dBw
35 See NTIA Final Reallocation Report at 4-11 and D-14 through D-18, supra note 20.

36 Id.

37 See DOD Final Report at D 15-17, supra note 6.

4-7

4. Air Combat Training Systems

The existing ACTS ground stations transmit data to the aircraft on factory-preset

frequencies of 1830 MHz or 1840 MHz, and receive data from the aircraft on 1778 MHz or

1788 MHz. Phase-modulated ranging tones and 62.5 kbps or 198 kbps data, using frequency

shift keying (FSK), transmit altitude, location, velocity, angle of attack, missile firing events, and

other data from up to 100 aircraft. The ACTS uses either omni-directional, or sector antennas

with gains of 0 dBi and 12 dBi, respectively. The geographical area of coverage for ACTS

systems is up to 65 nautical miles in diameter and operations may last up to 10 hours a day. 

Additionally, point-to-point links in this band are used to communicate the data from remote

sites to a central location (master station).

It should be noted the restructured JTCTS is scheduled to complement the existing

ACMI/TACTS. For purposes of this study, it was assumed that the restructured JTCTS has

similar operational requirements as the ACMI/TACTS, and that the restructured JTCTS has the

same technical parameters as the original JTCTS (described in J/F 12-06999/2) and has the

additional flexibility to tune across the 1710-1850 MHz band in 5 MHz increments. The

restructured JTCTS is expected to have the capability to operate without ground stations, in a

“rangeless” air-to-air mode.

In the NTIA Final Reallocation Report, NTIA addressed the technical issues regarding

the 1761-1842 MHz band segment used for ACTS systems such as ACMI and TACTS.35 The

report addressed interference to ACTS airborne receivers from mobile service stations as well as

interference to terrestrial stations from ACTS ground station transmitters. NTIA determined

ACTS airborne receivers are most susceptible to interference in the FSK demodulation stage. 

NTIA concluded reallocation of the 1845-1850 MHz band segment for terrestrial mobile and

personal stations with a 5 MHz guard band will degrade uplink ACTS transmissions.36

The DOD Final Report contains analyses of the potential for interference between IMT2000 base and mobile stations and ACTS and the original JTCTS operating in the frequency

band 1755-1850 MHz.37 The analyses assess the 1) potential for interference between IMT-2000

and ACTS ground stations, and 2) the potential for interference between IMT-2000 systems and

ACTS airborne stations.

Interference to the ACTS airborne receiver may be the limiting factor in sharing, since

the factory-fixed frequencies on the ground transmitters and aircraft receivers cannot be readily

changed to avoid interference. Depending on operational altitudes (100-60,000 feet), IMT-2000

transmissions could potentially degrade the ACTS airborne receivers requiring large protection

areas around training sites.
38 Id. at E-16.

4-8

ACTS systems require large ground separation from IMT-2000 systems in order to

operate co-channel. To ensure compatible ACTS operations and protect IMT-2000 systems on

co-channel operations, protection areas around ACTS (ACMI/TACTS) sites could be

determined, for example, based on the distances shown in the DOD Final Report.38 An example

is shown in Figure 14. These protection areas are shown, as an example, with radii of 400

kilometers. However, higher operating altitudes will increase the diameter of the circles. Figure

14 does not include potential “rangeless” ACTS operating areas.

Table 4-5

ACTS Parameters

Aircraft Altitude 30-20,000 meters

Ground-to-Air Transmitter Power 7 dBw

Ground-to-Air Antenna Height 30-45 meters

Ground Receiver Noise Figure 3 dB

Ground-to-Air Antenna Gain 3 dBi

System Losses 2 dB

Transmitted Data Rate 198.4 kbps

Aircraft Antenna Gain 0 dBi

Aircraft Receiver Noise Figure 7 dB

Eb/No for BER = 10-5 13.35 dB

Note: The listed ACTS parameters were considered only for conducting the preliminary EMC analysis and are not

considered representative of these range systems and its operational scenario for the aircraft attitude.

5. Precision Guided Munitions (PGM)

PGMs are weapons that provide the capability to attack single military targets with one

aircraft or one standoff weapon with greater probability of success than by flying waves of

aircraft dropping conventional, unguided bombs. The tactical control links that operate in this

band to support PGMs provide a decisive combat edge to U.S. military forces. PGMs increase

aircrew survivability by allowing the launch of weapons outside of enemy anti-air system threat

envelope, thereby significantly decreasing aircrew vulnerability. PGMs require regular testing

and training in the United States by operational units to maintain operational readiness and also

for systems testing and evaluations of upgrades.
4-9

Air Combat

Training Centers

Air Force ACMI

Navy TACTS

El Paso

Fresno

New Orleans

Nashville Charlotte

Houston

Los Angeles

Albuquerque

Oklahoma City

San Diego

San Antonio

Milwaukee

Chicago

Detroit

Virginia Beach

Washington Baltimore

Sacramento

San Francisco

Oakland

San Jose

Pittsburgh Columbus

Philadelphia

New York

Cincinnati

Indianapolis

St. Louis

Minneapolis

Cleveland

Kansas City

Atlanta

Austin

Boston Buffalo

Dallas

Denver

Jacksonville

Memphis

Miami

Omaha

Phoenix

Portland

Seattle

Tucson

Tulsa

Figure 14. Protection Areas of 400 Kilometers Around ACTS Sites.

Note: This figure does not include potential rangeless ACTS operating areas. Higher operating altitudes will

increase the diameter of the circles.

6. Other Systems

Other systems that operate in this band are critical to national defense and the missions of

other Federal agencies. These systems include deployable range training systems, deployable

emergency communications systems, combat identification systems, mobile tactical voice and

data systems, high resolution video links, robotic control functions, and target scoring systems. 

There are over 200 individual systems that currently operate in the 1755-1850 MHz band. 

Systems not already addressed will need to be analyzed on a case-by-case basis as necessary to

determine the potential for sharing or for relocation.

Band Sharing and Segmentation Options

This section examines three approaches to either sharing or segmentation of the 1710-

1850 MHz band. The first sharing approach considers in-band pairing with IMT-2000 mobiles

transmitting in the 1710-1755 MHz band, and base stations transmitting in the 1805-1850 MHz

band. The second sharing approach considers mobiles transmitting in the 1755-1790 MHz band

and the base stations transmitting in band(s) above 2110 MHz, such as 2110-2150 MHz and

2160-2165 MHz. The third approach involves segmenting the band, but with all Federal

operations migrating from the 1710-1755 MHz band in the long-term, and pairing the 1710-

1755 MHz band with the 2110-2150 MHz and 2160-2165 MHz bands.
39 Report of the San Diego Meeting of ITU-R 8F, August 2000, ITU-R 8F/63 at 55.

40 See NTIA NPRM, supra note 17. This NPRM addresses reimbursement of costs incurred for relocating

Federal radio systems as a result of the OBRA-93 and the BBA-97.

41 “Mixed Use” is a term defined in the OBRA-93 for frequency bands reallocated from Federal to private use in

accordance with this Act, which are partially retained for continued use by Federal stations.

4-10

Option 1: In-Band Pairing of the 1710-1850 MHz Band

1. Discussion

The 1710-1885 MHz band is available in Europe primarily for Global System for Mobile

Communications (GSM) systems. GSM mobiles transmit in the 1710-1785 MHz band, and the

base stations transmit in the 1805-1880 MHz band. This results in up to 2x75 MHz for GSM

second generation usage. The 1850-1880 MHz portion might not be available in the United

States since it is currently used for PCS. Dividing the 1710-1850 MHz band into segments of

1710-1755 MHz and 1805-1850 MHz would yield a maximum of 2x45 MHz (90 MHz) as a

candidate for IMT-2000 deployment. ITU-R Working Party 8F has initially concluded that this

could potentially facilitate the global harmonization of 2x45 MHz of spectrum, but also notes

that this would perpetuate the existing incompatible use in part of this band (1850-1880 MHz)

globally, and does not offer a full worldwide solution for IMT-2000.39 

The NTIA Interim Report found that sharing Federal operations in these band segments

with IMT-2000 systems would be possible only if restrictions in space and/or time prove

feasible. The conditions for sharing would include (1) IMT-2000 operations not impacting

Federal military operations, and that (2) most, if not all, of the Federal conventional fixed

systems would be relocated to alternative bands under a reimbursement plan.40 This sharing

would protect both the remaining Federal operations and IMT-2000 operations. IMT-2000

sharing with the present nationwide set of Federal fixed systems was found not to be feasible. 

The satellite control function, and military radio relay would operate as normal, with the IMT2000 systems sharing on the basis of geography and time. Any mitigation burden or operational

restrictions would need to be borne by the IMT-2000 community. Alternately, either all Federal

systems would need to be relocated, at a cost and time line shown in Section V, or IMT-2000

would not be deployed in this band.

Sharing in the 1710-1755 MHz Band Segment. The 1710-1755 MHz band was

identified to be reallocated and transferred to the FCC under OBRA-93 as a mixed-use band.41

Certain military facilities, safety-of-life, and power transmission fixed links were exempted from

the reallocation. Protection Areas were established around the 16 military facilities as shown in

the NTIA Final Reallocation Report. In this segmentation option (Option 1), IMT-2000 mobiles

would transmit in this portion of the band. To allow IMT-2000 operation within the protection

areas, IMT-2000 operators would coordinate their operation with the appropriate military

officials.
42 See NTIA NPRM, supra note 17.

4-11

Most Federal stations operating in the 1710-1755 MHz band may be entitled to

compensation for relocation to another frequency band.42 Although the currently-exempt fixed

links are not required to relocate, and compensation is not mandated, they might be voluntarily

moved at the expense of commercial IMT-2000 operators. This would clear the band of most

Federal operations, with the exception of the 16 protected military operations areas, and various

other Federal users.

Sharing in the 1805-1850 MHz Band Segment. The 1805-1850 MHz portion of the

band is currently used as described earlier in this report. This part of the band includes one-half

of the SGLS channels, i.e., channels 11 through 20. This band also includes multiple ACTS

ground-to-ground frequencies and two ground-to-air frequencies. The MSE also operates in this

band with assignments generally spaced 500 kHz apart.

There are 1,864 Federal frequency assignments in this portion of the band for stations in

the fixed service. If this band were to be reallocated, these conventional fixed stations would be

eligible for compensation for relocation by IMT-2000 operators. It is postulated that this band

could be cleared of most conventional fixed systems by a reimbursement process.

There are also a variety of other Federal operations not detailed in this report. Many of

these operations involve law enforcement, and operate nationwide. These systems would also

need to be relocated from the 1710-1755 MHz and 1805-1850 MHz segments by a

reimbursement process. The estimated costs to relocate these systems are shown in Section V.

2. Option 1 Sharing Considerations

In this Section we address the sharing issues associated with sharing the 1710-1850 MHz

band with IMT-2000 systems. While total sharing is not feasible, some sharing may be possible

under certain conditions. The first condition is that DOD operations within the 16 protected

areas as shown in the NTIA Final Reallocation Report areas are not impacted. Second, that it

would be possible to determine protection areas around other Federal operations, such as SGLS

sites, such that IMT-2000 systems operate normally outside of these areas. These systems would

need to accept interference from DOD emitters or dynamically reassign frequencies to avoid

interference if operating within the protection areas. Third, it would be necessary to relocate

most conventional Federal fixed service systems to alternate bands by a method of

reimbursement. Fourth, the SGLS uplink command signals to Federal satellites must be

protected. Finally, various other Federal operations would need to relocate to other bands or

re-tune to the remaining 1755-1805 MHz segment. The size of the protection areas may vary

from the values shown in this report, and would be determined by either a detailed analysis of

each site, using terrain data, or by field measurements of signal strengths.
43 See DOD Final Report, at C-10 supra note 6.

44 Id. at C-11.

45 Id. at C-10.

46 Id. at C-11.

47 See ITU-R F.1334, supra note 31.

4-12

1710-1755 MHz Segment

Tactical Radio Relay. The MSE and DWTS systems are used to support the warfighters’

data communications capabilities at all echelons of tactical operations. Because MSE systems

are transportable and used to support total Army missions, they can be in operation at any time. 

Unlike conventional fixed systems, the antennas associated with MSE systems are pointed in

different directions when activated at new locations. Using the interference thresholds presented

in Table C-7 from the DOD Final Report, IMT-2000 mobile stations could cause interference to

MSE receivers at distances from 9 to 20 km for 3.75 MHz IMT-2000 systems, and from 11 km

to 23 km for 1.25 MHz systems, depending on the position of the mobile station relative to the

main beam of the MSE antenna.43

The MSE transmitters could cause interference to IMT-2000 base receivers at ranges

from 60 to 75 km for 3.75 MHz systems, and from 62 to 82 km for 1.25 MHz systems,

depending on the location of the base station antenna relative to the main beam of the MSE

antenna, and interference thresholds for different IMT-2000 systems.44

Since the required separation distance, as a factor of the antenna coupling of the IMT2000 station to the MSE antenna, is shown to be less outside of +/- 20 degrees of the MSE

antenna boresight, and minimum outside of +/- 90 degrees, there is about a 50 percent

probability of a IMT-2000 station being in a minimum interference zone for any given MSE

station. Within this minimum interference zone, the protection distances would be from 9 km

to11 km for co-channel mobile transmitters (3.75 MHz and 1.25 MHz systems respectively),45

and from 60 km to 62 km for IMT-2000 base receivers (3.75 MHz and 1.25 MHz systems

respectively).46 The AN/GRC-245 and other similar radios performing radio relay functions

have nominally the same protection distances.

Conventional Fixed. The Federal Government operates many fixed, point-to-point

service links in the 1710-1755 MHz band. This band is identified for transfer to the FCC on a

mixed-use basis. Fixed links in this band that are within the military protection areas, and those

power transmission and public safety links shown in the NTIA Final Reallocation Report, will be

protected. These protection areas vary in size from 50 to 160 km. ITU-R Recommendations

have concluded that separation distances up to 120 km are necessary to prevent interference

between mobile and fixed stations.47 Due to the significant number of protected fixed systems,

the establishment of protection areas surrounding each of these protected fixed service links is

not considered practical. Federal stations, other than those in a protected status, may be entitled

to reimbursement for relocation to alternate frequency bands. Figure 15 illustrates the 16

protected areas and the protected fixed links remaining in the 1710-1755 MHz band after other
48 See DOD Final Report, at B-43 and B-44 supra note 6.

49 Cellular Telecommunications & Internet Association, Telecommunications Industry Association, and Personal

Communications Industry Association, Report of the Industry Association Group on Identification of Spectrum For

3G Services, at Attachment II (Feb. 22, 2001).

4-13

Federal Power Agencies

Dept. of Energy

TVA

Dept. of Interior

Army

Coast Guard

FAA

Dept. of Treasury

Federal safety-of-life Agencies

San Jose

San Francisco

Phoenix

San Diego

Los Angeles

Houston

Jacksonville

San Antonio

Memphis

Nashville

New Orleans

Washington

Columbus

Baltimore Indianapolis

Cleveland

Detroit

Chicago

Dallas

New York

Philadelphia

Boston

Milwaukee

El Paso

Seattle

Figure 15. Protected areas and protected fixed links in 1710-1755 MHz per OBRA-93.

Federal stations have been relocated. However, those protected fixed stations (outside of the 16

protected areas) may be able to voluntarily accept reimbursement for relocation.

Sharing in the 1805-1850 MHz Segment

Government Satellites. Under this segmentation option, the IMT-2000 base stations

would be transmitting (and mobile stations receiving) in the 1805-1850 MHz portion of the

band. A large number of base stations transmitting simultaneously would cause interference to

the satellite uplinks. The DOD Final Report shows that IMT-2000 base station transmitters

would cause a degradation to the link margin of DOD satellites (at orbital altitude of 833 km)

from 21 to 31 dB, depending on degree of IMT-2000 build-out.48 Analyses conducted by

members of the IAG arrive at different values of interference.49 These differences are due to the

methodologies employed in estimating the amplitude of interfering power emanating from

terrestrial IMT-2000 base stations worldwide. The DOD study used as a basis an ITU-R

approved approach for IMT-2000 interfering power density from areas visible from an orbiting
50 See DOD Final Report, supra note 6 at B-23 through B-32.

51 Id. at C-10.

52 Id. at C-11.

4-14

satellite. Other approaches to establish this input parameter may be valid, but there is no general

agreement at this time as to the total aggregated IMT-2000 emissions that may be seen at orbital

altitudes.

If the interference to the satellite results in the link margin to be less than specified by the

satellite user, operational integrity of the satellite-based mission would be impaired. The DOD

Final Report finds that satellite operations could be impaired by the year 2003 due to IMT-2000

build-out in the 1805-1850 MHz band. Migration of the satellite receive operations to an

alternate band, even if feasible, could not be completed by 2010, and some operations could last

until 2030.

Satellite Control Stations. Data from Tables 4-1 and 4-2 show that when satellite

control stations are transmitting, the IMT-2000 mobile receivers could receive interference at

distances from 37 km to 62 km for 3.75 MHz mobile systems, and from 41 km to 88 km for

1.25 MHz mobile systems, depending on SGLS transmitter power and antenna elevation. Actual

distances will be less than was calculated using a smooth-Earth model, because actual SGLS

signals will be propagated over rough terrain. For comparison, several plots of interference

contours surrounding SGLS sites, using actual terrain data, are included in the DOD Final

Report.50

During SGLS operations, the satellite control stations must transmit during the times of

satellite availability, and to service the satellite, the transmitting antenna cannot be operationally

restricted in azimuth or elevation. Sharing with IMT-2000 receiving stations around a SGLS site

may be possible by allowing sufficient geographical separation, or by a real-time IMT-2000

channel assignment method that avoids co-channel operations within a protection area during

SGLS transmit times. 

Tactical Radio Relay. The MSE and DWTS systems are used to support the warfighters’

data communications capabilities at all echelons of tactical operations. Because MSE systems

are transportable and used to support total Army missions, they can be in operation at any time. 

Unlike conventional fixed systems, the antennas associated with MSE are pointed in different

directions when activated at new locations. Using the interference thresholds presented in Table

C-7 from the DOD Final Report, IMT-2000 base stations could cause interference to MSE

receivers at distances ranging from 61 km to 78 km for 3.75 MHz systems, and from 64 km to 87

km for 1.25 MHz systems, depending on the position of the mobile station relative to the main

beam of the MSE antenna.51 The MSE transmitters could cause interference to IMT-2000

mobile receivers at ranges from 18 km to 32 km for 3.75 MHz systems, and from 20 km to 34

km for 1.25 MHz systems, depending on the location of the mobile station relative to the main

beam of the MSE antenna and the interference threshold used.52
53 Id. at C-10.

54 Id. at C-11.

55 Id. at E-10.

56 Id. at E-13.

57 Id. at E-15.

58 Id. at E-13, E-19.

4-15

Since the required separation distance, as a factor of the antenna coupling of the IMT2000 station to the MSE antenna, is indicated to be minimum outside of +/- 20 degrees of the

MSE antenna boresight, and minimum outside of +/- 90 degrees, there is about a 50 percent

probability of a IMT-2000 station being in a minimum interference zone for any given MSE

station. Within this minimum interference zone, the protection distances would range from 61

km to 64 km for co-channel base transmitters (3.75 MHz systems and 1.25 MHz, respectively).53

Protection distances would range from 18 km to 20 km for co-channel IMT-2000 mobile

receivers (3.75 MHz systems and 1.25 MHz systems respectively).54 The AN/GRC-245 and

other similar radios performing radio relay functions have nominally the same protection

distances.

Air Combat Training Systems. Generally, the analysis in the DOD Final Report shows

that the airborne receiving component of the air combat systems would suffer degradation

throughout much of the United States, with a 33 dB reduction in link margin in fairly large areas

due to IMT-2000 base stations transmitting (the only ACTS aircraft links in this band segment

are ground-to-air links).55 Multiple ground-to-ground and two ground-to-air frequencies would

be impacted. Data from the DOD Final Report indicates that the ACTS ground stations would

require separation distances ranging from 70 km to 146 km from transmitting IMT-2000 base

stations,56 but the mobile stations could operate at distances of from 12 to 48 km (51 km for

TDMA systems) from transmitting ACTS ground stations.57

The ground-based fixed links could be reaccommodated in alternate bands, or possibly

retuned to the 1755-1805 MHz portion, but the current airborne systems could not realistically

share without frequency separation. The air-to-ground and ground-to-air links could be retuned

to the 1755-1805 MHz band, but not before 2006. Because of the interaction of electronic

systems on modern aircraft, extensive co-site EMC analyses will be required to finalize any

relocation option.

Unlike the ACMI/TACTS, the JTCTS will employ an air-to-air communication function

as its primary link. The separation distances for the air-to-ground function of the JTCTS, which

is similar to ACMI/TACTS, are nominally the same.58 This function will be a secondary link for

JTCTS. The ground-to-ground function of the JTCTS will be considered a tertiary data link and

will not always be used. The DOD Final Report finds that the JTCTS may possibly be

reconfigured to operate with the two primary channels in the 1755-1805 MHz band; however,

further investigation is necessary to determine the extent of guard bands that would be required

to prevent interference near the band edges. The tertiary link could be relocated in an alternate
59 Id. at 1-3

60 Report of the San Diego, CA meeting of ITU-R 8F, (Aug. 2000) ITU-R 8F/63 at 62 .

61 See October 2000 contribution to ITU-R WR8F, ITU-R Doc 8F/148, (Oct. 20, 2000).

4-16

band. JTCTS could not replace the current TACTS/ACMI range systems until after the 2010

time frame.

Summary of the Sharing Potential for Option 1

It should be noted that in a general sharing scenario there will be a greater potential for

interference to and from IMT-2000 systems when both IMT-2000 radio links (mobile and base)

operate within the 1710-1850 MHz band, as opposed to only one link being in the band. 

Satellite uplink sharing with IMT-2000 base stations is problematic in the 1805-1850 MHz band,

and IMT-2000 mobile receive stations must either stay outside of the protection areas or avoid

co-channel operations during SGLS transmit times.

The DOD Final Report concludes that significant loss of spectrum in the 1755-1850 MHz

band would cause an unacceptable loss in proficiency training in the deployment of the TRR

systems. The MSE replacement system could not be deployed before Fiscal Year 2006. There is

no planned replacement for the DWTS, and a new system could not be fielded before at least

2010. No comparable alternate spectrum was identified for the MSE and other TRR systems.

The ACTS could possibly be reaccommodated within the 1755-1805 MHz band, with

some links relocated in alternate bands, but co-site EMC analyses are critical for any final

resolution.

Based on the above, Option 1 appears not to be feasible.

Option 2: Dual-Band Pairing Using the 1710-1790 MHz Band

1. Discussion

A second option for accommodation of IMT-2000 (Option 2) considers IMT-2000

mobiles transmitting from 1710 MHz up to 1790 MHz in phases,59 and base stations

transmitting in frequency bands above 2110 MHz. This would, in the long-term, yield up to

2x80 MHz for IMT-2000 implementation. This pairing arrangement is included in the work

being undertaken by ITU-R Working Party 8F, which had the preliminary comments: “[This

pairing] could provide global arrangements in the longer term and hence economies of scale, but

would require substantial re-planning of existing allocations, might not provide enough

forward-link capacity, and accommodation of TDD requirements needs to be considered.”60

Some countries in the Americas have endorsed this approach in order to promote long-term

harmonization.61

The analysis of the DOD Final Report shows that IMT-2000 mobile transmitters would

cause from 4 to14 dB degradation to the link margin of DOD satellites (at 833 km altitude) as a
62 See NTIA Final Reallocation Report, at F-4 supra note 20.

4-17

function of IMT-2000 build-out. SGLS link margins remain positive, but it is not known if

sufficient margins remain for mission success in all cases.

IMT-2000 base receiving stations could possibly share in the 1761-1790 MHz portion,

using a combination of geographical and time separation. For example, the base stations might

be able to detect SGLS transmissions and not assign mobile units to that particular frequency. 

Coordinating with Federal operations on a time-sharing basis would reduce the IMT-2000

system capacity within these protected areas during the times of Federal operation. In this case,

the spectrum in the 1755-1790 MHz band would be available to make up for the shortfall in

capacity in the protected areas. In geographical areas outside of the protection areas where this

additional spectrum would not be required, other IMT-2000 systems, such as Time Division

Duplex (TDD), could operate since paired frequencies are not needed for TDD operation. This

sharing arrangement would consist of three phases, however, NTIA has not estimated the timing

of Phases 2 or 3. The three phases are as follow:

Phase 1. In Phase 1, IMT-2000 mobiles would transmit in the 1710-1755 MHz band,

under conditions similar to the 1710-1755 MHz part of the in-band sharing Option 1 described

above, except that the mobile stations are now paired with base stations transmitting above

2110 MHz, e.g., 2110-2150 MHz and 2160-2165 MHz, as proposed in the FCC’s 3G NPRM. 

Protection Areas are areas around military facilities as shown in the NTIA Final Reallocation

Report.62

 

As noted in the discussion of Option 1, some Federal stations operating in the 1710-

1755 MHz band may be entitled to compensation for relocation to another frequency band. 

Although the currently exempt fixed links are not required to relocate and are not entitled to

compensation, they might be voluntarily moved at the expense of commercial IMT-2000

operators. This would clear the band of most Federal operations, with the exception of the 16

protected military operations areas and various other Federal users.

Phase 2. In Phase 2, the 1755-1780 MHz band would be added for sharing with

mobiles, paired with base stations above 2110 MHz (e.g., in the 2500-2690 MHz band). 

However, the potential for interference to satellite control uplinks from mobile transmitters

would exist, since this band segment contains SGLS channels 1-5. New protection areas could

be established around satellite control stations. Federal conventional fixed stations are assumed

to be relocated from the 1755-1780 MHz band by a reimbursement process.

The ACTS would not be able to share co-channel with IMT-2000 systems. Therefore,

multiple frequencies would need to be relocated by a reimbursement process. Within the

protection areas for satellite control sites, there may be technical solutions to sharing for some

types of IMT-2000 systems.

Phase 3. In Phase 3, the1780-1790 MHz band could be added for mobiles to transmit,

paired with base stations above 2110 MHz, e.g., in the 2500-2690 MHz band. Federal
63 See DOD Final Report, supra note 6 at E-16.

64 Id. at E-15.

4-18

conventional fixed stations could be relocated from the 1780-1790 MHz band by a process of

reimbursement. Within the protection areas, coordination would be required.

2. Sharing Considerations for Out-of-Band Pairing 

1710-1755 MHz Segment

The sharing potential would be the same as discussed under sharing Option 1. It is

assumed that in the long-term, most conventional fixed links outside on the protection areas will

be relocated to alternate frequency bands by a reimbursement process. It should be noted that

those protected fixed links are not required to relocate. Fixed links within the protection areas

may remain indefinitely, or volunteer to be relocated by reimbursement.

1755-1790 MHz Segment

The 1755-1790 MHz segment has in it the kinds of Federal systems seen in both the

1710-1755 MHz and the 1805-1850 MHz segments. 

Government Satellites. An analysis of the potential for IMT-2000 mobile (handheld)

stations to interfere with the SGLS uplink is contained in the DOD Final Report. This analysis

shows that IMT-2000 mobile transmitters would cause from 4 to 14 dB degradation to the link

margin of DOD satellites as a function of IMT-2000 build-out. The 1780 MHz end point for

Phase 2 was chosen to avoid IMT-2000 interference to the GPS uplink control channel (SGLS

channel 6) at 1783.74 MHz (+/- 2.002 MHz). If further analysis shows possible adjacent band 

interference to GPS, then the Phase 2 additional band would be reduced and Phase 3 not

implemented.

Satellite Control Stations. The IMT-2000 mobile stations would be transmitting (and

base stations receiving) in the1755-1790 MHz portion of the band. This portion of the band

contains SGLS channels 1-8, including the GPS uplink channel. The data from Tables 4-1 and

4-2 show that the radius of the protection areas surrounding satellite control sites would vary

from 134 km to 307 km for 3.75 MHz systems, and 164 km to 355 km for 1.25 MHz systems,

based on a smooth-Earth propagation model, depending on the uplink transmitting power and the

antenna elevation angle. Actual distances will be less, due to propagation over rough terrain. 

For comparison, several plots of interference contours surrounding SGLS sites, using actual

terrain data, are included in the DOD Final Report.

Tactical Radio Relay. The assessment for TRR in the 1755-1790 MHz segment is the

same as for the 1710-1755 MHz segment.

Air Combat Training Systems. Generally, the DOD Final Report shows that the ACTS

downlink at 1778 MHz and the ACTS master ground station transmitting at 1768 MHz would

cause interference to IMT-2000 receiving base stations at distances ranging from 48 km to

405 km63 and from 49 km to158 km (180 km for TDMA systems) from the ground stations,64
65 Id. at E-23.

66 Id. at E-13, E-19.

67 Operations supporting deep space activities have been effected under a primary allocation initiated pursuant to

FCC Report & Order (Docket No. 14712) released December 10, 1962.

4-19

respectively. The ground-based links could be reaccommodated in the 1790-1850 MHz portion,

or relocated to an alternate band. The airborne links could be retuned to the remaining 1755-

1850 MHz portion of the band.

Unlike the ACMI/TACTS, the JTCTS will employ an air-to-air communication function

as its primary link. The EMC between IMT-2000 systems and this JTCTS air-to-air link needs

to be investigated to determine the feasibility of sharing.65 The separation distances for the

air-to-ground function of the JTCTS, which is similar to ACMI/TACTS, are nominally the

same.66 This function will be a secondary link for JTCTS. The ground-to-ground function of the

JTCTS will be considered a tertiary data link and will not always be used. The DOD analysis

concludes that the JTCTS could be reconfigured to operate in the 1790-1850 MHz band by 2010;

however, further investigation into relationships with IMT-2000 near band edges would be

needed before a final decision could be made. Additionally, the compatibility of JTCTS

operations at adjacent ranges under this scenario has not been studied. Such a replacement for

the existing ACTS ranges could not be completed until much after 2010.

2110-2150 MHz Band

The band segment 2110-2120 MHz is also allocated via footnote US25267 to the National

Table of Frequency Allocations, for the Space Research service on a primary basis and is used by

NASA's Deep Space Network (DSN) facility at Goldstone, California, for uplink transmissions

to interplanetary spacecraft. Internationally, the band is allocated in all three ITU Regions to the

Fixed, Mobile and Space Research (deep space) (Earth-to-space) services and is used by NASA

at DSN facilities in Spain and Australia. In order to ensure link integrity over interplanetary

distances, the DSN earth station employs a transmit power of 400 kilowatts. During command

link operations it is likely that service disruption would be experienced by IMT-2000 mobile

receivers when attempting to operate within the areas surrounding Goldstone. As a result, these

areas would not be available for continuous IMT-2000 reception. See Appendix A for a NASA

analysis regarding the calculation of a protection contour surrounding the Goldstone facility.

Summary of Sharing Potential for Option 2

Satellite uplink sharing with IMT-2000 mobile stations is less severe than sharing with

base stations, but IMT-2000 base receive stations must either stay outside of the protection areas

or avoid co-channel operations during SGLS transmit times.

The DOD Final Report concludes that loss of significant spectrum in the 1755-1850 MHz

band would cause an unacceptable loss in proficiency training in the deployment of the TRR

systems. The DOD states that the MSE system could not be fully replaced before 2010. There is

no planned replacement for the DWTS, and a new system could not be fielded until after Fiscal
68 See DOD Final Report, supra note 6 at B-9 and B-12.

4-20

Year 2007. IMT-2000 operators would need to coordinate with Federal users in the protected

areas.

The ACTS could possibly be reaccommodated within the 1790-1850 MHz band but not

before 2006.

IMT-2000 receivers could experience interference within 200 km of the NASA

Goldstone facility.

Option 3: Migration From the 1710-1755 MHz Band.

1. Discussion

Previous options considered by NTIA and the DOD have included sharing, or vacating

the 1755-1850 MHz band. The first option has merit in that a sharing approach is offered,

contingent on DOD operations not being impacted. However, during the time since the release

of the NTIA Interim Report, no workable co-channel sharing technique has been shown to be

feasible. Although efforts on this front are continuing, the lack of an immediate solution to the

several sharing problems leads to a possible third option, in which segmentation in the

long-term, rather than sharing, is the main feature. This option is addressed here in addition to

the other options that were predicated on a degree of long-term sharing between IMT-2000

systems and DOD systems. This option has not been evaluated by the DOD, and is not included

in the DOD Final Report. Therefore, operational impacts to DOD operations are not known.

Technical analyses have shown that sharing requires frequency, distance, or time

separation to be effective. The DOD Final Report documents the conditions required for sharing

between many DOD and various possible IMT-2000 systems. The total scenario is complicated

by the large number of systems affected, the required separation distances, and the absence of

certain knowledge of what commercial mobile systems may be actually established in the 1710-

1850 MHz band, what future commercial technology may be implemented in the years to come,

and the future operational requirements of DOD. At best, sharing would be difficult, expensive,

and would require extensive frequency use coordination. At worst, sharing would be

unsuccessful, resulting in operational impacts to both DOD and commercial operations.

In Option 3, it is postulated that all Federal systems would be relocated from the 1710-

1755 MHz band, except in new protected areas, selected to ensure adequate operational areas to

support large-scale training operations. This band would be paired with the 2110-2150 MHz and

the 2160-2165 MHz bands, as proposed by the FCC in the 3G NPRM. The DOD Final Report

indicates that the TRR systems would be unacceptably impacted by a loss of significant spectrum

in the 1710-1850 MHz band.68 The requirement for the current spectrum stems from the high

usage of TRR systems during large-scale exercises. These exercises are generally held in

selected areas, and are somewhat remote from urban centers. During initial phases of IMT-2000

build-out, these areas would not have a significant IMT-2000 population. Therefore, if the TRR

systems in the current 16 protected areas (OBRA-93 areas) would cease operation in the 1710-
69 These areas would be the same as certain of the OBRA-93 areas.

4-21

1755 MHz band, and satisfy their requirements in the remaining 1755-1850 MHz band where

possible, and new protected areas would be established that encompass only the military training

areas needed for large-scale exercises,69 the 1710-1755 MHz band could continue to be used

within these new (3G ) protection areas until replacement systems for the current MSE and

DWTS have been deployed. In areas where sharing with space systems is feasible, the 1700-

1710 MHz band may also considered for use as necessary by TRR systems. 

With the procurement of the HCLOS TRR system (AN/GRC-245), TRR operations using

HCLOS systems would use 45 MHz of alternate spectrum within the HCLOS tuning range in

the new protected areas to compensate for the loss of the 1710-1755 MHz band. As the new

HCLOS radios are phased in, the use of the 1710-1755 MHz band would be phased out in the 3G

protected areas, allowing full IMT-2000 build-out nationwide. Spectrum may also be made

available for TRR use, as necessary, in the 2200-2290 MHz band in locations where sharing with

the space downlinks is shown to be feasible.

Under this option, MSE systems would not need replacing in the near-term, other than as

currently programmed, nor suffer restrictions when operating. The DWTS, however, will need a

program to replace the current system with equipment possessing a tuning range similar to the

HCLOS. ACTS systems and the SGLS stations would be unaffected. Also, IMT-2000

operations would be unrestricted in the 1710-1755 MHz band nationwide, other than within, in

the near-term, the new 3G protection areas. Federal conventional fixed systems in the 1710-

1755 MHz band would be relocated in accordance with the reimbursement rules established by

NTIA. DOD systems in the 16 OBRA-93 protected areas, including the DWTS, would be

reimbursed to relocate. Certain other DOD systems, such as PGMs, will require engineering

study to determine the feasibility of relocating to the remaining 1755-1850 MHz band, or other

bands as appropriate.

 

2. Potential Sharing Conflicts

2110-2150 MHz Band

Sharing in the 2110-2120 MHz band will be similar to the discussion under Option 2. 

During command link operations at Goldstone, California, it is likely that service disruption

would be experienced by IMT-2000 mobile receivers when attempting to operate in the 2110-

2120 MHz band within the areas surrounding Goldstone. As a result, these areas would not be

available for continuous IMT-2000 reception. See Appendix A for a NASA analysis regarding

the calculation of a protection contour surrounding the Goldstone facility.

New 3G Protection Areas

The DOD Final Report addresses the requirements for Army and Navy/Marines to

conduct large-scale exercises using TRR systems. Several locations are mentioned where these

exercises occur. As a preliminary proposal for comment, it is suggested that from the list of

areas mentioned, the training areas of 1) Camp Pendelton, California; 2) Ft. Irwin, California;
4-22

3) Ft. Bragg, North Carolina; and 4) Camp LeJeune, North Carolina be considered as candidates

for the new 3G Protection Areas. This would provide an Army and Navy/Marine training area

on each coast of the United States for large-scale exercises. Neither the reduction in protection

areas nor the proposed new locations have been examined by the DOD to determine whether

national security training and exercise requirements could be supported under this option.

Alternate Frequency Bands for Federal Systems

1. Discussion

The concept of sharing has been a primary consideration for the accommodation of IMT2000 systems thus far in this report. However, NTIA has not received any comments from

industry that support our proposal for a technological solution to co-channel sharing with Federal

systems. Absent a viable sharing scenario, either IMT-2000 operators would not be

accommodated, or accommodated on a secondary basis, or Federal systems would migrate to

alternate bands at the expense of the incoming commercial operators. Since the objective of this

study is to consider the accommodation of IMT-2000, the possible relocation of Federal systems

must be included as alternatives to sharing.

Federal systems operating in the 1710-1850 MHz band would require a band that is

equivalent from a technical and regulatory perspective. This is termed a comparable band for

the purposes of this report. The DOD Final Report examined several frequency bands as

alternatives to the 1755-1850 MHz band. These bands are studied in the DOD Final Report’s

appendices associated with the subject radio system. The reader is referred to the DOD Final

Report for details of the examination of alternate bands. For a complete discussion, see the

appendices of the DOD Final Report where alternate bands are discussed in detail for each

system. A brief summary of these examinations follows.

2. Alternate Bands for DOD Systems

Satellite Control Stations

The DOD satellite control stations have no existing comparable band in which to move. 

The band most suitable for this purpose is the 2025-2110 MHz band. This band currently

accommodates the unified S-band systems that are used by NASA to control NASA satellites,

and for control and communications with the space platforms associated with the manned space

flight program. Technically, this band is suitable for satellite control uplinks. From a regulatory

perspective, there are two major drawbacks. First, although the Federal Government has a

co-primary allocation in this band, under US Footnote 342, however, Federal earth stations

cannot impede the deployment of a variety of civil stations operating in the Auxiliary Broadcast

Service. NASA is currently able to coordinate its limited geographically defined use with the

electronic news gathering (ENG) operators. However, considering the number of SGLS sites,

and the amount of use, coordinating with ENG users becomes problematic, and ultimately,

unacceptable. If SGLS were to move to this band, the band would need to be reallocated to

ensure Federal space operations were fully protected.
70 See DOD Final Report, at B-11 supra note 6.

4-23

There are several issues that must be addressed and resolved that relate to migration of

SGLS to the 2025-2110 MHz band.

It is important that mission capability provided to end users by U.S. space systems will

not be degraded. Therefore, the Federal Government will need to maintain assured access to the

1761-1842 MHz band to satisfy mission objectives until the last satellite is no longer

functioning. Federal satellites currently in orbit or awaiting launch must be supported to the

end-of-life in the 1761-1842 MHz band, which could continue until 2030. It is expected that

current regulatory provisions will remain in effect in the 1761-1842 MHz band through any

period of SGLS migration.

Domestic regulatory provisions will need to be addressed so that the Federal Government

has assured access to the 2025-2110 MHz band for Launch, Early Orbit Operations, and

Anomaly Resolution and other space operations currently being performed in the 1761-

1842 MHz band, with Federal Government allocation status that is equivalent to that currently

provided in the 1761-1842 MHz band. Results of the WARC-92 have shown that sharing

between high density and conventional land mobile systems on the one hand, and space services

on the other hand is not feasible.

The DOD must determine if it is technically and operationally feasible to conduct

satellite TT&C in the 2025-2110 MHz band. Further, the United States will need to determine if

there is a reasonable prospect for international coordination of DOD satellite networks in the

2025-2110 MHz band.

Currently, the 2025-2110 MHz band is extensively used by major Federal Government

users (i.e., NASA and NOAA) for satellite uplinks. The 2025-2110 MHz band is also widely

used by other administrations for space operations. There is an extensive use of this band for

TT&C of manned and unmanned Earth-orbiting satellites and space vehicles either through

Earth-to-space links for satellites in all types of orbits or through space-to-space links using

geostationary data relay satellites. All satellites are required to be coordinated internationally,

which takes a significant time to accomplish. Current DOD satellites have been coordinated in

the 1761-1842 MHz band with little problems, since few other administrations use this band for

satellite control. The consummation of international coordination for constellations of U.S.

Federal satellites for TT&C in the band would be a challenging task.

Also, an option mentioned in the DOD Final Report70 considers operating some uplinks

in the frequency bands used in the satellite’s mission. This option, however, is not available to

satellites without a separate communication function (e.g., GPS). SGLS operations for satellites

with a communications function would then be limited to launch, early orbit, and anomaly

resolution support operations. It remains to be seen if coordination of these uses internationally

would be considerably easier.
71 Id. at C-36 through C-45.

72 Id. at E-9

4-24

Tactical Radio Relay

The MSE and the DWTS systems are transportable, fixed systems. Although other bands

could accommodate a conventional fixed service, the transportability and rapid set-up

requirements of the MSE/DWTS operations would cause the use of bands above 3 GHz be

unsuitable for this type of operation. The DOD Final Report addressed several frequency bands

for possible use by the TRR systems.71 The 2025-2110 MHz, 2200-2290 MHz, 2500-

2690 MHz, and 4400-4940 MHz bands were examined for comparability. The DOD Final

Report concluded that no comparable bands were found.

Air Combat Training Systems

The DOD Final Report indicates that the ACTS could possibly be reaccommodated,

either within the remaining portion(s) of the band, or by relocation of certain links in alternate

bands. EMC studies of the implications to aircraft co-site systems will be required prior to any

final decision.

Conventional Fixed Systems

The DOD Final Report addressed alternate bands for the conventional fixed microwave

operations. Based on engineering judgment, the DOD Final Report concluded that 84 percent of

the ACE fixed links have path lengths that would allow them to be replaced with equipment

operating in either the 4400-4940 MHz or 7125-8500 MHz bands as single hop links. The

remainder of the ACE links could be replaced with two-hop systems operating in one of the

above alternate bands. Other DOD conventional fixed systems may also be able to operate in the

above alternate bands, but further analysis would be required.72

Other Systems

Other systems that were addressed in the DOD Final Report are the Land Warrior

Wireless Local Area Network, the Combat Identification for the Dismounted Soldier, the Pointer

(FQM-151A) and the Exdrone (BQM-147A) unmanned aerial vehicles (UAV), the TCM-601

TOSS ordinance scoring system, and telemetry operations at the Aberdeen Test Center, located

at Aberdeen, Maryland. These systems are considered in Appendix E of the DOD Final Report. 

Of these systems, only the UAVs were able to be placed in alternate frequency bands (1350-

1390 MHz and 2200-2290 MHz). The DOD also studied several PGMs operating in the band. 

The results are contained in a classified annex to the DOD Final Report. It should be noted that

not all DOD systems were addressed, since there are more than 200 different DOD systems

currently authorized to operate in the 1710-1850 MHz band. All these systems will need to be

addressed.
4-25

Considerations for Reallocation

The DOD has stated that the DOD cannot accept any degradation to mission capability

resulting from a spectrum reallocation action. The DOD says that loss of access to spectrum,

above and beyond that already relinquished as a result of the OBRA-93 and the BBA-97, would

jeopardize the DOD’s ability to execute its mission.

In implementing any of the options involving band segmentation, many Federal systems

in the 1755-1850 MHz band may need to be either relocated to different frequency bands or

modified to operate in the remaining portions of the band. Major performance, compatibility,

funding, and regulatory issues would have to be thoroughly addressed before any relocation

could begin. A major uncertainty with the concept of large-scale relocation is that critical issues

regarding the costs, risks, and engineering efforts to assure the incumbent systems in the

alternate bands are protected are not addressed. In the aggregate, this would be a complex,

costly, and lengthy process. The major risk in relocating major national defense systems is the

uncertainty of future successful mission accomplishment.

Specifically, there are several issues that must be resolved before any spectrum can be

made available in the1755-1850 MHz for reallocation, including continuity of essential

government operations, interference, and regulatory protection of Federal Government systems

during any migration period, assurance of comparable spectrum available to which Federal

Government systems can relocate, and timely resolution of any regulatory actions necessary to

make such spectrum available.

If a decision is made to vacate all or a part of the 1755-1850 MHz band, it is expected

that the Federal Government will retain protected access for those systems that have not yet

migrated. New users in the band would be allowed to operate to the extent that their operations

do not interfere with remaining Federal systems.

The DOD states that the wide variety of systems operating in the 1755-1850 MHz band

are unique to this band and crucial to the defense of the United States and its allies. The DOD

further states that the United States and its national defense forces would be at a substantial

strategic and tactical disadvantage in combat and the outcome of battles and peacekeeping

operations could be jeopardized if the DOD were to lose its use of the band without provision of

comparable spectrum and satisfaction of other conditions as presented in Section 2, Essential

Conditions, of the DOD Final Report (Appendix D to this report).

The DOD also examined whether the DOD can fully vacate the 1755-1850 MHz band to

accommodate IMT-2000. The DOD states that the most optimistic estimates, based on funding

being available in FY02 to accomplish programmatic actions, indicate the DOD would be unable

to totally vacate this band until well beyond the time lines established for this study (i.e., by

2003, 2006, or 2010). Estimates indicate that, regardless of funding, vacating the band could

not be accomplished for most non-space systems until 2010 and beyond; and legacy space

systems would require continued protected access to this spectrum until 2017 and beyond. 

These dates are also predicated on funding availability in FY02. The preliminary estimated cost

to transition DOD systems out of the band in accordance with these time lines is estimated to be
73 See National Defense Authorization Act 1999, Pub. L. No. 106-65, 113 Stat. 512 (Oct. 5, 1999).

4-26

$4,354 million in Then Year dollars (TY$) or $3,951 million in FY02 dollars. Migration prior to

these dates would require premature system termination, which would have extremely serious

implications to the DOD’s ability to effectively execute its mission. Relocation from the band

would require comparable spectrum that is operationally suitable. The DOD Final Report,

however, indicates operationally suitable comparable spectrum may not be readily available.

Other Issues

International Concerns

Other countries are expected to implement advanced wireless mobile systems in the

1755-1850 MHz band. A particular concern in this case is the potential impact to United States

space borne and airborne receivers since these receivers will be subject to the emissions of

wireless systems operating in other countries.

National Defense Authorization Act of Fiscal Year 200073

Sharing scenarios have been postulated in this report as a means of accommodating IMT2000 systems. However, if sharing is determined not to be feasible, then either Federal systems

in the band segments required for IMT-2000 operation would be relocated, and the band

reallocated, or IMT-2000 services will not be implemented in the band. 

Further, with respect specifically to surrender of spectrum in which the DOD is a primary

user, the NDAA for Fiscal Year 2000 also requires that:

 “(A) the National Telecommunications and Information Administration, in consultation

with the Federal Communications Commission, identifies and makes available to the

Department for its primary use, if necessary, an alternative band or bands of frequencies

as a replacement for the band to be so surrendered; and

(B) the Secretary of Commerce, the Secretary of Defense, and the Chairman of the Joint

Chiefs of Staff jointly certify 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 such

alternative band or bands provides comparable technical characteristics to restore

essential military capability that will be lost as a result of the band of frequencies to be so

surrendered.”

The DOD would be regarded as a primary user in the 1710-1755 MHz band in the 16

protected areas shown in Figure 12, and in the 1755-1850 MHz band, thus requiring the approval

actions noted above.
74 The agencies are: DOD, USDA, DOE, DOJ, FAA, DOI, NASA, USCG, FEMA, NOAA, and the Department

of the Treasury.

75 Each assigned radio station is classified by the service in which it operates permanently or temporarily

(e.g., fixed, mobile). For Federal stations, various classes of stations are defined in Chapter 6 of the NTIA Manual. 

A list of station classes is given at the end of Appendix C.

5-1

V. Estimates of Costs for Relocation of Federal Systems

Discussion

This section provides an examination of the estimated costs associated with the potential

relocation to alternate frequency bands of current Federal operations within portions of the 1710-

1850 MHz band. Descriptions of the systems operating in the 1755-1850 MHz band are

provided in Section III. Included in this examination is a discussion of the estimated costs

associated with each of the various segmentation options that would allow portions of the 1710-

1755 and 1755-1850 MHz bands to be used for 3G accommodation, as discussed in Section IV. 

This section does not address the feasibility of whether any displaced systems can be adequately

accommodated in alternate frequency bands. Further, because of certain factors (e.g., alternate

frequency bands) for which there may currently be some uncertainty, the estimated costs as

shown in this report are not necessarily identical to those costs that NTIA, under its

reimbursement rules, will be required to transmit to the FCC prior to auctions.

In September 2000, the Administrator of NTIA sent letters to 11 Federal agencies74 that

had significant usage of the 1755-1850 MHz band requesting the costs and operational impacts

resulting from a potential migration from the current operations in the 1755-1850 MHz band to

alternate bands. As a follow-up to this request, Federal agencies were contacted to provide

additional information regarding the cost estimates associated with the various segmentation

options as discussed in Section IV. Appendix B contains the submissions received from the

various Federal agencies. The cost estimates for relocating DOD operations are contained in

Appendix D. All submissions received were submitted to the Office of Management and Budget

for review.

The GMF is the Federal Government’s master list of authorized frequency assignments.

As noted earlier, an assignment in the GMF does not necessarily represent the number of

transmitters associated with each assignment. There may be numerous transmitters and receivers

operating under a single frequency assignment. In addition, the GMF does not contain all of the

classified Federal frequency assignments. The majority of assignments are in the fixed service,

followed by mobile, space, land mobile, and aeronautical-mobile services. From a spectrum

management perspective, each class of radio station75 presents a different degree of difficulty

when being considered for relocation, and thus each station class must be considered on a

case-by-case basis. Table 3-2 provides the GMF assignment count by station class per agency

and radio service in the 1755-1850 MHz band as of January 2001. In general, agency

submissions reflected the number of their assignments for November 2000, although some

agencies have provided updates.
5-2

Conventional fixed service assignments for stations that operate in the 1755-1850 MHz

band are on discrete frequencies and operate at defined fixed locations. It should be noted that

frequencies for fixed microwave assignments operating in the 1755-1850 MHz band are typically

paired with frequencies in another portion of the 1755-1850 MHz portion of the band or in the

1710-1755 MHz band. A fixed microwave station operating on frequency 1761 MHz, for

example, might be paired with another fixed link assignment operating on a frequency such as

1712 MHz or 1812 MHz. Typically, a frequency separation range of 50 to 80 MHz is required

between fixed assignment pairs to ensure proper operation. Further, transportable fixed systems,

such as TRR systems, have the capability to tune throughout the 1350-1850 MHz band and are

used in several portions of their tuning range other than the 1710-1850 MHz band. However, the

uncompensated loss of any significant spectrum that is within the tuning range would result in

the system’s inability to successfully accomplish its mission, and, therefore, would require a

replacement of the entire system.

Other systems, such as mobile systems operating in the 1755-1850 MHz band may

operate on authorized frequencies at various locations, or while in motion in defined areas. 

However, some mobile systems, (e.g., audio/video surveillance), may be authorized to operate

anywhere in the US&P.

Federal space systems are one of the most difficult operations to consider for relocating

to other frequency bands. Federal agencies using space radiocommunications have unique

mission requirements, ranging from weather forecasting to nuclear detonation detection. Further,

satellites are often limited to single- or dual-frequency use and cannot be retuned to other

frequencies while in orbit. As explained previously, there are few frequency bands that can

accommodate Federal satellite operations.

Another factor to consider regarding relocation is the time it would take to relocate

existing operations to another frequency band. The time to relocate would vary depending on the

type of equipment, mission, and location of the operation. For conventional non-military fixed

systems, COTS-type of equipment may be readily available. As a result, these types of systems

could be redeployed within a few years. These types of systems could be established in alternate

bands relatively quickly once relocation funds were made available. For military systems,

extensive lead times may be required to relocate to alternative frequency bands since these types

of systems are typically complex and may require extensive re-engineering and development

efforts. Complex military systems typically take in excess of 10 years to be fully deployed once

funding is made available.

The 1710-1755 MHz segment of the 1710-1850 MHz band is currently allocated to the

Federal Government exclusively for fixed and mobile services on a primary basis, but was

identified by NTIA for transfer to the FCC under OBRA-93 as a mixed-use band. Because of the

extensive Federal use of this band, the reallocation of this band segment from the Federal

Government to the private sector will impact, in varying degrees, most major Federal

Government agencies.

It is assumed that all Federal agencies would be fully reimbursed for all marginal costs

associated with relocation from the 1755-1850 MHz band, or that facilities will be replaced by
76 It is important to note that the precise deflationary factor for different DOD systems may vary because of

different timing assumptions for each system.

77 NTIA, U.S. Department of Commerce, NTIA Special Publication 01-44, Assessment of Electromagnetic

Spectrum Reallocation (Jan. 2001).

5-3

comparable facilities by incoming commercial operators. Factors influencing marginal

relocation costs are: 1) whether the system can be retuned to another part of the band or must be

replaced by a system that operates in another band, 2) if moved to another band, what new

equipment must be purchased, 3) if moved to another band, must additional stations be

established to maintain the connectivity, 4) will any research and development costs be required,

and 5) other miscellaneous marginal costs. All these factors are not known at present, and some

cost estimates are averaged over several frequency assignments, so the estimates for relocation

costs may not reflect the actual per-assignment costs. Some of these unknown cost factors are

discussed below.

Cost Estimates by Frequency Band

The information contained in the agencies’ submissions (Appendix B) and the DOD

Final Report (Appendix D) was used to estimate the costs associated with relocating from the

1755-1850 MHz band or with implementing the various segmentation/sharing options. Federal

civil agencies and DOD used somewhat different conventions to report costs. Consistent with

DOD’s budgeting conventions, DOD estimated its costs in “Then Year Dollars” (TY$), which

reflect expected inflation through the year funds are obligated. These years vary depending on

the system. Federal civil agencies submitted estimates in current year dollars, assumed to be

FY02. In order to estimate total relocation costs for a given option, DOD and Federal civil

agencies’ estimates have been made consistent. Since DOD cost estimates for each system as

well as the total cost for each option are given in TY$s, a deflationary factor supplied by the

DOD was used to determine an equivalent FY02 dollar amount. This deflationary factor of

1.10276 was used to covert the DOD total cost for a given option in TY$s to FY02 dollars. For

example, if the combined DOD cost estimate for an particular option was $4,354 million (TY$),

this would be equivalent to $3,951 million in terms of FY02 dollars. DOD cost estimates are

shown in both TY$ and FY02 dollars. All cost estimates for the 1710-1755 MHz band in Table

5-1 are presented in FY02 dollars.

1710-1755 MHz Band Costs

Title X of the NDAA for Fiscal Year 2000 (Defense Act) required the Secretary of

Commerce, in coordination with the Chairman of the Federal Communications Communication,

to convene an interagency review and assessment of, among other things, impact of the

reallocation of Federal Government spectrum to non-Federal use, in

accordance with the amendments made by Title VI of OBRA-93 and Title III of BBA-97 and the

implications for each such reallocation to the affected Federal executive agencies.

In January 2001, the Secretary of Commerce submitted to the President and the Congress

the impact assessment study of the reallocated spectrum called for by the Defense Act. This

study included the estimated reallocation costs of the 1710-1755 MHz band.77 In the OBRA-93
78 These assignments were current as of February 1999. The NTIA NPRM on mandatory reimbursement proposes

that only “old assignments” within the affected bands, including the 1710-1755 MHz band would be eligible for

reimbursement. In the NPRM, an old assignment is characterized as one that was authorized or submitted for

authorization on or before October 17, 1998, because NTIA conducts EMC analysis on such request for frequency

authorization and the process to authorize a request could take up to three months. The number of assignments that

are entitled to reimbursement may currently be smaller than these numbers.

5-4

Report, it was noted that some Federal civil agencies’ fixed microwave links in the 1710-

1755 MHz band may be paired with links in the 1755-1850 MHz band. The reimbursement

strategy contained in that report is that if any part of a fixed service link is impacted and cannot

be tuned and accommodated in another part of the same band, the entire link must be replaced. 

For the purposes of cost estimating, it is assumed that the links will be replaced rather than

retuned. Because of that, in some instances the relocation cost estimates for a band may include

costs for systems that operate partially in bands other than that for which the cost is estimated. A

summary of the relocation costs per agency for the 1710-1755 MHz band is shown in Table 5-1. 

Note that $413 million was used throughout this report for this band.

Table 5-1 

Total Estimated (OBRA-93) Relocation Costs For The 1710-1755 MHz Band

Federal Agency Number of Frequency

Assignments78

Estimated Relocation

Costs (Millions)

Department of Agriculture 471 $48

Department of Defense 880 $38-$138a

Department of Energy 294 $3b

Department of the Interior 84 $8-$13

Department of Justice 204 $55c

National Aeronautics and Space

Administration 5 $1

Department of Transportation 153 $109d

 Department of the Treasury 22 $4-$46e

Total 2,113 $266-$413f

Notes:

a A revised and combined reallocation costs for the DOD (i.e., Army, Navy, and Air Force) is provided in the DOD

Letter Report to the Chairman of the Committee on Armed Services of the United States Senate (The Hon.

Strom Thurmond), Dec. 16, 1998. However, due to some reclaimed spectrum (i.e., 4635-4685 MHz band), the

total OBRA-93 reallocation costs for DOD is adjusted to $226-$346 million (non-reimbursable) and $38-$138

million (reimbursable). Lower cost ($38M) applies if the mission can be accomplished with reduced spectrum

capability. The higher cost ($138M) applies if mission function has to relocate to alternative spectrum.

b This cost does not include the protected fixed Federal Power Agencies’ (FPA) service links.

c This is an updated cost recently provided by DOJ. It includes INS links in the 1710-1850 MHz band.

d This cost could significantly increase if unacceptable interference to or from non-Federal systems necessitates

major hardware changes to Federal systems.

e This is an updated cost recently provided by the Treasury. It is unknown whether the Rainbow Microwave

System in Hawaii, which is currently on the protected list, will be eligible for reimbursement. The higher cost is

based on replacement of this system.

f This total is assumed to be in FY02 dollars.
79 Several agencies’ submissions in Appendix B assumed prior knowledge on part of the reader that the affected

systems are fixed microwave links.

80 To convert TY$ to FY02 dollars divide TY$ by 1.102.

5-5

1755-1850 MHz Band Costs

Based on the submissions provided by both the Federal civil agencies (Appendix B ) and

the DOD Final Report (Appendix D), cost estimates for relocating their entire operations out of

the 1755-1850 MHz band are summarized in Tables 5-2 and 5-3, respectively. Table 5-2

indicates that an estimated cost of $688.8 million (FY02) would be required to vacate the 1755-

1850 MHz band for Federal civil agencies. The majority of the costs for the Federal civil

agencies are for conventional fixed microwave links systems.79 Table 5-3 indicates that an

estimate of $4,354 (TY$)/$3,951 (FY02)80 million would be required for the DOD to vacate the

1755-1850 MHz band. Combining Tables 5-2 and 5-3 would result in an estimated cost of

$4,640 million (FY02) to vacate the 1755-1850 MHz band.

The DOD Final Report indicated that its cost estimates should be used only as guidelines

in determining the final relocation expenses. Estimated costs are based on very specific

assumptions and schedules. DOD states that to transition completely out of the band is not

possible for all non-space systems until the year 2010 or later, and for space systems, it is not

possible until the year 2017 or even to the year 2030 for some satellites. These time frames for

relocation from the 1755-1850 MHz are based on funds received starting in FY02. If funds are

not received as of FY02, then the DOD costs may change.

Many of the Federal civil agencies in their submissions expressed concerns about

estimating the cost to relocate out of the 1755-1850 MHz band, since many factors critical to

determine costs for relocation are unknown (e.g., selection of one or more alternative frequency

bands). For example, available spectrum below 3 GHz to accommodate these relocated systems

is severely limited. Use of spectrum above 3 GHz in some cases may adversely affect

communications support to its missions. Potential frequency bands for relocating fixed

microwave systems that are currently operating in the 1755-1850 MHz band are the 4400-

4940 MHz and the 7.1-8.5 GHz (7/8 GHz) bands. Due to the propagation characteristics of

microwave signals in higher frequency bands, additional relay stations may be needed to

maintain the same performance as in the 1755-1850 MHz band. This may require additional cost

in terms of additional repeaters and associated real estate.

In addition, moving 1755-1850 MHz fixed links to higher frequency band poses

additional problems in that it necessitates a more rigid antenna support structure. At the higher

frequencies the antenna has a narrower beam width and, in order not to compromise the

antenna’s directional orientation, existing towers may need to be refurbished or new, more rigid

towers may have to be constructed to prevent the tower from swaying to an unacceptable degree. 

These additional requirements will also add to the relocation cost.
5-6

Table 5-2

Total Estimated Federal Civil Agency Relocation Costs For The 1755-1850 MHz Band

Federal Agency Number of Frequency

Assignments

Estimated Relocation Costs

(Millions)

Department of Agriculture 805a $72.45b

Department of Energy 505 $340.56c

Department of Justice 241 $63.12d

Federal Aviation Administration 212e $65.23f

Department of the Interior 197g $27.95h 

U.S. Coast Guard 37l $13.9j

Department of Commerce 14k $3.54l

Department of the Treasury 34 $88.5m

National Aeronautics and

Space Administration 15n $13.59o

Total 2,060 $688.8p

Notes: 

a Based on 671 GMF fixed assignments, moving to 4 GHz or 7/8 GHz bands would require 20% additional sites

or an equivalent 805 assignments.

b Total cost was calculated at $90K per assignment.

c Total includes $35M satellite replacement costs at Albuquerque, NM and various other operations.

d Cost includes 222 fixed assignments totaling $60M (average cost of $270.3K per assignment), 13 video

(fixed/land mobile) systems totaling $3.1M, and six robotic (land mobile) links at totaling $22K.

e Based on telephone conversation with FAA personnel (2/5/01) the total number of assignments was reduced

from 221 to 212.

f Cost reflects updated information based on 212 fixed assignments at an average cost of $307.7K per

assignment. Total cost includes $17.13M for additional repeaters and equipment to move to higher frequency

bands (i.e., 7/8 GHz).

g Based on combining 64 TVA fixed assignments and 133 DOI fixed assignments totaling 197 assignments.

h Cost reflects combining 64 TVA fixed assignments and 133 DOI fixed assignments at $125K per assignment

and $150K per assignment, respectively.

i This number of GMF fixed assignments was based on updated information.

j In its submission, USCG included $12M replacement cost as its share to replace Treasury’s Rainbow

Microwave System in Hawaii. This $12M cost is not included in the estimate in the table since Treasury has

included it as part of the total replacement cost for the Rainbow Microwave System (footnote m). Total includes

37 fixed assignments at $375.7K per assignment.

k Based on updated information via telephone conversation with DOC personnel (2/6/01) resulting in a total of 14

total assignments.

l Includes $275K cost (over 10-year period) to acquire a commercial T1 line for two assignments, 10 fixed

assignments total $3.2M (average cost of $320K per assignment), and two assignments totaling $69K for

operations at NIST. One experimental assignment for ITS in the 1850-1990 MHz band was not considered.

m Total includes $47M total replacement cost for the Rainbow Microwave System in Hawaii , seven fixed

assignments totaling $1.2M (average cost $171.4K per assignment) over 10-year period to convert to

commercial circuits, 18 fixed tactical assignments totaling $40M (average cost $2.22M per assignment), and

two aeronautical assignments totaling $300K. 

n This is an updated clarification of assignment count based on NASA telephone conversation (2/9/01) which

deleted five assignments from the 20 assignments in the GMF.

o Total includes replacement at Wallops Flight Facility ($2M), Dryden Flight Research Center ($11M for

ground/airborne based equipment to relocate to a new band), Kennedy Space Center ($40K), and Langley

Research Center ($550K). 

p This total is assumed to be in FY02 dollars.
81 Details of the DOD costs are given in the DOD Final Report (Appendix D) at B-12, B-13, C-7, D-10, E-45, E46, and classified supplement. 

82 See NTIA NPRM, supra note 17.

5-7

Table 5-3

Total Estimated DOD Relocation Costs For The 1755-1850 MHz Band81

 Agency Estimated Relocation Costs (Millions)

Department of Defense Beyond 2010a

Total $4,354 (TY$)/$3,951 (FY02)b

Notes:

a The DOD states that relocating systems prior to 2010 is not feasible, so no costs are given.

b To convert TY$ to FY02 dollars divide TY$ by 1.102.

Further, during the transition period to other bands, the Federal agencies’ operational

capabilities should continue to be supported. It is noted that a number of frequency assignments

in the 1755-1850 MHz band supports, inter alia, law enforcement and safety-of-life operations. 

These operations should not be jeopardized.

Replacement of some national security systems, due to their specialized missions, may

require re-engineering and development efforts, resulting in several years from reimbursement to

deployment. This would be true for systems such as the Navy’s DWTS, since there is no

currently planned replacement system that could be accelerated. Also satellite control systems

cannot be replaced completely while current satellites are still operational. This latency factor

for systems should be considered in order to maintain operational readiness. 

Reimbursement for relocation, including the definition of marginal costs, will follow the

rules established by NTIA as a result of the NPRM for reimbursement82 for the 1710-1755 MHz

band. To determine actual costs to relocate specific operations out of the 1755-1850 MHz,

further discussions would be required between Federal agencies and IMT-2000 operators.

Cost Estimates by 3G Accommodation Option

Three approaches to sharing and/or segmentation of the 1710-1850 MHz band are

provided in Section IV of this report. Within the 1755-1850 MHz band, the various options will

have costs associated with relocating current operations from each of the 1755-1780 MHz, 1780-

1790 MHz and 1805-1850 MHz sub-bands. The cost given for the various options assumes all

operations within a particular sub-band would be relocated to an alternative frequency band(s). 

However, requiring all operations to vacate the entire sub-band may not be necessary if some

sharing is possible and, thus, would result in potentially lower cost as compared to vacating the

entire sub-band. Similarly, if systems could be configured to operate within the existing band 

then the costs may be significantly less when compared to vacating the entire sub-band.
5-8

To simplify cost estimates, the 1755-1780 MHz and 1780-1790 MHz sub-bands have

been combined into one 1755-1790 MHz sub-band. This section provides a discussion of the

estimated costs associated with each option. The 1790-1805 MHz portion of the band was

excluded as part of any segmentation option and was not evaluated separately for relocation

costs. However, the cost would be included in the relocation cost for the entire 1755-1850 MHz

band as provided in Table 5-2 and Table 5-3.

 To estimate the cost for Federal civil agencies for each sub-band, submissions given in

Appendix B were used. NTIA’s initial request was for information relating to relocating the

entire 1755-1850 MHz band. As other options were considered, additional information was

requested from the agencies. Due to time constraints, some of these agencies were not able to

fully assemble the additional information in the available time to provide sufficient detail for

estimating the costs for relocating operations from the various sub-bands within the 1755-

1850 MHz band. If sufficient details were not provided by the agencies, certain assumptions and

extrapolations were used to estimate the costs for relocating systems for each sub-band.

For conventional fixed assignments, if the number of assignments was not provided, the

number of assignments listed in the GMF was used, as shown in Tables 3-3, 3-4, and 3-6. The

cost estimate for conventional fixed assignments for each sub-band was determined by

multiplying the average cost per assignment by the number of assignments. Any variations in

this method or discrepancy between agency assignment count and the GMF count is noted in the

table for each sub-band cost estimate.

Non-conventional fixed systems, such as TRR, have the capability to tune on many

frequencies within the 1755-1850 MHz band as well as in other frequencies bands. If one of the

sub-bands contained assignments for this type of system, and the system could not satisfy

mission support requirements by operating on the remaining spectrum, then the cost to replace

the entire system was entered. While the cost of the entire systems may be included for each

sub-band cost estimate, they would not be counted more than once if sub-band costs were

aggregated. As a result, sub-band costs may approach costs equivalent to relocation of systems

from the entire 1755-1850 MHz band.

The count of assignments in a sub-band may in some cases be biased, since some

assignments may have center frequencies exactly on a band or sub-band edge and would impact

more than one sub-band. It is noted that when the emission bandwidth of an assignment is such

that it occupies parts of more than one sub-band, only one sub-band was used. The cost

estimates are based on assignments contained in the GMF listing as of January 2001, unless

otherwise noted in the agencies cost data submission (Appendix B) since assignments may have

increased or decreased since then. To take into account these unknown factors, further

discussions would be required between Federal agencies and IMT-2000 operators to determine

actual costs on a case-by-case basis to relocate specific operations out of any portion of the 1755-

1850 MHz band.

The DOD Final Report, contained in Appendix D, provides cost estimates for the

segmentation options considering both the 1755-1790 MHz and 1805-1850 MHz portions of the

1755-1850 MHz band.
5-9

Costs for Option 1

Option 1 considers in-band pairing of the 1710-1850 MHz band. Under Option 1, the

1710-1755 MHz band would be considered for transmitting IMT-2000 mobiles and the 1805-

1850 MHz band for transmitting IMT-2000 base stations. The 1710-1755 MHz band was

identified by NTIA for transfer to the FCC under OBRA-93 as a mixed-used band with an

estimated cost of between $266-$413 million as shown in Table 5-1. This would clear the 1710-

1755 MHz band of most Federal operations, with an exception of systems in the 16 OBRA-93

protected areas and the Federal Power Agencies’ (FPA) fixed service links. However, since

sharing with the FPA links is problematic, the estimated costs for the relocation of FPA links is

added for all options. The current number of protected fixed FPA links in the GMF as of

January 2001 was 318. The cost to relocate the protected FPA was calculated assuming an

average cost of $500K per assignment, multiplied by 318 assignments results in a total of $159

million.

The cost to clear the 1805-1850 MHz portion of the band is estimated to be $332.7

million for the Federal civil agencies and $2,802 TY$ /$2,543 (FY02) million for the DOD as

summarized in Tables 5-4 and 5-5, respectively.

Table 5-4

Total Estimated Federal Civil Agency Relocation Costs For The 1805-1850 MHz Band

Federal Agency Number of Frequency

Assignments

Estimated Relocation Costs

(Millions)

Department of Agriculture 427a $38.43b

Department of Energy 260c $138.32d 

Department of Justice 130 $35.56e

Federal Aviation Administration 110 $33.85f

Department of the Interior 97 $13.85g

U.S. Coast Guard 19h $7.14i

Department of Commerce 8j $1.94k

Department of the Treasury 14 $63.05l

National Aeronautics and

Space Administration 4m $0.59n

Total 1,069 $332.7o

Notes:

a Based on 356 GMF fixed assignments, moving to 4 GHz or 7/8 GHz bands would require 20% additional sites

or an equivalent 427 assignments.

b Cost was calculated at $90K per assignment.

c Includes 260 assignments. Based on updated information.

d Costs includes various assignments totaling $138.32M.

e Total includes 120 fixed assignments at $270.3K per assignment, $3.1M costs to replace video/surveillance

equipment and $22K to replace robotic equipment.

f Cost reflects updated information based on 110 fixed assignments at average cost of $307.7K per assignment.

g Includes both DOI (69) and TVA (28) fixed assignments at $150K per assignment and $125K per assignment,
83 Details of the DOD costs are given in the DOD Final Report (Appendix D) at B-12, B-13, C-7, D-10, E-45, E46, and classified supplement.

5-10

respectively.

h The 37 fixed assignments were assumed to be distributed as follows: 19 assignments in the 1805-1850 MHz

band and 18 assignments in the 1755-1790 MHz band.

i In its submission, USCG included $12M replacement cost as its share to replace Treasury’s Rainbow

Microwave System. This $12M cost is not included in the estimate in the Table since Treasury included it as

part of the total replacement cost for the Rainbow Microwave System. Total was based on 19 fixed

assignments at $375.7K per assignment.

j One experimental assignment for ITS in the 1850-1990 MHz band was not considered.

k Includes $275K cost (over 10-year period) to acquire a commercial T1 line, five fixed assignments totaling

$1.6M, and two fixed assignments totaling $69K.

l This includes $47M total replacement cost for the Rainbow Microwave System in Hawaii, three fixed

assignments at $171.4K per assignment to convert to commercial circuits over 10-year period, and seven

tactical assignments at $2.22M per assignment.

m This is an updated clarification of assignment count based on NASA telephone conversation (2/9/01).

n Cost total includes replacement at Kennedy Space Center ($40K), and Langley Research Center ($550K).

o This total is assumed to be in FY02 dollars.

Table 5-5

Total Estimated DOD Relocation Costs For The 1805-1850 MHz Band83

 Agency Estimated Relocation Costs (Millions)

Department of Defense Beyond 2010a

Total $2,802 (TY$)/$2,543 (FY02)b

Notes:

a The DOD states that relocating systems prior to 2010 is not feasible, so no costs are given for prior years.

b To convert TY$ to FY02 dollars, divide TY$ by 1.102.

The estimated total cost for Option 1 is the aggregated cost for the 1710-1755 MHz band

(Table 5-1), excluding the 16 protected areas, plus FPA, and the Federal civil agencies and

DOD costs for the 1805-1850 MHz band. This cost is $3,448 million (FY02). Sharing the

band without impact to DOD operations would significantly reduce the cost.
5-11

Costs for Option 2

In Option 2, Federal Government spectrum would be made available in three phases;

1710-1755 MHz (excluding systems in the 16 protected areas), 1755-1780 MHz and 1780-

1790 MHz for IMT-2000 mobiles. Table 5-6 provides the cost estimates for Federal civil

agencies in the1755-1790 MHz band. Table 5-7 provides the costs estimated for the DOD in the

1755-1790 MHz band. Table 5-1, shown previously, provides the cost estimates for the 1710-

1755 MHz 

Table 5-6

Total Estimated Federal Civil Agency Relocation Costs For The 1755-1790 MHz Band 

Federal Agency Number of Frequency

Assignments

Estimated Relocation Costs

(Millions)

Department of Agriculture 258a $23.22b

Department of Energy 194c $286.02d

Department of Justice 67 $19.07e

Federal Aviation Administration 79 $24.31f

Department of the Interior 69 $9.90g

U.S. Coast Guard 18h $6.77i

Department of Commerce 6j $1.88k

Department of the Treasury 13 $61.13l

National Aeronautics and 

Space Administration 4m $2.55n

Total 708 $434.9o

Notes:

a Based on 215 GMF fixed assignments, moving to a 4 GHz or 7/8 GHz band would require 20% additional sites

or an equivalent 258 assignments.

b Cost was calculated at $90K per assignment.

c Includes 194 assignments. Based on updated information.

d Includes $35M satellite replacement costs at Albuquerque, NM and various other operations. 

e Total includes 59 assignments at $270.3K/ assignment, $3.1M costs to replace video/surveillance equipment

and $22K to replace robotic equipment. 

f Cost reflects updated information based on 79 fixed assignments at average cost of $307.7K per assignment. 

g Includes both DOI (51) and TVA (18) fixed assignments at $150K per assignment and $125K per assignment,

respectively.

h The 37 fixed assignments was assumed to be distributed as follows: 19 in the 1805-1850 MHz band, and 18 in

the 1755-1790 MHz band.

i In its submission, the USCG has included $12M replacement cost as its share to replace Treasury’s Rainbow

Microwave System. This $12M cost is not included in the estimate since Treasury has included it as part of the

total replacement cost for the Rainbow System. Total includes 18 fixed assignments at $375.7K per

assignment.

j One experimental assignment for ITS in the 1850-1990 MHz band was not considered.

k Includes $275K cost (over 10-year period) to acquire a commercial T1 line, and five fixed assignments totaling

$1.6M.

l This includes $47M total replacement cost for the Rainbow Microwave System in Hawaii, three fixed

assignments at $171.4K per assignment to convert to commercial circuits over 10-year period, six tactical

assignments at $2.22M per assignment, and two aeronautical assignments totaling $300K.

m This is an updated clarification of assignment count based on NASA phone conversation (2/9/01).

n Total includes replacement at Wallops Flight Facility ($2M) and Langley Research Center ($550K).

o This total is assumed to be in FY02 dollars.
84 Details of the DOD costs are given in the DOD Final Report in (Appendix D) at B-12, B-13, C-7, D-10, E-45,

E-46, and classified supplement.

85 Systems such as telemetry, aircraft video, and telecommand have unique functions that will require further

discussion with the DOD to determine the cost on a case-by-case basis.

5-12

Table 5-7

Total Estimated DOD Relocation Costs For The 1755-1790 MHz Band84

 Agency Estimated Relocation Costs (Millions)

Department of Defense Beyond 2010a

Total $3,902 (TY$)/$3,541(FY02)b

Notes:

a The DOD states that relocating systems prior to 2010 is not feasible; so no costs are given for prior years.

b To convert TY$ to FY02 dollars divide TY$ by 1.102.

Costs for Option 3

Option 3 is an option that was not addressed in the interim NTIA report nor addressed

within the DOD Final Report (Appendix D). The cost estimates provided for Option 3 should be

considered preliminary since not all aspects to estimate the cost for Option 3 have been taken

into account. As a result, further discussion with the DOD and Federal civil agencies would be

required to determine the costs for this option. In Option 3, it is postulated that the number of

protected areas within the 1710-1755 MHz would be reduced. It is noted that some of the

systems within each of the 16 protected areas were not included in the cost estimates as given in

Table 5-1.85 The protected fixed FPA links within the 1710-1755 MHz band are also included in

the estimated costs. Table 5-1, shown previously, provides the OBRA-93 cost estimates for the

1710-1755 MHz band. In addition, because of the long-term loss of the 1710-1755 MHz band,

the relocation costs for TRR systems along with various DOD systems operating outside the 16

protected areas within the 1710-1755 MHz band, must also be included in the cost estimates. 

These systems and associated additional costs are listed in Table 5-8.

The estimated total cost for Option 2 is the aggregated cost for the 1710-1755 MHz band (Table

5-1, excluding the 16 protected areas), FPA, the Federal civil agencies and DOD costs for the

1755-1790 MHz bands. The cost for relocating systems is estimated to be $4,548 million (FY02). 

Sharing the band without impact to DOD operations would significantly reduce the costs. 
86 Details of the DOD costs are given in the DOD Final Report in (Appendix D) at C-7, E-45, and classified

supplement.

5-13

Table 5-8 

Estimated Additional DOD Relocation Costs For The 1710-1755 MHz Band86

Military Department Type of System Estimated Relocation Costs

(Millions) 2010 a

Department of Army MSE (HCLOS)b $289.5

Department of Navy DWTSc $1,048.4

Department of Air Force TCL/PGMd $447.5

Total $1,785 (TY$)/$1,620 (FY02)e

Notes:

a Assumes mission impact will prohibit relocation before 2010.

b Includes Army Corps of Engineers at $125M, $15M for Army’s share of various additional fixed links, and

$149.5M for the MSC (HCLOS). Details are provided in the DOD Final Report (Appendix D).

c Includes Tactical Control Links/Precision Guided Missiles at $432.5M, $15M for Navy’s share of various

additional fixed links, and $600.9M for the DWTS. Details are provided in the DOD Final Report (Appendix D).

d Tactical Control Links/Precision Guided Missiles at $432.5M, and $15M for Air Force’s share of various

additional fixed links. Details are provided in the DOD Final Report (Appendix D).

e To convert TY$ to FY02 dollars divide TY$ by 1.102.

The estimated total for Option 3 is the aggregated cost for the 1710-1755 MHz band (Table

5-1), FPA, and other DOD systems as given in Table 5-8. The estimated cost to relocate is

$2,192 million (FY02). Costs for some systems in the 16 OBRA-93 protected areas were not

known. Therefore, this is a partial cost. Option 3 was not part of the DOD Final Report and,

therefore, estimates of DOD costs associated with this option were not provided by the DOD. 

Further discussions would be required with the DOD and Federal agencies to determine the

costs for this option.
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A-1

Appendix A

Protection Contour Surrounding the Goldstone DSN Facility

NASA uses very high up-link transmit powers at its DSN facility in Goldstone,

California in order to ensure link availability to deep space satellites. It is expected that IMT2000 mobile receivers would experience service disruption in the 2110-2120 MHz band when

attempting to operate in areas surrounding the Goldstone site and during uplink transmissions. 

The severity and duration of such disruption would depend upon the frequency channel assigned

to the mobile unit, time, and power of transmission at Goldstone, orientation of the transmitting

antenna, distance and terrain between Goldstone and the mobile unit, and weather in the area.

In order to assess the geographic extent of this interference potential, the Jet Propulsion

Laboratory (JPL) has developed an interference contour based upon characteristics of anticipated

IMT-2000 receivers, the DSN antennas and high power transmitter, the terrain around

Goldstone, and upon ITU propagation models.

Using these models, interference power levels and required separation distances

surrounding the DSN Goldstone transmitter has been calculated. The distances are those at

which the radiation levels from DSN transmissions will exceed the IMT-2000 permissible

interference levels for a given percentage of time. In calculating interference power, JPL has

used the 70-meter DSN antenna with 400 kW (56 dBw) transmitting power, 62 dBi antenna gain

for the main lobe, and -10 dBi gain for side lobes. For the IMT-2000 users, it is assumed that the

receiving antenna is omni-directional with a 0 dBi gain. It is also assumed that the permissible

interference level is -109 dBm based on UMTS mobile receiver specifications. The rain climatic

zone used for the model is ITU region E, which includes Goldstone.

Figure A-1 presents a contour map showing anticipated interference distances (or

required separation distances) in all directions around Goldstone. The contour encloses an area

within which a mobile receiver would receive emissions from the DSN site above a threshold of

-109 dBm for more than 1 percent of time. In the directions without the shielding of large

mountains, as in the deserts southeast and northeast of Goldstone, the interference may propagate

further, beyond the contour line.

It is expected that interference would occur in the 2110-2120 MHz band to IMT-2000

receivers in the region of southern California and part of Nevada surrounding the JPL facility at

Goldstone. The interference contour associated with Goldstone is largely determined by

mountains, with a radius of roughly 200 km. Mobile receivers using the 2110-2120 MHz band

outside the contour could expect little or no interruption. Probabilities for interference outside

the contour are less than 1 percent and are lower in areas shielded by large mountains.

It would be very difficult for mobile users inside the contour to time-share the same

frequencies with Goldstone transmissions. The Goldstone site operates 24 hours a day, 7 days a

week, with transmissions occurring on a daily basis and lasting, on average, 8 hours or longer. 
A-2

Figure A-1. Calculated Interference Zones Surrounding DSN station at Goldstone.

These transmission periods, while normally scheduled, can at times be unpredictable because of

unplanned spacecraft events.
B-1

Appendix B

Federal Agency Cost Submissions

NTIA requested cost data, time lines, and operational impacts from the Federal agencies

with radiocommunications systems operating in the 1755-1850 MHz band. This appendix is a

compilation of digitally replicated copies of the NTIA letter to the Federal agencies and

correspondence received in response.

 Federal Agency Page 

NTIA Letter to Federal Agencies . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . B-3 

U.S. Department of Agriculture . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . B-5 

U.S. Coast Guard . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . B-7 

Department of Defense . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . B-11

U.S. Department of Commerce . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . B-15

Department of Energy . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . B-19

Federal Aviation Administration . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . B-23

U.S. Department of the Interior . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . B-25

U.S. Department of Justice . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . B-27

National Aeronautics and Space Administration . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . B-33

Department of the Treasury . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . B-39
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B-3

UNITED STATES DEPARTMENT OF COMMERCE

The Assistant Secretary for Communications

and Information

Washington, D.C. 20230

July 24, 2000

The implementation of 3rd generation (3G) personal communications systems in the

United States presents an opportunity for U.S. industry to maintain its global leadership in the

manufacturing of telecommunications devices, and will give the American public an unparalleled

choice of new communications services. The recent International Telecommunication Union

(ITU) World Radiocommunication Conference-2000 has identified several frequency bands that

administrations may use for the implementation of 3G systems. One of the two frequency bands

under active consideration for 3G use in the United States is the 1755-1850 MHz band. This

band is allocated for exclusive use of Federal Government agencies, and is heavily used by many

of the Executive Branch agencies. The other band is the 2500-2650 MHz band, used exclusively

by commercial entities, and regulated by the Federal Communications Commission (FCC).

In the near future, a national-level decision must be made to select a frequency band to

accommodate the new 3G systems. The decision must maximize the public interest, considering

the national potential for economic growth and increases in our quality of life, balanced by the

cost and mission/business impact to incumbent users of the bands in question. This important

decision must be based on the most accurate information available to us. The National

Telecommunications and Information Administration (NTIA) is preparing a report that will detail

the use of the 1755-1850 MHz band, alternate frequency bands for the reaccommodation of

potentially displaced Federal radio systems if this band is selected for 3G use, and the costs and

time lines associated with any transitions of Federal systems to new frequency bands.

To prepare the most comprehensive report possible, NTIA needs accurate cost data from

the Federal agencies that operate spectrum-dependent systems in the 1755-1850 MHz band. 

(This data may be subject to review by the Office of Management and Budget or Congressional

Committees.)

Therefore, I am requesting that you furnish NTIA with this cost data, to include the

current value of your agency’s infrastructure of radiocommunication systems in the 1755-

1850 MHz band, and the marginal costs of relocating these radiocommunications systems to

another appropriate frequency band. The marginal costs should include costs for retuning

equipment should a minor shift in frequency be necessary, or costs for the purchase of new

equipment, installation of this equipment and associated training, and, if necessary, additional

real property should a move to a frequency band be required wherein the present equipment

would not be serviceable. If you have previously submitted such data, I request that you review

this information and certify its accuracy.

Mailing

Address

Salutation:
B-4

We know that relocation of communications systems is not without operational impact. It

would be helpful to us to know what operational impacts such a relocation of these systems

would have on your agency, and the approximate length of time required for transition to another

frequency band, if this becomes necessary.

In order to meet our schedule for release of the NTIA report by March 2001, I request this

data be furnished to me no later than November 15, 2000 so we can move forward on the

selection of spectrum for 3G systems in the United States without excessive delays. Our pointof-contact for this effort is W. Russell Slye. He can be reached at 202-482-6497, or electronic

mail at: rslye@ntia.doc.gov. I look forward to working with your agency on this most important

effort.

 

Sincerely,

Gregory L. Rohde
 AN EQUAL OPPORTUNITY EMPLOYER B-5

Unites States

Department of

Agriculture

Office of the Chief

Information Officer

1400 Independence

Avenue, SW

Washington, DC

 

January 30, 2001

Mr. Stephen R. Veader

Executive Secretary, IRAC

National Telecommunications and Information Administration

Department of Commerce

Herbert C. Hoover Building, Room 1087

1401 Constitution Avenue, N.W.

Washington, D.C. 20230

Dear Mr. Veader:

This is in response to Assistant Secretary Rohde’s letter of July 24, 2000, requesting we

provide the National Telecommunications and Information Administration (NTIA) with

estimated cost data for relocating USDA radiocommunications systems from the 1755-

1850 MHz band to support proposed 3rd Generation (3G) personal communications.

We fully support the goal of implementing 3G personal communications systems in the

United States. We are also aware of the problems associated with selecting spectrum to

support 3G implementation. One of the bands under consideration for 3G is the 1755-

1850 MHz microwave band. This band is very heavily populated by Federal

Government systems. We, therefore, understand the need to obtain estimated costs for

Federal agencies to move to alternative frequency bands if the 1755-1850 MHz band is

reallocated for non-Federal use. We appreciate the work you and your staff in NTIA are

doing to support the financial needs of agencies who may have to vacate the 1755-

1850 MHz band.

The Department of Agriculture (USDA) owns and maintains microwave systems

operating in the 1755-1850 MHz band throughout the United States. These microwave

systems are used primarily in the Forest Service as backbone links to interconnect land

mobile radio system mountaintop repeaters and remote controlled base stations. The

land mobile radio systems are installed to support the health and safety of employees and

the public on and around public lands, the fighting of wildfires and other natural

disasters, as well as the protection of property. All of the installations are standard

off-the-shelf analog microwave transmitters, receivers, and associated equipment. Most

operate within a 2 MHz bandwidth.

Equipment at all USDA microwave sites would have to be replaced to allow for

operation on an alternate band if the 1755-1850 MHz band were to be reallocated to

non-Federal use. There are two alternative bands that are considered reasonable for

transition: 4 GHz and 7 GHz. If either of these bands were selected for the transition,

our current systems would have to have their number of sites increased by approximately

20 percent. This is caused by a reduction in the effective communications distance

between the sites due to the higher frequency of operation. The estimates provided
B-6

below cover the cost of moving to an alternative band and include the additional

installations required by the higher frequency band of operation.

Following the NTIA example of basing costs on the number of frequency assignments,

we have averaged our transition costs to be approximately $90,000 per assignment. We

mentioned previously that the alternative bands under consideration for transition would

require approximately 20 percent additional sites to provide comparable communications. 

We have included that additional percentage in our calculations thereby increasing the

estimated total number of frequency assignments under consideration to 805. At

$90,000 each, the total cost for transition is estimated to be $72,450,000. Since USDA

microwave systems are used to support safety-of-life communications, any replacement

systems would have to be installed and operational before the old systems could be

disabled. The steps of system redesign, equipment procurement (advertisement,

selection, award and purchase), installation, and testing are estimated to take a minimum

of 3 years once funding is provided. The schedule could be shortened at increased costs

for additional contracting support. These steps are our basis for cost estimates.

If you have questions, please have a member of your staff contact Ms. Brenda F. Boger

on (202) 720-8025.

Sincerely,

Ira L. Hobbs

Acting Chief Information Officer
B-7

2100 2nd St. SW

Washington, DC 20593

Staff Symbol: G-SC

Phone: 202 267 2860

FAX: 202-267 4106

Commandant

U.S. Coast Guard

2000

Mr. Gregory L. Rohde 15 November 2000

Assistant Secretary of Commerce for

 Communications and Information

U. S. Department of Commerce

Washington, D C 20230

Dear Mr. Rohde:

This responds to your letter of July 24, 2000, requesting cost data from Federal agencies that

operate spectrum-dependent systems in the 1755-1850 MHz band, and the marginal costs of

relocating these radiocommunications systems to another appropriate frequency band.

The Coast Guard has identified 37 microwave links that would require replacement if we were

directed to move from the 1755-1850 MHz bands. The estimated existing value of these links is

$9.7M. The replacement cost is estimated at $13.9M assuming necessary spectrum is available

in the next higher Federal Government band. Wherever possible, commercial facilities vice

government-owned or operated systems have been utilized in reaching this estimate. The

remoteness of many of these sites, the short construction season in Alaska and along the

Washington-Oregon coasts and the availability of personnel and equipment to perform this

replacement are factors in the replacement costs.

Each of the circuits provided by the existing or replacement microwave paths supports Safety of

Life, command and control and general communications utilized by the Coast Guard to support

its various missions. I must emphasize that we cannot terminate an existing link until the

replacement link is installed, tested and operational. Enclosure (1) provides a listing of circuits

requiring replacement and a more detailed breakdown of associated costs.

In addition, the Coast Guard is a participant in the Hawaii Rainbow System that operates

partially within this band along with the Department of the Treasury and the State of Hawaii. 

The radio frequencies associated with this system are grandfathered by your agency. However,

if required to be replaced for 3rd generation personal communications systems, the estimated

system replacement cost is $46M with the Coast Guard share of the cost being approximately

$12M. The estimated cost of the Coast Guard share of the existing system is $6M. These costs

are in addition to those outlined above.

2000

U.S. Department

of Transportation

United States

Coast Guard
B-8

Please advise me if you require further information regarding these circuits.

Sincerely,

C.I. PEARSON

Captain, U. S. Coast Guard

Acting Assistant Commandant for Systems

Encl: (1) List of Circuits

2
B-9

Microwave Circuits

Location # of paths Replacement Cost

Berwick Bay, LA 4 $24K

Alaska 13 $7.465M

Naked Island (2)

Cape Hinchenbrook

Potato Point (2)

Valdez

Mount Thomas (4)

Pillar Mountain (2)

Pillar Point

Washington/Oregon 21 $6.4M

Winchester Hill (2)

Astoria

Seven Devils (3)

Adams Hill (3)

North Bend

Yaquina Head

Goodwin Peak

Cape Blanco

Seattle (3)

Raymond (2)

South Mountain

Naselle Ridge (2)

Encl (1)
This page left intentionally blank.
B-11

DEPUTY SECRETARY OF DEFENSE

1010 DEFENSE PENTAGON

WASHINGTON, DC 20301-1010

Honorable Donald L. Evans February 13, 2001

Secretary of Commerce

U.S. Department of Commerce

Herbert C. Hoover Building

1401 Constitution Avenue N.W.

Washington, D.C. 20230

Dear Mr. Evans:

In response to President Clinton’s October 13, 2000, Executive Memorandum

on Advanced Mobile Communications/Third Generation Wireless Systems, the

Department of Defense (DoD) provides the enclosed report for inclusion into the Final

NTIA/ FCC Third Generation (3G) Band Study and Report scheduled for public

release on or about March 30, 2001. Loss of access to spectrum, above and beyond

that already relinquished as a result of the Omnibus Budget Reconciliation Act of 1993

and the Balanced Budget Act of 1997, would jeopardize the DoD’s ability to execute

its mission.

The DoD report examines. the, feasibility of accommodating International

Mobile Telecommunications (IMT) 2000 systems by sharing the 1755-1850 MHz

band, and concludes that full band sharing is not possible due to predictable, mutual

interference over large geographic areas and major metropolitan centers. Mitigating

that interference would require unacceptable restrictions on military operations,

training, and readiness. The report concludes that regardless of financial investment,

the Department cannot vacate or segment the band until at least 2010 for non-space

systems and at least 2017 for space systems (possibly as late as 2030 for some

satellites). Even then, vacation or segmentation of the band would be acceptable only

if comparable, operationally suitable spectrum with equivalent regulatory protection is

made available and the costs of relocation are fully reimbursed prior to any transition.

The conclusions of this report are based on the fundamental principle that the

DoD cannot accept any degradation to mission capability resulting from a spectrum

reallocation action. The 1755-1850 MHz band is indispensable to the defense of the

United States and its allies. It is used, among other things, for satellite telemetry,

tracking, and commanding of critical satellite systems (including Global Positioning

System (GPS), Milstar, and Defense Support Program (DSP)); PGMs; Army and

Navy/Marine Corps tactical radio relay systems; air combat training systems;

targeting; intelligence; and the real-time delivery of voice, video, and data information

to warfighters and their commanders. Our Nation's armed forces would be at a
B-12

substantial strategic and tactical disadvantage in combat and the execution of military

operations could be jeopardized if the Department lost its use of the band.

A final caution: This report is the result of an accelerated and preliminary

review. The Department was required to make certain critical assumptions and was

not able to take into account secondary and tertiary costs that would result if hundreds

of defense systems were moved out of the 1755-1850 band with attendant changes in

tactics, training, doctrine, personnel, and long-lead procurement and program

execution.

We took forward to continuing close coordination with NTIA and FCC in

reaching the best decision for the Nation in identifying spectrum for the next

generation of wireless systems.

Sincerely,

Rudy de Leon

Enclosure
B-13

Enclosure to the Deputy Secretary of Defense Letter

 See Appendix D

The enclosure is a DOD report titled: Department of Defense Investigation of the Feasibility of

Accommodating the International Mobile Telecommunications (IMT) 2000 Within the 1755-

1850 MHz Band). It is over 300 pages in length and is printed separately as Appendix D (less

Attachment) to this report. The DOD report in its entirety can be viewed on the NTIA homepage

at: www.ntia.doc.gov.
This page left intentionally blank.
B-15

UNITED STATES DEPARTMENT OF COMMERCE

National Oceanic and Atmospheric Administration

NATIONAL ENVIRONMENTAL SATELLITE, DATA, 

 AND INFORMATION SERVICE 

Washington, D.C.20233

Office of Radio Frequency Management

Room 2246, SSMC-2

1325 East West Highway

Silver Spring, MD 20910 

November 14, 2000

MEMORANDUM FOR: NTIA -W. Russell Slye

FROM: ORFM - Richard Barth 

SUBJECT: Impact of Losing 1755 - 1850 MHz

This responds to AS Greg Rohde's letter to DUS Scott Gudes dated July 24, 2000 asking for

information about the radio systems currently operating in the band 1755 - 1850 MHz and the

marginal cost of relocating these systems to other spectrum.

The Department of Commerce currently has 31 assignments in this band. Nine are no longer

required and have been or will be deleted. The remainder are distributed as follows:

NWS - 17 ERL - 2 NIST - 2 ITS - 1

The cost of replacing these systems has been estimated by the element operating them, with the

following results:

• NWS: $3.2 million estimated to relocate the 17 systems to the 7 GHz band. Further

details are provided in the attachments. Note that about 3 years will be required

after funding is obtained for the effort.

• ERL: The current system operates in knife-edge diffraction mode and higher 

frequencies are not expected to perform adequately. If forced to vacate the

1755 MHz band, users plan to lease a T1 line for a total cost of about $275K over

a 10year period (the presumed life of a replacement microwave system.)

• NIST: $69,060. Details attached.

• ITS: $50-100,000. This experimental area assignment in the band 1850 - 1990 MHz is

used for an active antenna test bed, for propagation tests in support

of PCS standards definition. Continued use of the band is expected

to be required, since it is here that PCS systems will operate.

Attachments

Attachment
B-16

IMPACT ASSESSMENT OF POTENTIAL LOSS OF THE MICROWAVE LINE OF

SIGHT (MLOS) SYSTEMS IN THE BAND 1755-1810 MHz ON THE U.S.

METEOROLOGICAL DOPPLER WEATHER SURVEILLANCE RADAR (WSR-88D)

1.0 Introduction

The 1710-1855 MHz band is being targeted worldwide for use by

IMT-2000, the “3rd Generation” (3G) mobile system which is being

promoted by industry and supporting governments in much of the

world. This band is used worldwide, except in North America, for

cellular telephone, and its availability on this continent would

make it possible for cellular equipment producers to manufacture

hardware that could be sold and used globally. Part of the band

from 1710-1755 MHz was designated for auction under the Omnibus

Budget Reconciliation Act of 1993 (OBRA-93), and the National

Telecommunications and Information Administration (NTIA) is now

considering the potential impact on Federal communications should

the 1755-1850 MHz band be made available to industry.

2.0 Current Use of the Band 1755-1810 MHz

The National Weather Service (NWS) currently operates the WSR-88D

MLOS system in the 1755-1810 MHz band. These systems were

recently upgraded from the 1710-1755 MHz band in response to

OBRA-93. The MLOS system is five terrestrial microwave data

links operating in support of WSR-88D. These microwave links

allow the data gathered at the radars located on remote mountain

peaks where normal communication infrastructure is not feasible

to be transmitted to the Weather Forecast Offices for processing.

The WSR-88D MLOS system connects the following sites:

RADAR SITES WEATHER FORECAST OFFICES

Sulphur Mountain, CA Los Angeles, CA

Mauna Kapu, HI Ewa Beach, HI

Point Six Mountain, MT Missoula, MT

Twin Lakes, OK Norman, OK

Mount Ashland, OR Medford, OR

The data transmitted over these microwave links is vital for

improving short-term forecasting and detection of life-

-threatening severe weather. Without these microwave links, the

people living in these locations would not receive the protection

of life and property that WSR-88D provides.

3.0 Frequency Relocation

Should the NTIA make the 1755-1810 MHz band available to IMT-2000

and require the MLOS to relocate, the next available Government

frequency band is 4400-4800 MHz. However, a thorough analysis

has determined a relocation to the 4400-4800 MHz band is not

practical. A survey of radio manufacturers discovered there are

no American manufacturers that build radios in this frequency

band. A unique one-of-a-kind system would have to be built and
B-17

the NWS would be very dependent on the vendor for replacements

and repairs to the system. A system of this nature would also be

too expensive.

A more practical solution would be to relocate to 7125-7250 MHz

band which is the next available Government band after 4400-

4800 MHz. There are numerous American radio manufactures that

build systems in this frequency band. Obtaining commercialoff-the-shelf equipment would be advantageous and more cost

effective over the life of the system.

3.1 Cost

The current value of the five existing NWS WSR-88D MLOS systems

is estimated at $5M. The transition of the WSR-88D MLOS systems

to a portion of the band 7125-7250 MHz is estimated at $3.2M.

This estimate includes all costs associated with the system

engineering, radios, antennas, tower extensions, associated

hardware, installation, travel, and warranty.

3.2 Operational Impact

Operational impact to the MLOS should be minimal during the

frequency relocation. Since there is not adequate room on the

towers and in equipment shelters for the new antennas, radios and

associated hardware required for this relocation, the old system

will be removed from operation until the new systems is installed

and tested. The cut-over can be performed with a radar downtime

of 2 to 3 days.

3.3 Time-frame for Transition

The transition of the NWS WSR-88D MLOS system to the band 7125-

7250 MHz is expected to require approximately 3 years from the

notification and receipt of adequate funding.

4.0 Conclusion

The NWS considered the available options for the WSR-88D MLOS

relocation out of the 1755-1810 MHz band. Relocation to the

7125-7250 MHz band was determined to be the most feasible

solution. The costs for implementing this relocation is

estimated to be $3.2M. There should be little operational impact

to the WSR-88D MLOS system created by this relocation. The

relocation will require 3 years to complete once funding is

approved and obtained.
B-18

Impact of Loss of 1755-1810 MHz

Subject: Impact of Loss of 1755-1810 MHz

Date: Fri, 22 Sep 2000 14:34:03 -0400

From: Harold Fogle <harold.fogle@nist.gov>

To: Richard.Barth@noaa.gov

CC: john.antonishek@nist.gov, Rachel.Cockrell@nist.gov, Karl.Murphy@nist.gov

The National Institute of Standards and Technology (NIST) has two frequencies in the band

width which are being considered for elimination by the Government.

Both frequencies, M1800 and M1833 are in support of the Intelligent Highway Systems Research

Program at Gaithersburg, Md.

The users have researched the impact of replacing these frequencies and have estimated the

following transition costs.

Transmitters (2) at $6,545.00 ea. Totaling $13,090.00

Receivers (2) at $5,290.00 ea. Totaling $10,580.00

Antennas (5). at $748.00 ea. Totaling $3,740.00

(2) at $220.00 ea. Totaling $440.00

(2) at $605.00 ea. Totaling $1,210.00

Labor Totaling $40,000.00

Total cost of transition is $69,060.00.

One question everyone must have on their mind is the source of transition money in these tight

budget years. The timing for transition will be dictated by our budget. Certainly, in the case of

NIST, this will have a large affect on the project using these frequencies.

Please contact me should you require any other information. My email address is

Harold.Fogle@nist.gov and my telephone number is 301-975-3330.
B-19

Department of Energy

Washington, DC 20585

November 15, 2000

Mr. Gregory L. Rohde

Assistant Secretary for Communications and Information

Department of Commerce

1401 Constitution Avenue

Washington, D.C. 20230

Dear Mr. Rohde:

The Department of Energy (DOE) is responding to your request for economic and

operational impact data for the relocation of Departmental radio systems that operate in

the 1755-1850 MHz band, as requested in your letter of July 24, 2000. We appreciate the

national importance of implementation of third-generation personal communications

systems as outlined in your letter, as well as the October 13, 2000, White House

Memorandum on that subject. The estimated cost to relocate DOE radiocommunications

systems from this band is $340,400,000. The cost data, as well as other operational

impacts, are identified in the enclosed Table 1. Estimates are based on transition times

from 3 to 10 years depending on the radio system in question. Accelerated transition

schedules significantly increase costs and may not be feasible.

If you require additional information, please contact Brian Klug of my staff on

202-586-6095.

Sincerely,

Nancy W. Tomford

Acting Chief Information Officer

Enclosure
B-20

U.S. Department of Energy Summary Impact of National Reallocation

of Band 1755 - 1850 MHz

Summary

Responses from field users that formed the basis to evaluate moving Department of Energy (DOE) systems

operating in the band 1755-1850 MHz to a different frequency band are summarized in table 1. Data was

structured based upon the incoming request from the National Telecommunications and Information

Administration (NTIA). For each affected DOE Office, the table contains the original system costs,

number of frequency authorizations in the 1755-1850 MHz band as of July 2000, projected cost to replace

the current systems, impact summary, and expected transition time.

Table 1. 1755-1850 MHz Impact Assessment Summary

Field Office Original

Cost

Number

Asgmts

Costs to

Replace

Impact

Summary

Transition

Time

Albuquerquea $35,135,000 16 $36,600,000 Possibly, some mission

impact due to satellite

3-5 years

without

considering

satellite

Bonneville Power

Administration $138,100,000 99 $115,500,000 Mission impact-seewrite-up 7-10 years

Oak Ridge 4 $400,000d No mission impact

reported 3-5 years

Oakland $70,000 14 $150,000 Possible mission impact 3-5 years

Nevada $408,000 19 $1,900,000 No mission impact 3-5 years

Rocky Flats 1 $0 Assume site shutdown in

2006 5 years

Savannah River 1 $100,000d No mission impact

reported 3-5 years

Strategic Petroleum

Reserveb $40,000 1 $150,000 Are relocating one link 2 years

Southwestern

Power

Administrationc $12,800,000 62 $31,000,000 Mission impact-see

write-up

7 years

(estimate)

Western Area

Power

Administration

$219,700,000 301 $154,600,000 Mission impact-see

write-up 7-10 years

Totals $406,253,000 502 $340,400,000

Notes:

a: data includes a satellite that may be difficult to replace; the estimated cost is $35 million.

b: this system has been modified with part discontinued and part planned equipment replacement.

c: timeframes of these systems are highly dependent upon getting funding approved, possibly from

the ratepayers.

d: assumed $100,000 for each frequency authorization, since data was not provided within the

required NTIA timeframe for these 5 assignments

1

Field microwave users reported that other microwave bands would be used to replace systems in the bands

1755-1850 MHz. In cases where highly reliable systems are required, the 7/8 GHz band will be used. In a
B-21

minority of cases, if allowed after considering reliability and interference potential due to high population

density, unlicensed spread spectrum digital systems operating in the 2.4 and 5.8 GHz nonlicensed bands

may be used. Since frequency changes in satellite systems are not practical, a replacement would require

launch of a new satellite in cooperation with program partners.

Operational Impact

Operational impact is dependent upon allowing sufficient transition time. The impact will potentially be

the greatest on the satellite system used to collect data for stockpile stewardship and the microwave

systems serving Bonneville Power, Southwestern Power, and Western Area Power Administrations. The

fixed point-to-point microwave communications systems support the supervision, control, and protection of

the electrical power transmission system. The channels are used for high-speed relaying, supervisory

control, load control, telemetering, data acquisition, land-mobile radio dispatching, operations, and

maintenance. If forced to hastily vacate the 2 GHz band, the operational impact on the power transmission

system could include extensive outages, loss of revenue, inability to deliver power to the customers,

increased operating costs, power system instability, and potential loss of life and equipment. For systems

listed in table 1 that have indicated no mission impact, it is assumed that the associated transition time will

be given for relocation.

Transition Time

Transition times listed in table 1 span 2 to 10 years due to the complexity of systems and geographic

locations. In many cases, lengthy lead times from manufacturers to acquire equipment and custom-built

components, such as battery/charger systems, antenna/waveguide systems, and radio and/or fiber systems

are required. In other cases, time is required to allow for budgeting, environmental approvals, and a billing

process to customers. Many of the microwave systems are located in the western United States in

mountainous areas that experience heavy snowfall. This results in a shorter construction season that limits

the length of time work can be performed and restricts the number of new and existing sites that can be

completed in a season. All of these factors contribute to a transition time of up to 10 years for some of the

more critical systems.

2
B-22

The following supplemental information was provided to NTIA by Mr. Hollingsworth/DOE on 3/8/01. 

It was requested that this information be used to estimate the DOE costs to relocate systems from the

1755-1850 MHz band. In addition, as a result of this supplemental submission, it was requested that the

various entries contained within the DOE letter on Pages B-19 and 20 be modified. The suggested

modifications are as follows: 1) the number of assignments at Savannah River be increased to 1 to 4;

2) the costs for the four assignments at Savannah River results in a total of cost of $240,000; and 3) the

cost for the one assignment at Rocky Flats would increase from $0 to $20,000. The results of these

changes would increase the number of assignments from 502 to 505 and increase the total costs from

$340,400 to $340,560. This change in the total costs would also be reflected on the cover page

increasing the amount from $340,000 to $340,560.

Impact to DOE

1805-1850 MHz 1780-1790 MHz 1755-1780 MHz COST

Albuquerque

Operations

Office

7 $1.75M

2 $470K

7 $36.5M

Nevada 

Operations 

Office

9 $2.5M

2 $559K

5 $1.5M

Oak Ridge

Operations Office

3 $750K

1 $250K

Oakland

Operations

Office

5 $134K

5 $134K

4 $107K

Savannah River

Operations Office

2 $40K

1 $100K

Rocky Flats

Field Office 1 $20K

Strategic

Petroleum Reserve 1 $150K

Bonneville

Power

Administration

22 $19M

24 $20M

48 $41M

Southwestern Power

Administration

38 $31M

2 $31M

17 $31M

Western Area

Power

Administration

173 $83M

7 $78M

68 $83M

Total Costs $138.324M $130.263M $193.377M $340.560M

Note: Relocation costs for vacating the combined 1755-1780 MHz and 1780-1790 MHz band segments would

not exceed the total cost of vacating the entire 1755-1850 MHz band, so the estimated cost for vacating the 1755-

1790 MHz band segment would be no more than $286.02M. The combined costs of all three band segments for

some DOE field offices may be greater than the cost impact for having to relocate from the entire 1755-1850 MHz

band. This is because these costs represent replacement of entire systems, where system path links in one band

segment may also be in common with another band segment (e.g., SWPA has only one analog microwave system

with path links across all 3 band segments). Also, there is an increased cost factor for having to vacate from just

one band segment due to the cost of re-engineering whole new systems and procuring new equipment.
B-23

Mr. Gregory L. Rhode November 7, 2000

Assistant Secretary for Communication

Department of Commerce

Washington, DC 20230

Dear Mr. Rhode:

In reference to your letter dated July 24, we have researched

and prepared the enclosed estimated cost data required to

relocate 221 Federal Aviation Administration frequency

assignments remaining in the 1755-1850 MHz band. This is

our best estimate at this time. Actual costs will depend on

such factors as geographic location and final configuration

of the relocated assignments. This estimate does not include

any real estate costs.

While cost issues are important, the National

Telecommunications and Information Administration will need

to address the spectrum suitability and availability in

alternative frequency bands for those systems being

displaced. Keep in mind that due to the limited propagation

characteristics of microwave signals in higher frequency

bands, some of the 221 links may not be able to be moved to

those bands if real estate is not available to accommodate

repeaters.

If you require additional information, please contact

Mr. Oscar Alvarez, Manager, Spectrum Assignment and

Engineering Division, at (202) 267-7531.

Sincerely,

Steven J. Brown

Acting Associate Administrator

for Air Traffic Services

cc: Enclosure

Enclosure

U.S. Department Associate Administrator for Air Traffic Services 800 Independence Ave, SW

of Transportation Washington, DC 20591 

Federal Aviation

Administration
B-24

COSTS TO RELOCATE LOW DENSITY RADIO COMMUNICATION LINKS

(LDRCL):

221 Assignments $48,096,893

50 Repeaters 10,881,650

200 ft Towers (for repeaters)

(FREE STANDING)

*Includes lighting, fencing,

security

@ $125,000.00 ea x 50 6,250,000

TOTAL COST: $65,228,543

S\asr\1755el.doc
B-25

FOR AGENDA Doc. 31810/1

United States Department of the Interior

OFFICE OF THE SECRETARY

Washington, D.C. 20240-0001

Ref Doc. 31744/1

 

Mr. Steven R. Veader February 16, 2001

Executive Secretary, IRAC

National Telecommunications and

 Information Administration (NTIA)

U.S. Department of Commerce

Herbert C. Hoover Building, Room 1087

1401 Constitution Avenue, NW

Washington, D.C. 20230

Dear Mr. Veader,

The purpose of this letter is to inform the NTIA that we are revising our initial estimate of

marginal costs incurred by this Department in the 1755-1850 MHz band. Assistant Secretary

Rohde's letter of July 24, 2000, requests Department of Interior (DOI) provide NTIA with

estimate on costs for relocation of our radio communications systems operating in the 1755-1850

MHz band to support proposed 3rd Generation (3G) personal communications. Our initial

response during November 2000 identifies 143 DOI frequency assignments having a six million

dollar total marginal cost for relocation to another band.

Our first submission reflects information gathered from only four DOI bureaus. We are adding,

The United States Geological Service (USGS), another DOI Bureau to our original cost estimate. 

The USGS uses frequencies in the 1755-1850 MHz band for earthquake and tidal wave

monitoring operations. Because DOI has an existing agreement with TVA for spectrum

management our revision includes relocation cost data from the Tennessee Valley Authority

(TVA). The TVA uses frequencies in this band for automated remotely controlled hydroelectric

power generation grid and its internal voice communications backbone.

Following the NTIA example of basing costs on the number of frequency assignments, we have

compiled our transition costs in the following chart.

Bureau

Average

Marginal

Cost

Number

Assignments

Cost to

Replace

Interior $ 150,000 133 $ 19,950,000

TVA $ 125,000 64 $ 8,000,000

Totals $ 275, 000 197 $ 27,950,000

Five DOI bureaus have 133 frequency assignments in this band with average transition costs of

$150,000 per assignment. DOI total marginal costs equal $20 million dollars. The TVA has 64

frequencies with an average transition cost of $125,000 per assignment. The TVA total 

marginal cost equals $8 million dollars. The combined transition cost for Interior and TVA

equal $28 million dollars. Since DOI/USDA microwave systems are used to support safety-oflife communications, any replacement systems would have to be installed and operational before

the old systems could be disabled.
B-26

System redesign, equipment purchase, installation, testing and acceptance will take a minimum

of 3 years for DOI systems once funding is available. The Bureau of Reclamation and TVA

hydrological systems, and USGS earthquake monitoring/detection systems take approximately 7

years to go through the same process. They also require extensive engineering studies because

of design constraints and environmental impact. Contracting out any of these missions will

drive costs up. Please direct any requests for information about this system to the undersigned at

(202) 208-3939

Sincerely,

Arthur L. Nelson

US Department of the Interior

Interdepartment Radio Advisory Committee Representative
B-27

U.S. Department of Justice

Washington, D.C. 20530

Mr. Gregory L. Rohde November 16, 2000

Assistant Secretary for

Communications and Information

Department of Commerce

Washington, DC 20230

Dear Mr. Rohde:

In response to your request, the Department of Justice (DOJ) has

reviewed its wireless operations in the 1755-1850 MHz band and

has concerns with the ability to find suitable alternative

spectrum below 3 GHz and the time and cost that will be incurred

in developing replacement equipment and systems. DOJ uses the

1755-1850 MHz band for various wireless applications supporting

law enforcement operations. These are primarily fixed microwave

linking portions of our land mobile radio communications

infrastructure, audio/video surveillance systems and wireless

robot operations. We have concerns that other spectrum locations

may not support these operations at a level equal to or better

than that served by the present spectrum location. Alternative

spectrum locations below 3 GHz are severely limited and may

adversely affect these applications and DOJ's mission. Also,

there may be significant costs incurred to support these

applications in other areas of the spectrum.

The current estimate for relocating the fixed microwave links in

this band is approximately $60 million. DOJ is considering a

transition to alternative spectrum or services to coincide with

the implementation of the consolidated Justice Wireless Network

program, but this would have to take place over the next 5 to 8

years.

The cost for relocating the audio/video surveillance equipment is

approximately $3.1 million. Operationally, this equipment is

used to support collection of audio and video information for

evidence in criminal, counterterrorism and foreign

counterintelligence investigations. The time line to accomplish

a relocation of this equipment and the operational impact is

dependent on identifying suitable replacement spectrum and

research development efforts. This may take additional time and

money.
B-28

Mr. Gregory L. Rohde 2

The estimated cost for relocating the robot operations is

$22,000. The robots are used in suspected bomb scenes, with

other hazardous materials and to support forensic investigations.

As is the case with the audio/video equipment, the estimated time

line to relocate the robot operations cannot be determined until

adequate spectrum is identified, and research and development

occurs.

DOJ relies on the ability to use advanced technologies as

investigative tools in support of its mission. The increased

demand on the limited spectrum resources supporting these

technologies creates challenges for the users and the regulators.

All spectrum alternatives for third generation personal

communications systems must be explored before decisions are made

that limit the resources available to support the DOJ operations.

If you have any further questions please contact Merri Jo Gamble

on 703-322-1660.

Sincerely,

Stephen R. Colgate

Assistant Attorney General

for Administration
B-29

U.S. Department of Justice

Wireless Management Office

Fairfax, Virginia 22033

January 29, 2001

Mr. Russell W. Slye

National Telecommunications and

Information Administration

Department of Commerce

Herbert C. Hoover Building, Room 4082

1401 Constitution Avenue, N.W.

Washington, D.C. 20230

Dear Mr. Slye:

During a meeting at the National Telecommunications and Information Administration (NTIA)

with the Office and Management and Budget and several other federal agencies on January 23, 2001,

the Department of Justice (DOJ) was asked to provide additional information on its use of the 1755-

1850 MHz band. Specifically, DOJ was asked to break down its use of this band to include the

number of frequency assignments, and to provide an explanation of how the existing microwave links

relate to the Justice Wireless Network (JWN) implementation.

There are a total of 241 frequency assignments in the Government Master File for DOJ use of

the 1755-1850 MHz band. The DOJ uses this band primarily for fixed microwave linking of our land

mobile radio communications infrastructure, audio/video surveillance systems and wireless robot

operations. Currently, there are 223 frequency assignments authorizing the fixed microwave links at

specific geographic locations. The audio/video surveillance systems are authorized by 13 frequency

assignments. These 13 frequency assignments allow a maximum of 736 individual pieces of equipment

to operate anywhere in the United States and Possessions. The eleven wireless robots are authorized

for operation anywhere in the United States and Possessions by 5 frequency assignments.

DOJ has been directed by Congress to combine the individual land mobile radio (LMR)

systems used by each of the DOJ components into a consolidated JWN. The implementation of the

JWN is a multi-year effort driven by the need to comply with the NTIA VHF narrowband mandate of

January 1, 2005. The current individual component LMR systems are linked in some areas of the

country by microwave equipment operating in the 1710-1850 MHz band. In many areas this

equipment has been operational for approximately 15 to 20 years.

 When the 1710-1755 MHz band was identified for reallocation from government to nongovernment use in 1993, the Federal Bureau of Investigation made the decision to convert its existing

microwave links in the 1710-1850 MHz band to wireline modem where technically and operationally
B-30

feasible. This effort is not yet completed. The Immigration and Naturalization Service (INS) currently

has existing microwave links that operate in the 1710-1850 MHz band. No other DOJ components

have microwave links in the 1710-1850 MHz band. As DOJ develops the design and implementation

plans for the JWN, each geographic area is evaluated with a view towards consolidating redundant

sites and retaining the existing infrastructure, especially if there is a system linking capability already

in place. The existing microwave links are viewed as DOJ system assets that will need to be

reaccommodated to comply with the reallocation of the 1710-1755 MHz band and should be taken into

account in any evaluation of potential reallocation of the 1755-1850 MHz band.

If there are any further questions, please contact me at 703-322-1666.

Sincerely,

Merri Jo Gamble

Spectrum Manager
B-31

The following supplemental information was provided to NTIA by Ms Merri Jo Gamble/DOJ on

2/1/01. It was requested that this information be used as part of the information to estimate the

DOJ costs to relocate systems from the 1755-1850 MHz band.

Breakdown on the Justice Assignments by Sub-Band

Fixed

1755-1780 = 47

1780-1790 = 12 (This total does not include 3 assignments listed in 1755-1780)

1790-1805 = 43

1805-1850 = 120 (This total does not include 14 assignments listed in 1790-1805)

Video

1755-1780 = 3

1780-1790 = 4

1790-1805 = 1 (This total does not include 4 assignments listed in 1780-1790)

1805-1850 = 5 (This total does not include 1 assignment listed in 1790-1805)

Robot

1755-1780 = 1

1780-1790 = 0

1790-1805 = 0

1805-1850 = 5

Total Number = 241
This page left intentionally blank.
B-33

National Aeronautics and

Space Administration

Headquarters

Washington, DC 20546-0001

Reply to Attn of: M-3 November 3, 2000

Mr. Gregory L. Rhode

Assistant Secretary

 for Communications and Information 

U. S. Department of Commerce 

Herbert C. Hoover Building 

14th & Constitution Avenue, NW 

Washington, DC 20230

Dear Secretary Rhode:

I am responding to your July 24, 2000, letter describing the Federal Government's

plans for implementing a third generation (3G) personal communications system in

addition to requesting certain cost data related to migrating NASA operations from

the 1755-1850 MHz band.

Action is underway by Agency Spectrum Management personnel who, as per your

direction, are compiling both the actual value of our overall infrastructure of

radiocommunications systems relying on use of the band, and the marginal costs of

relocating these systems to other suitable spectrum areas in the time frame

proscribed. This information will be provided to Mr. W. Russell Slye by 

Mr. James Hollansworth to meet your November 15, 2000 deadline.

If we can be of further assistance, please advise.

Sincerely,

Joseph H. Rothenberg

Associate Administrator

 for Space Flight

cc:

GRC/54-2/Mr. J. Hollansworth

DOC/Mr. W. Slye
B-34

From- James E Hollanswofth <James.E.Hollansworth@lerc.nasa.gov>

To: <RSLYE@ntia.doc.gov>, <David.Struba@hq.nasa.gov>

Date: Wed, Nov 15,2000 5:31 PM

Subject: Action Item M/2000-00948, 3rd Generation (3G) Personal Communication System

Dave:

The following NASA frequencies are in the indicated IMT-2000 Band 1755-1850 MHz. Below is the partial

information you requested. I am awaiting input from Dryden Flight Research Center and Wallops Flight

Facility.

Johnson Space Center

Number Center FrequencyCenter Indicated Use

NASA840033 1763.000000 JSC NSTS Payload

Integration. DoD payload frequency.

No cost involved on this

frequency.

Langley Research Center

Number Center FrequencyCenter Indicated Use

NASA940130 1780.500000 LARC Uplink Data Transmission

NASA760222 1804.500000 LARC Air-to-Ground Command

NASA940173 1804.500000 LARC Air-to-Ground Telecommand

NASA900122 1820.000000 LARC Free Flight

NASA900123 1835.500000 LARC Scale Model Aircraft Research

NASA940174 1835.500000 LARC Scale Model Aircraft Research

Blended Wing Body at Langley and at Dryden. This link is imperative

because the Blended Wing Body Low Speed Vehicle (LSV) is a remotely piloted research aircraft to be flown

at Edwards AFB in 2001. Langley is impacted because the LSV is being built at Langley and all systems are

integrated here.

Langley move costs would be approximately the following:

Design, Equipment and Installation $ 500,000.00.

each aircraft antenna, transmitters and receivers/demodulators $ 50,000.00 ea.

Move Costs will depend upon frequency availability and assignment.

Kennedy Space Center

Number Center FrequencyCenter Indicated Use

NASA980091 1800.000000 KSC CLIM

Cost of existing equipment is estimated at $ 20,000.00. No estimated replacement cost available at this time.

Kennedy Space Center

Number Center FrequencyCenter Indicated Use

NASA970062 1846.000000 KSC Video Link-Hazardous Ops Robot

Andros Hazardous Duty Robotics System plus additional equipment costs
B-35

$22,000.00. Hardware replacement cost and moving system are estimated to be $35,000.00-$40,000.00.

Additional costs not determined are research, procurement and support equipment.

Wallops Flight Facility

Number Center FrequencyCenter Indicated Use

NASA800313 1771.000000 WFF Balloon

NASA800314 1780.000000 WFF Balloon

NASA800320 1780.000000 WFF Balloon

NASA800313 1771 MHz (Palestine, TX) - This frequency is used extensively at Palestine, Texas, Fort

Sumner, New Mexico, and abroad in support of wideband video.

NASA800314 1780 MHz (Wallops Island) - This frequency is used on occasion. With the new Ultra Long

Duration Balloon (ULDB) program under development at Wallops, it is anticipated that there will be increased

demands for use of this frequency.

The current estimated cost of existing equipment in these bands is as follows: 1. Transmitters $ 30,000.00 and

2. GSE $ 324,000.00.

If we have to relocate above 2299 MHz the cost could be as much as $ 2,000,000.00.

Dryden Flight Research Center

Number Center FrequencyCenter Indicated Use

NASA940205 1804.500000 DFRC Air-to-Ground PCM

NASA900149 1804.500000 DFRC Remote Pilot Telemetry

NASA990018 1804.500000 DFRC Remote Pilot Telemetry

Existing NASA equipment currently in this band costs:

Ground Support: $ 5 Million

Airborne: $ 0.2 Million

Relocation costs would be determined by where we must relocate. The higher the frequency the higher the

cost. There would be a minimum of twelve months lead time to build the ground support equipment

depending on the band or bands relocated to. Program delays would be significant if we are forced out of

these bands.

Russ if you have any questions about the above material please feel free to call or e-mail me.

Jim Hollansworth

---------------------------------------------------------------------------------

James E. Hollansworth Telephone: (216) 433-3458

Glenn Research Center FAX: (216) 977-7444
B-36

NASA 1755-1850 MHz Impact Assessment Summary

hnson Space Center Langley Research Center Kennedy Space Center Wallops Flight Facility Dryden Flight Research Center

1 6 2 3 3

NA 14 2 Info not submitted 9 (ground) 4 (airborne)

NA 14 2 Info not submitted 24 (ground) 6 (airborne)

NA $277,500.00 $42,000.00 $354,000.00 $5,000,000.00 (ground) $200,000 (airborne)

NA

• $500,000.00 (Design,equipment, and installationestimated).• $50,000.00 (Aircraftantenna, transmitter andreceive demodulators).

$40,000.00 

$2,000,000.00 (If we have

to relocate above

2290 MHz)

• $2,000,000.00 (Groundbased if inband whereequipment exists).• $10,000,000.00 (Groundbased in new band and noequipment exists).• $200,000.00 (Airbornebased if in band whereequipment exists).• $1,000,000.00 (Airbornebased in new band and noequipment exists).

NA See note below NA NA See note below

S Payload Integration. 

D payload frequency. 

Blended Wing Body atLangley and at Dryden. Thislink is imperative becausethe Blended Wing Body LowSpeed Vehicle (LSV) is aremotely piloted researchaircraft to be flown atEdwards AFB in 2001.Langley and all systems areintegrated here.

The balloon program hasongoing operations yeararound to collect highaltitude atmospheric data. Requirements call forbroadband real-time videoand highspeed data. Thisprogram is an internationaleffort between the US andCanada. This is the secondtime this program has beenforced to move duecommercialization ofGovernment spectrum.

Program delays due to theinability to conduct timelytesting can be extremelycostly if we are forced out ofthese bands. Delays intesting can causesignificant program costoverruns. Test delaystypically could cost up to$100,000.00 a day (SourceNASA White Paper).

NA 3-5 years 2 years 3-5 years 3-5 years

NA to 10 years ------------ to 10 years to 10 years
NASA 1755-1850 MHz Impact Assessment Summary

hnson Space Center Langley Research Center Kennedy Space Center Wallops Flight Facility Dryden Flight Research Center

B-37

Assignments include:1 ea Facility for Uplink

data transmission.

2 ea Freq for air-to-gnd

cmd and telecmd.

1 ea Free flight.2 ea Scales model

aircraft research. 

Assignments include: 1 ea CLIM

Assignments include:1 ea Facility used

extensively atPalestine, TX., FtSumner, NM, andabroad in supportof wideband video.

Assignments include:1 ea Facility for

air-to-ground PCM.

2 ea Facility for remote

pilot telemetry.

be determined, we must know what band we are moving to.
This page left intentionally blank.
B-39

DEPARTMENT OF THE TREASURY

WASHINGTON, D.C. 20220

Mr. Gregory L. Rohde November 14, 2000

Administrator and Assistant Secretary

 for Communications and Information

U.S. Department of Commerce

National Telecommunications &

 Information Administration

HCHB, Room 4898

1401 Constitution Avenue, N.W.

Washington, D.C. 20230

Dear Mr. Rohde:

The Department of the Treasury operates a number of radio communications systems in the

subject band, which support the law enforcement missions of several of our bureaus. The

loss of any spectrum in the 1755-1850 MHz band would have a significant impact, both

financially and operationally, on the ability to support the Department's statutory protective

and investigative missions. Should the Treasury Bureaus be required to relocate from the

current band, our costs are estimated to be just over $100 million. These costs are explained

in more detail in Attachment One.

However, while we are concerned about the financial impact resulting from the loss of the

subject spectrum, our primary concern is more focused on the operational impact on our

bureaus' ability to continue their specific law enforcement and investigative activities.

As the remaining Federal spectrum becomes more congested, it becomes more difficult for

Federal users to identify and allocate spectrum with the appropriate propagation

characteristics to support broadband video and data requirements. We are confident the

availability of commercially provided services will increase, and technology will continue to

improve. As these commercial services become more cost effective, a significant portion of

the communications requirements supporting operations in this band can be shifted, thus

vacating a portion of this spectrum. However, specific investigative and protective support

requirements cannot be fulfilled with commercially provided services.

While Treasury is a strong supporter of emerging wireless technology and fully endorses the

activities to locate and provide spectrum for the Third Generation (3G) Technology, we

must also remain focused on our commitment to continue the fight against crime and

consider the impact to our Federal law enforcement mission, as well as the public safety

community.
B-40

We look forward to being an active participant in the working group that has been formed to

address potential spectrum support for future wireless technologies. Treasury will also continue

our involvement with the National Telecommunications and Information Administration

(NTIA) in the development of analysis and reports concerning the utilization of this spectrum

and feasibility of reallocation.

We thank you for the opportunity to address this important matter. Please direct any questions

concerning this matter to Mr. James Downes, of my staff, at (202) 622-1582 or via email at

james.downes@cio.treas.gov.

Sincerely,

James J. Flyzik

Deputy Assistant Secretary (Information Systems)

and Chief Information Officer

Attachment
B-41

 Attachment One

Specific Treasury Utilization

Specifically, the Department of the Treasury utilizes the following systems, which operate in

the 1755 - 1850 MHz band:

a. The U.S. Customs Service operates and maintains an analog microwave system,

commonly referred to as the Hawaii Rainbow Microwave System, which provides a 120-

channel intra- and inter-island backbone system throughout the Hawaiian Islands. The

system currently utilizes spectrum in the 1710-1850 MHz band. This system is a joint

agency endeavor utilized by Federal, State, and local users. The primary users of the system

include the U.S. Coast Guard, Drug Enforcement Administration, National Oceanic and

Atmospheric Administration (Tsunami Warning System), State Forestry Service and Civil

Defense, as well as some local police and emergency services. The system carries search,

rescue, and emergency distress information and other high priority communications.

 A portion of the spectrum used in the Rainbow System was protected from interference

under the mixed use criteria established by Title VI of the Budget Reconciliation Act of 1993

and was included in the list of Federal stations that will remain in the 1710 - 1755 MHz band. 

We strongly urge that any reallocation efforts in the 1755 - 1850 MHz band include

provisions to also protect this portion of the band.

However, due to the reallocation of this spectrum, manufacturers no longer support

equipment and systems operating in this frequency band. This impacts the cost in two ways. 

First, as the system continues to become more obsolescent, replacement parts are increasingly

scarce and maintenance costs continue to rise. Second, there are no possible alternatives to

upgrade/replace the system and remain in the 1710-1850 MHz band. Consequently, a study

has been initiated to evaluate and consider replacement alternatives. As a new digital

microwave system is considered it becomes obvious that the system must operate in a higher

frequency band, which will increase the number of required sites due to the propagation

characteristics of the higher frequencies. This will directly impact the cost of the system,

which is currently estimated to be approximately $46 million. Although other alternatives

are being investigated, the life cycle costs are expected to be of similar proportions. The

preliminary study is expected to be complete in February 2001 and further system

considerations will be addressed at that time.

b. One Treasury Bureau maintains microwave systems at various sites in Dallas, Texas and

Los Angeles, California. The systems provide broadband connectivity to land mobile radio

(LMR) systems supporting investigative and law enforcement activities, as well as protection

of national leaders and visiting heads of State. The Department of the Treasury is evaluating

the alternatives for replacing these microwave links with commercially provided circuits. 

The current estimate for this replacement is $40,000 to $50,000 for installation and monthly

recurring charges of approximately $120,000 per year. The recurring monthly charges will

 be approximately $1.2 million over a ten-year life cycle, although we anticipate these costs

would decrease as technology and commercial competition improves.
B-42

c. The bureaus within the Department of the Treasury deploy tactical microwave (video

surveillance) systems throughout the United States and possessions for both protective

operations and criminal investigations. Although our analysis has just begun, we anticipate

the cost to replace these tactical microwave systems into another band would exceed

$40 million, more than triple the current cost for the same systems operating in the 1755-

1850 MHz. Treasury has plans to replace this equipment over the next four years and has a

contract currently in place for this type equipment. However, current plans reflect

replacement in the same band at an estimated cost of $11.8 million.

Operational Impacts

While the cost impact is not insignificant, Treasury is more concerned with the operational

impact that would be experienced should this band be reallocated. This is particularly true with the

technical investigative activities supported with tactical microwave. The only available spectrum

that could support the bandwidth for these activities is in the higher ranges above 4 GigaHertz, which

becomes extremely problematic with range and antenna size. As the operating frequency increases,

the directional orientation of the antennas becomes paramount and the coverage range also

diminishes. Additional time and technical expertise will be necessary for the installation and use of

tactical microwave. Not only will low profile surveillance activities become very expensive, the

technology will put investigative operations at risk and jeopardize undercover missions.

We are extremely concerned that the loss of additional spectrum in this particular band will

seriously impact our ability to continue our law enforcement and protective missions within not only

the Department of the Treasury, but the entire Federal law enforcement community.
B-43

DEPARTMENT OF THE TREASURY

Washington, D.C.

March 5, 2001

Mr. W. Russell Slye

Manager, Strategic Spectrum 

 Planning Program

National Telecommunications & 

 Information Administration

HCHB, Room 4082

1401 Constitution Avenue, NW

Washington, D.C. 20230 

Re: Mr. James Flyzik’s Nov. 14, 2000 letter responding to Mr. Rohde’s June 19, 2000 letter

Dear Mr. Slye:

This letter revises the referenced letter and responds to questions raised by Messrs. Patrick

and Druhan after the January 23, 2001 Interdepartment Radio Advisory Committee meeting. The

questions concerned Mr. James Flyzik’s, Treasury Deputy Assistant Secretary (Information

Systems) and Chief Information Officer, response to Assistant Secretary Rohde’s June 19, 2000

letter, concerning the impact of possible reallocation of the 1755-1850 MHz band.

The Department of the Treasury bureaus’ inability to continue utilizing the 1755 -1850 MHz

band would have a detrimental effect on their ability to perform their statutory protective and

investigative missions. The Department operates a number of radio communication systems in

this band, particularly technical investigative activities supported with tactical microwave.

Although the replacement bands have not been identified, the relatively wide bandwidth required

for video surveillance activities will likely require these sensitive operations to move to higher

bands. As you are aware, the propagation characteristics in a higher frequency band will

significantly reduce the operating range and thus likely increase the cost of replacement systems.

Although relocating Treasury’s surveillance operations to another band would be a relatively

expensive cost, it is not the primary concern. The primary interest is the additional risk to

undercover missions that may unnecessarily endanger agents’ lives and jeopardize mission

integrity.

The following table lists Treasury’s current use of frequencies by system and frequency subbands as discussed in phone conversations with Mr. Patrick.

System 1755 - 1780 MHz 1780 - 1790 MHz 1790 - 1805 MHz 1805 - 1850 MHz

Rainbow Microwave (para. b) 2 1 4

Fixed Microwave (para. c) 2 1 1 3

Tactical Microwave (para. D) 5 1 5 7

Aeronautical (para. e) 1 1

Total 10 3 7 14
B-44

Response to the specific questions follows:

a. Why is there a discrepancy between “just over $100 million” estimate and the total of

$87.2 million listed in Attachment One? Both of the amounts in the referenced letter

were incorrect, the correct total estimate should be $88.5 million. The $100 million

estimate listed in the first paragraph did not accurately reflect the estimated costs listed in

attachment one of the original letter and the costs for the aeronautical systems were not

included in the previous estimates. The revised estimates are listed in the following

paragraphs.

b. Coast Guard’s estimate for their portion of the total cost of the Rainbow Microwave

System is $12 million, how much should Treasury’s portion of the total cost ($47 million)

be? The total cost for replacing the Rainbow system includes $9 million for site

enhancements for upgrading the LMR network in Hawaii. The Coast Guard, along with

the Departments of the Treasury and Justice, are currently the primary Federal users of

the Rainbow Network and generally divide the system costs evenly. Coast Guard,

however, does not have an LMR requirement in Hawaii, so they are proposing to pay onethird of the non-LMR portion of the Rainbow Digital Project which totals approximately

$12 million. Treasury’s portion of the replacement cost would be $35 million, however,

Treasury will likely request the total $47 million project cost and will seek reimbursement

from the other participating agencies.

c. What are the estimated costs for the fixed microwave systems? Treasury maintains

microwave systems at various sites in Texas and California. The systems provide

broadband connectivity to land mobile radio (LMR) systems supporting investigative and

law enforcement activities, as well as protection of national leaders and visiting

dignitaries. The Treasury Department is evaluating the alternatives for replacing these

microwave links with commercially provided circuits. The current estimate for this

replacement is $40,000 to $50,000 for installation and monthly recurring charges of

approximately $120,000 per year. The recurring monthly charges will be approximately

$1.2M over a ten-year life cycle, although we anticipate these costs would decrease as

technology and commercial competition continues to emerge.

 

d. Explain the reasons for “...more than triple the current cost for the same systems

operating in the 1755 - 1850 MHz band.” There are several reasons for tripling the cost

of the current systems in the band. First, the tactical microwave systems used by Treasury

in this band are very specialized and designed to operate in the spectrum allocated for

Federal government use. Currently, there are limited manufacturers of tactical microwave

systems in higher bands due to the limited market for tactical microwave systems. 

Consequently, potential manufacturers are unwilling to invest resources for research and

development without compensation. Second, operating in these higher frequency bands

will diminish the range of equipment, so more equipment will likely be required to

maintain equivalent capability. Further, it must be emphasized that the propagation and

beamwidth characteristics of the antennas will likely endanger the covert nature of the
B-45

undercover operations and jeopardize the mission and possibly the lives of the

agents/officers. Currently, initial estimates from potential manufacturers are about $40

million, including R&D costs.

 

e. What are Treasury’s aeronautical requirements? Treasury uses data from these systems

for its border law enforcement activities. The U.S. Air Force’s Air Combat Command

Project Office currently manages this project, but Treasury is expecting to assume

program management responsibilities in the near future. The Air Force estimates the

costs for relocating systems out of the 1755 - 1850 MHz band to be between $250,000

and $300,000.

We thank you for the opportunity to address this important matter. Please direct any questions or

comments concerning this matter to me or Ralph Robles at (202) 622-1582 or via email at

james.downes@cio.treas.gov or ralph.robles@cio.treas.gov.

Sincerely,

James E. Downes

Assistant Director, Wireless
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C-1

Appendix C

Frequency Assignment Tables by State/Location

The following tables list the frequency assignments of the Federal Agencies by state, number of

assignments, Federal agency, and station class. Assignments are listed for both the 1710-

1755 MHz band and the 1755-1850 MHz band. The assignments are taken from the Government

Master File of January 2001. Glossaries of abbreviations used may be found following the

tables.
1710-1755 MHz

STATE/

LOCATION No. AGENCY STATIONCLASS

STATE/

LOCATION No. AGENCY STATIONCLASS

C-2

AK 2 AF FX

AK 48 AR FX

AK 5 CG FX

AK 7 FAA FX

AK 6 I FX

TOTAL 68

AL 22 AR FX

AL 1 AR XD

AL 2 AR XT

AL 2 I FX

AL 2 J FX

AL 4 TVA FX

TOTAL 33

AR 12 A FX

AR 30 AR FX

AR 10 DOE FX

AR 1 N MOEA

TOTAL 53

AZ 55 A FX

AZ 7 AF FX

AZ 5 AR FX

AZ 2 AR MOEA

AZ 13 DOE FX

AZ 1 FAA FX

AZ 2 I FX

AZ 11 J FX

AZ 1 N FX

AZ 2 N FXE

AZ 3 N MAD

AZ 2 N MOEB

AZ 1 SI FX

TOTAL 105

BAH 1 FAA FX

TOTAL 1

CA 95 A FX

CA 1 AF FX

CA 1 AF FXD

CA 4 AF XD

CA 31 AR FX

CA 1 AR ML

CA 2 AR XT

CA 1 C FX

CA 5 CG FX

CA 9 DOE FX

CA 11 FAA FX

CA 7 I FX

CA 1 I FXE

CA 28 J FX

CA 24 N FX

CA 9 N MAD

CA 1 N ML

CA 12 N MOEA

CA 5 N MOEB

CA 1 N MOEB

CA 1 N MOEC

CA 1 NASA MOEA

CA 2 T FX

TOTAL 253

CAN 2 N FX

TOTAL 2

CO 25 A FX

CO 18 AR FX

CO 3 C FX

CO 12 DOE FX

CO 3 FAA FX

CO 7 I FX

CO 1 TRAN FLEC

TOTAL 69

CT 1 AR FX

TOTAL 1

DC 1 AR MA

TOTAL 1

FL 7 AF FX

FL 3 AF MA

FL 1 AF MAD

FL 1 AF MLD

FL 2 AF MO

FL 1 AF MOEB

FL 1 AF XD

FL 4 AF XD

FL 1 AF XT

FL 1 AR MOEB

FL 3 J FX

FL 4 N MOEA

FL 2 N MOEB

TOTAL 31
1710-1755 MHz

STATE/

LOCATION No. AGENCY STATIONCLASS

STATE/

LOCATION No. AGENCY STATIONCLASS

C-3

GA 18 A FX

GA 1 AF FX

GA 9 AR FX

GA 1 AR XT

GA 3 FAA FX

GA 12 J FX

GA 2 N FX

GA 1 TVA FX

TOTAL 47

GLM 4 AF FX

TOTAL 4

GUM 2 FAA FX

TOTAL 2

HI 2 C FX

HI 1 CG FX

HI 8 FAA FX

HI 8 N FX

HI 7 T FX

TOTAL 26

IA 10 AR FX

IA 1 DOE FX

TOTAL 11

ID 34 A FX

ID 1 AR FX

ID 9 DOE FX

ID 1 FAA FX

TOTAL 45

IL 12 AR FX

TOTAL 12

IN 1 AF MOEA

IN 1 AR FX

TOTAL 2

KS 1 AR FX

TOTAL 1

KY 16 AR FX

KY 4 TVA FX

TOTAL 20

LA 55 AR FX

LA 1 J FX

LA 2 N MOEA

LA 1 VA FX

TOTAL 59

MA 1 AR FX

TOTAL 1

MD 1 AR FX

MD 1 AR ML

MD 2 N FX

MD 3 N MOEA

TOTAL 7

ME 1 N FXD

TOTAL 1

MN 10 AR FX

MN 7 DOE FX

MN 1 FAA FX

TOTAL 18

MO 1 AF XT

MO 21 AR FX

MO 3 AR XT

MO 8 DOE FX

MO 4 FAA FX

TOTAL 37

MS 20 AR FX

MS 1 FAA FX

MS 7 I FX

MS 4 TVA FX

TOTAL 32

MT 5 A FX

MT 1 C FX

MT 23 DOE FX

MT 1 FAA FX

TOTAL 30
1710-1755 MHz

STATE/

LOCATION No. AGENCY STATIONCLASS

STATE/

LOCATION No. AGENCY STATIONCLASS

C-4

NC 12 A FX

NC 1 AR FX

NC 2 C FX

NC 6 I FX

NC 10 N FX

NC 1 N FXD

NC 3 N MAD

NC 24 N ML

TOTAL 59

ND 1 AF FX

ND 22 DOE FX

TOTAL 23

NE 20 AR FX

NE 10 DOE FX

TOTAL 30

NJ 4 AR FX

NJ 3 FAA FX

NJ 1 N MA

TOTAL 8

NM 65 A FX

NM 2 AF MAD

NM 7 AR FLE

NM 7 AR FX

NM 1 AR FX

NM 4 DOE FX

NM 4 FAA FX

NM 3 I FX

NM 7 J FX

NM 2 N MOEB

NM 1 T MOEB

TOTAL 103

NV 5 A FX

NV 6 AF FX

NV 2 AF FXD

NV 3 AR FX

NV 8 DOE FX

NV 2 DOE MA

NV 1 DOE ML

NV 1 DOE MOD

NV 6 FAA FX

NV 3 I FX

NV 3 J FX

NV 3 N MAD

TOTAL 43

NY 8 AR FX

NY 3 N FX

TOTAL 11

OH 1 AF MOEA

OH 1 N FX

TOTAL 2

OK 5 AR FX

OK 2 C FX

OK 15 DOE FX

OK 1 FAA FX

TOTAL 23

OR 31 A FX

OR 4 AR FX

OR 1 C FX

OR 3 CG FX

OR 14 DOE FX

OR 2 FAA FX

TOTAL 55

PA 2 AR FX

PA 11 J FX

TOTAL 13

PR 5 AR FX

PR 4 CG FX

PR 9 FAA FX

PR 3 J FX

PR 1 N FXE

PR 1 N MOEA

TOTAL 23

RI 1 N MOEA

RI 1 N XT

TOTAL 2

SC 11 AR FX

SC 1 N FX

SC 3 N MAD

TOTAL 15
1710-1755 MHz

STATE/

LOCATION No. AGENCY STATIONCLASS

STATE/

LOCATION No. AGENCY STATIONCLASS

C-5

SD 1 A FX

SD 42 DOE FX

TOTAL 43

SMA 2 FAA FX

SMA 3 I FX

TOTAL 5

TN 16 A FX

TN 3 AR FX

TN 1 DOE ML

TN 1 I FX

TN 21 TVA FX

TOTAL 42

TX 1 AF FX

TX 1 AR FLEC

TX 26 AR FX

TX 5 AR XT

TX 1 CG FX

TX 3 DOE FX

TX 2 FAA FX

TX 1 FEMA FX

TX 27 J FX

TX 1 NASA FX

TX 1 T FX

TOTAL 69

USA 45 AR FX

USA 10 FEMA FX

USA 1 HUD FX

USA 1 NASA MOEB

TOTAL 57

USP 3 J FX

USP 1 J FX

USP 8 T FX

USP 1 T MA

USP 1 USPS FX

TOTAL 14

UT 30 A FX

UT 6 AF FX

UT 1 AF FXD

UT 1 AF MAD

UT 6 AR FX

UT 1 I FX

TOTAL 45

VA 17 A FX

VA 3 AR FX

VA 3 FAA FX

VA 4 FEMA FX

VA 6 I FX

VA 3 N FX

VA 3 N MAD

VA 3 N MOEA

VA 2 NASA MOEA

TOTAL 44

VI 10 FAA FX

TOTAL 10

WA 31 AR FX

WA 14 CG FX

WA 11 DOE FX

WA 3 FAA FX

WA 3 N FX

TOTAL 62

WI 15 AR FX

WI 1 J FX

TOTAL 16

WY 9 A FX

WY 18 DOE FX

WY 9 I FX

TOTAL 36
1755-1850 MHz

STATE/

LOCATION No. AGENCY STATIONCLASS

STATE/

LOCATION No. AGENCY STATIONCLASS

C-6

AK 31 AF FLEB

AK 71 AF FX

AK 5 AF MOEB

AK 99 AR FX

AK 1 AR FXD

AK 1 C TD

AK 15 CG FX

AK 1 DOE TC

AK 13 FAA FX

TOTAL 237

AL 34 AR FX

AL 1 AR MA

AL 1 AR MOEA

AL 4 AR XT

AL 1 J ML

AL 9 TVA FX

TOTAL 50

AR 18 A FX

AR 1 AF ML

AR 43 AR FX

AR 26 DOE FX

AR 1 N MOEA

TOTAL 89

AZ 60 A FX

AZ 1 AF FA

AZ 8 AF FLEB

AZ 21 AF FX

AZ 1 AF ML

AZ 1 AF MOEA

AZ 1 AF MOEB

AZ 18 AR FX

AZ 1 AR MA

AZ 1 AR ML

AZ 1 AR MOEB

AZ 30 DOE FX

AZ 1 FAA FX

AZ 26 I FX

AZ 14 J FX

AZ 13 N FLEB

AZ 4 N FX

AZ 32 N FXE

AZ 2 N MAD

AZ 5 N MOEB

AZ 1 SI FX

TOTAL 242

BAH 1 FAA FX

TOTAL 1

CA 194 A FX

CA 20 AF FLEB

CA 64 AF FX

CA 1 AF FXD

CA 2 AF ML

CA 10 AF MOEA

CA 5 AF MOEB

CA 41 AF TD

CA 2 AF TK

CA 8 AF XD

CA 40 AF XT

CA 5 AR FLEB

CA 101 AR FX

CA 4 AR ML

CA 2 AR XT

CA 4 C FX

CA 5 CG FX

CA 13 DOE FX

CA 4 DOE ML

CA 33 FAA FX

CA 34 I FX

CA 1 I FXE

CA 43 J FX

CA 1 N FLEB

CA 50 N FX

CA 4 N FXE

CA 6 N MAD

CA 3 N ML

CA 1 N MO

CA 1 N MOE

CA 35 N MOEA

CA 15 N MOEB

CA 1 N MOEC

CA 2 N MS

CA 2 NASA FAT

CA 3 NASA FX

CA 3 NASA MOEA

CA 4 T FX

TOTAL 767

CAN 1 N FX

TOTAL 1

CO 38 A FX

CO 18 AF TD

CO 1 AF TK

CO 40 AR FX

CO 1 C FX

CO 19 DOE FX

CO 1 DOE ML

CO 15 FAA FX

CO 7 I FX

CO 2 NSF FXE

TOTAL 142

CT 2 AR FX

TOTAL 2
1755-1850 MHz

STATE/

LOCATION No. AGENCY STATIONCLASS

STATE/

LOCATION No. AGENCY STATIONCLASS

C-7

DC 1 AR FX

DC 1 J FX

DC 1 USCP FX

TOTAL 3

DE 1 AF MOEC

DE 1 AR FX

TOTAL 2

DGA 20 AF TD

TOTAL 20

FL 9 AF FLEB

FL 2 AF FLEC

FL 9 AF FX

FL 1 AF FXE

FL 4 AF MA

FL 1 AF MAD

FL 4 AF ML

FL 5 AF MLD

FL 3 AF MO

FL 5 AF MOEB

FL 6 AF MOEC

FL 18 AF TD

FL 10 AF XD

FL 2 AF XT

FL 1 AR MR

FL 8 FAA FX

FL 4 J FX

FL 6 N FLEA

FL 18 N FXE

FL 5 N MOEA

FL 8 N MOEB

FL 1 NASA FL

FL 1 NASA ML

TOTAL 131

G 20 AF TD

TOTAL 20

GA 25 A FX

GA 1 AF FX

GA 29 AR FX

GA 1 AR XT

GA 6 FAA FX

GA 20 J FX

GA 1 N FX

GA 1 T FX

GA 1 TVA FX

TOTAL 85

GLM 2 AF FA

GLM 11 AF FLEB

GLM 37 AF FX

GLM 2 AF MOEB

TOTAL 52

GUM 1 AF MO

GUM 21 AF TD

GUM 4 FAA FX

TOTAL 26

HI 2 AF FX

HI 20 AF TD

HI 1 AR FX

HI 1 AR MOEB

HI 2 C FX

HI 1 CG FX

HI 24 FAA FX

HI 6 N FX

HI 1 N ML

HI 1 N MO

HI 7 T FX

TOTAL 66

IA 25 AR FX

IA 5 DOE FX

TOTAL 30

ID 55 A FX

ID 1 AF ML

ID 3 AR FX

ID 15 DOE FX

ID 3 DOE ML

ID 2 FAA FX

TOTAL 79

IL 1 AF MOEC

IL 26 AR FX

IL 2 FAA FX

TOTAL 29

IN 1 N ML

TOTAL 1

KS 1 AF MO

TOTAL 1

KY 55 AR FX

KY 9 TVA FX

TOTAL 64

LA 1 AF ML

LA 103 AR FX

LA 9 CG FX

LA 1 J FX

LA 2 N MOEA

TOTAL 116
1755-1850 MHz

STATE/

LOCATION No. AGENCY STATIONCLASS

STATE/

LOCATION No. AGENCY STATIONCLASS

C-8

LANT 4 N FLEA

LANT 19 N FLEB

LANT 1 N FX

LANT 31 N FXE

TOTAL 55

MA 2 AF XT

MA 3 AR FX

MA 2 FAA FX

MA 9 J FX

TOTAL 16

MD 1 AF XD

MD 2 AR FX

MD 3 AR ML

MD 2 C ML

MD 1 HHS FX

MD 1 N FLEA

MD 5 N FX

MD 3 N MOEA

MD 2 N MOEB

MD 20 N TD

TOTAL 40

ME 10 J FX

ME 1 N FX

TOTAL 11

MHL 1 AF TD

TOTAL 1

MI 1 AF MOEA

TOTAL 1

MN 20 AR FX

MN 13 DOE FX

MN 1 FAA FX

TOTAL 34

MO 1 AF XD

MO 32 AR FX

MO 3 AR XT

MO 17 DOE FX

MO 8 FAA FX

TOTAL 61

MT 9 A FX

MT 1 AF ML

MT 5 AR FX

MT 2 C FX

MT 50 DOE FX

MT 3 FAA FX

TOTAL 70

NC 29 A FX

NC 2 AF ML

NC 1 AR XT

NC 4 FEMA FX

NC 3 I FX

NC 7 N FLEA

NC 26 N FLEB

NC 22 N FX

NC 65 N FXE

NC 2 N MAD

NC 18 N ML

NC 35 N MO

NC 1 N MOEA

NC 12 N MOEB

TOTAL 227

ND 1 AF ML

ND 39 DOE FX

TOTAL 40

NE 20 AR FX

NE 15 DOE FX

TOTAL 35

NH 22 AF TD

NH 74 AR FX

NH 2 J FX

TOTAL 98

NJ 1 AF MOEC

NJ 4 AR FX

NJ 1 C FX

NJ 5 FAA FX

NJ 1 J FX

NJ 1 N MOEB

TOTAL 13

MS 7 AF FLEB

MS 9 AF FX

MS 19 AR FX

MS 3 FAA FX

MS 12 I FX

MS 11 TVA FX

TOTAL 61
1755-1850 MHz

STATE/

LOCATION No. AGENCY STATIONCLASS

STATE/

LOCATION No. AGENCY STATIONCLASS

C-9

NM 66 A FX

NM 2 AF MA

NM 3 AF MAD

NM 1 AF MOEB

NM 20 AF TD

NM 1 AF XD

NM 1 AF XT

NM 3 AR FLE

NM 12 AR FX

NM 1 AR MA

NM 2 AR MOEA

NM 3 AR MR

NM 6 DOE FX

NM 1 DOE ML

NM 1 DOE XT

NM 12 FAA FX

NM 18 I FX

NM 16 J FX

NM 2 N MOEB

NM 2 T FAD

NM 1 T FX

TOTAL 174

NV 6 A FX

NV 2 AF FA

NV 27 AF FLEB

NV 146 AF FX

NV 3 AF FXD

NV 1 AF FXE

NV 1 AF ML

NV 4 AF MOEB

NV 2 AF XD

NV 6 AF XT

NV 3 AR FX

NV 17 DOE FX

NV 2 DOE FXE

NV 1 DOE ML

NV 18 FAA FX

NV 1 I FX

NV 5 J FX

NV 26 N FLEA

NV 23 N FLEB

NV 87 N FXE

NV 2 N MAD

NV 3 N MOEB

TOTAL 386

OK 1 AR FLD

OK 32 AR FX

OK 3 C FX

OK 22 DOE FX

OK 3 FAA FX

TOTAL 61

OR 47 A FX

OR 10 AR FX

OR 2 C FX

OR 6 CG FX

OR 33 DOE FX

OR 4 FAA FX

TOTAL 102

PA 3 AR FX

PA 2 FEMA FX

PA 25 J FX

TOTAL 30

PR 13 AR FX

PR 2 CG FX

PR 20 FAA FX

PR 5 J FX

PR 3 N MOEA

TOTAL 43

RI 1 J FX

TOTAL 1

SC 1 AF MOEC

SC 19 AR FX

SC 2 DOE MA

SC 1 DOE ML

SC 2 N FLEB

SC 2 N FX

SC 2 N MAD

SC 1 N MO

SC 1 N MOD

SC 2 N MOEB

TOTAL 33

SD 2 A FX

SD 75 DOE FX

TOTAL 77

SMA 2 FAA FX

SMA 4 I FX

TOTAL 6

SPCE 1 NASA ED

TOTAL 1

NY 35 AR FX

NY 6 CG FX

NY 9 N FX

TOTAL 50

OH 1 N FX

TOTAL 1
1755-1850 MHz

STATE/

LOCATION No. AGENCY STATIONCLASS

STATE/

LOCATION No. AGENCY STATIONCLASS

C-10

TN 21 A FX

TN 4 AR FX

TN 2 DOE FX

TN 5 DOE ML

TN 4 I FX

TN 34 TVA FX

TOTAL 70

TX 1 AF FX

TX 2 AF ML

TX 20 AF TD

TX 8 AF XT

TX 2 AR FLD

TX 49 AR FX

TX 9 AR XT

TX 1 CG FX

TX 5 DOE FX

TX 2 FAA FX

TX 1 FEMA FX

TX 62 J FX

TX 3 T FX

TOTAL 165

USA 3 A FX

USA 1 AID FX

USA 93 AR FX

USA 2 DOE FX

USA 1 EPA FX

USA 1 HHS MLP

USA 5 HUD FX

USA 1 L FX

USA 3 NASA MOEB

USA 1 NRC FX

TOTAL 111

VA 24 A FX

VA 1 AR MOEA

VA 3 FAA FX

VA 4 FEMA FX

VA 3 I FX

VA 3 J FX

VA 5 N FC

VA 8 N FX

VA 2 N MAD

VA 1 N MO

VA 3 N MOEA

VA 1 N MOEB

VA 20 N TD

VA 5 NASA FAD

VA 1 NASA MOEA

TOTAL 84

VI 1 CG FX

VI 14 FAA FX

TOTAL 15

WA 4 A FX

WA 1 AF MO

WA 1 AF MOEC

WA 63 AR FX

WA 25 CG FX

WA 42 DOE FX

WA 3 DOE ML

WA 3 FAA FX

WA 2 J FX

WA 5 N FX

WA 1 N MAD

TOTAL 150

WI 1 AF FLEB

WI 1 AF FXE

WI 17 AR FX

WI 1 J FX

TOTAL 20

WV 2 FEMA FX

TOTAL 2

USP 1 HUD FX

USP 10 J FX

USP 5 J ML

USP 15 T FX

USP 1 T MA

USP 2 USPS FX

TOTAL 34

UT 57 A FX

UT 10 AF FX

UT 1 AF MAD

UT 1 AF ML

UT 2 AF MOEA

UT 10 AR FX

UT 1 AR MR

UT 1 DOE FX

UT 7 I FX

TOTAL 90

WY 13 A FX

WY 31 DOE FX

WY 13 I FX

TOTAL 57
C-11

Station Class Definitions

FA--Aeronautical Station: A land station in the aeronautical mobile service. In certain instances, an aeronautical

station may be located, for example on board ship or on a platform at sea. (RR)

FAD--Telecommand Aeronautical Station: A land station in the aeronautical mobile service the emissions of which

are used for terrestrial telecommand.

FAT--Flight Test Station: An aeronautical station used for the transmission of essential communications in connection with the testing of aircraft or major components of aircraft.

FC--Coast Station: A land station in the maritime mobile service. (RR) 

FL--Land Station: A station in the mobile service not intended to be used while in motion. (RR)

FLD--Telecommand Land Station: A land station in the mobile service the emissions of which are used for

terrestrial telecommand.

FLE--Telemetering Land Station: A land station the emissions of which are used for telemetering.

FLEA--Aeronautical Telemetering Land Station: A telemetering land station used in the flight testing of manned or

unmanned aircraft, missiles, or major components thereof.

FLEB--Flight Telemetering Land Station: A telemetering land station the emissions of which are used for telemetering to a balloon; to a booster or rocket, excluding a booster or rocket in orbit about the Earth or in deep space; or

to an aircraft, excluding a station used in the flight testing of an aircraft.

FLEC--Surface Telemetering Land Station: A telemetering land station the emissions of which are intended to be

received on the surface of the Earth.

FX--Fixed Station: A station in the fixed service. (RR) 

FXE--Telemetering Fixed Station: A fixed station the emissions of which are used for telemetering.

LR--Radiolocation Land Station: A station in the radiolocation service not intended to be used while in motion.

(RR) 

MA--Aircraft Station: A mobile station in the aeronautical mobile service other than a survival craft station, located

on board an aircraft. (RR) 

MAD--Telecommand Aircraft Station: A mobile station in the aeronautical mobile service the emissions of which

are used for terrestrial telecommand.

ML--Land Mobile Station: A mobile station in the land mobile service capable of surface movement within the

geographical limits of a country or continent. (RR) 

MLD--Telecommand Land Mobile Station: A mobile station in the land mobile service the emissions of which are

used for terrestrial telecommand.

MLP--Portable Land Mobile Station: A portable station operating in the land mobile service.

MO--Mobile Station: A station in the mobile service intended to be used while in motion or during halts at unspecified points. (RR) 

MOD--Telecommand Mobile Station: A mobile station in the mobile service the emissions of which are used for

terrestrial telecommand.

MOE--Telemetering Mobile Station: A mobile station the emissions of which are used for telemetering.

MOEA--Aeronautical Telemetering Mobile Station: A telemetering mobile station used for transmitting data

directly related to the airborne testing of the vehicle, (or major components), on which the station is installed.
C-12

MOEB--Flight Telemetering Mobile Station: A telemetering mobile station used for transmitting data from an

airborne vehicle, excluding data related to airborne testing of the vehicle itself, (or major components thereof).

MOEC--Surface Telemetering Mobile Station: A telemetering mobile station located on the surface of the Earth

and the emissions of which are intended to be received on the surface of the Earth.

MR--Radiolocation Mobile Station: A station in the radiolocation service intended to be used while in motion or

during halts at unspecified points. (RR) 

MS--Ship Station: A mobile station in the maritime mobile service located on board a vessel which is not

permanently moored, other than a survival craft station. (RR) 

TC--Fixed-Satellite Earth Station: An earth station in the fixed-satellite service. (RR) 

TD--Space Telecommand Earth Station: An earth station the emissions of which are used for space telecommand.

TK--Space Tracking Earth Station: An earth station which transmits or receives emissions used for space tracking. 

XD--Experimental Developmental Station: An experimental station used for evaluation or testing of electronics

equipment or systems in a design or development stage.

XT--Experimental Testing Station: An experimental station used for the evaluation or testing of electronics equipment or systems, including site selection and transmission path surveys, which have been developed for operational

use.
C-13

Geographical Abbreviations

AK Alaska 

AL Alabama 

AR Arkansas

AZ Arizona 

BAH Bahamas (Commonwealth of the)

CA California 

CAN Canada

CO Colorado 

CT Connecticut 

DC District of Columbia 

DE Delaware 

DGA Diego Garcia 

FL Florida 

GA Georgia 

GLM Gulf of Mexico

GUM Guam

HI Hawaii 

IA Iowa 

ID Idaho 

IL Illinois 

IN Indiana 

KS Kansas 

KY Kentucky 

LA Louisiana 

LANT Atlantic Ocean

MA Massachusetts 

MD Maryland 

ME Maine 

MHL Marshall Islands

MI Michigan 

MN Minnesota 

MO Missouri 

MS Mississippi 

MT Montana 

NC North Carolina 

ND North Dakota 

NE Nebraska 

NH New Hampshire 

NJ New Jersey 

NM New Mexico 

NV Nevada 

NY New York 

OH Ohio 

OK Oklahoma 

OR Oregon 

PR Puerto Rico (including Culebra, Mona, and

Vieques)

PA Pennsylvania 

RI Rhode Island 

SC South Carolina 

SD South Dakota 

SMA American Samoa

SPCE Space

TN Tennessee 

TX Texas 

UT Utah 

USA For use only when transmitting and/or

receiving in the 48 Contiguous States of the

United States and the District of Columbia

(This excludes Alaska and Hawaii)

USP For use only when transmitting and/or

receiving throughout the US (50 States and

District of Columbia), the Commonwealth of

Puerto Rico, and the Territories and

Possessions. (does not include the former

Trust Territory of the Pacific Islands)

VA Virginia 

VT Vermont

WA Washington 

WI Wisconsin 

WV West Virginia 

WY Wyoming
C-14

Abbreviations for the Federal Entities

as used in this Appendix

A Department of Agriculture

AID Agency for International Development

AF Department of the Air Force

AR Department of the Army

FAA Federal Aviation Administration

C Department of Commerce

CG United States Coast Guard

DOE Department of Energy

EPA Environmental Protection Agency

FAA Federal Aviation Administration

FEMA Federal Emergency Management Agency

HHS Department of Health and Human Services

HUD Department of Housing and Urban Development

I Department of the Interior

J Department of Justice

L Department of Labor

N Department of the Navy

NASA National Aeronautics and Space Administration

NRC Nuclear Regulatory Commission (Now DOE)

NSF National Science Foundation

T Department of the Treasury

TVA Tennessee Valley Authority

USPS United States Postal Service

VA Department of Veterans Affairs
D-1

Appendix D

DOD Final Report

Department of Defense

Investigation of the Feasibility of Accommodating the

International Mobile Telecommunications (IMT) 2000

Within the 1755-1850 MHz Band

This report is printed separately as Appendix D (less Attachment 1) to this report. This DOD

report can be viewed in its entirety on the NTIA homepage at: www.ntia.doc.gov.