CARRIERS FLOAT PROPOSED RULE CHANGES FOR ADVANCED WIRELESS

The FCC earlier this year in a series of decisions, including an order that granted ancillary terrestrial authority to mobile satellite service (MSS) licensees, adopted: (1) An order that allocated fixed and mobile wireless services at 1990-2000 MHz, 2020-2025 MHz and 2165- 2180 MHz. It concluded 2 GHz MSS, which has been authorized to use 1990-2025 MHz and 2165-2200 MHz, can operate in less than the 70 MHz of spectrum previously allocated. That kept 40 MHz for MSS at 2000-2020 MHz and 2180-2200 MHz. (2) A proposal on the use of 1910-1920 MHz that consisted of unused, unlicensed PCS operations. The proposal suggested several possible combinations of uses involving 1990-2000 MHz, 2155-2160/62 MHz used by MDS and the 2160-2165 MHz earmarked for emerging technologies. The FCC didn’t take any action that would affect the outcome of pending 800 MHz reconfiguration proceeding, which involves several pieces of that spectrum. The reallocation order freed 30 MHz for fixed and mobile service through 21 MHz that MSS operators that missed their milestones would relinquish. The MDS operators have objected to part of the order that reallocated 2150-2155 MHz to advanced wireless systems such as 3G, a move they said effectively displaced MDS from the entire 2150-2162 MHz band but deferred relocation considerations to a future further notice. The Satellite Industry Assn. and ICO filed challenges to the MSS reallocation order (see separate story, this issue).

Opposing a Nextel-backed alternative, Cingular supported a proposal by a coalition of MDS operators to pair spectrum at 1.9 GHz for use by relocated MDS licensees that will operate under broadband PCS licensing rules. Sprint and the Wireless Communications Assn. asked the FCC in Feb. to reconsider its decision to reallocate spectrum for advanced wireless services without providing incumbent MDS licensees with replacement spectrum or guaranteed reimbursement. Sprint said it had spent more than $1 billion to obtain MDS licenses and leases of MDS/Instructional TV Fixed Service (ITFS) capacity. Cingular backed WCA and Sprint in urging the Commission to support the MDS coalition proposal. “Conversely, the Commission should reject Nextel’s proposal to obtain access to 10 MHz of spectrum in this band under the pretext that it is necessary to resolve interference issues in the 800 MHz band; it is nothing more than a self-serving spectrum grab,” Cingular said.

Cingular is among the wireless carriers challenging the FCC’s 2 GHz MSS licensing decisions. But if those licensees continue to use 2000-2020 MHz and 2180-2200 MHz, Cingular asked for: (1) Retaining 1916-1930 MHz for unlicensed PCS. (2) Designating 1996-2000 MHz as a guard band to separate PCS base station transmitters from MSS and ancillary terrestrial component (ATC) base station receivers. (3) Relocating displaced govt. users to 2020-2025 MHz. (4) Reserving 2155- 2170 MHz for future advanced wireless service base transmit pairings or combining 2110-2155 MHz for an “asymmetric base transmit pairing” with 1710-1755 MHz. (5) Allocating 2170- 2180 MHz for future or asymmetrical advanced wireless service pairings or allocation of the band for low power unlicensed use on a noninterfering basis.

Motorola urged the FCC to give “paramount consideration” to the potential for interference to existing and future licensees when designating advanced wireless spectrum. Among the bands in the proposal that hold significant potential for PCS and advanced wireless deployment are 1910-1915 MHz and 1990-1995 MHz, it said. Those blocks offer a chance to create a new band pair for short-term deployment of PCS services and longer term rollout of advanced wireless services (AWS), Motorola said. It also singled out 2155-2180 MHz as holding “enormous” promise for expanding advanced wireless service by forming a 2110-2180 MHz downlink that would be in line with existing international 3G allocations. Motorola cautioned that some bands identified in the proposal would be of less use for AWS, “due to the limited amount of spectrum available and the need to protect existing licensees in the PCS and future licensees in the previously allocated 90 MHz of AWS spectrum from harmful interference.” In proposing that FCC keep 1915-1920 MHz for unlicensed PCS operations, Motorola urged it to alter its Part 15 rules to allow the use of isochronous -- or voice -- devices in the band. It backed a tentative FCC conclusion to not reallocate 1920-1930 MHz of unlicensed PCS spectrum to support AWS. While Cingular endorsed relocation of displaced govt. users to 2020-2025 MHz, Motorola suggested that could be used as unpaired spectrum for TDD applications with technical limits that would minimize potential interference to the adjacent uplink band for MSS-based ATC operations.

CTIA supported the FCC’s proposal that, in line with its decision to reallocate 1990-2000 MHz from MSS to fixed and mobile use, would consider pairing some of that spectrum with unlicensed PCS spectrum at 1910-1930 MHz for a “PCS-like service.” CTIA backed the creation of a “G-block” that would pair 1910-1915 MHz with 1990-1995 MHz for a PCS-like terrestrial wireless service. Because that block would be next to existing broadband PCS spectrum, CTIA said it should be subject to the same Part 24 technical rules and should have designated mobile and base transmit bands consistent with the existing operations in adjacent PCS bands. The group said that pairing those two 5 MHz blocks would leverage the use of existing PCS equipment. At the same time, CTIA cautioned the FCC against expanding the broadband PCS spectrum by more than 5 MHz because PCS base and mobile transmit frequencies required at least 15 MHz of separation to prevent harmful interference to PCS receivers. It said the MSS uplink band just made available for ATC at 2000-2020 MHz provided a separation of only 10 MHz between that band and the edge of the existing PCS base transmit band.

Ericsson recommended the FCC: (1) Create a G-band adjacent to the PCS band and extend isochronous unlicensed PCS from 1920-1930 MHz to 1915-1930 MHz. (2) Create a paired 5 MHz channel -- 2020-2025 MHz and 2175-2180 MHz -- that would either be auctioned or used as relocation spectrum. (3) Designate a guard band between the new G-block and MSS/ATC operations. (4) Extend the advanced wireless services band to 2175 MHz.

Nextel urged the FCC to redesignate unused unlicensed PCS spectrum at 1910-1920 MHz for licensed services. It said the Commission should assign part of the spectrum, at 1910- 1915/1990-1995 MHz, to Nextel as replacement spectrum in line with its proposed 800 MHz realignment plan. The spectrum is part of a proposal by Nextel, public safety groups and the Industrial Telecom Assn. to realign frequencies to mitigate interference to public safety at 800 MHz. The unlicensed PCS spectrum is part of replacement spectrum Nextel would receive in a swap in which it would give up frequencies at 700, 800 and 900 MHz. “Providing Nextel replacement spectrum at 1.9 GHz allows it to swap spectrum with public safety and private wireless licensees so that incompatible technologies are isolated into separate, exclusive spectrum blocks, instead of interleaved among each other, thereby remedy interference,” Nextel said. Assigning spectrum at 1910-1915/1990-1995 MHz to Nextel “will raise no interference issues,” the carrier said. It said its operations at 1910-1915 would not result in harmful interference to broadband PCS handsets operating above 1930 MHz.

Verizon Wireless recommended the FCC reallocate 2155- 2180 MHz and pair it asymmetrically with 1710-1755/2110-2155 MHz, which are already allocated for advanced wireless. Like other commenters, Verizon stressed the need to protect existing services from interference. “As the Commission decides how best to make use of the reallocated MSS spectrum, it must take into account the potential for some uses to cause harmful interference to existing services,” Verizon said. It particularly stressed the need to avoid interference to existing PCS subscribers, citing effects such as dropped calls, reduced coverage and a decline in service quality. Verizon said it was possible to reallocate the 1910-1915 MHz band, paired with 1990-1995 MHz, for new licensed PCS services, the G-block, without causing harmful interference to existing PCS customers. But it reiterated its opposition to reallocating 1915-1920 MHz, or any spectrum in the 1915-1930 MHz range, for new uses, including the creation of an H-block. “The use of the existing PCS guard band for such purposes would result in substantial harmful interference to existing PCS services,” Verizon said. The best use of 1915-1930 MHz would be unlicensed PCS devices, it said.