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FCC NPRM on 3G. Todd D.Gray Dow, Lohnes & Albertson Counsel, National ITFS Association. NPRM and Order. Captioned ET Docket No. 00-258, RM 9920 and RM 9911 Issued by the FCC on January 5, 2001 Comment Deadline: 30 days from Federal Register Publication (early to mid February)
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FCC NPRM on 3G Todd D.Gray Dow, Lohnes & Albertson Counsel, National ITFS Association
NPRM and Order • Captioned ET Docket No. 00-258, RM 9920 and RM 9911 • Issued by the FCC on January 5, 2001 • Comment Deadline: 30 days from Federal Register Publication (early to mid February) • Reply Deadline: 45 days from Federal Register Publication (mid to late February)
Generally, the NPRM: • Explores introduction of new advanced mobile and fixed services in frequency bands currently used for cellular, PCS and SMR services, as well as five other bands: 1710-1755 MHz, 1755-1850 MHz, 2110-2150 MHz, 2160-2165 MHz and 2500-2690 MHz
The NPRM also: • Denies the petition of Satellite Industry Association (“SIA”) requesting that the 2500-2520 MHz and 2670-2690 MHz bands be reallocated to the Mobile Satellite Service (“MSS”) • The SIA Petition was strongly opposed by ITFS and MDS interests
The Problem to be Solved • Purported need for 160 MHz of additional spectrum to meet projected requirements of 3G systems in highest traffic areas by 2010 (according to WRC-2000) • 3G spectrum needs to be located below 3 GHz • 3G spectrum may need to be coordinated with other countries to allow global roaming
More on the Problem • 160 MHz of new spectrum below 3 GHz is NOT available without relocating existing users • Moreover, it is not clear that 160 MHz of new spectrum is really needed
Comments Requested: 3G Needs • What are the range of advanced services to be introduced over time? • Will these services be fixed or mobile? • Can existing mobile bands (cellular, PCS, SMR) be transitioned to 3G? • How much additional spectrum is really needed?
Comments Requested: 3G Bands • 1850-1910/1930-1990 MHz -- 40 MHz of PCS spectrum already to be re-auctioned • 746-806 MHz -- TV Channels 60-69 -- 30 MHz may be available for 3G • 1710-1755 MHz -- former government spectrum already slated to be auctioned
Possible 3G Bands (cont’d) • 1755-1850 MHz -- the “1.7 Band” now being considered for re-allocation from Governmental Use by NTIA • 2110-2150 MHz -- already slated to be auctioned • 2160-2165 MHz -- Note that 2160-2162 MHz is part of MDS 2
Possible 3G Bands (cont’d) • 2150-2162 MHz -- MDS 1 and 2/2A (The Unexpected Big Problem) • 2500-2690 MHz -- the ITFS and MMDS Band (The Anticipated Big Problem)
Comments on 2.5 GHz Band • Would mobile allocation be beneficial without reallocating the spectrum to other licensees (that is, allowing ITFS and MMDS licensees to provide mobile service)? • Could a portion of the band be made available to new entities? If so, how much spectrum, and where in the band?
Comments on 2.5 GHz (cont’d) • Could incumbent ITFS/MMDS licensees be accommodated in other bands? • If so, what relocation procedures would apply to ITFS/MMDS licensees being relocated (expense reimbursement, alternative facilities, etc.)?
So: Where do we go from here? • Filing comments with FCC, jointly and/or individually • Support of ITFS industry efforts (including financial support) • Support of WEB Now Coalition efforts