FCC URGED TO FREE UP MORE SPECTRUM FOR 3G, WITH EYE ON 1.7 GHZ

Not surprisingly, agency also received flood of comments from Instructional TV Fixed Service (ITFS) and Multichannel, Multipoint Distribution Service (MMDS) licensees staunchly defending broadband fixed wireless applications used for underserved areas. Sprint outlined its $2 billion investment in MMDS, pointing out it was offering high-speed, 2-way broadband service in 13 markets. It stressed that comparable spectrum wasn’t available for MMDS and ITFS licensees and that FCC policy for involuntary relocation of incumbents in such cases was “woefully inadequate.” Any FCC retreat from policy of encouraging development of 2.1 GHz and 2.5 GHz bands for advanced fixed wireless services would be “arbitrary and capricious,” Sprint said. No other spectrum is set aside specifically for formal education instruction and move to free up those bands for 3G would “potentially halt ITFS operations.” Sprint cited interim report on 2.5 GHz spectrum released last fall by FCC that concluded there were significant challenges to sharing between mobile and fixed users without creating interference.

Comments were response to FCC’s notice of proposed rulemaking on potential need for additional spectrum for advanced wireless services, including 3G. As part of overall govt. exercise examining alternatives for 3G spectrum, FCC has purview over ITFS and MMDS licensees in 2500-2690 MHz, and NTIA is examining 1755- 1850 MHz band now occupied mostly by Defense Dept. Both agencies are working toward final reports on alternatives that are due next month, including potential relocation costs and alternative spectrum for incumbent relocation.

Sprint outlined framework for increased costs it would face if spectrum availability were decreased. It said if it had access to 26 channels in market with 173,930 pops, it must make $479 per subscriber in capital expenditures to roll out broadband service using supercell configuration. If allocation dropped to 11 channels, “the required level of investment rises by a factor of 6,” due to elements such as cost of additional cells and decline in subscribers. That would brings per-subscriber investment to $2,928, Sprint said. Such increases would occur in every market, making service “economically infeasible,” it said.

Meanwhile, ITFS licensees organized Internet campaign to galvanize educators to oppose use of 2.5 GHz for 3G services. “The push to find additional spectrum for cellphones and other personal devices threatens to take ITFS licenses away from educators,” warns Web site, www.itfs.org/webnow, sponsored by ITFS Spectrum Development Alliance and National ITFS Assn. In joint comments, dozens of education organizations opposed reallocation of band, giving detailed examples of how educators were using bands for distance learning, professional education, other initiatives. They emphasized: (1) Digital educational materials and video programming were used to reach “millions” of students. (2) Two-way, wireless data transmissions were used for distance learning. “Educators are just beginning to realize the enormous potential of this technology.” (3) Partnerships of wireless companies and ITFS licensees shared spectrum. (4) Two-way, wireless broadband services had potential to reach underserved rural, urban and tribal areas “that cable modem and DSL providers cannot or will not serve.”

Among equipment makers, Qualcomm urged FCC to consider version of DCS-1800 spectrum allocation scheme used in countries throughout Americas which pair 1710-1785 MHz with 1805-1880 MHz. It acknowledged that couldn’t be followed exactly without refarming PCS frequencies in U.S., which isn’t viable. “It is not feasible to clear or share with the incumbent users of the 1755- 1850 MHz band and allocate these frequencies in a manner that is consistent with the DCS-1800 band plan,” Qualcomm said. “Next best” option would be to pair 1710-1755 MHz with 2110-2150/2160- 2165 MHz, it said. As example, it said 2110 MHz range could be used as “global common downlink band” to provide global roaming capability. While DCS-1800 band is developed for GSM services in much of world, one drawback to that pairing scenario would be that frequencies above 2 GHz weren’t likely to support roaming outside of metro areas in near term, especially in Asia, Qualcomm said.

Ericsson advocated phased approach of allocating 3G spectrum that would make more available than under initial options outlined in govt. proposals. Phases proposed by Ericsson included: (1) 1710-1770 MHz as uplink and 2110-2170 as downlink with availability in 2003. (2) Part or all of 1770-1850 MHz as uplink and parts or all of 2500-2690 MHz as downlink, with availability in 2005-2008. (3) Addition of 3G mobile allocation in mobile satellite service bands, “depending on market conditions,” which would entail 1990-2025 MHz as uplink and 2170-2200 MHz as downlink. (4) Beyond 2010, “market-based transition of PCS band- plan” by using 1850-1990 MHz as uplink. Shared use of 1710-1770 MHz between commercial wireless and Dept. of Defense users wouldn’t be feasible because 3G services always are on, Ericsson acknowledged. Incumbent users would have to be offered reimbursement under that scenario, but company told FCC it would be less disruptive to incumbent federal users than other spectrum alternatives that require using larger chunk of 1710-1850 MHz.

Large part of spectrum that Ericsson proposed for initial advanced wireless service uplink “has already been identified for reallocation” and is becoming available for mixed commercial use. Because all of proposed downlink at 2110-2170 MHz must be made available, Ericsson proposed FCC clear band and cover relocation costs from new licensee’s auction proceeds. This would “create a predictable level of total spectrum license costs.” Ericsson pitched one advantage of plan as creating 2110-2170 as “global downlink” for 3G with 1710-1770 MHz as common regional uplink. On recommendation that FCC examine MSS bands as downlink for possible allocation by 2009, Ericsson said agency “can examine the MSS market to determine whether this spectrum is fully and efficiently utilized or sparsely populated.”

Motorola said FCC should allocate 1710-1850 MHz and 2110- 2150/2160-2165 MHz for advanced terrestrial 3G services. It characterized 2500-2690 MHz as “highly desirable” mobile spectrum but said that band didn’t offer same near-term potential for international spectrum harmonization as 1.7 GHz does. Critical to spectrum’s being used, however, is restructuring of auction policy so proceeds can be used to fund relocation of affected incumbents, company said. “Motorola intends to work with Congress, the FCC and NTIA on these issues during the coming months,” company said.

Specifically, it recommended pairing of 1710-1755 MHz for mobile station transmit with 1800-1845 MHz for base station transmit. Spectrum from 1755-1780 MHz could be paired with 2110- 2150/2160-2165 MHz. Motorola stressed need for relocation expenses to be identified before auction of spectrum. New licensees would be required to deposit funds into U.S. Treasury account of federal entity concerned. “These funds would then be available to the federal entity, subject to the provisions of its authorization acts and appropriations acts.”