Cingular Wireless urged FCC last week to reallocate 2 GHz mobile ...

industry is not economically viable,” Cingular said in comments to FCC on further notice of proposed rulemaking covering additional frequency bands for 3G. Cingular asked that agency “immediately allocate” at least 160 MHz of additional spectrum below 3 GHz to meet broadband spectrum needs for advanced wireless services, in line with recommendations of World Radio Conference (WRC) 2000. Cingular said: “Internationally, the United States has taken the position that large contiguous blocks of spectrum should be considered for advanced wireless services.” Blocks identified at WRC-2000 by U.S. as candidate bands for advanced wireless services “are no longer being considered for these services domestically,” Cingular said. Carrier urged FCC to consider blocks of spectrum that would be harmonized as much as possible with ITU recommendations. It said that at last WRC, U.S. had largely won support for its position on multiband approach for 3G, including 1710-1850 MHz and 2500-2690 MHz. Based on results of WRC, “Cingular expected that a substantial portion of these frequencies would be reallocated for these services.” Since then, Commission has moved 2500-2690 MHz occupied by MMDS and Instructional TV Fixed Service licensees off table for relocation for 3G. NTIA also has announced that 1770-1850 MHz, used mostly by military systems, “would not be used for such services,” Cingular said. That means that out of 365 MHz identified by U.S. for advanced wireless services, all but 60 MHz have been taken out of running for 3G, Cingular said. Carrier noted CTIA has urged Commission to reallocate MSS band for terrestrial wireless use. FCC should adopt core principles, according to Cingular, including: (1) Elimination of spectrum cap. (2) Decision that spectrum should be cleared by “date certain” for advanced wireless services. (3) Extension of relocation procedures adopted in emerging technology docket to all spectrum clearing. (4) Creation of “clear title” before allowing auction of reallocated spectrum. “The Commission should address the apparent inconsistency between the international recognition that at least 200 MHz of spectrum will be necessary to adequately address advanced wireless needs in the United States and its proposals to allocate only slivers of spectrum spread across numerous bands on a piecemeal basis,” Cingular said.