The FCC Mon. posted 2 GHz comments filed after our Tues. deadline...

TMI/TerreStar and ICO haven’t proven they need more spectrum. And because the MSS licensees have said they would use the extra spectrum they seek for terrestrial ATC operations, CTIA said, the FCC should reallocate spectrum to terrestrial use and auction it: “Reallocating abandoned spectrum to flexible, terrestrial use and making the spectrum available at auction avoids unjust enrichment, creates a level playing field, and ensures the spectrum will be put to its highest and most effective use for the benefit of the public.” Further, CTIA said, the spectrum should be reallocated because it should be made available to systems that are operational; the MSS systems vying for it won’t be operational until 2007 and 2008. Sprint Nextel agreed, saying competitive bidding is the answer to the question of what to do with the extra 13.3 MHz of spectrum: “Market forces, not government regulators, will best decide what services consumers want.” Sprint Nextel also said the spectrum shouldn’t go to the MSS licensees for the homeland security reasons they've offered: “TMI does not explain what these homeland security wireless applications are, when -- if ever -- it will deploy them, or how these services would differ from the low-cost and extensive suite of services that commercial terrestrial carriers offer today without billions of dollars in new spectrum subsidies.” T-Mobile said it needs the spectrum to be a competitive wireless provider. In the last year, the ranks of nationwide wireless providers have shrunk from 6 to 4, T-Mobile said: “In an environment of increasing wireless consolidation, mid-sized and smaller wireless providers such as T-Mobile need additional spectrum to effectively compete in the mobile telephony market.” T-Mobile said the 2 GHz spectrum would be ideal for Advanced Wireless Services (AWS), since it could be used “easily in conjunction with the J block (or other PCS/AWS bands) or on a stand-alone basis.” MSS competitor Inmarsat said it’s well-qualified to deploy a 2 GHz MSS system, and that the commission should have at least 3 MSS competitors at 2 GHz. Providing for 3 MSS competitors instead of 2 would “ensure that the MSS industry will have the opportunity to play a vital role in the wireless broadband revolution,” Inmarsat said. MSS competitor Globalstar also said it wants to deploy a 2 GHz system, again asking for an FCC decision on the status of its 2 GHz application, which it said was “erroneously cancelled” in 2003. Sirius said MSS and terrestrial wireless both have enough spectrum to satisfy current demand. The commenters “fail to present a public interest reason to bestow additional spectrum to any mobile telephony service,” Sirius said, declaring it would use the spectrum for video and broadband offerings and telematics. SkyTerra, with ownership interests in TerreStar, and ICO advocated granting the 2 GHz spectrum in its entirety to ICO and TMI/TerreStar.