ࡱ>  ;=./0123456789:5@ bjbj22 XXn9( ~,^^^DH'ЯЯЯPDH'C|VZ(@@3HCCCCCCC$DROG,&C^ջ^3&C@@;Csss8@^@CsCssr F^"@ jxxЯp "T QC0C~!{G{G"t#2d{G^" s&C&CH'H'@ hGsH'H' h FINAL REPORT March 30, 2001 SPECTRUM STUDY OF THE 25002690MHz BAND The Potential for Accommodating Third Generation Mobile Systems  Federal Communications Commission Staff Report Issued by: Office of Engineering and Technology Mass Media Bureau Wireless Telecommunications Bureau International Bureau ACKNOWLEDGEMENTS This Final Report was prepared under the leadership of the Office of Engineering and Technology, in cooperation with the Mass Media Bureau, Wireless Telecommunications Bureau, and International Bureau Office of Engineering and Technology Anthony Asongwed, Donald Campbell, Thomas Derenge, Robert Eckert, Bruce Franca, Nancy Gillis, Kathryn Hosford, Ira Keltz, Julius Knapp, Geraldine Matise, Rodney Small, Fred Thomas Mass Media Bureau Charles Dziedzic, Joe Johnson, Keith Larson, Brad Lerner, David Roberts Wireless Telecommunications Bureau Charles Rush, John Spencer International Bureau Richard Engelman, Trey Hanbury, Ron Repasi  Text extracted from International Telecommunication Union (ITU) material has been reproduced with the prior authorization of the ITU as copyright holder. The sole responsibility for selecting extracts for reproduction lies with the Federal Communications Commission and can in no way be attributed to the ITU. The complete volume(s) of the ITU material, from which the texts reproduced are extracted, can be obtained from: International Telecommunication Union Sales and Marketing Service Place des Nations CH1211 GENEVA 20 (Switzerland) Telephone: +41 22 730 61 41 (English)/+41 22 730 51 94 (French)/+41 22 730 61 43 (Spanish) Telex: 421 000 uit ch / Fax: +41 22 730 51 94 X.400 : S=sales; P=itu; A=400net; C=ch Email: sales @itu.int /  HYPERLINK http://www.itu.int/publications http://www.itu.int/publications Tableof Contents Section Page Executive Summary  PAGEREF _Ref498839663 \h i 1. Introduction  PAGEREF _Ref498839670 \h 1 2. 3G System Description  PAGEREF _Ref509217672 \h 7 3. Incumbent Systems in the 25002690MHz Band  PAGEREF _Ref509217685 \h 13 4. Evaluation of Spectrum Sharing  PAGEREF _Ref509245179 \h 28 5. Evaluation of Band Segmentation  PAGEREF _Ref498910875 \h 38 6. Identification and Analysis of Potential Alternate Frequency Bands for ITFS/MDS  PAGEREF _Ref509993303 \h 60 7. Analysis of Costs and Benefits  PAGEREF _Ref509993314 \h 82 Appendices Appendices for Section 1 A1 Appendices for Section 2 A21 Appendices for Section 3 A41 Appendices for Section 4 A53 Appendices for Section 5 A77 Appendices for Section 6 A87 EXECUTIVE SUMMARY This Final Report describes the current uses of the 25002690MHz band and analyzes the potential for using that band for third generation (3G) wireless systems. This band is one of several frequency bands identified at the 2000 World Radiocommunication Conference (WRC2000) for possible 3G use. Third generation wireless systems will provide mobile, highspeed access to the Internet and other broadband services. In the United States, the 25002690MHz band is currently used by the Instructional Television Fixed Service (ITFS), Multipoint Distribution Service (MDS), and Multichannel Multipoint Distribution Service (MMDS). The study of the 25002690MHz band has been conducted in two stages. In the Interim Report, we examined the nature and technical characteristics of planned 3G services, the current and planned use of the 25002690MHz band by incumbent services, potential opportunities for sharing spectrum between 3G and incumbent services, and the potential impact on incumbent services of segmenting this band to provide separate spectrum for 3G and incumbent services. In this Final Report, we review and evaluate the earlier analyses and evaluate additional topics, including the possible relocation of incumbent services and the costs associated with such relocation. This band study is one part of the FCCs effort to identify additional spectrum for advanced wireless systems, including 3G as well as future generations of wireless systems. The FCC issued the Advanced Wireless Services Notice of Proposed Rulemaking (NPRM) on January 5, 2001, to examine and propose spectrum for such use. This proceeding explores the possibility of introducing new advanced mobile and fixed services in frequency bands currently used for cellular, broadband Personal Communications Service (PCS), and Specialized Mobile Radio (SMR) services, as well as in five other frequency bands: 17101755MHz, 17551850MHz, 21102150MHz, 21602165MHz and 25002690MHz. This Final Report represents the results of analyses by FCC staff in the Office of Engineering and Technology, Mass Media Bureau, Wireless Telecommunications Bureau, and International Bureau. It does not necessarily represent the views of the FCC or its Commissioners. SUMMARY OF FINDINGS The key findings of our study of the 25002690MHz band are as follows: The International Telecommunication Union (ITU) has done considerable work to develop the key technical characteristics of 3G systems and to identify several frequency bands that could be used for 3G systems. The ITU is conducting further studies of how IMT2000 may be implemented in the frequency bands that were identified at the 1992 World Administrative Radio Conference (WARC92) and WRC2000, taking into account the impact on incumbent systems, opportunities for worldwide roaming, equipment design considerations, and backward compatibility with first and second generation (1G and 2G) systems. There currently is no single global approach as to how the frequency bands identified at WARC92 and WRC2000 will be used to implement 3G systems, and no consensus that common global bands for use by 3G systems are achievable. The 25002690MHz band is in a state of rapid evolution by incumbent ITFS and MDS licensees. The MDS industry has invested several billion dollars to develop broadband fixed wireless data systems in this band, including highspeed access to the Internet. These systems offer a significant opportunity for further competition with cable and digital subscriber line (DSL) services in the provision of broadband services in urban and rural areas. The band is used to provide video services for education and training in schools, health care centers and a wide variety of other institutions, as well as for the provision of a commercial video distribution service known as wireless cable. This spectrum is heavily licensed throughout the country, with several licensees already providing highspeed Internet services to customers; other licensees are ramping up for full operational use in the very near term. Incumbent ITFS and MDS use of the 25002690MHz band varies from one geographic area to another. This lack of uniformity presents serious challenges to developing band sharing or segmentation options that could be used across the country without severely disrupting ITFS and MDS use. For example, ITFS and MDS licensees provide a variety of analog and digital oneway and twoway services; ITFS and MDS are licensed with different authorized service or interference protection areas; extensive leasing arrangements exist between the two services; ITFS and MDS licensees have exchanged channels in various markets as permitted by current service rules; and flexible channel band plans for combined ITFS/MDS twoway systems will coexist with some incumbent oneway systems operating under the traditional channel band plan. This technical analysis shows that if currently contemplated 3G systems were to share the same spectrum or channels in any given geographic area large cochannel separation distances would be needed between 3G systems and incumbent ITFS and MDS systems. Without adequate separation distances, 3G systems and ITFS and MDS would cause extensive interference to each other. This is because the 25002690MHz band is licensed to ITFS and MDS systems in most populated areas of the country and 3G licensees would likely want to operate in these same areas. There are, however, a few geographic areas where some spectrum is not used by incumbent systems. In areas where spectrum is not yet at full operational capacity, voluntary partitioning between incumbent users and 3G operators may offer some promise of sharing, although it is unlikely that these areas would be sufficient to deploy a viable 3G service in the band. Segmenting the 25002690MHz band to enable third generation mobile wireless systems access to a portion of this spectrum would raise significant technical and economic difficulties for incumbents, especially if all ITFS/MDS operations were to be relocated within the band. While there may be long term options to segment the 25002690MHz band, segmentation could affect the economics of current and planned ITFS and MDS systems and lessen their ability to provide service to rural areas or smaller markets. With reduced spectrum, ITFS/MDS providers may need to reduce their service areas and services to customers in outlying areas or add more transmitter sites to maintain services. In addition, any segmentation option would have to account for the flexible service configurations and offerings that incumbent licensees are currently implementing. There is no readily identifiable alternate frequency band that could accommodate a substantial relocation of the incumbent operations in the 25002690MHz band. Furthermore, relocation of ITFS/MDS operations to a band above 3GHz would affect deployment of these systems to account for changes in signal propagation in higher bands. Relocation to higher bands could affect significantly the economics of current and planned ITFS and MDS systems and lessen their ability to provide service to rural areas or smaller markets. In addition, incumbent users in those alternate bands would have to be relocated, causing serious disruption to other established services; and relocation of some incumbent users (e.g., satellite systems) could significantly delay ITFS/MDS access to these alternate bands. Implementation of either the segmentation or relocation options would significantly affect deployment of and impose considerable costs on ITFS/MDS. One study suggests, for example, that the cost to ITFS/MDS operations over a ten-year period could be up to $19 billion. Either option would require considerable time to implement and significant costs to reengineer and deploy systems; and delivery of fixed wireless broadband services to the public and educational users would be delayed or, in rural areas or smaller markets, may never be realized. The relocation option also would require other services to relocate, and the time and costs to move those additional services would be significant, ranging from approximately $10.230.4 billion. These costs would need to be balanced with the broadbased benefits to prospective users and the national economy of deploying both 3G and fixed wireless broadband systems. The details of the analyses that lead to these findings are provided in the following Sections and Appendices. SECTION 1 INTRODUCTION This Final Report addresses the current spectrum uses and the potential for sharing or segmenting the 25002690MHz band for possible third generation wireless systems, as well as the potential for relocating incumbent users of the band in order to make spectrum available for possible 3G wireless systems. This band study, which is in response to the October 13, 2000 Presidential Memorandum, follows the processes described in the Study Plan released by the Department of Commerce on October 20, 2000. This study relies on certain technical assumptions that are based largely on work conducted by the ITU and on information provided by industry. This Final Report represents the results of analyses by the Federal Communications Commission (FCC) staff in the Office of Engineering and Technology, Mass Media Bureau, Wireless Telecommunications Bureau, and International Bureau. It does not necessarily represent the views of the FCC or the Commissioners. THE PRESIDENTIAL MEMORANDUM AND THE STUDY PLAN The October 13, 2000 Presidential Memorandum establishes guiding principles for the Executive Agencies to use in selecting spectrum for 3G wireless systems, and strongly encourages independent federal agencies, such as the FCC, to follow the same principles in any actions taken related to the development of 3G systems. These principles are: (1) the federal government must cooperate with industry to identify spectrum that can be used for 3G systems, whether by reallocation, sharing or evolution of existing systems; (2) incumbent users of spectrum identified for reallocation or sharing must be treated equitably, taking national security and public safety into account; (3) the federal government must be technologyneutral in spectrum allocation and licensing decisions; (4) the federal government must support policies that encourage competition in services and provide flexibility in spectrum allocations to encourage competition; and (5) the federal government must support industry efforts as far as practicable and based on market demand and national considerations to harmonize spectrum allocations regionally and internationally. The Study Plan released by NTIA on October 20, 2000 adheres to the principles in the Presidential Memorandum. The Study Plan notes that a variety of frequency bands have been identified for possible 3G system use by two International Telecommunication Union (ITU) radio conferences, WARC92 and WRC2000. Further, the Study Plan indicates that the United States will give full consideration to all identified frequency bands in identifying spectrum for possible 3G system use. In order to have a full understanding of all options available, NTIA and FCC were tasked with studying two frequency bands identified by WRC2000 for possible 3G use. NTIA is studying the 17551850MHz band, and the FCC is studying the 25002690MHz band. The Study Plan states that the purpose of the studies is to determine whether, and under what conditions, these bands could be made available for 3G systems and the cost and operating impacts to incumbent users. The Study Plan notes that the same analysis will be applied to both bands under study. The basic requirements for the overall studies cover three areas: a description of 3G system requirements; a description of incumbent systems in the study bands; and identification of potential alternate bands for incumbent users of the study bands. Using this information, the studies are to include a technical evaluation of the following sharing/relocation options: (1) system sharing between current and planned systems in the bands and 3G systems; and (2) band/channel segmentation, including alternate band combinations to relocate incumbent users of the study bands. Finally, the studies are to consider costs for the spectrum sharing/relocation options identified for the study bands and benefits of using the spectrum in the study bands for 3G systems. As noted by the Study Plan, the studies have been conducted in two phases. Interim Reports on each band were released November 15, 2000, and each Report includes a description of 3G systems, a description of incumbent systems, and an evaluation of system sharing and band segmentation options. Final Reports on each band, to be released by March 30, 2001, build on the Interim Reports and include the remainder of the study requirements, including information on other bands, a description of alternate bands and relocation studies, and cost/benefit analyses of system sharing, segmentation and relocation options identified. Outreach to industry is an important component of the overall process to identify spectrum for 3G systems. As instructed by the Presidential Memorandum, NTIA, on behalf of the Secretary of Commerce, initiated the Departments outreach program to industry. The outreach program, in which FCC staff participated, consisted of a series of regular public meetings, which were supplemented by a series of industry sponsored meetings. Most prominent in this regard was the formation of the 3G Industry Association Group. This group held a series of meetings to develop technical and operational proposals for sharing between 3G and incumbent systems or for relocation of incumbent systems. FCCs ROLE IN IDENTIFYING SPECTRUM FOR 3G SYSTEMS The FCC has several key roles in the overall process to identify spectrum for 3G systems. In addition to studying the 25002690MHz band, the FCC issued a Notice of Proposed Rulemaking (Advanced Wireless Services NPRM) on January 5, 2001, to examine and propose spectrum for allocation to fixed and mobile services that would be capable of being used to provide 3G wireless service. The FCC has solicited industry input through this NPRM and other procedures to develop recommendations and plans for identifying spectrum for 3G wireless systems. The Advanced Wireless Services NPRM recognizes that a number of frequency bands, including those identified by WARC92 and WRC2000, are capable of supporting third generation as well as future generations of mobile wireless systems. This proceeding explores the types of advanced mobile and fixed communication services that will likely be provided in the future, including the technical characteristics of such systems, and the spectrum requirements needed to support the introduction of such services, including the amount of spectrum needed and frequency bands that could be used by such systems. This proceeding also will explore the possibility of introducing new advanced mobile and fixed services in frequency bands currently used for cellular, broadband Personal Communications Service (PCS), and Specialized Mobile Radio (SMR) services, as well as in five other frequency bands: 17101755MHz, 17551850MHz, 21102150MHz, 21602165MHz and 25002690MHz. Concerning the possible use of these additional bands for advanced wireless systems, the Advanced Wireless Services NPRM does the following: proposes to allocate for mobile and fixed services the 17101755MHz band that was designated for reallocation from Federal Government to nonFederal Government use under two statutory directives, the 1993 Omnibus Budget Reconciliation Act (OBRA93) and the 1997 Balanced Budget Act (BBA97); seeks comment on providing mobile and fixed service allocations for the 17551850MHz band, if spectrum in the band is made available for nonFederal Government use; proposes to designate advanced mobile and fixed service use of the 21102150MHz and 21602165MHz bands that are currently used for a variety of fixed and mobile services and that were identified for reallocation under the Commissions 1992 Emerging Technologies proceeding (ET Docket No. 929); seeks comment on various approaches for the 25002690MHz band, which is currently used for Multichannel Multipoint Distribution and Instructional Television Fixed Services (MMDS and ITFS). The Interim Report and Final Report on the 25002690MHz band will become part of the official record for the rulemaking proceeding, and comments on the Reports will be considered in the context of that proceeding. Commenters to the rulemaking proceeding also may address the NTIA Interim Report and Final Report for the 17551850MHz band. SCOPE OF FINAL REPORT ON 25002690MHz BAND For purposes of studying the 25002690MHz bands, certain fundamental assumptions were made concerning the overall spectrum requirements and technical characteristics of future 3G systems. As we noted in the Advanced Wireless Services NPRM, we recognize that there are many ways in which various frequency bands may be partitioned or paired to implement 3G services. We expect further information in this regard to become available through dialogue with industry, additional international studies on 3G, and the FCC rulemaking proceeding. The assumptions made for purposes of this study are intended to facilitate analyses and are not intended to prejudge or foreclose other options. The study of the 25002690MHz band has been conducted in two phases. In the Interim Report, we examined the nature and technical characteristics of planned 3G services, the current and planned use of the 25002690MHz band by incumbent services, potential opportunities for sharing spectrum between 3G and incumbent services, and the potential impact on incumbent services of segmenting this band to provide separate spectrum for 3G and incumbent services. We invited comment on the Interim Report in the Advanced Wireless Services NPRM. The Final Report reviews the initial analyses in the Interim Report; identifies potential alternate bands for relocating incumbent users of the 25002690MHz band; analyzes the relocation potential of incumbent users to alternate bands; and evaluates the cost and migration schedules for three time periods (2003, 2006, 2010) for the sharing, band segmentation and relocation options presented. To the extent possible, we have taken into consideration comments filed on the Interim Report in response to the Advanced Wireless Services NPRM, as well as information provided by industry during NTIAs outreach program. The Final Report is organized in the following manner. Section 2 summarizes the 3G system requirements identified in the Interim Report and discusses suggested changes to this study information basic requirement made in the rulemaking or outreach program. Section 3 summarizes the information in the Interim Report on incumbent ITFS and MDS systems in the 25002690MHz band, as well as suggested changes to this study information basic requirement made in the rulemaking or outreach program. Section 4 evaluates the spectrum sharing options between ITFS/MDS and potential 3G systems presented in the Interim Report, including the cochannel and adjacent channel protection requirements of ITFS/MDS systems and the technical feasibility of cochannel sharing between ITFS/MDS and 3G systems. Section 5 evaluates the possible options for segmenting the 25002690MHz band to provide spectrum for 3G systems presented in the Interim Report. Using the Interim Reports assumption that the introduction of 3G systems in the band would require 90megahertz of spectrum, this section addresses the impacts on incumbent systems if no additional spectrum were made available to them to compensate for the reduction of spectrum in this band. Section 6 describes assumptions made in identifying appropriate spectrum for relocating incumbent ITFS/MDS systems to alternate frequency bands and identifies potential alternate frequency bands for these systems. This section also analyzes the potential for relocating ITFS/MDS systems to the identified potential alternate frequency bands. For each potential alternate band, this section addresses existing rules and regulations for the band; whether allocation or regulation changes would be needed to accommodate ITFS/MDS; whether the existing users of the potential alternate band would have to be relocated; and whether operational constraints would exist for ITFS/MDS and existing users of the potential alternate band. Section 7 identifies cost estimates and potential benefits for implementing the sharing, band segmentation and relocation options discussed in the study. This section also describes the assumptions made in identifying the cost estimates and potential benefits. SECTION 2 3G SYSTEM DESCRIPTION As noted in the Interim Report, the Study Plan calls for the FCC to provide a description of 3G system requirements, which include: (1) nature of proposed use; (2) system technical characteristic description (as a minimum, the necessary information to perform sharing studies with candidate band systems); (3) spectrum required including channeling bandwidths and overall spectrum plans (includes segmentation of candidate bands) to cover regions or nationwide; (4) timing requirements for identification of spectrum; (5) planned geographical deployments; (6) interference thresholds (ITU based if available); (7) potential relationship with other countries deployment of 3G and global roaming; (8) potential alternate spectrum band plans including any band segmentation; and, (9) any operational considerations that will have a bearing on the evaluation of the sharing/relocation options. In the Interim Report, we simplified the presentation of the material called for in the Study Plan and combined the discussion of related items. For example, the discussion on 3G technical characteristics also addressed interference thresholds. The discussion on 3G spectrum requirements addressed other administrations current spectrum usage for wireless mobile services as well as their planned spectrum usage for 3G systems. In addition, some of the information listed above was discussed in our analyses of spectrum sharing and band segmentation. In this section, we provide a summary of the basic 3G system characteristics that were presented in the Interim Report and that provide the basis for the study of the 25002690MHz band. As we noted in the Interim Report, the ITU has been fostering the development of 3G systems for a number of years, under the name IMT2000 and, earlier, FPLMTS (future public land mobile telecommunication systems). Therefore, for the purposes of this study, we relied largely on the international definitions and technical characteristics of IMT2000 and 3G systems developed by the ITU. We also have incorporated other sources of information to the extent practicable. The information presented is intended to facilitate our analyses of the 25002690MHz band and is not intended to prejudge or foreclose any future decisions that may be made regarding the implementation of 3G systems. PROPOSED USES According to the ITU, third generation or IMT2000 wireless systems will provide mobile, highspeed access to a wide range of telecommunication services supported by fixed telecommunication networks (e.g., PSTN/ISDN), and to other services that are specific to mobile users. A range of mobile terminal types is encompassed, linking to terrestrial or satellitebased networks, and the terminals may be designed for mobile or fixed use. Key features of 3G or IMT2000 systems are: high degree of commonality of design worldwide; compatibility of services within IMT2000 and with fixed networks; high quality; use of small pocketterminal with worldwide roaming capability; capability for multimedia applications, and a wide range of services (paging, voice telephony, digital data, audio and visual communications) and terminals. Table2.1 describes some of the key service attributes and capabilities expected of IMT2000 or 3G systems: Table2.1: IMT2000 Systems/Capabilities Capabilities to support circuit and packet data at high bit rates:  144 kb/s or higher in high mobility (vehicular) traffic  384 kb/s or higher for pedestrian traffic  2 Mb/s or higher for indoor trafficInteroperability and roaming among IMT2000 family of systemsCommon billing/user profiles:  Sharing of usage/rate information between service providers  Standardized call detail recording  Standardized user profilesCapability to determine geographic position of mobiles and report it to both the network and the mobile terminalSupport of multimedia services/capabilities:  Fixed and variable rate bit traffic  Bandwidth on demand  Asymmetric data rates in the forward and reverse links  Multimedia mail store and forward  Broadband access up to 2 Mb/s A key objective of IMT2000 is to enable users of personal terminals to go anywhere in the world and, in a variety of situations (e.g., indoor/outdoor and in a range of geographic environments), to have access to a minimum set of services (e.g., voice telephony and a selection of data services). Services will cover a wide range of offerings, and many new applications will be developed for IMT2000 systems, of a nature that cannot readily be forecast today. IMT2000 users will not, in most circumstances, notice that a radio link is used to connect their terminal to the world's telecommunication networks. TECHNICAL CHARACTERISTICS The ITU has developed a series of technical recommendations, or standards, that define the key characteristics of IMT2000 radio systems. The standards are intended to minimize the number of different radio interfaces, maximize their commonality, and provide a transition path to 3G from first generation (1G) and second generation (2G) technologies. There are five recommended radio interfaces for the terrestrial component of IMT2000: CDMA Direct Spread  This interface is called the Universal Terrestrial Radio Access (UTRA) Frequency Division Duplex (FDD) or Wideband CDMA. FDD operations require paired uplink and downlink spectrum segments. The radio access scheme is directsequence CDMA with information spread over a bandwidth of about 5megahertz with a chip rate of 3.84 Mcps. Modulation is dualchannel QPSK. CDMA MultiCarrier  This radio interface also is called cdma2000 and operates in FDD. The radio interface is a wideband spread spectrum system that uses code division multiple access (CDMA) technology and provides a 3G evolution for systems using the current TIA/EIA95B family of standards. RF channel bandwidths of 1.25megahertz and 3.75megahertz are supported at this time but the specification can be extended to bandwidths up to 15megahertz. CDMA TDD  This radio interface employs a directsequence CDMA radio access scheme. There are two versions: UTRA Time Division Duplex (TDD) that uses a 5megahertz bandwidth and a chip rate of 3.84 Mcps, and TDSCDMA that uses 1.6megahertz bandwidth with a chip rate of 1.28 Mcps. TDD systems can operate within unpaired spectrum segments. The UTRA TDD specifications were developed to provide commonality with UTRA FDD. In addition, the specifications were developed based on an evolved GSMMAP but include capabilities for operation with an evolved ANSI41 based network. TDMA SingleCarrier  This radio interface also is called Universal Wireless Communication136 (UWC136) and is an FDD system. It was developed with the objective of maximum commonality between TIA/EIA136 and GSM General Packet Radio Service. The radio interface is intended for evolving TIA/EIA136 technology to 3G. This is done by enhancing the voice and data capabilities of the 30kHz channels, adding a 200kHz carrier for high speed data (384 kbits/s) for high mobility applications and adding a 1.6megahertz carrier for very high speed data (2 Mbits/s) for low mobility applications. FDMA/TDMA This radio interface also is called Digital Enhanced Cordless Telecommunications (DECT) and is defined by a set of European Technical Standards Institute (ETSI) standards. These five radio interfaces support various channel bandwidths and have significantly different technical characteristics. The FCC has generally declined to mandate specific air interface standards for commercial mobile radio services. We anticipate that this policy will likely apply in any spectrum that may be made available for IMT2000 systems. Therefore, United States providers of these services may choose to employ the IMT2000 standards for 3G systems, or they could deviate from these standards provided they do not cause interference to other users of the spectrum. SPECTRUM CONSIDERATIONS As indicated in the Interim Report, the ITU has identified a number of frequency bands for possible use by terrestrial 3G operations. WARC92 identified the 18852025MHz and 21102200MHz bands for future public land mobile telecommunications systems, including those that later became known IMT2000. Over the past decade, the United States participated in the ITUs efforts to determine how much additional spectrum nextgeneration wireless systems would require and sought to identify additional frequency bands outside of the 18852025MHz and 21102200MHz bands that could be used for IMT2000 systems. ITU Task Group 8/1 eventually determined that by 2010 up to 160megahertz of additional spectrum might be needed for terrestrial IMT2000 systems i.e., spectrum beyond that already allocated for first and secondgeneration wireless systems and previously identified at WARC92. WRC2000 identified additional spectrum for possible use by terrestrial IMT2000 systems, including the 806960, 17101885 and 25002690MHz bands. The WRC2000 results allow countries flexibility in deciding how to implement IMT2000 systems. The conference recognized that in many countries the frequency bands identified for 3G use are likely to be heavily encumbered by equally vital services that for either strategic or economic reasons cannot be readily displaced or relocated. Furthermore, not all countries in the world require equal amounts of spectrum to support future wireless services. The availability of spectrum to be used for future wireless services depends upon current spectrum usage, ease of deployment of future radiobased systems, and possible transition of incumbents to different frequency bands. In the United States, the 698746, 746794, 806960 (includes present cellular band), 17101850, 18501990 (present PCS bands), 21102150, 21602165 and 25002690MHz bands could be considered for use by future 3G systems. The FCC has initiated the Advanced Wireless Services proceeding to identify spectrum that could be made available for use by 3G systems. WRC2000 also adopted a plan for the ITUR to study the additional frequency bands identified for IMT2000 systems in order to determine their applicability for providing IMT2000 systems. Included in this plan (Resolution 223 and Annex 1 thereto) are studies that address the sharing implications of IMT2000 with other services in the newly identified bands above 1GHz, harmonized frequency arrangements for the implementation of IMT2000 systems taking into account the frequency arrangements of second generation systems in the bands, and means to facilitate global roaming in light of different regional band usage. The ITUR studies recognize the fact reflected in the US proposal to WRC2000 that not all the spectrum required for IMT2000 systems can, and must be, obtained from the same frequency bands. ITU Working Party 8F has been tasked to perform these studies over the next three years. In performing this work, Working Party 8F is expected to examine various ways in which the spectrum identified both at the WARC92 and WRC2000 might be divided into blocks and potentially paired to facilitate backward compatibility with 2G systems. At this time Study Group 8F is in the early stages of identifying a variety of options for further consideration and study. There currently is no global consensus as to how the frequency bands identified at the WARC92 and WRC2000 will be used to implement 3G. The Interim Report described the current and intended used of these bands by various countries. The chart in Appendix 2.2, which includes excerpts from ITUR Report M.2024, summarizes some of the current uses of the 17101885MHz and 25002690MHz bands around the world. Since the release of the Interim Report there have not been any major changes involving these bands. OTHER CONSIDERATIONS For any frequency band identified for possible use by 3G systems, the time period in which spectrum may need to be made available for 3G systems will greatly affect the impact on incumbent services in those bands. Also, various operational considerations often will enable different systems to share spectrum. For example, fixed satellite and terrestrial fixed operations often are able to share spectrum due to the ability to coordinate operations to avoid mutual interference. 3G systems are expected to be ubiquitous and may operate at any time. These timing and operational considerations are considered in the sharing, segmentation and relocation aspects of this study. SECTION 3 INCUMBENT SYSTEMS IN THE 25002690MHz BAND The Interim Report noted that a basic requirement of the Study Plan is to describe incumbent systems in the candidate band. Specifically, the studies are to describe incumbent systems in the candidate bands, including: (1) nature of use, (2) system technical characteristics (at a minimum, the necessary information to perform sharing studies with 3G systems), (3) spectrum currently used, including channeling bandwidths and overall spectrum to cover regions or nationwide, (4) current geographical deployments, (5) planned geographical deployments, (6) system life expectancy, (7) planned replacement systems, (8) interference thresholds (ITU based, if available), (9) unique operational features (e.g., specific location, area or elevation required, or relationship with other frequency bands such as separation between uplinks and downlinks), and (10) any operational considerations including national security and public safety that will have a bearing on the evaluation of the sharing or relocation options. The Interim Report provided information on the incumbent uses of the 25002690MHz band. In this section, we provide a summary of the information presented in the Interim Report as well as some additional information on incumbents planned uses of the band. The predominant use of the 25002690MHz band is by the Fixed Service for Multipoint Distribution Service (MDS), Multichannel Multipoint Distribution Service (MMDS), and Instructional Television Fixed Service (ITFS). ITFS licensees make extensive use of the spectrum to provide formal classroom instruction, distance learning, and videoconference capability to a wide variety of educational users throughout the nation. Often supported by leasing arrangements to access excess capacity from ITFS licensed spectrum, MDS licensees provide a commercial video programming service in this frequency band. The frequency band is in a state of rapid evolution and development by both ITFS and MDS licensees so that they can provide highspeed, twoway access to the Internet. The MDS industry has invested severalbillion dollars to develop the band for broadband fixed wireless data systems. These systems will provide a significant opportunity for further competition with cable and digital subscriber line (DSL) services in the provision of broadband services in urban areas and deliver broadband services to rural areas. These systems also will enable ITFS operators to bring a wide variety of broadband services to educational users, often in cooperation with MDS operators in the band. NATURE OF USE The predominant use of the 25002690MHz band is by ITFS, which is licensed under Part 74 of the Commissions Rules, and MDS, which is licensed under Part 21 of the Commissions Rules. ITFS and MDS share 190megahertz of spectrum in the 25002690MHz band. ITFS licensees are allotted 120megahertz of spectrum, and MDS licensees are allotted 66megahertz of spectrum. In addition, the 4megahertz of spectrum in the 26862690MHz band is allotted for ITFS response channels and is shared between ITFS licensees and private operations. ITFS has approximately 1,275 entities holding over 2,175 ITFS licenses in urban and rural locations throughout the United States. Over 70,000 locations serve as registered ITFS receive sites, although the number of actual locations at which ITFS programming is viewed is likely much higher since receive sites are typically located within a 56.3kilometer (35mile) protected service area around an ITFS base station. ITFS stations traditionally have been utilized for a wide variety of services, including the provision of formal telecourses (on the K12, secondary, and postsecondary levels) to schools, hospitals, workplaces and other places of learning; transmission of other educationally valuable programming (including news, public affairs and similar material) into schools; provision of professional and worker training (such as for teachers, health professionals and public safety officers); and transmission of teleconferences for educational, training and administrative purposes. ITFS licensees are permitted to lease excess channel capacity to MDS licensees, with the income from those leases typically helping to underwrite the cost of providing ITFS. Traditionally, MDS spectrum has been primarily used to deliver multichannel video programming, similar to cable television service, to residential customers. MDS currently has 2,570 station licensees and conditional licensees (i.e., authorizations to construct or modify facilities). ITFS and MDS share the spectrum through complex licensing and leasing arrangements that have evolved over time and that are not uniform in all geographic areas. Although the ITFS/MDS spectrum traditionally was used for oneway analog video transmission, the Commission rules permit the spectrum to be used for very high speed, fixed wireless broadband services. The Commissions July 1996, Digital Declaratory Ruling permitted licensees to digitize their MDS and ITFS spectrum. With this Commission ruling and the advances in digital technology, ITFS/MDS video providers can now deliver as many as 200 channels of programming. In October 1996, the Commission allowed wireless cable and ITFS operators to use their spectrum for highspeed digital data applications, including Internet access. In 1998 the FCC approved the use of twoway transmissions on MDS and ITFS frequencies, effectively enabling the provision of voice, video, and data services. The introduction of twoway service will allow many educational users to develop broadband access to support education throughout the nation and MDS entities to develop a commercial wireless broadband alternative, especially to residential and small office/home office (SOHO) customers. Given the complex interference environment in the 25002690MHz band, the Commission adopted a specific authorization process for this band. The initial filing window for twoway service occurred from August 14, 2000 until August 18, 2000, and approximately 2, 267 applications were received. On November 29, 2000, we issued a Public Notice listing the applications tendered for filing. At the conclusion of a 60day amendment period, we issued a Public Notice on February 1, 2001, listing the applications that had been accepted for filing; all tendered applications were accepted for filing. Absent petitions to deny, these applications will be granted after an additional 60day period, which ends in early April, 2001. Subsequent to this initial licensing process, twoway applications will be processed under a rolling oneday filing window. MDS entities have been able to provide twoway service on MDS channels located at 21502160/2162MHz since 1998, and MDS providers such as Sprint, WorldCom and Nucentrix have continued to rollout highspeed Internet access in new markets across the country. Sprint has acquired interests in more than 90 markets covering about 30million households. It holds licenses for 642 MDS/commercial ITFS channels; leases to use the capacity of 349 MDS/commercial ITFS channels; and leases to use the capacity of 1394 ITFS channels. Sprint indicates that it holds a total of 532 leases, twothirds of which are with ITFS licensees. Sprint Broadband Direct service is now available in Phoenix, AZ, Tucson, AZ, Detroit, MI, Colorado Springs, CO (business only), Houston, TX, San Jose, TX, Oakland, CA, Denver, CO, Salt Lake City, UT, Wichita, KS, Melbourne, FL, Oklahoma City, OK and Fresno, CA. Applications for 15 additional markets were granted in December 2000. Sprint was providing advanced fixed wireless services to more than 20,000 residential and small business customers as of December 31, 2000 and is adding over 2,000 new customers every week. In addition, Sprint and its partners filed almost 400 applications in 45 markets prior to the end of the Commissions twoway filing window. Sprints residential Broadband Direct service provides downstream speeds of 1Mbps, upstream speeds of 512kbps, and burst rates of up to 5Mbps. WorldCom holds MDS licenses covering over 31million households in 78 markets. WorldCom is offering fixed wireless highspeed Internet access to residential and SOHO customers. Currently, the company is providing commercial fixed wireless broadband services in Jackson, MS; Baton Rouge, LA; and Memphis, TN and plans to provide service in 30 markets by the end of 2001. WorldCom plans to roll out fixed wireless service to 30 metropolitan areas by the end of 2001. In August, the company filed over 380 applications to offer twoway service in more than 60 markets. WorldCom offers its residential customers twoway speeds of 310kbps and businesses speeds of 128kbps to 8Mbps. Nucentrix Broadband Services, Inc. (Nucentrix) currently offers twoway highspeed Internet access service in Austin and ShermanDenison, TX, and is conducting a trial of the service in Amarillo, TX. In February 2001, Nucentrix announced it would extend its trial in Amarillo, where it is testing Ciscos Vector Orthogonal Frequency Division Multiplexing (VOFDM) technology with over 125 customers, until April 2001. Nucentrix holds licenses that cover 90 small and medium markets across Texas and the Midwest. In August 2000, Nucentrix filed applications to offer twoway service in 70 markets. At least 24 other companies offer fixed wireless services in approximately 33 different counties. These companies are small, independent MDS licensees offering Internet access at up to 11Mbps downstream to a limited number of residential and small business customers in one to five markets apiece (generally smaller towns and cities). For example, LMA Systems offers twoway Internet access at 1.54Mbps downstream and 768kbps upstream in WilkesBarre and Sunbury, PA. and has plans to enter additional markets. Oxford Telecom offers twoway MDSbased Internet access in Portland, ME. Some MDS carriers  including QuadraVision in Carson City and Reno, NV and American Rural TV in La Junta, CO offer fixed wireless Internet access on a oneway basis and use a telephone line for the return path. SPECTRUM USE Except for two channels at 2150MHz, the majority of ITFS and MDS operations are located in the 190megahertz in the 25002690MHz band. In this band, ITFS licensees are allotted five groups of 6megahertz channels (120megahertz of spectrum), and MDS licensees are allotted three groups of 6megahertz channels (66megahertz of spectrum). Each 6megahertz channel has associated with it a 125kHz response channel (4megahertz of spectrum). In the largest fifty metropolitan areas in the country, MDS utilizes two 6megahertz channels in the 21502162MHz band. In the rest of the country, the 6megahertz MDS 2 channel is replaced by a 4megahertz MDS 2A channel (2150 to 2160MHz). The channel plan is shown in Figure 3.1. Figure 3.1: ITFS/MDS Channel Plan  Over the years, the MDS and ITFS operators typically operated in a symbiotic relationship with MDS operators providing funding used by ITFS licensees for their educational mission in exchange for the extra channel capacity needed to make MDS systems viable. Today, most ITFS licensees lease excess capacity to MDS operators, subject to certain technical limitations and programming requirements. Although the Commissions licensing processes can identify in a given geographic area how many channels MDS licensees own through either areawide and site specific licensing, this information does not reveal how much additional spectrum is being leased from ITFS licensees or the extent to which MDS spectrum is being leased to other companies. In its 1998 TwoWay Order, the Commission established a regulatory framework under which MDS has become a fully flexible service in which licensees can provide either oneway or twoway service to fixed or portable locations in response to local marketplace demands. MDS and ITFS licensees were given the flexibility to reconfigure their licensed spectrum not only to change the direction of transmissions but also to change the bandwidth used in any direction. In these twoway systems, operators are able to deploy a cellular configuration to take advantage of frequency reuse techniques and to employ modulation schemes that would permit the use of variable bandwidth while assuring appropriate levels of interference protection to other licensed users of the spectrum. The most common characteristics of the twoway systems now being deployed are described below. See Appendix 3.3 for a pictorial representation of ITFS/MDS band plans. Either the highest or lowest frequencies in the 25002690MHz band are used for upstream service from the user to the systems receiver; downstream voice and/or data channels occupy the remaining spectrum. This arrangement provides approximately 30megahertz separation between upstream and downstream transmissions to provide sufficient isolation of upstream and downstream signals in the duplex switch. Bandwidth is assigned as needed to meet the asynchronous bandwidth needs of their customers, including offering adjustable bandwidth on demand. Licensees can subchannelize and superchannelize the 6megahertz main channels and the Ichannels (125kHz response channels) to permit the maximum possible operating flexibility. For example, the downstream Internet speeds reported by MDS operators range from 750kbps to 11Mbps, and MDS Internet systems can be designed in pointtopoint or pointtomultipoint configurations to meet these requirements. Upstream data channels typically are either 200 or 400kHz, and they are most often delivered by subchanneling 6megahertz main channels. Licensees can choose the bandwidth plan for each licensed station, taking into account channel availability (both licensed and leased channel availability) and interference protection to other authorized users of the band. Thus, the bandwidth plans for twoway systems will likely vary from one geographic area to another. ITFS and MDS licensees can exchange channels, subject to Commission approval. Also, under certain circumstances, MDS entities could apply for licenses for up to eight ITFS channels per community, and ITFS entities have a subsequent right of access to those channels. GEOGRAPHIC DEPLOYMENT ITFS and MDS are licensed with different service areas and thus have different geographic areas entitled to interference protection. ITFS is authorized on a sitespecific and channelspecific basis. Although an ITFS licensee may be authorized to use multiple channels, not all available ITFS channels may be licensed at any given site or in any given geographic area. Originally, ITFS transmit and receive sites were licensed on a pointtopoint basis. Eventually the Commission adopted a protected service area (PSA) concept and, with the adoption of the TwoWay Order, receive sites located within a 56.3kilometers (35miles) radius of a licensed ITFS transmitter are entitled to interference protection. The Commission continues to provide interference protection to numerous previously registered receive sites that are beyond the 56.3kilometer (35mile) PSA boundary. Today, interference protection for ITFS transmit and receive sites is an amalgam of different channels and geographic boundaries that vary from location to location. MDS originally was licensed on a sitespecific and channelspecific basis as well. Because MDS is a pointtomultipoint service, the Commission subsequently provided interference protection to receivers located within a PSA of 56.3kilometers (35miles), surrounding licensed transmit sites. In 1996, the Commission allotted, through a simultaneous multiple round bidding process, one MDS authorization for each of the 487 Basic Trading Areas (BTAs) and six additional similar geographic areas. The BTA licensees are authorized to construct facilities to provide service over any usable MDS channel within the BTA and have preferred rights to the available ITFS channels. Today, some incumbent sitespecific MDS licensees continue to provide service within PSAs that either overlap with or lie within licensed BTAs. As discussed above, the TwoWay Order allows both ITFS and MDS licensees to modify the historic band plan and to operate with subchannels or superchannels. In effect, the traditional channel boundaries across the band are erased, but the geographic protection areas licensed to a particular band segment remain for interference protection purposes. This has practical consequences for combined systems that utilize interleaved channels from both MDS and ITFS channel groups. For example, channel B1 is immediately adjacent to channel A1. Protection of the BTA boundary would only apply to the band segment licensed under the MDS channel group, whereas a 56.3kilometer (35mile) PSA boundary would apply to the band segment licensed under the ITFS channel group or MDS stations authorized prior to the BTA auction. Consequently, the actual overlay of BTA and PSA boundaries would be a relevant consideration in determining the actual service area boundary of a superchannel that crosses historic band channel boundaries. SYSTEM CHARACTERISTICS The architectures and technical characteristics of ITFS/MDS systems in the 25002690MHz band vary and depend on the type of service being offered, the population of the market being served, and terrain characteristics of the area being served. Today there are four basic service offerings by ITFS/MDS operators: downstream analog video, downstream digital video, downstream digital data and downstream/upstream digital data. An ITFS or MDS system may be providing any one of these services or a combination of services. The typical system characteristics of traditional oneway ITFS and MDS systems as well as proposed twoway ITFS and MDS systems is considered below. In Appendix 3.2, the specific technical characteristics for stations in traditional oneway ITFS and MDS systems are provided in Tables 3A (base stations) and 3B (response stations). These are primarily specifications for analog systems, and they also apply to any digital system authorized prior to the adoption of the TwoWay Order in 1998. In Appendix 3.2, the specific technical characteristics for stations in twoway ITFS and MDS systems are provided in Tables 3C (base stations) and 3D (response stations). These are primarily specifications for twoway digital systems that have been authorized since 1998. Traditional OneWay ITFS Systems Traditional oneway ITFS systems provide oneway video transmission service to their users. In such a system, a main station transmitter broadcasts (usually omnidirectionally) to multiple receive sites located within the system service area, typically a radius of 56.3kilometers (35miles). Such receive sites are typically at schools or similar facilities where a reception antenna can be located on a tower or roof in order to provide a lineofsight path back to the main station location. A 125kHz response station transmitter may be located at any or all of the receive sites to enable students (and/or faculty) at the receive site to communicate with faculty (and/or students) at the main station site. One or more booster stations may be used to retransmit the main station signal to locations where the signal cannot be received directly, e.g., where there is terrain blockage. Most systems make use of standard 6megahertz composite NTSC video/audio modulation for the downstream signal and wideband FM for response transmissions. Traditional OneWay MDS Systems Traditional oneway MDS systems provide oneway multichannel video programming to subscribers, a service known as wireless cable. Wireless cable systems operate similar to ITFS systems, with a main station transmitter broadcasting (usually omnidirectionally) multiple channels of feeforservice entertainment television programming to customer premises located within the MDS service area. Each customer typically has a towermounted or rooftopmounted reception antenna and is connected, via a block downconverter, to one or more television sets. As in ITFS systems, an MDS system makes use of booster stations to achieve coverage in portions of the service area where direct coverage from the main station is impossible. Also in common with ITFS systems, most MDS systems make use of standard 6megahertz composite NTSC video/audio modulation, although a few systems have implemented digital modulation in recent years. TwoWay ITFS/MDS Systems The TwoWay Order introduced a wholly new method of configuring MDS and ITFS systems. In discussing the technical aspects of ITFS/MDS systems, it is important to be familiar with the following terms: Main Station: The primary station authorized by the Commission to the MDS or ITFS licensee for providing coverage within a given service area. A maximum station power of 33dBW (2000 watts) (per 6megahertz bandwidth) effective isotropic radiated power (EIRP) is permitted. Booster Station (high power): A station used by an ITFS or MDS licensee to provide service within a given service area to locations not served by the main station. Any number of such stations may be located within a given service area and they may both repeat main station transmissions and originate transmissions. These stations operate at a power level greater than 9dBW (125 milliwatts) up to a maximum of 33dBW (2000 watts) (per 6megahertz bandwidth) EIRP. Booster Station (low power): Same as above except limited to a maximum power of 9dBW (125 milliwatts) (per 6megahertz bandwidth) EIRP. These stations may be activated without prior Commission approval and operate so long as they do not cause harmful interference. Receive Site: A location at which a receiver is located and used in conjunction with an ITFS system. A site may be 'registered (with the Commission) and thus protected from harmful interference or unregistered and not protected from interference in certain circumstances. Response Station (traditional): A transmitting station used within a traditional, oneway ITFS system for transmitting an audio signal from a receive site back to the main station using 125kHz response channels located in the 26862690MHz range. Response Station (twoway system): A customerpremises transceiver used for the reception of downstream and transmission of upstream signals as part of a large system of such stations licensed under the authority of a single license. A maximum EIRP of 33dBW (2000 watts) (per 6megahertz) is permitted. Hub Station: A receiveonly station licensed as part of a system of response stations in a twoway system and used for the purpose of receiving the upstream transmissions of those response stations. Sectorization (at main or booster stations): The use of multiple directional transmitting antennas for the purpose of achieving simultaneous frequency reuse at a single site. Sectorization (at hub stations): The use of multiple directional receiving antennas for the purpose of receiving transmissions on the same frequencies from multiple directions simultaneously. In a twoway MDS or ITFS system, a main station transmitter is used to send data using digital modulation to numerous users. Each user has at least one response station transceiver with its receive antenna oriented towards the main station and its transmit antenna oriented towards its associated hub station. Typically, a large number of response stations will be served by a single main station and by a single hub station linked to that main station, and in most cases these stations will be colocated. Additionally, typical systems will utilize numerous booster stations, each of which serves its own system of response stations and is associated with its own hub station. Similar to other cellular networks, twoway systems employ frequency reuse techniques such as using sectored antennas within a cell or splitting one cell into several cells. Twoway systems using digital modulation may also subchannelize and superchannelize their authorized spectrum on a realtime dynamic basis to meet needs within the system. There is no limit on the number or locations of response stations so long as the aggregate interference generated by the stations within the system falls at or below the level required for protection of neighboring systems. Bandwidths and associated data rates may be symmetrical or asymmetrical for upstream and downstream paths, dependant on system architecture and the nature of the service(s) provided. Hybrid systems are also permissible, consisting of both traditional oneway and twoway operations within the same service area. In the wake of the TwoWay Order, MDS equipment manufacturers have begun developing new ways to use the available MDS spectrum more efficiently, such as sectored antennas and advanced modulation techniques. For example, Wireless Online utilizes an antenna technology that enhances the coverage, quality, and capacity of MDS networks. NextNet, Inc. has developed a sectorized base station that uses 6megahertz channels, with each of the six 60degree sectors of the base station occupying one channel. The system minimizes multipath signal propagation and reportedly delivers maximum user capacity permegahertz allocated. Hybrid Network, Inc.s equipment allows licensees to split one 6megahertz channel into three 2megahertz channels and thereby offer different levels of service using the different 2megahertz channels. Also, in December 1999, Cisco Systems released a cellularization technology for MDS and unlicensed spectrum called VOFDM. VOFDM captures signals as they bounce off buildings and other objects and redirects them to enduser transceivers, therefore eliminating the need for a fixed lineofsight between a transmitter and a receiver. Nucentrix recently completed a field trial of Ciscos VOFDM equipment in Austin, TX and plans to deploy the technology in at least 20 markets by the end of 2001. WorldCom is also testing VOFDM in its Dallas trial. All of these innovations permit MDS licensees to make ever more effective use of their spectrum. INTERFERENCE PROTECTION STANDARDS The calculation of permissible interference levels on an intersystem basis is extremely complex. The requirements for MDS system protection are set out in sections 21.902, 21.909, 21.913, 21.933, 21.937 and 21.938 of the Commissions rules. The requirements for ITFS system protection are set out in sections 74.903, 74.939, 74.949 and 74.985 of the Commissions rules. Additional requirements and procedures for interference protection for stations in both services are found in Appendix D (titled Methodology) to Report and Order on Further Reconsideration and Further Notice of Proposed Rulemaking in MM Docket 97217. Interference is calculated using desired/undesired (D/U) signal ratios and field strength values that are always referenced to the bandwidths of the two signals involved in the calculation. The D/U values specified in the MDS and ITFS rules are normalized to 6megahertz and all calculations are based on these normalized values. Interference is also calculated using a reference field strength value specified indBW per square meter, and this value is also always referenced and normalized to 6megahertz bandwidth. The geographical areas for MDS systems that must be protected fall into 3 basic categories. First, there are protected service areas (PSA), typically with a 56.3kilometer (35mile) radius, for incumbent MDS licensees who received their authorizations prior to March 1996 when the MDS channels were auctioned nationwide. The second geographic classification is a Basic Trading Area (BTA), including portions of BTAs that are created when a BTA is partitioned. Finally, ITFS registered receive sites within an area swept by a 56.3 kilometer (35mile) radius surrounding the main station transmitter are entitled to protection. Interference is calculated using aggregated values for the power flux density on any given channel, subchannel or superchannel, i.e., interference potential is based on the summation of all of the individual potential interference contributions of all of the transmitters within a system, which might be received in a neighboring system. Aggregation must be used for calculation of both D/U signal ratios and field strength values. Interference protection is calculated with reference to specific, known locations in an ITFS system, and to general geographic areas. The calculation is done using a grid of points laid out checkerboard fashion using a reference antenna pattern and a reference standard antenna height above ground level (AGL). The most interferencesensitive portion of a twoway system is the hub station receiver. This receiver must be protected down to its noise floor by all neighboring systems, using a calculation that takes into account its noise figure, feedline loss, antenna gain and other pertinent factors. All ITFS/MDS interference calculations must utilize the EpsteinPeterson propagation formulations found in the Methodology. Because the locations of response stations in twoway systems are not known prior to licensing of the system, a totally theoretical construct was devised for estimating interference from response stations into neighboring systems. SECTION 4 EVALUATION OF SPECTRUM SHARING In the Interim Report, we presented a technical evaluation of options for sharing between 3G and incumbent ITFS and MDS operations in the 25002690MHz band. In this section, we review and assess that technical evaluation. The technical feasibility of cochannel and adjacent channel sharing between licensed ITFS/MDS stations and 3G base and mobile stations was examined by calculating minimum distance separation requirements using the interference protection criteria established in the Commissions rules for ITFS and MDS. ITFS/MDS licenses within the spectrum band were examined to assess where, in light of the minimum separation distances, 3G systems could operate without causing harmful interference to ITFS/MDS systems. In this Final Report, we also assess the predicted levels of cochannel interference from an ITFS/MDS transmitter into 3G base and mobile stations. INTERFERENCE PROTECTION REQUIREMENTS In the Interim Report we calculated the predicted levels of cochannel and first adjacent channel interference from 3G base and mobile stations into an ITFS/MDS licensees receivers at hub and response sites and determined the minimum distance separation required to avoid harmful interference. As discussed below, we determined that large cochannel separation distances are needed between 3G systems and ITFS/MDS systems to avoid causing harmful interference to ITFS/MDS systems, and that adjacent channel separation requirements do not appear to be as limiting. In order to perform technical analyses of the ability of 3G systems to share spectrum with incumbent systems, we made certain assumptions about 3G systems and incumbent ITFS/MDS systems: For the likely technical characteristics of 3G systems, such as the power levels likely to be used by base stations and mobile units and the bandwidths of 3G signals, we used, where appropriate, the ITU technical standards for IMT2000 systems. These technical characteristics have been updated since the release of the Interim Report by the Industry Association Group. Interference from a 3G system into the ITFS/MDS stations receivers could come from either the 3G base station or the 3G mobile unit. Because base stations are fixed, it was fairly straightforward to predict the interference from a 3G base station into ITFS/MDS receivers. We also analyzed the effect that a single typical 3G mobile unit would have on ITFS/MDS receivers. ITFS/MDS systems can be implemented using a main transmitter configuration or architecture. These systems typically have a single high power base station transmitter located at high elevation with an omnidirectional or wide cardioid antenna pattern. FCC rules set the maximum permitted EIRP for ITFS/MDS base stations at 2000 watts (33dBW). Typical EIRP for analog systems are in the 1001000 watt (2030dBW) range and are slightly higher for digital or cardioid antennas. Both horizontal and vertical polarization are used and are often precisely calibrated to avoid cochannel interference to neighboring systems. Booster stations are also used in some system designs to overcome signal loss within a protected service area. Cellular architectures are also being developed and deployed for twoway ITFS/MDS data transmission systems in densely populated areas. Because transceivers are located close together, power levels are scaled back for both downstream and upstream transmissions to between 1 and 100 watts (020dBW) EIRP, using the minimum power necessary to achieve path reliability. Interference is controlled within the protected service area by careful frequency planning and by using polarization, sector geometry and receive antenna isolation. For example, antennas located at customer premises have downstream gains of 12 to 27dBi, similar to that for a single cell oneway system, and have upstream gains of 10 to 24dBi. To determine cochannel and first adjacent channel protection requirements, technical characteristics specified in the FCC rules for a typical ITFS/MDS station were used. Current FCC rules require cochannel ITFS/MDS licensees to maintain a D/U signal level of 45dB at all unobstructed areas within the 56.3kilometer (35mile) radius protected service area of an incumbent station. This is particularly important in analog single station architectures, where a high D/U ratio is required to maintain a high quality video signal. For digital single station architectures, the D/U ratio can be less than 45dB as a practical matter because digital systems can tolerate more interference. However, FCC rules do not specify different D/U ratio values based upon whether the incumbent licensee is operating an analog or digital system. Therefore, for purposes of this study the required 45dB D/U ratio was used for the cochannel analysis. For the adjacent channel analysis, FCC rules specify that a D/U ratio of 0dB be maintained. Tables 4A and 4B in Appendix 4.1 summarize the pertinent provisions of the FCC rules for ITFS/MDS response stations and ITFS/MDS main stations. The analysis assumed two operating scenarios for 3G base stations based on the five IMT2000 radio interface standards, one operating with high power 500 watts EIRP (27dBW), and one operating with low power 10 watts EIRP (10dBW). The analysis of the interference potential from an IMT2000 mobile station into an ITFS/MDS receiver assumed the 3G mobile station was operating with 100 milliwatts (10dBW) EIRP. Table4.1 shows the minimum spacing required to prevent interference between cochannel 3G base and mobile stations and ITFS/MDS hub and response station receivers based on our assumptions and the planning factors set forth in Tables 4A and 4B in Appendix 4.1. The required separation is first tabulated assuming free space conditions, as prescribed in the FCCs rules for radio propagation predictions for ITFS/MDS service. However, as a practical matter, interference does not extend beyond the radio horizon. FCC rules recognize this concept by setting 161kilometers (100miles) as a limiting distance for purposes of establishing minimum distance separations. Accordingly, if the calculated free space distance separation exceeds this limit, the practical limit of 161kilometers (100miles) is shown in the table. Table4.1: Calculation of Cochannel Separation Distances of 3G Stations to ITFS/MDS Stations ITFS/MDS System Parameters3G System Parameters3G Base Station (500 Watts)3G Base Station (10 Watts)3G Mobile Station (100 milliwatts)Protected Receiver TypeBandwidth (kHz)Modulation TypeBandwidth (kHz) EIRP (dBW)Minimum Separation (km) EIRP (dBW)Minimum Separation (km) EIRP (dBW)Minimum Separation (km)Hub125CDMA1250271611016110161125CDMA3750271611016110148125WCDMA5000271611016110127125TDMA30271611016110161125TDMA200271611016110161Response Station6000CDMA12502716110161101616000CDMA37502716110161101146000WCDMA50002716110161101006000TDMA302716110161101616000TDMA200271611016110161 Similar to the analysis above, Table 4.2 tabulates the minimum spacing required to prevent interference between 3G base and mobile stations and first adjacent ITFS/MDS main and response station receivers. Table4.2: Calculation of Adjacent Channel Separation Distances of 3G Stations to ITFS/MDS Stations ITFS/MDS System Parameters3G System Parameters3G Base Station (500 Watts)3G Base Station (10 Watts)3G Mobile Station (100 milliwatts)Protected Receiver TypeBandwidth (kHz)Modulation TypeBandwidth (kHz) EIRP (dBW)Minimum Separation (km) EIRP (dBW)Minimum Separation (km) EIRP (dBW)Minimum Separation (km)Hub125CDMA1250271011014101125CDMA37502758108101125WCDMA50002751107101125TDMA30271611093109125TDMA200271611036104Response Station6000CDMA125027161109910106000CDMA37502716110571066000WCDMA50002716110501056000TDMA30271611016110646000TDMA20027161101611025 These tables show, generally, that large cochannel separation distances are needed between 3G systems and ITFS/MDS systems to avoid causing harmful interference to ITFS/MDS systems. For example, a 3G base station, whether a highpowered 500 watt base station or a lowpowered 10 watt base station, would need to be beyond the radio horizon of the ITFS/MDS station or 161kilometers (100miles) to avoid causing interference to cochannel ITFS/MDS receivers at either hub or response stations. Very lowpowered 3G mobile stations must maintain distances between 100 kilometers (62miles) and 161kilometers (100miles) to avoid causing harmful interference to cochannel ITFS/MDS hub and response stations. The results of this analysis of predicted level of interference and associated minimum separation distances are consistent with a similar study conducted by MSI. The analyses in the Interim Report relied on appropriate ITU standards for the 3G system technical characteristics. As noted above, these technical characteristics have been superseded by the Industry Association Group 3G Technical Characteristics Report. A review of the updated 3G technical characteristics reveals that much of the data we relied on for calculating cochannel and adjacent channel separation distances only has minor changes or is unchanged. Taking these changes into account, we believe that the conclusions of our initial analysis remain valid. In addition, we note that commenters from both the ITFS/MDS and wireless industries also concluded that sharing in the 25002690MHz band was not feasible. In addition to the interference from a 3G system into an ITFS/MDS system, we considered the interference that a 3G system would receive from a cochannel ITFS/MDS system for this Final Report. In its comments to our Advanced Wireless Services NPRM, the WCA included such an analysis performed by MSI. MSI concludes that very large separation distances are needed to protect cochannel 3G systems from receiving interference from ITFS/MDS systems. In general, MSIs analysis shows that ITFS/MDS and 3G systems must be separated by distances exceeding the radio horizon (161km or 100 mi) to ensure that ITFS/MDS transmitters will not cause harmful interference to 3G receivers. We agree with the conclusions contained in this analysis and do not believe that further analysis is necessary at this time. ITFS/MDS CHANNEL LICENSING In the Interim Report, we examined the 25002690MHz band to determine if there are any vacant channels (i.e., channels not currently licensed) that could be made available for 3G use. This study looked at channel availability in the 50 largest metropolitan areas in terms of population. To determine whether there are any vacant channels, the FCCs database as of November 6, 2000 was used. The database contains information on licensees, their channel number and geographic coordinates of the main transmitter. Using this licensing data, the number of ITFS/MDS channels licensed within 161kilometers (100miles) of the city center coordinates was determined for each of the 50cities. Appendix 5.4 of the Interim Report indicated the number of channels licensed per city. This analysis showed that in 49 of the 50 cities all 31 ITFS/MDS channels are licensed within 161 kilometers (100miles) of the 50 cities considered. We also analyzed the locations of hub and response stations and the protected service areas for each of the of 31ITFS and MDS channels. We noted that the entire 66megahertz of spectrum allocated to MDS is encumbered throughout the entire United States. This is because the rights to provide MDS in all areas of the country were acquired by winning auction bidders and are not subject to a site specific license and protected service area. Recognizing that not all of the BTAs have been completely builtout, we also examined the actual occupancy of a sample MDS channel to identify where licensed facilities exist. This analysis was done in order to be as complete as possible in describing the occupancy of this spectrum band for purposes of assessing the feasibility of sharing with 3G systems, e.g., whether MDS licensees might be able to partition an area within their BTA to prospective 3G system operators. Our analysis showed that there are no significant differences in use and occupancy across each of the 11 MDS channels. MDS channels are generally fully deployed in each of the major metropolitan areas of the United States. As an example, figures 4.1 and 4.2 show only limited areas within some BTAs where MDS Channel E1 might be available for 3G systems use, given a 161 kilometer minimum separation between 3G and MDS systems. Figure4.1: Single MDS Channel E1  Figure4.1 shows the 56.3kilometer (35mile) protected service areas of licensed MDS stations on MDS channel E1. Figure4.2 shows the map of Channel E1 but substitutes 217kilometer (135mile) circles for the 56.3kilometer (35mile) protected service areas shown in Figure4.1. Only in the very limited white space of Figure4.2 would it be possible to locate a 3G station on Channel E1 and maintain the 161kilometer (100mile) base station separation requirement. Figure4.2: Single MDS Channel E1 With 217kilometer (135mile) Protected Service Areas  We also conducted a similar analysis of the 20 ITFS channels. Our analysis showed that at least one ITFS station operates in most areas of the United States, and that the use and occupancy of the 20 ITFS channels is not significantly different for any ITFS channel. As an example, to visualize the degree to which each ITFS channel is used, the occupancy of ITFS Channel A1 was examined. Our analysis showed that although cochannel operation of 3G systems might be possible in some areas, these areas would be significantly limited if a 161 kilometer minimum separation were to be achieved between 3G and ITFS systems. For Channel A1, this is illustrated by figures 4.3 and 4.4. Figure4.3: Single ITFS Channel A1  The white areas of this map reflect those areas of the country beyond the 56.3kilometer (35 mile) protected service area of current ITFS stations. This reveals that only in the least populated areas of the country is ITFS spectrum not currently occupied. However, as noted above, cochannel sharing of 3G with ITFS/MDS may not occur within 161kilometers (100miles) of an ITFS/MDS receive site. Thus, the available area for locating a 3G system within the ITFS spectrum is significantly less than the white area depicted in Figure4.3. To illustrate, this map is reproduced, but instead of depicting the 56.3kilometer (35mile) protected service areas, the circles are enlarged to 217kilometers (135miles) and show the areas of the country where a 3G system can be deployed without causing harmful interference. Only in the very limited white space of Figure4.4 would it be possible to locate a 3G station and maintain the 161kilometer (100mile) base station separation requirement. Figure4.4: Single ITFS Channel A1 With 217kilometer (135mile) Protected Service Areas  Our analyses demonstrated that there is no significant difference between any of the ITFS or MDS channels and Channels A1 and E1. We determined that ITFS and MDS channels are used in the major metropolitan areas, and the areas available for possible 3G services within the 25002690MHz band is significantly limited when the 161kilometer (100mile) minimum distance separation requirement is considered. SUMMARY Based on the assumptions used, we accordingly concluded in the Interim Report that sharing between 3G systems and ITFS/MDS operations is extremely problematic. We affirm this conclusion in this Final Report. Although voluntary partitioning between incumbent users and 3G operators could offer some promise of sharing as an interim measure, there does not appear to be enough spectrum in the 25002690MHz band in populated areas to support a viable 3G service based on sharing of existing spectrum in this band. SECTION 5 EVALUATION OF BAND SEGMENTATION In the Interim Report, we described three possible band segmentation options for the 25002690MHz band. We noted that band segmentation would require the relocation of ITFS/MDS systems from a portion of the band so that spectrum could be made available for 3G systems. In this Final Report, we review the analysis regarding the feasibility of dividing the 25002690MHz band into segments to meet the radiocommunications requirements for 3G systems and ITFS/MDS systems. We also examine what impact the segmentation options would have on ITFS/MDS systems if we did not replace the spectrum that would be used by 3G systems, and instead require ITFS/MDS to operate only on the remaining spectrum in the 25002690MHz band. In addition, because segmentation entails placing ITFS/MDS and 3G systems sidebyside at the edges of segmented spectrum, we estimate the size of the guard band that would be necessary to protect adjacent channel ITFS/MDS and 3G systems from interfering with each other. In this Section, we focus our analysis primarily on the relationships between decreased spectrum availability, system deployment, and cell size; possible relocation of ITFS/MDS to alternate frequency bands is discussed in Section 6. Finally, our evaluation considered implementation of the three segmentation options in three possible time periods2003, 2006 and 2010. SPECTRUM REQUIREMENTS FOR 3G SYSTEMS In the Interim Report, in order to perform an analysis of band segmentation options, we made certain assumptions about the overall amount of spectrum that may be made available for 3G systems in the 25002690MHz band. We believe that these assumptions are still valid, and we review them below. First, we assume that a substantial part of the 25002690MHz band would continue to be required to support ITFS/MDS operations. Second, a number of options are under consideration in the ITU for either developing IMT2000 for independent operation in the 25002690MHz band or to pair some portion of this spectrum with other bands. It is not clear at this time what, if any, spectrum from other bands will be suggested for pairing with the 25002690MHz band for 3G systems. Therefore, for purposes of this study, we assume that 3G systems would operate independently in this band. If 3G systems were implemented independently in the 25002690MHz band, sufficient spectrum would need to be made available to support multiple licensees to promote competition. Also, the spectrum would need to be of sufficient size to enable development of systems that are economically viable and support the economies of scale necessary to warrant development of transmitters, antennas, consumer handsets, and other related equipment. For example, the Commission has allocated a total of 120megahertz of spectrum for Personal Communications Service (PCS) in the 1.9GHz band, which provided for three licenses of 30megahertz and three licenses of 10megahertz in each geographic area. Also, a number of European countries have recently made spectrum available for 3G services in excess of 100megahertz. Spectrum also must be made available in contiguous blocks of some minimal size, both to facilitate reasonable system design and to allow licensees to choose from all available technologies. For example, wideband CDMA technology requires a minimal spectrum block size of about 5megahertz  paired, duplex operation would require two blocks of 5megahertz. In light of these factors, to assess the viability of various segmentation options in this study, we assume that 90megahertz of spectrum in the 25002690MHz band would be made available for 3G systems. This would continue to leave more than half of the current spectrum available for ITFS/MDS. It would also provide sufficient spectrum for multiple 3G licenses. For example, an allocation of 90megahertz could provide for three 3G licenses of 30megahertz each, or three 3G licenses of 20megahertz each and three 3G licenses of 10megahertz each. In comments filed in response to the Advanced Wireless Services NPRM, Verizon argues that only sixmegahertz of spectrum is needed to support an ITFS stations instructional purposes and that both 3G systems and ITFS can be accommodated through segmentation of the band. Verizon states that 30megahertz appears to be sufficient to ensure the economic viability of one 3G system, and that at least two operators should be licensed to facilitate the economies of scale necessary to warrant the development of 3G equipment. Accordingly, Verizon recommends that at least 60megahertz of spectrum be made available for 3G systems in the 25002690MHz band. VoiceStream, on the other hand, supports making at least 120megahertz of spectrum available in the band for 3G systems, using two 60megahertz blocks, in order to ensure that adequate spectrum is available for 3G systems over the next 510 years. For purposes of this study, we continue to assume that 90megahertz of spectrum may be needed in this band to support the introduction of 3G systems. With respect to the comments of Verizon and VoiceStream, we do not believe that there would be a significant difference in the analysis of band segmentation options if 60 or 120megahertz was made available for 3G systems. We note however, that the assumption of 90megahertz has been chosen solely to illustrate possible band segmentation scenarios. It should not in any way be considered indicative of any position that the Commission may ultimately take on how much spectrum or which frequency band(s) should be used for the provision of 3G services. Other factors are also relevant in analyzing various segmentation options. For example, the choice of frequency division duplex (FDD) or time division duplex (TDD) radio interfaces affects the segmentation options studied. Similarly, the architecture of planned new twoway ITFS/MDS systems must be taken into account. As described in Section 3, most planned implementations use FDD technology and require a separation of at least 30megahertz between upstream (customer to base) and downstream (base to customer) transmissions. For FDD operation, this separation is necessary to provide sufficient isolation of upstream and downstream signals in the duplexer. TDD systems also must be accommodated. These systems, which tend to be less robust than FDD systems, generally require a guard band between their band of operation and adjacent bands to minimize the potential of harmful interference. Finally, a variety of other technical factors may also be relevant to determining spectrum requirements for future 3G systems. These include constraints on the separation between paired frequency blocks for frequency duplex technologies, compatibility with existing channeling plans for incumbent systems, adjacent channel interference, and backward compatibility with existing 1G and 2G systems. The traffic loading requirements for 3G data services, where downstream traffic is much greater than upstream traffic, may lead to asymmetric pairing of spectrum bands. These factors were not considered in the Interim Report, nor are they considered in this Final Report because no new information has become available. TWOWAY ITFS/MDS SYSTEMS: BAND PLANS As discussed in Section 3, ITFS and MDS licensees are now beginning to deploy twoway systems in the 25002690MHz band. System configuration in any given geographic area is subject to certain limitations arising from current spectrum use in that area. As noted, geographic MDS licenses have been awarded through the competitive bidding process. These licensees, in implementing their systems, must protect incumbent MDS systems licensed on a sitespecific basis for 56.3 kilometers (35miles) around each transmitter. With respect to ITFS channels, not all are licensed in all areas. However, where they are licensed, the MDS licensee may lease excess capacity on the ITFS channels, and MDS and ITFS licensees can broker channel swaps with each other. Additionally, geographic MDS licensees have limited ability to gain access to ITFS channels that are not licensed at this time. Because of the regulatory flexibility that the Commission has allowed in this band and the licensing differences between each geographic area, conclusions cannot be made regarding the configuration of a typical ITFS/MDS system. To accommodate this flexibility, the MDS industry has initiated a number of band plans to accommodate new service offerings, such as twoway service, as well as to accommodate existing ITFS and MDS users. The figure in Appendix 3.1 shows a pictorial representation of the various band plans that MDS licensees are contemplating. The sample plans presented in this figure are for study purposes only and do not reflect other options that could be deployed by ITFS/MDS licensees in the future. As seen in this figure, WorldCom has indicated that it is implementing three types of twoway deployment. WorldCom1 depicts a scheme where twoway ITFS/MDS is overlaid in a market that has heavy ITFS video use. WorldCom2 depicts a band plan that provides a single main transmitter and cellular configurations where video would be accommodated either on the twoway system or a limited number of ITFS channels. WorldCom3 depicts a deployment that has to accommodate various individual licenses. Sprint and Nucentrix both indicate two generic plans each that depict asymmetric systems by grouping the upstream transmissions on either the upper or the lower channels. And as noted above, all plans depict a 30megahertz separation between the upstream and downstream data transmissions. BAND SEGMENTATION OPTIONS The Interim Report presented three band segmentation options. These are depicted in Figure5.1 below. The Interim Reports analysis of the impact that these options would have on ITFS/MDS and 3G systems, which is summarized below, considered the functional and operational factors described in the previous sections. Figure5.1: Band Segmentation Options  Option 1 provides two 45megahertz frequency blocks for 3G services and leaves the remaining 100megahertz for ITFS/MDS in two 50megahertz segments. A benefit of this option is that it provides frequency separation between paired channel blocks for both 3G and ITFS/MDS operations for FDD technology. Just as important, the ability to implement TDD systems is not precluded by this segmentation plan. An operator may implement TDD technology on any spectrum block for which it is licensed. To accommodate the differences between ITFS/MDS and 3G systems, guard bands between the segments have been included. Further analysis of this option includes an examination of which current ITFS/MDS channels would be impacted. As can be seen from Figure5.1, the placement of the 3G channels in this option coincide with the lower portion of the ITFS band (channels A1 through B4) and the MDS band (channels E1 through F4). This is problematic because, as described earlier, all of the MDS channels have been licensed on a geographic basis through the competitive bidding process and these geographic licensees have legal rights to build systems anywhere within their BTA that is not encumbered. Alternatively, a similar segmentation plan with the 3G segments in the center and upper portion of the band (channels C1 through D4, channels G1 through G4, and channel I) may be considered. Under this scenario, 3G channels coincide with fewer MDS channels that have been sold at auction (the interleaved channels H1, H2, and H3) than the option depicted in Figure 6.1. This option, however, would cede the response channel (channel I) to 3G systems. This channel, is used for interactive systems, such as distance learning, to provide an audio channel so that persons at remote locations can converse with persons located in the studio. The response channel is currently able to be accessed by any licensee in the ITFS/MDS band. Finally, the examination must assess the number of licensees that may be affected under segmentation Option 1. As can be seen in the following map, there are numerous systems deployed all over the United States that would have to be accommodated. Figure5.2: ITFS/MDS Stations Affected by Segmentation Option 1.  Option 2 provides a segmentation option in which both the 3G and ITFS/MDS spectrum is combined in a contiguous block. As seen in Figure5.1, 90megahertz of 3G spectrum is provided at the lower end of the band. The ITFS/MDS spectrum, including a single guard band, is located at the upper end of the band. Under this option, the 3G portion of the band could be divided into six 15megahertz blocks. These could be paired to provide three 3G licensees with 30megahertz of spectrum with 30megahertz separation between blocks for FDD technology (i.e., Block A, Block B, Block C, Block A, Block B, Block C each block contains 15megahertz of spectrum). This option also lends itself nicely to TDD technology for both 3G and ITFS/MDS systems. This option provides flexibility for any individual operator to implement the technology of its choice. Under this option, the spectrum denoted for 3G systems would impact only ITFS channels (channels A1 through C4) and the channels that were auctioned to MDS would remain with that service. Because of this, the option as depicted provides a better choice than reversing the segments (i.e., placing the 3G segment at the upper portion of the band and the ITFS/MDS segment in the lower portion of the band) where the 3G segments would encompass all the MDS channels and the response channel (channel I). Finally, as with the option presented above, the map shown below depicts the numerous stations that are currently licensed on the channels segmented to 3G systems. Figure5.3: ITFS/MDS Stations Affected by Segmentation Option 2.  Option 3 provides a combination of options 1 and 2. Under this option, two 45megahertz frequency blocks would be provided for 3G systems at the extreme upper and lower ends of the band. The ITFS/MDS spectrum is provided between these two 3G spectrum blocks. The frequency separation provided for 3G systems preserves the ability of system operators to implement FDD technology and the ITFS/MDS spectrum can be paired in a similar fashion as the 3G spectrum in Option 2 to accommodate FDD technology. Under this option, the channels segmented for 3G systems would encompass ITFS channels A1 through B4, and all the ITFS/MDS interleaved channels G1 through G4 plus the response channel (channel I). As described above for Option 1, this is problematic in that auctioned MDS spectrum would need to be retrieved to provide spectrum for 3G operators. Finally, as with Options 1 and 2, there are numerous ITFS and MDS assignments that would need to be accommodated to implement this segmentation option. This is shown on the map in Figure 5.4. Figure5.4: ITFS/MDS Stations Affected by Segmentation Option 3.  IMPACT OF BAND SEGMENTATION ON DEPLOYMENT OF ITFS/MDS SYSTEMS The flexible use of the 25002690MHz band makes it extremely difficult to assess the actual impact that each segmentation option would have on deployed systems. Such an analysis would entail an examination of the complex interaction of stations in any given geographic area, including the way station operation is influenced by lease arrangements and channel swaps. In light of this situation, we make some assessments below regarding the impact that station relocation within band or more efficient spectrum usage would have on ITFS/MDS operations. Our analysis does not address legal or policy issues concerning leasing arrangements or the acquisition of licenses through competitive bidding or transfer of control, which are beyond the scope of this study. To obtain a more quantitative evaluation of the effect segmentation would have on licensees, we examined the number of transmitters that would be affected by each option. In the Interim Report we stated that, based on the licensing database, over 60,000 transmitters would need to be accommodated in any 90megahertz segment of spectrum in the 25002690MHz band that is reallocated to 3G. Because the licensing database has not substantially changed since then, we believe that this conclusion is still valid. The majority of the stations represented in the database are mainly incumbent oneway systems. As geographic MDS licensees begin deploying twoway service, the number of stations will increase considerably because each subscribers location becomes an additional transmit site for upstream traffic. Thus, for every transmitter that a geographic MDS licensee currently has licensed, there is the potential for many times that number to ultimately exist. Additionally, educational institutions could continue to license ITFS stations where spectrum is available. Therefore, over 60,000 transmitters would need to be relocated regardless of which segmentation option is considered. If 90megahertz of spectrum is reallocated from the 25002690MHz band to 3G systems, the ITFS/MDS would have to provide their services using only 100megahertz, rather than the 190megahertz, of spectrum in the band. Such a scenario would require some ITFS/MDS operations to move from the reallocated spectrum to the remaining spectrum. One way to accommodate the influx of stations in the remaining spectrum would be for ITFS/MDS stations to transmit with narrower bandwidths or to reduce power. Thus, options for increasing the spectrum efficiency of ITFS/MDS operations must be explored. First, we can consider the effect segmentation would have on traditional oneway ITFS/MDS licensees that provide oneway video transmission services. Generally, these systems transmit using standard 6megahertz composite NTSC video/audio modulation. In addition, the ITFS licensees may use a 125kHz response station transmitter located at any or all of the receive sites to enable students or faculty at the receive site to communicate with others at the main station site. These response channels typically operate using wideband FM modulation. In recent years, some incumbent MDS systems have converted to digital systems. If the band was segmented, these stations would presumably convert to digital modulation in order to operate more efficiently. Based on the broadcasting services experience, we know that, when upgrading from analog to digital TV and employing MPEG2 video compression, efficiencies in the range of 4:1 (i.e., 4 distinct programs can be transmitted over one 6megahertz channel) up to about 8:1 can be achieved depending on the content and desired picture quality. Under these digital modulation schemes, though, the transmitted signal still occupies a 6megahertz channel; transmitters broadcasting a single program do not reduce their bandwidth to transmit over 1 or 2megahertz. Therefore, to accommodate the continued operations of all incumbent ITFS and MDS licensees in any given area, at least 6megahertz of spectrum per each incumbent user must be dedicated for such use in each area. If any of these licensees typically broadcast more than 68 programs simultaneously, additional channels must be set aside. Therefore, in order to maintain the 70megahertz of spectrum MDS is currently allotted under the existing band plan, there could be no more than 5 incumbent oneway ITFS and MDS licensees in any given area. This could be problematic in many metropolitan areas. For example, in New York City, 6 incumbent ITFS licensees hold 9 licenses, and 4 incumbent MDS licensees hold 5 licenses. Further, many of these licenses are for multiple channels. In contrast, in Buffalo, NY, there are no incumbent ITFS licensees and only 1 incumbent MDS licensee, holding 2 licenses. Analysis of the 50 largest metropolitan areas in terms of population shows that the average and median number of licenses in each area is 8 and the average number of different licensees holding these licenses is 5. Appendix 5.1 shows the number of incumbent ITFS and MDS licensees in metropolitan area. Licensees may already be using digital modulation techniques to provide data services at high data rates. For example, Nucentrix points out that they and other operators deliver data using efficient OFDM and highorder QAM modulations, and Cisco notes that major MDS licensees are conducting trials using their VOFDM technology. Operators that are already using digital modulation, including both oneway and twoway systems, may not be able to compress their signals to narrower bandwidths and still provide the same grade of service. These operators would have to decrease the size of the service area of each tower in order to continue offering high speed data services with reduced spectrum. This is explored below. The ITFS/MDS operators argue that to offer acceptable twoway service they need to have access to most of the 190megahertz of spectrum now allocated for ITFS/MDS in the 25002690MHz band. In commenting on the Advanced Wireless Services NPRM, WorldCom states that certain channels are not available in many markets due to cochannel ITFS/MDS operations in adjacent markets, that up to 42megahertz of separation is needed between upstream and downstream traffic, and that guard bands are needed between high power video downstream and low power data downstream channels to avoid station downconverter overload. Worldcom further states the these constraints result in an average availability of 158megahertz (including the 1012megahertz allocated in the 21502160/62MHz band) of spectrum in most markets for use by twoway systems. Similarly, the HAI Study determined that a reasonable estimate of the amount of spectrum to which twoway systems have access is 158megahertz (26 channels of 6megahertz each plus an additional 2megahertz). Finally, Cisco points out that to serve the San JoseSilicon Valley market, a microcell network (3 sectors per cell, 3 cells per cluster) is needed in which each cluster requires 9 sets of frequencies to provide 10.5megahertz downstream and 7.5megahertz upstream shared among all customers for a total of 162megahertz. Guard Bands Each of the segmentation options would provide significantly less spectrum for twoway ITFS/MDS systems than is currently available. If 90megahertz of spectrum was made available for 3G systems, the remaining 100megahertz of spectrum would have to support incumbent ITFS/MDS systems, geographic area MDS systems, and guard bands. Therefore, the usable spectrum for ITFS/MDS systems would be further reduced from 100megahertz based on the size of the guard band needed to protect adjacent channel operations. Below, we present an analysis estimating the size of the guard band necessary to ensure interference free operation between ITFS/MDS and 3G systems. Just as with the analysis to determine distance separations in Section 4, the technical characteristics for this analysis include the five ITU IMT2000 radio interface standards and the rules for ITFS/MDS interference protection. The analysis calculates the required mileage separation between ITFS/MDS base stations and 3G base stations for various guard band sizes. Calculations of separation distance are made for ITFS/MDS interfering with 3G systems and for 3G systems interfering with ITFS/MDS systems. The analysis looked at interference caused by energy contained in the adjacent channel, and for completeness also looked at energy from the adjacent channel that overlapped the desired channel (spillover). For the analysis of ITFS/MDS interference to 3G systems, we assume worst case operating parameters. For example, we assume that the main transmitter is operating with a sectored antenna at maximum power. For this type of operation, the rules allow up to 39dBW (7943 watts) EIRP. A complete list of planning factors used in the analysis is provided in Appendix 5.2. Also, as with the analysis in Section 4, computed values that exceed the distance to the radio horizon are reduced to the distance to the radio horizon or 161 kilometers (100miles). Table 5.1 shows the relationship between guard band size and the distance separation needed between 3G base stations and ITFS/MDS hub and response stations to avoid harmful interference due to the energy present in the adjacent channel. The table shows that for a guard band of 2megahertz, the distance separation necessary between ITFS/MDS and 3G systems is reduced to almost zero. In fact, from our planning factors in Appendix 5.1, it is easily deduced that each additionalmegahertz added to the guard band reduces the required separation by a factor of 100. Therefore, for this situation, we conclude that a guard band of at least 2megahertz seems reasonable to ensure protection of ITFS/MDS stations from 3G base stations. Table 5.1: Calculation of Separation Distances, 3G Base Station to ITFS/MDS Guard Band Analysis Based on Interference Power in Adjacent or Nearby Channels 3G System ParametersITFS/MDS System ParametersRequired Separation (km) Modulation Type EIRP (dBW) Bandwidth (kHz) Protected Receiver Bandwidth (kHz) Desired Signal Power Density (dBW/m2) Adjacent Channels (No Guard Band) Guard Band Width (MHz) 0.5 1 2CDMA271250Hub12590161161.60.02CDMA27375012590161161.60.02WCDMA27500012590161161.60.02TDMA273012590100101.00.02TDMA2720012590161161.60.02CDMA271250Response Station6000676.40.60.060.00CDMA27375060006711.31.10.110.00WCDMA27500060006712.91.30.130.00TDMA27306000671.60.20.020.00TDMA272006000673.20.30.030.00 Table 5.2 also shows that only 2megahertz of guard band is need to account for the 3G system energy that overlaps the ITFS/MDS channel. Therefore, the energy in the adjacent channel is the limiting factor in this case. We conclude that to protect ITFS/MDS stations from harmful interference from adjacent channel 3G systems, a guard band of at least 2megahertz is needed. Table 5.2: Calculation of Separation Distances, 3G Base Station to ITFS/MDS Guard Band Analysis Based on CoChannel Interference Power (Spillover) 3G System ParametersITFS/MDS System ParametersRequired Separation (km) Modulation Type OffChannel EIRP (dBW per 100kHz) Bandwidth (kHz) Protected Receiver Bandwidth (kHz)Noise Floor (NF), or Desired Signal (DS) Level (dBW) Adjacent Channels (No Guard Band) Guard Band Width (MHz) 0.5 1 2CDMA161250Hub125118 (NF)262.60.260.00CDMA163750125118 (NF)262.60.260.00WCDMA165000125118 (NF)262.60.260.00TDMA1630125118 (NF)262.60.260.00TDMA16200125118 (NF)262.60.260.00CDMA161250Response Station600083 (DS)161161.60.02CDMA163750600083 (DS)161161.60.02WCDMA165000600083 (DS)161161.60.02TDMA1630600083 (DS)161161.60.02TDMA16200600083 (DS)161161.60.02 Tables 5.3 and 5.4 show that the interference to 3G systems from ITFS/MDS main and response stations is slightly worse than the interference 3G systems impact on ITFS/MDS. Table 5.3 indicates that an ITFS/MDS main transmitter would need to be 57 kilometers away from a UWC136 (TDMA) base station to avoid interference if the guard band is 2megahertz. Since, as explained above, eachmegahertz decreases this distance by a factor of 100, an additional 2megahertz will reduce the distance to 0.01 kilometers. Therefore, we conclude that a guard band of up to a 4megahertz is needed to ensure interference free operation. Table 5.3: Calculation of Separation Distances, ITFS/MDS to 3G Base Station Guard Band Analysis Based on Interference Power in Adjacent or Nearby Channels ITFS/MDS System Parameters3G System ParametersRequired Separation (km) Type of Transmitter Bandwidth (kHz) EIRP (dBW) Modulation Type Bandwidth (kHz) Noise in Receive Bandwidth (dBW) Adjacent Channels (No Guard Band) Guard Band Width (MHz) 0.5 1 2Main600039CDMA12501381611611614.7600039CDMA37501331611611612.7600039WCDMA50001321611611612.4600039TDMA3015416116116157.1600039TDMA20014616116116120.3Response Station12522CDMA12501381611611612.312522CDMA37501331611611612.112522WCDMA50001321611611612.112522TDMA301541611611614.012522TDMA2001461611611613.5 Table 5.4: Calculation of Separation Distances, ITFS/MDS to 3G Base Station Guard Band Analysis Based on CoChannel Interference Power (Spillover) ITFS/MDS System Parameters3G System ParametersRequired Separation (km) Type of Transmitter Bandwidth (kHz) EIRP (dBW) Modulation Type Bandwidth (kHz) Noise in Receive Bandwidth (dBW) Adjacent Channels (No Guard Band) Guard Band Width (MHz) 0.5 1 2Main600039CDMA125013816115375.60.1600039CDMA375013316110151.50.1600039WCDMA50001321614220.90.05600039TDMA301541611611610.4600039TDMA2001461611611610.3Response Station12522CDMA12501381616130.60.0612522CDMA37501331613717.70.0312522WCDMA500013290104.80.0212522TDMA30154161161119.10.2412522TDMA2001461611666.00.13 From the Tables, the relationship between distance separation and guard band size is apparent. When planning a system, these two parameters can be adjusted to provide the necessary level interference protection. However, as a practical matter, in Section 4, we showed that the 25002690MHz spectrum is so heavily encumbered and the distance separations necessary for sharing are so large, that the only alternative for deploying 3G systems in this band is to clear spectrum and provide an adequate guard band between 3G and ITFS/MDS segments. In this case, we believe that to accommodate each of the ITU IMT2000 air interface standards, a guard band of up to 4megahertz may be needed to protect 3G and ITFS/MDS systems from interfering with each other. However, a more modest 2megahertz guard band could be sufficient to protect most 3G systems. In its comments to the Advanced Wireless Systems NPRM, Verizon asserts that unacceptable interference would occur regardless of the size of the guard band. Their analysis is based on the Commissions emission limits for ITFS/MDS transmitters and assumes maximum outofband emissions. Further, Cisco Systems (Cisco), states that its preliminary analysis indicated that its existing equipment could theoretically operate with 18megahertz guard bands separating fixed broadband and 3G services. Cisco notes that the design of its current equipment is based on tradeoffs it made under the assumption that no mobile services would be permitted in the 25002690MHz band. They acknowledge that a narrower guard band could be accommodated through reengineering of its equipments channel filtering capabilities and implementing new duplexers. Worldcom, in its comments also claims that a guard band of 1218megahertz may be needed to protect against interservice interference from neighboring allocations. Upon reviewing Verizons analysis, we believe that their claim of unacceptable interference regardless of guard band size is greatly exaggerated. They assume that outofband emissions adhere exactly to the ITFS/MDS emission mask and continue at 60 dB below the average 6megahertz channel power level beyond 3megahertz from the channel edge. However, this analysis does not take into account the behavior of the transmitted energy under real world conditions where the energy will continue to attenuate below the 60 dB level at distances greater than 3megahertz beyond the band edge. While we acknowledge that with existing equipment, a guard band may be necessary, we believe that this situation could be necessary only for the shortterm. Even Cisco admits that a smaller guard band than the 18megahertz is achievable, but that it would require some equipment redesign. We realize that such an endeavor could take as much as a year or more to complete. However, because mobile systems do not currently operate in the 25002690MHz band, and this band is not compatible with existing mobile allocations, such as the PCS band at 18501990MHz, mobile radio equipment manufacturers would also have to undertake a design effort. It is reasonable to assume that if a decision to put 3G systems in the 25002690MHz band is made, it would take several years until the first system is actually deployed. This should provide ample time for ITFS/MDS equipment manufacturers to complete necessary design changes and for service providers to begin replacing equipment. Accordingly, we believe that our conclusion that only a 4megahertz guard band is necessary to prevent interservice interference at the allocation edges between 3G and ITFS/MDS systems is reasonable for planning and analysis purposes. Moreover, we believe that equipment manufacturers can adapt to designing equipment around such a guard band in timeframes sufficient to deploy equipment, if a portion of the 25002690MHz band is made available for 3G systems. Effect of Guard Bands on Band Segmentation Options In devising our segmentation options, one of our guiding assumptions was that 90megahertz of spectrum in the 25002690MHz band would have to be made available for 3G services. Therefore, the remaining 100megahertz in this band would support incumbent ITFS/MDS systems, geographic MDS systems, and the guard bands. Below, we examine, based on our analysis concluding that 4megahertz guard bands are sufficient, the effect that the guard bands would have on the amount of spectrum available under each option. Under option 1, the spectrum available for twoway ITFS/MDS systems would be reduced by 12megahertz of spectrum to accommodate three guard bands of 4megahertz each. Additionally, we showed that, on average, 30megahertz of spectrum (five 6megahertz channels) may need to be set aside for incumbent operators. Depending on how many incumbent oneway systems need to be accommodated, as little as 58megahertz or as much as 88megahertz of spectrum would be available for twoway ITFS/MDS systems. Under option 2 (one guard band), the amount of spectrum available for twoway ITFS/MDS systems would range from 66megahertz to 96megahertz; and under option 3 (two guard bands), from 62megahertz to 92megahertz. The segmentation options will also effect the way service providers manage their spectrum and assign channels for specific purposes. Twoway ITFS/MDS systems need approximately 30megahertz of separation between upstream and downstream traffic to accommodate the duplexer. Under option 1, 3G systems would use the spectrum separating the ITFS/MDS spectrum and thus provide ITFS/MDS systems with the needed separation between upstream and downstream traffic. This would allow the ITFS/MDS system to operate, at some times, with almost all of the available 88megahertz of spectrum. Options 2 and 3, however, do not allow use of the entire available spectrum using a 30megahertz separation; either some portion of the spectrum would go unused or would need to employ an alternative technology such as TDD. Impact of Band Segmentation on Data Rates In each segmentation option, the amount of spectrum available for twoway ITFS/MDS systems is sharply reduced from the approximately 156megahertz that these systems have under the current allocation and channel plan. This reduction in spectrum will effect twoway service by either reducing data speeds, which may in turn limit the type of service that these systems can provide or forcing MDS providers to reduce the coverage area of each cell to keep data rates at their current level. The latter situation is discussed in the section below. The HMI study lists data rates for MDS service up to 512kbps downstream and up to 256kbps upstream for residential service. Clearly, if the amount of spectrum is reduced, these data rates would have to be scaled back. To understand how such a reduction in data speeds would affect the marketability of twoway wireless broadband service a comparison must be made with the services with which it will compete: digital subscriber line (DSL) and cable modems. As an example, in Los Angeles County, California, Pacific Bell offers standard residential and business DSL service with speeds of between 384kbps and 1.5Mbps downstream and 128kbps upstream. GTE offers DSL packages ranging from 256kbps to 1.5Mbps downstream and from 64kbps to 768kbps upstream; with its Bronze Plus service (768kbps downstream and 128kbps upstream) being the most popular. Cable modem service in Los Angeles is offered by a number of providers. As an example, Media One/AT&T offers service with up to 1.5Mbps downstream and up to 300kbps upstream. Time Warner also offers cable modem access with speeds ranging from 2Mbps to 10Mbps downstream to up to 384kbps upstream. While we are unable to ascertain the exact decrease in data rates that a reduction in spectrum would have, we can make certain observations regarding its effect on the marketability of twoway service. It is evident that under current or projected service offerings twoway wireless broadband service offers downstream data rates in the low to mid range of DSL and at the low end of cable modem service. Upstream data rates compare very favorably with the best rates offered for DSL and slightly below those of cable modems. Based on these observations, it is likely that any decrease in twoway service data rates could reduce or eliminate that services ability to compete in the marketplace. Impact of Band Segmentation on Cell Size As described above, the net effect of segmentation would be to reduce the amount of spectrum available for ITFS and MDS operations. The section above describes the effect such a reduction would have on data rates. In this section we explore the effect that reduced spectrum would have on cell size if providers, under segmentation, opted to keep data rates at current levels. Figure5.5 below indicates the amount of spectrum needed per cell site to serve customers within a specified distance from that site. As illustrated by the figure, if the total amount of spectrum available for twoway ITFS/MDS systems is reduced, the cell size of the ITFS/MDS system must be reduced to continue providing the same service. Thus, the licensee can continue operating the site with reduced grade of service to its customers, continue operating the site with the same grade of service but serving fewer customers (most likely rural and underserved areas), or construct and maintain new transmit sites to continue serving all its current customers with the same grade of service. For example, the figure shows that a single main transmitter operating with its full complement of spectrum (approximately 160megahertz) can serve a cell with a 32mile radius. Figure5.5: Cell Size As A Function of Available Spectrum  Based on Figure 5.5 and the amount of spectrum we determined would be available for geographic MDS licensees under each segmentation option, we present the effect each segmentation option would have on cell size in the Tables below. Our calculations are based on an existing MDS system using 160megahertz (including the 1012megahertz allocated in the 21502160/62MHz band) of spectrum over a cell with a 32 mile radius. Table 5.5: Effect of Segmentation Options on Cell Size for Minimum Available Spectrum OptionMinimum Spectrum Available in the 25002690MHz Band (MHz)Minimum Total Spectrum Available (MHz)*% of Total Spectrum Available for UseCell Size (mi.)#Cell Area (sq. mi.)% of Original Area158 = b2+12 \* MERGEFORMAT 70 =(c2/160)*100 \# "0.0" \* MERGEFORMAT 43.821.0 =e2^2*3.14159 \# "0" 1385 =(f2/3217)*100 \# "0.0" \* MERGEFORMAT 43.1266 = b3+12 \* MERGEFORMAT 78 =(c3/160)*100 \# "0.0" \* MERGEFORMAT 48.822.3 =e3^2*3.14159 \# "0" 1562 =(f3/3217)*100 \# "0.0" \* MERGEFORMAT 48.6362 = b4+12 \* MERGEFORMAT 74 =(c4/160)*100 \# "0.0" \* MERGEFORMAT 46.321.7 =e4^2*3.14159 \# "0" 1479 =(f4/3217)*100 \# "0.0" \* MERGEFORMAT 46.0* Includes 12megahertz from the 21502162MHz band. # Assumes linear interpolation between curves in Figure 5.5. Table 5.6: Effect of Segmentation Options on Cell Size for Maximum Available Spectrum OptionMaximum Spectrum Available in the 25002690MHz Band (MHz)Minimum Total Spectrum Available (MHz)*% of Total Spectrum Available for UseCell Size (mi.)#Cell Area (sq. mi.)% of Original Area188 = b2+12 \* MERGEFORMAT 100 =(c2/160)*100 \# "0.0" \* MERGEFORMAT 62.525.0 =e2^2*3.14159 \# "0" 1963 =(f2/3217)*100 \# "0.0" \* MERGEFORMAT 61.0296 = b3+12 \* MERGEFORMAT 108 =(c3/160)*100 \# "0.0" \* MERGEFORMAT 67.525.7 =e3^2*3.14159 \# "0" 2075 =(f3/3217)*100 \# "0.0" \* MERGEFORMAT 64.5392 = b4+12 \* MERGEFORMAT 104 =(c4/160)*100 \# "0.0" \* MERGEFORMAT 65.025.3 =e4^2*3.14159 \# "0" 2011 =(f4/3217)*100 \# "0.0" \* MERGEFORMAT 62.5* Includes 12megahertz from the 21502162MHz band. # Assumes linear interpolation between curves in Figure 5.5. The data contained in the tables show that to maintain the same gradeofservice under each segmentation, the area served by any one transmitting site is significantly reduced. Even in the best case, cell size is reduced by almost forty percent. Under these conditions, we expect that a licensee could require 35 transmitter sites to cover the same geographic area as the single main transmitter. Thus, the MDS operator either must incur the cost of building additional sites to continue serving its current customer base or cease providing service to customers in outlying areas. The economic impact of these choices are examined in Section 7. MIGRATION SCHEDULE A number of factors would influence the amount of time needed to implement any of the segmentation options studied. First, as discussed above, some incumbent oneway systems would need time to convert from analog to digital modulation. The use of more spectrally efficient technology for these types of systems would provide maximum spectrum for introducing twoway ITFS/MDS systems in the band. Second, implementation of any of the segmentation options would require manufacturers to reengineer planned twoway systems for operation using reduced spectrum in the band. Manufacturers and ITFS/MDS operators would have to reconfigure network design and deploy new equipment. Cisco estimates that it would need a year or more to complete and test fully new equipment for use in band if segmentation were implemented. Cisco states that it would need to revisit the entire design and manufacture cycle; redesign both hardware and software; revisit component supply chains and partner agreements; duplicate lab and field trials; and reinitialize manufacturing plants. The introduction of guardbands also would require equipment modifications. Cisco states that it would have to reengineer channel filtering technology to achieve more robust adjacent channel rejection, design new duplexers to accommodate different transmit and receive capabilities, and assume new reuse and deployment patterns. Given the complex interference environment already present in the 25002690MHz band, accommodating additional ITFS/MDS operations in only certain portions of the band will take considerable time and effort if such an approach is undertaken. Both sitespecific oneway and twoway systems and widearea twoway systems will have to be coordinated. Furthermore, in any geographic area, adjacent channel use by widearea 3G systems also will need to be coordinated. Because of the localized nature of sharing and leasing agreements between geographic MDS licensees and incumbent ITFS and MDS licensees, migration schedules will likely be different for each area. Also, because all channels in the 25002690MHz band are licensed in or near the top 50 metropolitan areas, the relocation of any specific station will need to be closely coordinated with all other nearby stations. And migration may not be able to occur until the equipment needed for twoway systems is redesigned, tested, and available to licensees. Although it may be possible for some incumbent ITFS and MDS systems to relocate within band by 2003, largescale band reorganization may be necessary before all incumbent systems, twoway systems, and 3G systems could operate under band segmentation. Thus, accommodation of all systems would not likely occur until 2010 or beyond. SUMMARY Based on our analysis of various segmentation options for the 25002690MHz band, we find that the conclusions made in the Interim Report remain valid. Any segmentation option would need to take into account the flexible service configurations and offerings that ITFS and MDS licensees are now implementing. Further, the number of guard bands affects the impact that band segmentation has on spectrum available for ITFS/MDS operations. While Option 2, with only one guard band, provides the most spectrum for ITFS/MDS operations, it may require more equipment redesign than Option 1 where 3G systems and ITFS/MDS systems are interspersed. Additionally, under any of the options a substantial number of licensees would need to be accommodated. Also, if segmentation is pursued, ITFS/MDS service providers may need to reduce their service areas and services to customers in outlying areas or add more transmitter sites to maintain services. Finally, because of the complex licensing scheme present in this band (e.g., the mix of sitespecific and widearea licensing, channel swaps, and lease agreements), we cannot describe uniform impacts for each of the segmentation options studied. To fully understand the implications of any segmentation plan on the ITFS/MDS, one would need to analyze each geographic area individually. SECTION 6 IDENTIFICATION AND ANALYSIS OF POTENTIAL ALTERNATE FREQUENCY BANDS FOR ITFS/MDS The Study Plan calls for the identification of alternate frequency bands for incumbent users of the candidate bands being studied for possible 3G system use. The Study Plan sets forth certain criteria for identifying alternate frequency bands: (1) consideration should first be given to those bands in which no, or minimum, disruption would occur to the incumbents of the identified alternate bands; and (2) potential alternate bands should afford candidate band incumbent systems that may require replacement spectrum the capability to function without loss of functionality or necessary interoperability in the alternate band(s). The Study Plan also states that any study of alternate bands will describe the alternate band(s) as to: (1) existing rules and regulations that govern the use of the bands; (2) the changes in allocation rules and regulations that would be necessary to make them acceptable to the candidate band incumbent users; (3) the relocation of alternate band incumbents if necessary; (4)the operational constraints on the alternate band incumbents or on the candidate band systems; and (5) any other considerations, including national security and public safety, in the use of the alternate bands that would have a negative effect on candidate band incumbent users. This section identifies and analyzes potential alternate frequency bands that could be used by ITFS/MDS systems if spectrum in the 25002690MHz band were reallocated for use by 3G systems. The analysis states the assumptions made, identifies potential alternate frequency bands, and analyzes the bands in accordance with the Study Plan criteria listed above. ASSUMPTIONS For purposes of this study, we have made certain assumptions in identifying potential alternate frequency bands for ITFS/MDS systems. These assumptions are as follows: Relocation of ITFS and MDS systems would likely be based on policies similar to those established in the Emerging Technologies proceeding), which allow new entrants to provide incumbents with comparable facilities using any acceptable technology, and some services could be relocated from spectrumbased networks to wirelinebased networks. For purposes of this study, we assume that all ITFS/MDS operations would continue as spectrumbased networks. ITFS/MDS is in a state of rapid evolution to offer highspeed, twoway access to the Internet. We assume that any relocation would minimize any loss of functionality to ITFS and MDS licensees of analog and digital oneway and twoway services, which are provided on a widearea, ubiquitous basis in both urban and rural areas, and would allow for future deployment of twoway systems. ITFS and MDS operations would not be relocated to separate frequency bands. The two services currently have extensive and complex channel leasing arrangements that provide benefits for education, businesses and consumers. Separation of these operations would have extensive policy ramifications beyond the scope of this study. It is not clear that either service would be viable if they were separated into different frequency bands, even if this were technically possible. Alternate frequency bands would need to provide at a minimum 90megahertz of contiguous spectrum for ITFS/MDS to replace the 90megahertz of spectrum in the 25002690MHz band that would be made available for 3G use under the segmentation analysis of this study. Alternate frequency bands may need to provide for the relocation of the entire 202megahertz of spectrum currently occupied by ITFS/MDS to assure the continued functionality of ITFS and MDS that is one of the criteria for the Study Plan. The actual amount of spectrum needed to relocate ITFS/MDS could be affected by other factors that were not taken into account here. For example, it may be necessary to provide a greater amount of spectrum at higher frequencies to offset the impact of increased propagation losses. When considering relocation bands, first preference is for the ITFS/MDS operation (incumbents A) to be compatible with existing operations in the alternate bands and not displace any existing operations in the alternate bands. However, if the incumbents in the alternate band (incumbents B) have to be relocated to another band, incumbents B cannot displace any other existing operations in which they are relocated. We assume that more than one relocation move is too disruptive to existing operations and therefore we have not explored such possibilities in this study. Based on these assumptions, we identified the frequency bands listed in Table 6.1 for further analysis as potential alternate frequency bands for ITFS/MDS. These are bands that are already allocated for Fixed Services and that could satisfy the amount of spectrum assumed for our analysis. Table 6.1: Bands for Further Assessment Frequency Band Size Allocation Radio Services (MHz) 37004200MHz 500 NG Fixed, FixedSatellite (spaceEarth) 59256425MHz 500 NG Fixed, FixedSatellite (Earthspace) 64257125MHz 64256525 100 NG FixedSatellite (Earthspace), Mobile 65256875 350 NG Fixed, FixedSatellite (Earthspace) 68757075 200 NG Fixed, FixedSatellite (Earthspace), Mobile 70757125 50 NG Fixed, Mobile 71258500MHz Federal Government Fixed Band 10.713.25GHz 10.711.7 1000 NG Fixed, FixedSatellite (spaceEarth) 11.712.2 500 NG FixedSatellite (spaceEarth) 12.212.7 500 NG Fixed, BroadcastingSatellite 12.713.25 550 NG Fixed, FixedSatellite (Earthspace), Mobile G = Federal Government NG = NonFederal Government ASSESSMENT OF THE BANDS 37004200MHz and 59256425MHz Allocation Description The bands 37004200MHz and 59256425MHz (500megahertz each) are allocated on a primary basis to the nonFederal Government for the fixed service (FS) and fixedsatellite service (FSS). An excerpt from the Table of Frequency Allocations for this portion of the spectrum is provided below in Table 6.2. The applicable service definitions and associated footnotes for this portion of the Table are provided in Appendix 6.2 and 6.3 respectively. These bands are paired for fixedsatellite purposes, and collectively are known as the Cband. For FSS, the band 37004200MHz supports spacetoEarth (downlink) operations and the band 59256425MHz supports Earthtospace (uplink) operations. These bands may also be used by stations in the international fixed public and international control services for operations located in the U.S. Possessions in the Caribbean area. Table 6.2: Table of Frequency Allocations for 37004200/59256425MHz (See Appendix 6.3 for footnote text.) Federal Government NonFederal Government FCC Rule Part(s)37004200 37004200 FIXED NG41 FIXEDSATELLITE (spacetoEarth) International Fixed (23) Satellite Communications (25) Fixed Microwave (101) 59256425MHz Federal Government NonFederal Government FCC Rule Part(s)59256425 59256425 FIXED NG41 FIXEDSATELLITE (Earthtospace) International Fixed (23) Satellite Communications (25) Fixed Microwave (101) Description of Current and Planned Band Use (37004200/59256425MHz) The bands 37004200 and 59256425MHz are heavily used by both the fixedsatellite service (FSS) and the terrestrial fixed service (FS). The FCC rules and regulations for fixedsatellite and fixed services are contained in 47 C.F.R. Parts 23, 25, and 101. Cband fixedsatellite systems provide private and commercial communication links for various businesses and industries, feeds to terrestrial television and radio broadcast networks and to cable headends, programming directly to customers with home satellite receivers and tracking, telemetry, and control (TT&C) operations for U.S. and nonU.S. satellites. Cband satellites are being used to provide twoway, broadband data backbone and services via satellite.). Currently, there are 35 U.S. licensed geostationary (GSO) satellites providing international and/or domestic service to the United States in the Cband. More than 15 additional satellites are planned to operate in conjunction with the existing satellites and eventually replace the currently operating satellites once they reach their end of life. The satellites are generally spaced at orbital separations of two degrees around the GSO. A typical Cband transponder uses 36megahertz bandwidths. Transponder loading depends on the type of service offered over the transponder (i.e., few video channels versus hundreds of low data rate channels can be offered over one transponder). There are approximately 13,500 registered earth station antennas within the United States and its possessions that operate through the Cband fixedsatellites. Further, we estimate that there are tens of thousands of unregistered receiveonly earth stations in the Cband used by the general public for directtohome (DTH) video programming reception. Registered earth stations cover the entire country but are concentrated more heavily in urban areas. (See map in Appendix 6.4) There is no information on the geographical distribution of the unregistered earth stations, but historically they have been used in all areas of the country. In particular, they are used in rural areas where conventional broadcasting was not available and the potential to receive interference from other licensed users is relatively lower than in urban areas. The Commission has proposed to streamline its earth station application filing requirements to facilitate blanket authorization of satellite data terminals in the CBand (with appropriate coordination and reporting requirements). The 37004200 and 59256425MHz bands also support a number of fixed pointtopoint operations. These bands provide backbone and longhaul operations for commoncarrier and private business, industry, utilities and public safety communications networks. There are currently over 11,000 pointtopoint links in the 37004200MHz band, and over 38,500 pointtopoint links in the 59256425MHz band. For the 37004200MHz, the average path length is 43km (26.7miles) and, for the 59256425MHz, the average path length is 39km (24.2miles). The current fixed, pointtopoint channeling plan for the band 37004200MHz provides for paired 20megahertz channels with 40megahertz separation between the transmit and receive channels. However, there are a number of grandfathered systems in this band with different channel bandwidths and separations. The current fixed pointtopoint channeling plan for the band 59256425MHz provides for a varied bandwidths from 0.4 to 30megahertz channels with 250megahertz separation between the transmit and receive channels. Both the channel loading and the geographical distributions of the pointtopoint facilities in these bands are fairly uniform across the band and across the country, respectively. See the maps in Appendix 6.4. Recently, the fixed service community has expressed concern that the proliferation of satellite earth stations in the CBand is freezing any future growth of fixed operations in this range. The problem is worse in the 37004200MHz portion due to the protection of video distribution operations to cable head ends and television stations. The 59256425MHz portion is also impacted and the problem of coordinating with new fixed operations. Finally, we note that while there are no Federal Government services allocated in these bands, the band 59256425MHz is used by Federal Government agencies (e.g., USIA, FAA, and Navy) for FSS operations. These operations are on a case by case, coordinated basis to operate earth stations that transmit voice, data, video signals through the nonFederal Government GSO satellite systems. Additionally, there are several Federal Government operations in both bands that operate on a noninterference basis. Specifically, NASA operates downlink telemetry, on a noninterference basis, during launch and emergencies in support of the NASA Advanced Communications Technology Satellite Space Program. Further, various Federal Government agencies also operate test stations of radiolocation systems on a noninterference basis. Assessment for ITFS/MDS Operations (37004200/59256425MHz) These bands are closest to the current ITFS/MDS bands among those considered for relocation. These bands appear to hold the least technical impact for the viability of ITFS/MDS operations. Signal propagation losses would increase somewhat, but the effect would not be as significant as higher bands. The cost and availability of electronic components and antennas may also increase somewhat, but would benefit from the extensive development that has already occurred for this band. With regard to the sharing between ITFS/MDS and the FSS downlink band 37004200MHz, satellite earth stations would be susceptible to receiving harmful interference from ITFS/MDS transmitters, and highly susceptible to receiving interference from subscriber based ITFS/MDS transmitters deployed for twoway service. Interference could occur if an ITFS/MDS transmitter were located within approximately 200km (124miles) of a receiving satellite earth station. With regard to the sharing in the FSS uplink band 59256425MHz, because ITFS/MDS are ubiquitous widearea systems with broadbeam and omnidirectional antennas and deployed ubiquitously, the ITFS/MDS system would be highly susceptible to receiving harmful interference from thousands of earth stations currently operating in this frequency band. Sharing between these services on a geographic basis does not appear feasible because they are both effectively ubiquitous. See the map in Appendix 6.4. Segmenting either of these frequency bands to accommodate ITFS/MDS does not appear feasible. Satellites are designed to make use of the entire 500megahertz of spectrum in both the downlink and uplink bands. Any reduction in spectrum would have a severe impact on existing satellite operations. There are no frequency bands where Cband satellite operations might be reaccommodated. Neither sharing nor segmentation appears feasible relative to existing fixed operations. This problem is exacerbated by the fact that this spectrum was identified for relocation of existing fixed operations in the 2GHz region to accommodate personal communications services and other emerging technologies as laid out in ET Docket 929. (See the maps in Appendix 6.5.). Higher frequency bands that are available for fixed operations are also becoming increasingly congested. Summary (37004200/59256425MHz) Our analyses indicate that ITFS/MDS operations could not share with the existing operations in the bands 37004200MHz and 59256425MHz. As demonstrated above, both the FSS and FS heavily use these bands. The widearea, ubiquitous coverage characteristics of ITFS and MDS are not compatible with either fixed pointtopoint or fixedsatellite operations in any geographic area. Segmenting either band to accommodate ITFS/MDS operations also does not appear viable because this could not be accomplished without significant harm to current and future uses of the FSS and FS. Therefore, reallocation of spectrum to accommodate ITFS/MDS does not appear feasible for either the 37004200MHz or the 59256425MHz band. ASSESSMENT OF BAND 6425 7125MHz Allocation Description The 64257125MHz band is allocated on an exclusive basis to the nonFederal Government and consists of four bands. An excerpt from the Table of Frequency Allocations for this portion of the spectrum is provided below in Table 6.3. The applicable service definitions and associated footnotes for this portion of the Table are provided in Appendices 6.2 and 6.3, respectively. The band 64256525MHz (100megahertz) is allocated on a primary basis to the fixedsatellite and mobile services. The band 65256875MHz (350megahertz) is allocated on a primary basis to the fixed and fixedsatellite services. The band 68757075MHz (200megahertz) is allocated on a primary basis to the fixed, fixedsatellite, and mobile services. The band 70757125MHz (50megahertz) is allocated on a primary basis to the fixed and mobile services. In the band 68757125MHz, television translator relay station licensees may be authorized to use frequencies on a secondary basis to other stations in the television broadcast auxiliary service. Table 6.3: Table of Frequency Allocations for 64257125MHz (See Appendix 6.3 for footnote text.) Federal Government NonFederal Government FCC Rule Part(s)64256525 S5.440 S5.45864256525 FIXEDSATELLITE (Earthtospace) MOBILE S5.440 S5.458Auxiliary Broadcasting (74) Cable TV Relay (78) Fixed Microwave (101)65256875 S5.45865256875 FIXED FIXEDSATELLITE (Earthtospace) 792A S5.458Satellite Communications (25) Fixed Microwave (101) 6875712568757075 FIXED FIXEDSATELLITE (Earthtospace) 792A MOBILE S5.458 NG118Auxiliary Broadcasting (74) Cable TV Relay (78) S5.45870757125 FIXED MOBILE S5.458 NG118 Description of Current and Planned Band Use (6425 7125MHz) The 64257125MHz spectrum is used by the fixedsatellite, fixed, broadcast auxiliary, and mobile services. We will evaluate each of these bands below to determine the viability of ITFS/MDS operations in this range. For the purposes of analysis of assignments, we have divided the band into three separate portions: 64256525, 65256875, and 68757125MHz. (See Table 6.4:Band Usage 64257125MHz.) Each is discussed below. 64256525MHz portion. As indicated above, the band 64256525MHz (100megahertz) is allocated to FSS and mobile services. In addition to providing uplinks for the FSS, licensed under Part 25 of the Commissions Rules, this band is used primarily for television related services. Currently, it supports remote pickup in the broadcast auxiliary service (BAS), licensed under Part 74 of the Commissions Rules. BAS offers service to television broadcast stations, television network entities, cable system operators, and cable network entities via common carrier providers in the local television transmission services (LTTS) licensed under Part 101 of the Commissions Rules. The band also accommodates mobile operations in the cable antenna relay services (CARS), licensed under Part 78 of the Commissions Rules. There are currently 304 broadcast auxiliary links, 33 cable relay links, and 501 temporary fixed links for local television transmissions in the 64256525MHz band. This band also contains 16 fixed pointtopoint microwave links. The Earthtospace (uplinks) configuration supports 522 links associated with licensed earth stations and an unknown number of unregistered receive only earth stations. The Commissions Rules allow BAS and LTTS bandwidths of 1, 8, or 25megahertz, while CARS may employ bandwidths of 25megahertz. The fixed rules provide for operations of 1, 8, or 25megahertz bandwidths with 50megahertz separation between transmit and receive channels. Both the channel loading and the geographical distributions of licensed links in this band are shown in maps in Appendix 6.4. 65256875MHz portion. As mentioned above, the band 65256875MHz (350megahertz) is allocated to the FSS and FS, licensed respectively under Parts 25 and 101 of the Commissions Rules. The band 65256875MHz supports generalpurpose fixed microwave FS operations for a variety of public and private entities, such as, nonFederal Government, industrial, common carrier, and transportation licensees. For the FS, the average path link is 32km (19.9miles). The channeling plan provides for varied bandwidths from 0.4 to 10megahertz channels with 250megahertz separation between transmit and receive channels. In addition to the FS operations, the band 65256875MHz (extending through to 7075MHz) also provides feeder uplinks (Earthtospace) including tracking, telemetry, and control of satellites, for "Big LEO" and digital audio radio services (DARS) satellites. The band 65256875MHz currently supports 4 U.S. licensed geostationary (GSO) satellites and 6 feeder links associated with U.S. licensed nongeostationary (NGSO) satellites. Moreover, the band supports fixed microwave operations with over 25,000 pointtopoint links. Both the channel loading and the geographical distributions of the pointtopoint facilities in this band are fairly uniform across the band and across the country, respectively. See the map in Appendix 6.4. Additionally, the band 65256875MHz was identified in 1993 in the Emerging Technologies proceeding as a future home for fixed pointtopoint operations to be relocated from the 2GHz band. (See the maps in Appendix 6.5.) The band 67007075MHz also is the subject of a proposal to add feeder downlinks for NSGO satellites in support of mobile satellite service (MSS) satellites (Big LEOs). The frequency 6427MHz (along with 4202MHz) is available, but unused, for twoway satellite time signal communications. 68757125MHz portion. The band 68757125MHz (250megahertz) is allocated to the fixed and mobile services, and 200megahertz of this band, i.e., 68757075MHz, is shared on a coprimary basis with the fixedsatellite service. At present the band 68757075MHz supports approximately 120 uplinks for the FSS. The 68757125MHz provides for television related services similar to the mobile band 64256525MHz discussed above, but on both a fixed and mobile basis. For the 68757125MHz band, there are currently approximately 6,000 fixed links and 1,700 mobile operations licensed for the BAS. This band also supports about 10 fixed and 9mobile links for CARS, and approximately 27 temporary fixed and 250 mobile links for LTTS. The bandwidths for oneway, fixed BAS operations are 16, 17, or 25megahertz channels. The average path length is 42km (26.1miles). The bandwidth for BAS mobile operations is 25megahertz. The CARS use bandwidths of 12.5 or 25megahertz for fixed and 25megahertz for mobile operations, and the average path length for fixed links is 40km (24.9miles). The LTTS uses bandwidths of 16, 17, or 25megahertz for both fixed and mobile operations. The channel loading and the geographical distributions of licensed links in this band are shown in maps in Appendix 6.4. Table 6.4: Band Usage 64257125MHz FSS (uplink) FSS (uplink) Proposed FSS (NGSO MSS downlinks) MOBILE BAS, CARS, LTTS FIXED PointtoPoint Microwave  FIXED/MOBILE PointtoPoint Microwave BAS, CARS, LTTS Secondary TV Translators Federal Agency Testing NASA passive microwave sensor measurements over oceans Radio astronomy spectral line observations (6668.518MHz)  | | | | | | 6425 6525 6700 6875 7075 7125 Assessment for ITFS/MDS Operations (6425 7125MHz) The technical characteristics of this band would be somewhat more challenging for ITFS/MDS, but would not be insurmountable. However, because ITFS and MDS use is ubiquitous in nature, these services will not be able to share with the current users of the band. The mobile and fixed operations of BAS, CARS, and LTTS would pose particular problems to the bands 64256525 and 68757125MHz, as well as the extensive deployment of fixed pointtopoint operations in the band 65256875MHz. Therefore, to provide for ITFS/MDS, 202megahertz of spectrum will have to be cleared by relocating or segmenting all of the incumbent users in that spectrum. 64256525MHz (100megahertz) Reaccommodating ITFS/MDS in the 64256525MHz band is impractical due to the international nature of fixedsatellites and operational characteristics of mobile services. As discussed in Section 4 above, sharing between ITFS/MDS and mobile operations in the same geographic area is not feasible. ITFS/MDS are ubiquitous widearea systems with broadbeam and omnidirectional antennas. As mentioned above, there are over 800 licensed stations with an unknown number of mobile units that could operate anywhere. Because the incumbent mobile services could be dispersed throughout the country and ITFS/MDS cannot coordinate with these incumbent operations to avoid interference, sharing between ITFS/MDS and mobile service is not feasible. Additionally, sharing between ITFS/MDS and FSS is also impractical. Because the band 64256525MHz supports over 500 uplink facilities for the FSS, ITFS/MDS stations would receive interference from these earth stations if located within approximately 200km (124miles) of each other. Again, due to the widearea deployment of ITFS/MDS throughout the country sharing with FSS does not appear to be feasible. With regard to segmentation of the band, we note that this band would only provide 100megahertz of the 202megahertz that may be needed to accommodate the ITFS/MDS service. Therefore, we conclude that if ITFS/MDS were to be relocated into the band 64256525MHz, the incumbent FSS and mobile operations would have to be relocated to other bands and an additional 102megahertz of nearby spectrum would need to be found. 65256875MHz (350megahertz) Relocating ITFS/MDS into the band 65256875MHz would be extremely difficult due to the very extensive use of this band by fixed pointtopoint microwave services (over 25,000 licensed links). As shown in the other band assessments, sharing between ITFS/MDS and the fixed service is not practical in most situations. While it may be possible for cochannel sharing in remote areas, most fixed, pointtopoint microwave operations in this band are located in areas where ITFS/MDS operations will operate. Additionally, this band also is allocated to the FSS. Although this band currently is lightly used for FSS (6 feeder links), half the band (175megahertz) is the subject of current examination to permit feeder downlinks for MSS NSGO satellites (Big LEOs). Again we note that sharing between ITFS/MDS and FSS incumbents is impractical due to technical characteristics of ITFS/MDS operations, which provide ubiquitous widearea systems using broadbeam and omnidirectional antennas. Therefore, sharing is not possible and if ITFS/MDS were to be accommodated in this band, the incumbent services would have to be relocated into the remaining spectrum or to higher frequency bands. Segmentation of the band 65256875MHz for ITFS/MDS would also be difficult due to the paired nature of satellite operations in the band and the congestion that already exists in this band. 68757125MHz (250megahertz) Accommodation of ITFS/MDS into this band would create severe disruption to the incumbent services. As noted above, the 68757125MHz band is heavily used by fixed and mobile services, and by the fixedsatellite service particularly for feeder links. The band 68757125MHz is used extensively for both fixed (over 6,000 links) and mobile operations (almost 2,000 licenses) to support television and cable stations. As shown previously, sharing between ITFS/MDS and fixed and mobile operations are not feasible in the same geographic area. Additionally, a portion of this band 68757075MHz (200megahertz) is shared with the FSS. Again we note that this band is the subject of a proceeding to permit feeder downlinks for MSS NSGO satellites (Big LEOs), and that sharing between ITFS/MDS and FSS impractical. Segmentation of the band also is not feasible due to the heavy use by fixed and mobile operations that would have to be accommodated within the remaining 48megahertz of spectrum. Other matters. In addition to the points discussed above, while there are no Federal Government services allocated in this band, there are several Federal Government operations that operate on a noninterference basis. Specifically, NASA operates downlink telemetry, on a noninterference basis, during launch and emergencies in support of the NASA Advanced Communications Technology Satellite Space Program. Further, various Federal Government agencies also operate test stations of radiolocation systems on a noninterference basis. For radio astronomy, the frequency 6668.518MHz is an important tracer of star formation activity. Summary (6425 7125MHz) As discussed above, the propagation characteristics and technical considerations start to affect the design of the incumbent system as frequency increases. While the 67GHz range could technically accommodate ITFS/MDS operations, the impact on coverage and equipment design begins to be more complicated at higher frequency ranges. Moreover, we have determined from the above investigation that ITFS/MDS operations would not be compatible with incumbent FS, FSS, and mobile operations. ITFS and MDS are twoway, pointtomultipoint operations that are designed to provide ubiquitous coverage over a wide area. Such operations would not be capable of sharing with either fixed pointtopoint or fixedsatellite operations in any geographic area. As discussed above, sharing between ITFS/MDS and mobile operations in the same geographic area also is not practical. Because the incumbent mobile services could be dispersed throughout the country and ITFS/MDS cannot coordinate with these incumbent operations to avoid interference, sharing between ITFS/MDS and mobile service is not feasible. Our analysis indicate that both of these bands are extensively used by fixedsatellite, fixed and mobile operations across the United States with concentrations in populated areas where ITFS and MDS deployment is desired and likely. Therefore, sharing between ITFS/MDS and the incumbent services in the 64257125MHz spectrum range is not possible. As indicated above, if ITFS/MDS was to be relocated into the 64257125MHz range, perhaps 202megahertz of spectrum would have to be cleared by segmentation and reaccommodation of the incumbent users to higher frequency bands. However, our investigations indicate that removing any significant amount of spectrum to accommodate ITFS/MDS would have a significant impact to the incumbent fixed and mobile services due to their extremely heavy use. Relocation of the satellite links to other spectrum would also be extremely disruptive, would take several years, and be extremely costly due to the need to construct new satellites and replace earth stations that are extensively deployed. While relocation of terrestrial fixed and mobile operations could be done in shorter time and at lesser costs, identification of alternative spectrum would be extremely difficult as discussed above. Accordingly, relocating ITFS/MDS systems into the 64257125MHz would significantly impact the incumbent fixedsatellite, fixed and mobile operations in this frequency band. ASSESSMENT OF THE BAND 7125 8500MHz The band 71258500MHz is currently restricted exclusively for Federal Government operations and is allocated on a primary basis to the fixed, fixedsatellite and other services. This spectrum is included in this report because it has technical and propagation characteristics that potentially could accommodate ITFS/MDS similar to the bands 59256425 and 64257125MHz described above. However, because these bands are allocated for exclusive Federal Government use and because the Commission only has limited information about their loading, this will be a cursory review of this spectrum. This spectrum is divided into 13 bands and each band is shared with one or more other Federal Government services. The other Federal Government allocations and uses in this spectrum include space research, mobilesatellite, meteorologicalsatellite, and Earth explorationsatellite. Many Federal Government agencies use this spectrum for fixed, pointtopoint microwave links, including longhaul and backbone systems, for their internal communication. The NTIAs March 2000 Report on Spectrum Usage for the fixed services indicates that there are 8226 Federal Government fixed assignments listed in the Governments master frequency (GMF) file in this band. The largest listing of fixed assignments is held by the Federal Aviation Administration (FAA), which has over 4,000 assignments in a nationwide network to support air traffic control with communications and radar data from remote sites. The Department of Defense (DoD) agencies have about 2,000 fixed assignments to support their voice and data networks, and the Department of Energy (DoE) has 1,200 fixed assignments used for system control and data acquisition (SCADA) for electric power distribution networks. With regard to FSS operations in the 71258500MHz spectrum, the DoD uses portions of this spectrum for military satellite communications, such as the Defense Satellite Communications Systems (DSCS) for voice and data communications including NATO communication requirements. The FAA also uses this spectrum for the FSS Radio Communication Link (RCL) network connecting air traffic and radar sites. Other uses include deep space communications, such as the NASAs Mars Pathfinder program in the 71907235MHz (uplink) and 84008450MHz (downlink) bands. The band 74507550MHz is used by the meteorologicalsatellite service to downlink weather data. Further, the band 80258400GHz is allocated for earth explorationsatellite service and is used for land remote sensing to deliver images and some satellite telemetry and control. This description attempts to note some of the major uses of the band 71258500MHz; however, it is neither exhaustive nor complete. Specifically no attempt has been made to investigate incumbent use other than the fixed operations or numbers of assignments within this spectrum. Nevertheless, this cursory review indicates that the number of fixed assignments for this 1375megahertz of spectrum is far less permegahertz than is found in the nonFederal Government fixed bands. While this fact alone is not sufficient to conclude that ITFS/MDS systems could be relocated to this band it may warrant further consideration if ITFS/MDS systems are to be relocated from the 25002690MHz band. ASSESSMENT OF THE BAND 10.7 13.25GHz Allocation Description The spectrum between 10.713.25GHz is allocated exclusively to the nonFederal Government and consists of five bands. An excerpt from the Table of Frequency Allocations for this portion of the spectrum is provided below in Table 6.5. The applicable service definitions and associated footnotes for this portion of the Table are provided in Appendices 6.2 and 6.3, respectively. The 10.711.7GHz (1000megahertz) band is allocated on a coprimary basis to the fixed and fixedsatellite services. This band may also be used by stations in the international fixed public and international control services for operations located in the U.S. Possessions in the Caribbean area. The band 11.712.2GHz (500megahertz) is allocated on a primary basis to the fixedsatellite service and secondarily to mobile services (except for aeronautical mobile). In the band 11.712.2GHz, transponders on space stations in the fixedsatellite service may be used additionally for transmissions in the broadcastingsatellite service, provided that certain limitations are met. The satellite community refers to this spectrum range as the Kuband. The band 12.212.7GHz (500megahertz) is allocated on a primary basis to the fixed and broadcastingsatellite services, but licensing of fixed stations in the United States has been frozen to protect Direct Broadcast Satellite (DBS) operations. The bands 12.712.75GHz (50megahertz) and 12.7513.25GHz (500megahertz) are allocated on a primary basis to the fixed, fixedsatellite, and mobile services. In the band 12.713.25GHz (along with bands 20252110MHz, 68757125MHz), television translator relay stations may be authorized on a secondary basis to other services. Further, the band 12.7513.25GHz is also allocated to the space research service (deep space, spacetoEarth) for reception only at Goldstone, California. Table 6.5: Table of Frequency Allocations for 10.713.25GHz (See Appendix 6.3 for footnote text.) Federal Government NonFederal Government FCC Rule Part(s)10.711.7 US21110.711.7 FIXED NG41 FIXEDSATELLITE (spacetoEarth) S5.441 US211 NG104 US355International Fixed (23) Satellite Communications (25) Fixed Microwave (101)11.712.1 S5.48611.712.2 FIXEDSATELLITE (spacetoEarth) NG143 NG145 Mobile except aeronautical Mobile Satellite Communications (25) Fixed Microwave (101)12.112.2 S5.486 S5.48812.212.7 S5.49012.212.7 FIXED BROADCASTINGSATELLITE S5.487A S5.488 S5.490International Fixed (23) Satellite Communications (25) Direct Broadcast Satellite (100) Fixed Microwave (101)12.712.75 12.712.75 FIXED NG118 FIXEDSATELLITE (Earthtospace) MOBILE NG53Satellite Communications (25) Auxiliary Broadcasting (74) Cable TV Relay (78) Fixed Microwave (101)12.7513.25 US25112.7513.25 FIXED NG118 FIXEDSATELLITE (Earthtospace) S5.441 NG104 MOBILE US251 NG53 Description of Current and Planned Band Use (10.713.25GHz) The band 10.713.25GHz has a variety of operations including fixed pointtopoint operations, DBS, intercontinental FSS and VSAT FSS, broadcast auxiliary links and cable system backbone links. We also note that this frequency range is the subject of an ongoing Commission proceeding to allow nongeostationary orbit (NGSO) FSS and terrestrial multichannel video distribution and data service (MVDDS) operations on these and other bands through out the Kuband. We have evaluated each of these bands below to determine the viability of ITFS/MDS operations in this range. For the purposes of this analysis, we have divided the band into four segments: 10.711.7, 11.712.2, 12.212.7, and 12.713.25GHz (See Table 6.6: Band Usage 10.713.25GHz). 10.711.7GHz portion. As indicated above, the band 10.711.7GHz is currently allocated on a coprimary basis to the FS, licensed under Part 101 of the Commission's Rules; and to the FSS for international systems (downlinks), licensed under Part 25 of the Commission's Rules. The FS links in this band support a wide array of communication services used by utilities, railroads, telephone companies, state and local governments, public safety agencies, and others. There are currently over 31,000 pointtopoint links licensed in this band. The average path length is 32km (19.9miles). The channeling plan provides for varied bandwidths from 1.25 to 40megahertz channels with 500megahertz separation between the transmit and receive channels. There are also several GSO FSS earth stations for international systems in this band. Currently, there are 10 U.S. licensed geostationary (GSO) satellites providing international service and almost 600 downlinks associated with licensed earth stations. Further, this band is also used for telemetry, tracking, and control (TT&C) functions for the GSO FSS satellites authorized within this band. In 2000, the Commission authorized NGSO FSS downlink gateway earth stations in this frequency range. Both the channel loading and the geographical distributions of the incumbent facilities in this band are fairly uniform across the band and across the country, respectively. See the map in Appendix 6.4. Moreover, the band 10.711.7GHz was identified in 1993 in the Emerging Technologies proceeding and in 1997 in the mobilesatellite service (MSS) 2GHz allocation proceeding as a future home for fixed pointtopoint operations to be relocated from the 2GHz band. (See the maps in Appendix 6.5.) 11.712.2GHz portion. As mentioned above, the band 11.712.2GHz is allocated in the U.S. on a primary basis for FSS downlinks and is heavily used by television program distribution and VSAT operations. The downlink FSS band 11.712.2GHz is paired with the uplink FSS band 14.014.5GHz. These bands accommodate 25 U.S. licensed GSO satellites, including VSAT operations. Transponders on space stations in the FSS may be used, depending upon certain limitations, for DirecttoHome (DTH) transmissions. The Commission has also authorized NGSO FSS service downlink operations in this band to user terminals. The band 11.712.2GHz supports over 4,200 links associated with licensed earth stations. We also note that mobile operations are permitted in the band on a secondary basis, but there are only a few mobile operations in the band. 12.212.7GHz portion. The band 12.212.7GHz is allocated on a primary basis to BSS for use by DBS systems. The DBS service provides for direct reception of radiocommunications signals by the general public and DBS programming typically includes video distribution, payperview movies, and CDquality audio channels. The two domestic DBS licenses are DirecTV and EchoStars DISH Network, which combined service in excess of 15million customers using 11 U.S. licensed GSO satellites. The FCC rules and regulations for DBS are contained in 47 C.F.R. Part 100. While the band has a primary allocation for the FS, fixed systems licensed in the band after September 9, 1983 must operate on a nonharmful interference basis to the BSS. Currently, there are approximately 400 links in the terrestrial fixed services, with an average path length of 15km (9.3miles). In ET Docket 98206, the Commission allocated this spectrum band for NGSO FSS service downlinks to user terminals and concluded that oneway terrestrial pointtomultipoint operations could be designed around incumbent BSS operations if technical parameters are constrained and systems were designed to protect BSS or mitigate any harmful interference. The specific method of protecting DBS systems from terrestrial interference is the subject of an ongoing proceeding. 12.7513.25GHz portion. The band 12.7513.25GHz band is allocated on a coprimary basis to fixed, FSS uplink, and mobile operations. This band is primarily used by Part 74 broadcast auxiliary services (BAS), Part 78 cable relay services (CARS), and Part 101 FS operations. Television stations use the fixed allocation for BAS studiotransmitter links and the mobile allocation for electronic news gathering ("ENG"). CARS licensees use this band to send video signals between points in their networks. GSO FSS operations in this band must meet the requirements of the ITU Appendix 30B plan, and Part 2 of the Commission's Rules limits these operations to international systems. Similar to the 10.711.7GHz band, the international system only requirement for GSO FSS uplink operations has limited the number of earth stations in this band. Further, our rules do not currently address coordination between FSS operations and BAS operations, but this is the subject of an upcoming proceeding. The band may also be used for vital TT&C functions for GSO FSS satellites. ET Docket No. 98206 permitted NGSO FSS uplink gateway operations in this band subject to appropriate coordination and sharing criteria. This band is used primarily by CARS operations plus BAS, LTTS, and fixed, pointtopoint microwave. For the CARS, there are currently 145,281 fixed and 725 mobile links licensed in this band. The fixed operations bandwidths ranges are 6, 12.5, or 25megahertz, while the mobile operations use 25megahertz channel bandwidths. The average path length for fixed operations is 20km (12.4miles). The band 12.713.25GHz also supports 2,069 fixed and 2,779 mobile links for BAS, and 636 fixed and 988 mobile links for LTTS. For BAS, the fixed bandwidths are 10 and 20megahertz channels, and the mobile bandwidth is 25megahertz, with a 250megahertz separation between transmit and receive operations. The average path length for fixed operations is 15km (9.3miles). The LTTS uses bandwidths of 16, 17, or 25megahertz for both fixed and mobile operations and an average path length of 21km (13.0miles). The band 12.713.25GHz provides 116 uplinks for the 10 GSO satellites mentioned above in the 10.711.7GHz discussion. The channel loading and the geographical distributions of licensed links in this band are shown in maps in Appendix 6.4. Table 6.6: Band Usage 10.713.25GHz FSS (downlink) International Sat. only  FSS (downlink) VSATs Direct Broadcast Satellite FSS (up) FSS (uplink) International Sat. only FIXED PointtoPoint Microwave LTTS Secondary mobile  FIXED PointtoPoint Microwave  FIXED/MOBILE PointtoPoint Microwave BAS, CARS, LTTS Secondary TV Translators Federal Agency Testing (10.711.7 and 12.213.25GHz) Radio Astronomy (passive sensing 1214GHz)  NASA space research at Goldstone, CA | | | | | | 10.7 11.7 12.2 12.7 12.75 13.25 Assessment for ITFS/MDS Operations (10.713.25GHz) The technical characteristics in the 1013GHz spectrum range are significantly different from that experienced at the 25002690MHz band. Consequently, relocation of the ITFS/MDS systems from the 2.5GHz band to 1013GHz would require major changes to ITFS/MDS equipment and network design. 10.711.7GHz (1000megahertz). Accommodation of ITFS/MDS in the band 10.711.7GHz would be extremely difficult due to the heavy use of FS and the international nature of FSS operations. As noted earlier, this band currently supports over 31,000 FS links and almost 600 FSS downlinks. Sharing between ITFS/MDS and the incumbent users is not feasible because ITFS/MDS are ubiquitous, widearea systems using broadbeam and omnidirectional antennas, which are not compatible with other operations in the same geographical markets. Segmenting the band into 202megahertz for ITFS/MDS and 798megahertz also is impractical due to the heavy use by the incumbent services. Thus, relocating ITFS/MDS into the band 10.711.7MHz would require reaccommodating a portion of the incumbent users into other higher frequency bands. This would be very disruptive to the FS due to the varied bandwidths and the paired operations used by the FS operations. Relocation of the FSS would also need to accommodate the crossband pairing of this band with the FSS 14GHz band and would have a significant cost impact to deploy new satellites and earth stations. 11.712.2GHz (500megahertz) Accommodating ITFS/MDS in the band 11.712.2GHz would be very disruptive to the fixedsatellite services. As mentioned above, this downlink band supports the VSAT, DTH, and NGSO FSS services and the widearea, ubiquitous nature of ITFS/MDS services are not compatible with the broad deployment of FSS terminals. If 202megahertz of spectrum were to be cleared for ITFS/MDS, the incumbent services would have to be relocated into the remaining 298megahertz of spectrum or be reaccommodated in higher frequency bands. For FSS purposes, this band is paired with the band 14.014.5GHz. Therefore, relocating the FSS operations either into the remaining 298megahertz of spectrum or relocating into higher bands would require a full realignment of this spectrum. This would create considerable disruption to the incumbent services. Additionally, consideration would have to be made regarding the Commissions recent decision to allow NGSO FSS service downlinks in this spectrum range (ET 98206). Finally, although not protected, some accommodation of the secondary mobile use in the band 11.712.2GHz band would need to be examined further. 12.212.7GHz (500megahertz). This band supports the deployment of the DBS operations. (See discussion above.) Relocation of ITFS/MDS services into the 12.212.7GHz band would be a severe hardship to the current and future deployment of DBS in this country. Again, sharing of this band between ITFS/MDS and broadcastingsatellites is not feasible due to the inability to coordinate ubiquitous DBS use with a twoway service. Further, we note that segmentation of this band or relocation of the incumbents into higher bands is fraught with difficulty due to the international nature of the broadcastingsatellite services. Recently, there has been considerable growth in the DBS services. Relocation of these incumbent DBS services would require a reconfiguration of the satellites andmillions of home terminals. Additionally, further consideration is needed regarding the NGSO FSS downlink proceeding ET 98206. 12.713.25GHz (550megahertz) Reaccommodation of ITFS/MDS into the 12.713.25GHz band is impractical due to the bands heavy use by fixed, fixedsatellite, and mobile services. With regard to mobile operations, BAS, CARS, and LTTS pose particular difficulties to sharing between these incumbent services and ITFS/MDS. As discussed in Section 4 above, sharing between ITFS/MDS and mobile operations in the same geographic area is not feasible. Because the incumbent mobile services are dispersed throughout the country, ITFS/MDS could not share with these incumbent operations. Segmentation of the band into 202megahertz for ITFS/MDS and the remainder for the incumbent services also is not reasonable due to the extensive use of the entire spectrum band by the incumbent services. The band 12.713.25GHz supports approximately 148,000 fixed and 4,500 mobile links licensed in this band. Thus, relocating ITFS/MDS into this band would require reaccommodating a large portion of the incumbent users into higher frequency bands. Due to the propagation characteristics at these higher frequencies (18GHz or above), the relocated fixed services would require additional facilities to provide the equivalent service ranges. The mobile services would be severely impacted and may not be operational at all due to multipath and signal fading. Such action also would exacerbate current difficulties that already exist with relocating fixed links from the 2GHz band as laid out in ET Docket 929, and those fixed services relocating from the DBS band 12.212.7GHz as noted above. (See the maps in Appendix 6.5.) Other matters. In addition to the points discussed above, there are several Federal Government operations that operate on a noninterference basis. Specifically, NASA operates downlink telemetry, on a noninterference basis, during launch and emergencies in support of the NASA Advanced Communications Technology Satellite Space Program. In the bands 10.711.7 and 12.213.25GHz, federal agencies use this spectrum on a noninterference basis for experimental testing for such studies as millimeter wave propagation studies. For radio astronomy, the FSS and FS that operate in the 10.711.7GHz band are urged to take all practicable steps to protect the passive sensing and radio astronomy studies of quasars that are conducted in the adjacent band 10.6810.7GHz. Further, the band 12.7513.25GHz also is allocated on a primary basis to space research for reception only at NASAs Goldstone, California facility. Summary (10.713.25GHz) As described above, ITFS and MDS is not compatible with the incumbent services in the 10.713.25GHz spectrum. The extensive deployment of fixed pointtopoint operations in the band 10.711.7GHz poses particular problems to relocation in this band. The growing deployment of VSATs and DBS terminals throughout the country also creates difficulties with relocating ITFS/MDS in either the 11.712.2GHz or 12.212.7GHz bands. The mobile and fixed operations of BAS, CARS, and LTTS also create problems with relocating operations in the band 12.713.25GHz as well. Due to the technical characteristics of ITFS/MDS services, sharing with the incumbent services is not possible in most geographic areas. Therefore, to provide for ITFS/MDS, 202megahertz of spectrum will have to be cleared by relocating or segmenting all of the incumbent users in that portion of the spectrum. As discussed above, reaccommodating these services in higher bands would severely impact the incumbent users. Moreover, the spectrum in the 1013GHz range cannot provide functional equivalency for the ITFS/MDS services due to the considerable technical differences from the 2.5GHz spectrum range. Therefore, we believe the 10.713.25GHz spectrum is not practical as an alternate band for ITFS/MDS services. MIGRATION SCHEDULE (2003, 2006, 2010) If the ITFS/MDS services are relocated to any of the NonFederal Government bands except the 50megahertz in the band 70757125MHz, a substantial amount of time would be needed to relocate incumbent satellite operations. Any relocation of FSS or BSS will entail the design, construction, and launch of new satellites at higher satellite frequency bands, which, alone, would take a number of years. GSO satellites are constructed with an expected lifetime of 15 years, and NGSO satellites have a life expectancy of 7 years. Once the satellites are launched, however, there is no way to relocate them to different frequency bands. It is therefore not possible to meet a migration schedule that is less than the expected lifetime of the currently operating satellites. Otherwise an existing and valuable resource would be wasted. On the other hand, relocation of the FS pointtopoint operations could start as early as 2003 because each facility could be relocated on an individual, as needed, basis. This is similar to the process being used for the 2GHz fixed microwave pointtopoint operations that are being relocated for emerging technologies, such as PCS, but as fixed operations are forced to higher frequencies the technical impact and challenges increase substantially. Mobile operations also could be relocated on an individual as needed basis; however, the technical challenges for mobile communications at higher frequencies is even greater than fixed services and it is highly unlikely that suitable spectrum in nearby frequency bands could be located for these incumbent services. SECTION 7 ANALYSIS OF COSTS AND BENEFITS The Study Plan states that for each band option being analyzed (i.e., sharing, segmentation and relocation), the study will estimate and describe the costs to implement each option and any associated assumptions. The estimates should address implementation of the options in 2003, 2006, 2010 or at times where there is a potential cost advantage to do so (e.g., if costs can be mitigated by ceasing further deployment of incumbent systems in the band under study, thereby reducing costs to relocate incumbent systems to alternate bands). The Study Plan also states that the study should estimate and describe the benefits (including assumptions), if any, including potential auction receipts that could be realized as a result of making spectrum available for 3G systems in the frequency band under study. Finally, the study should include a cost and benefit analysis for each option and implementation timeframe under consideration. In this section, we describe the costs and benefits for ITFS/MDS and future 3G systems if spectrum were made available for 3G systems either through segmentation of the 25002690MHz band or relocation of ITFS/MDS systems to alternate bands, as addressed in Sections 5 and 6, respectively. We identify the types of cost and benefit factors that we considered in our analysis, and we discuss some of these factors in more detail visvis the segmentation and relocation options that we considered in this study. The analysis in this section is based on information received in response to the Advanced Wireless Services NPRMand our independent study. We do not analyze the cost and benefit of making spectrum available for 3G systems by sharing the 2500-2690 MHz band with ITFS/MDS, because, as discussed in Section4, we conclude that sharing the band among these services would be extremely problematic. COST AND BENEFIT FACTORS We have identified certain cost and benefit factors that could reasonably be included in this study, and these are discussed below. In considering the cost impact to ITFS/MDS to implement any of the segmentation or relocation options under study, we focused primarily on prospective costs to maintain functionality and services. We note, for example, that the relocation policy used to accommodate new PCS entrants in the 18501990MHz bands requires that the new entrants provide incumbent users, who are being moved out of the band, with comparable facilities, which are evaluated in terms of throughput, reliability and operating costs. This approach assumes a continuing public benefit by maintaining ITFS/MDS functionality and services, and focuses on the costs necessary to maintain this benefit. We did not analyze what benefits, if any, might accrue to ITFS/MDS entities under the segmentation or relocation options. For example, we considered the cost to deploy additional cell sites to maintain a desired service area and the cost to acquire new equipment, which may not yet be available, at higher frequency bands. To the extent possible, we considered costs for analog and digital, oneway and twoway systems. If functionality could not reasonably be maintained (e.g., segmentation of the 25002690MHz band), we considered lost opportunity costs from fewer customers or fewer services. In the segmentation and relocation discussions that follow, we explain in more detail the cost factors used in analyzing those options. We recognize that by focusing on prospective costs to maintain functionality and services, our analysis does not include certain costs incurred by ITFS/MDS entities for the current and planned deployment of services in the 25002690MHz band. For example, the auction of MDS widearea licenses in 19951996 generated winning net bids of $216.2million. Sprint and WorldCom have spent over $2billion to acquire numerous incumbent MDS licenses after the FCC decided to allow the deployment of twoway systems in the 25002690MHz band. MDS entities also have numerous lease arrangements with ITFS licensees. If these lease arrangements are not maintained, ITFS licensees could lose significant revenues and inkind compensation to support their educational missions. These cost factors present legal and policy issues that are beyond the scope of this proceeding and estimates of the costs cannot reasonably be made at this time. Therefore, we do not include them in our analysis for purposes of this study. Our analysis did not consider the costs to deploy 3G systems in the 25002690MHz band nor the potential benefits to prospective providers of 3G services. At this time, we do not have a record on which to base cost estimates for different types of systems or different types of services that may be deployed. Further, we can only speculate on the potential public benefits that could be realized as a result of making spectrum available for 3G systems in the 25002690MHz band. For example, we assume that if spectrum in the 25002690MHz band were made available for 3G use, the spectrum would be licensed under competitive bidding processes. The amount of revenue that might be generated by any auction depends on a number of factors, including the amount of spectrum made available, the state of technology, the extent to which the spectrum is encumbered, and volatility in capital markets. Other factors also may affect the proceeds generated by a spectrum auction. We have not attempted to estimate the amount of revenue that might be generated if spectrum in the 25002690MHz band were made available for 3G use, but some information is available that suggests auctions of spectrum for 3G use could generate significant revenue. The Congressional Budget Office (CBO), for example, has provided projections of receipts from FCC spectrum auctions likely to occur between now and 2007 when the FCCs statutory authority to conduct spectrum auctions expires. The CBOs recent projections, which are based on past auctions and private sales of comparable licenses, were recently revised upward based on higher prices paid recently for spectrum licenses. The CBO projects that spectrum auctions will bring in $1billion in 2001, between $4billion and $10billion each year from 2002 to 2004, and smaller amount in subsequent years. These projections assume that some of the auctions will be for spectrum for 3G use. We also note that the FCC recently completed an auction for certain PCS spectrum, which could be used for 3G systems, and a total of $16.8billion in net high bids was received. Thus, this auction alone exceeded the CBO projection for 2001. Finally, both advanced wireless mobile and fixed services have the potential to provide numerous benefits to the public. The FCC noted in its Fifth Competition Report on commercial mobile services that although only about two percent of mobile traffic is currently data, substantial growth is expected in the future. The Fifth Competition Report pointed to one forecast that wireless data subscribers will outnumber wireline data subscribers by 2002 and another that predicts at least $35$40billion in revenues by 2007an annual growth rate of 25 to 30 percentand 100million subscribers using some form of mobile data. An October 2000 Council of Economic Advisers Report estimates the annual consumer benefits of 3G services to be in the range of $53111billion. The potential market for fixed wireless services also is promising. We noted in the Interim Report that available evidence indicates that over the next several years the demand for affordable broadband services in the United States will far outpace the ability of incumbent local exchange carriers and cable operators to provide those services. The U.S. market for fixed wireless broadband services is expected to increase from $767million in 1999 to $7.4billion by 2003, with the total number of fixed wireless broadband subscribers predicted to increase from 200,000 this year to 9.4million in 2005. SEGMENTATION In Section 5, we analyzed the effect on ITFS/MDS of segmenting the 25002690MHz band if 90megahertz of spectrum were reallocated for 3G systems use. We considered three optional band plans for making this spectrum available for 3G systems. Our analysis shows that each of the optional band plans would have significant impacts on ITFS/MDS if the 90megahertz of spectrum were not replaced with spectrum from another band, and ITFS/MDS entities had to operate on no more than 100megahertz of remaining spectrum in the band. First, incumbent oneway ITFS/MDS systems, both analog and digital, would have to be accommodated in the remaining 100megahertz of spectrum. Second, segmentation would have one of two results for twoway ITFS/MDS systems: either ITFS/MDS deployment would be significantly constrained with substantial reductions in customers served or services provided, or additional cell sites would have to be deployed to maintain service areas. Our analysis is consistent with views expressed by several commenters in response to the Advanced Wireless Services NPRM. As we have noted throughout this study, the current use of the 25002690MHz band by ITFS/MDS is very complex and is not uniform from one geographic area to another. Consequently, each of the segmentation options considered in this study would have different impacts on ITFS/MDS, depending on the geographic area under review. Thus, it is not possible to provide one cost estimate to implement each of the segmentation options considered. Rather, we have looked at several specific cost factors, which would apply in most cases, and in each geographic area the implementation costs would reflect the types of use that exist. Under each of the segmentation options, some traditional oneway ITFS and MDS operations would have to be moved into the remaining spectrum. We noted in Section 5 that approximately 60,000 transmitters would be affected by the segmentation options studied. Generally, these systems transmit using standard 6megahertz composite NTSC video/audio modulation. ITFS licensees may use a 125kHz response station transmitter at receive sites, which operate using wideband FM modulation. Based on information provided by one commenter to the Advanced Wireless Services NPRM, the cost to relocate this type of facility could be approximately $500,000. We also noted in Section 5 that if some ITFS/MDS operators using multiple channels converted their systems to digital modulation, spectrum use in the band would be more efficient. Digital modulation may be a viable option only for those operators using multiple channels, so the ability to compress these uses into the least number of channels will vary from one geographic area to another. Of course, converting oneway systems to digital modulation would entail another cost to ITFS/MDS operators. The relocation of incumbent oneway systems into the remaining spectrum is only one factor that would exacerbate the difficulty of operators of twoway digital systems in the band finding sufficient spectrum. Each of the segmentation options also would require guardbands between ITFS/MDS and 3G operations, further reducing the amount of spectrum available for twoway ITFS/MDS systems. As noted in Section 5, the amount of spectrum available for twoway systems would vary depending on the size and number of guardbands. Taking into account accommodation of incumbent oneway systems (which would vary depending on geographic area) and guardbands, the amount of spectrum available for twoway systems would range from 5282megahertz for option 1, 6494megahertz for option 2, or 5888megahertz for option 3. Guardband requirements themselves impose additional equipment costs on both manufacturers and service providers, since manufacturers would have to modify, for example, channel filtering, duplexers, and cellular reuse patterns. In addition to the costs to manufacturers to reengineer equipment for use in the band, operators would be penalized by the one or more years needed to redesign and deploy new equipment. This would delay the introduction of new broadband services in many markets and to many educational users. At a time when the provision of highspeed data services to residential and business users is expected to increase rapidly, MDS entities may lose the opportunity to enter some markets as a competitor to DSL and cable modem services. The significant reduction in spectrum available to deploy twoway systems in the band would impair the ability of ITFS/MDS operators to deploy service as planned. Operators would either have to accept the reduction in system capacity and thus serve fewer customers or provide fewer services, or increase system capacity by adding additional cells. With reduced spectrum and system capacity, operators may not be able to offer data services at speeds sufficient to compete with alternative technology such as DSL or cable modem service. If the number of subscribers is significantly reduced, operators would not have a sufficient revenue source to make the systems profitable. For example, Cisco studied the impact on two markets if 90megahertz of spectrum were no longer available for twoway ITFS/MDS systems. In one large market, the system would experience nearly a 71 percent loss of capacity, reducing the number of subscribers reached from 84,000 to 24,000 households; in a small market, system capacity would be reduced by onehalf, with subscribers reached decreasing from 7,500 to 3,800 households. As already noted, an ITFS/MDS twoway system could add cells in order to maintain functionality and services under any of the segmentation options. As noted in Section 3, twoway ITFS/MDS systems have been designed to use a variety of network configurations. Generally, operators intend to use one supercell in small markets or rural areas, and sectorized cells or additional cells in large markets. System capacity can be increased in most markets to meet increased demand by sectorized cells or additional cells. Several commenters to the Advanced Wireless Services NPRM addressed the costs, both to ITFS/MDS operators and to the public, to add additional cells to address spectrum reduction rather than increased demand. The consensus of these commenters is that the deployment of additional cells would increase operators costs significantly, reduce profitability, and jeopardize the ability to introduce broadband services in rural or smaller markets. The HAI Study presents analysis developed from an engineeringeconomic model that calculated capital investment requirements, operating expenses and revenue projections for a normalized twoway ITFS/MDS operation in a given market over a tenyear study period. The HAI Study examined the impacts for five sample markets of varying sizes using a generic business case. The key drivers for the model were investment costs, market size as measured by households in the sample markets; 10th year subscriber penetration targets (the demand function); subscriber service levels and pricing; and the amount of spectrum available in the market. The penetration targets drive subscribership and capacity requirements, which in turn generate investment requirements and operating expenses. The HAI Study reached the following conclusions. Except for the smallest sample market, all sample markets had to be multicell markets to have enough capacity to meet subscriber targets, and in larger markets the number of cell sites increased by a factor of 2.7. Capital investment requirements increased in all sample markets, and the total capital requirement for the industry would increase from $2.705billion to $8.975billion, a threefold increase. Operating expenses also would increase significantly, so that over a 10year period cumulative operating expenses would rise from $5.3 to $6.5million in the smallest sample market and from $43.3 to $74.9million in the largest sample market. Further, the 10year rate of return on investment for all sample markets would be negative. Finally, the net present value of costs that would be incurred by ITFS/MDS operators over the tenyear period as a result of a 90megahertz spectrum reduction would be about $19billion. Cisco performed a cost analysis for one large market, estimating the increased capital and operational expenses over a five year period, and extrapolated these figures to the top 100Metropolitan Statistical Areas (MSAs). Cisco states that the capital and operational expenses to deploy broadband fixed wireless in the top 100 MSAs would increase by $5.19billion over the first five years, from $12.15billion to $17.34billion. These studies have significant implications for future deployment of twoway ITFS/MDS in the 25002690MHz band if the band was segmented and spectrum made available for 3G systems. In the remaining spectrum, twoway systems would not likely be deployed in most small markets or rural areas, and, depending on the circumstances, twoway systems may not be profitable in some large markets as well. By and large, twoway systems have not yet been deployed in the 25002690MHz band, although operators have plans to begin deployments later this year once the initial application processing for twoway systems is complete. If the band was segmented and new twoway system applications were limited to certain portions of the band, the relocation expenses that new entrants in the band would have to pay would be mitigated. Under the Commissions current relocation policy, incumbents are entitled to relocation costs only for those links that pose an interference problem, and thus incumbents would not receive compensation for future systems for which they have not applied or which have not been licensed. On the other hand, if it were not profitable for incumbents to assume the costs to deploy twoway systems in the remaining spectrum, the public would lose the benefits that could be realized by introducing competitive broadband services, especially in many small markets or rural areas. RELOCATION In Section 6, we identified and analyzed potential alternate frequency bands for ITFS/MDS: 37004200MHz, 59256425MHz, 64257125MHz, 71258500MHz, and 10.713.25GHz. Our analysis shows that each of these bands is already heavily utilized by other services, and that relocating ITFS/MDS operations anywhere in this spectrum would be highly problematic. Relocating ITFS/MDS to any of these alternate bands would require that incumbent operations in these bands also would have to be relocated. This secondary relocation, plus the time needed to develop ITFS/MDS equipment for use in any of the alternate bands, would add costs and delays to implementation of the relocation option. Few comments filed in response to the Advanced Wireless Services NPRM addressed ITFS/MDS relocation cost issues, and only one provided cost estimates for relocating traditional ITFS facilities. The National ITFS Association (NIA) estimates that relocation costs for traditional ITFS facilities, which are generally oneway analog systems used for distance learning, would be approximately $19billion over 15 years. Although NIAs cost estimates are not bandspecific, NIA assumes that any ITFS relocation band would be above 3GHz and, because of differences in propagation characteristics as compared to the 25002690MHz band, numerous additional transmitter sites would be needed. NIA also assumes that equipment would have to be developed to operate in a higher band, and that the cost of this equipment would be significantly higher than current equipment for video/data transmission and reception. NIA breaks its estimates into facility replacement costs, increased operation and maintenance costs, and lost lease revenues. With respect to facility replacement costs, NIA assumes that at least three transmitter sites would be required to replicate current ITFS coverage at 25002690MHz, thus increasing all costs related to transmitter sites, as well as adding new tower and backhaul costs. NIA further assumes that equipment costs would be higher due to the technical challenges of the higher band and the lack of opportunity of joint development with MDS operators. Finally, NIA assumes that substantial costs would be involved for removal and reconstruction of existing sites, including engineering, shipping and insurance, and removal and installation of transmitters. NIA estimates the total cost of replacing 2400 existing ITFS stations as $3.7billion. Unlike our relocation analysis in Section 6, NIA assumes that any relocation would result in the termination of the ITFS/MDS partnership, thereby increasing ITFS licensees costs and decreasing their revenues. With respect to ITFS operation and maintenance costs, NIA assumes that ITFS licensees would have to bear several costs that are now being borne by their MDS partners such as transmitter site rental costs, utilities, and other nonpersonnel and depreciation costs for transmitter sites. NIA estimates that these costs would total about $7.9billion over the 15year lease period that typically exists at present between ITFS licensees and MDS operators. NIA also assumes that, over the typical 15year lease period, ITFS licensees would lose significant revenues, which are used to support ITFS operations and other educational endeavors. NIA assumes that ITFS licensees would collect 5% of the revenues of broadband wireless systems in the 25002690MHz band, and if those lease revenues are foregone, NIA estimates the loss to ITFS licensees over 15 years to be $7.2billion. In addition to NIAs cost estimates for relocating traditional ITFS systems, we make the following general observations about the potential costs to implement the relocation option for ITFS and MDS in any of the frequency bands studied. If relocation of ITFS/MDS incumbents were attempted, it is likely that relocation costs would be lowest in the 37004200MHz band, but they still could be significant. Both Cisco and the HAI Study note that the ITFS/MDS equipment for twoway systems now being used in the 25002690MHz band has been adapted from designs used in the 1.9GHz and 2.4GHz bands, and could not be used beyond 3GHz, thereby requiring equipment reengineering above 3GHz. Cisco considered the impacts on equipment reengineering and deployment if ITFS/MDS lost 100megahertz of spectrum in the 25002690MHz that was replaced with 100megahertz in the 3700MHz band. This switch to dualband operation would impose costs on equipment manufacturers and service providers, as well as delay market entry by one to two years. Cisco notes that the RF components for both the base stations and subscriber units would have to be reengineered, and, for example, that the cost of customer premises equipment (CPE) would rise by about 25 percent. Cisco further contends that because of changes in signal propagation, the coverage area of a cell with a 20 mile radius at 25002690MHz, would shrink to less than a 14 mile radius at 3700MHz. This reduction in coverage would negatively affect provision of service in smaller markets and rural communities. The HAI Study provides cost estimates for some of the above functions in the 25002690MHz band. While that study did not examine the costs of relocating ITFS/MDS users from the 25002690MHz band, we believe the study has some relevance since costs for some of the following representative items would likely be more at higher frequency bands. Supercell fixed site investment for upstream sectorization: $700,000 for omnidirectional antennas, $1.1million for four sectorized antennas, and $1.7million for ten sectorized antennas (does not include radios). Multicell fixed site investment: $850,000 (plus another $150,000 per market for Internet Protocol switching/routing). Backhaul microwave system (dedicated) between the hub site and the local exchange carrier (LEC): $145,000 for a DS3 system with hotstandby redundancy. Backhaul system (leased): monthly lease of $3000 per DS3, and a monthly charge of $20,000 per highspeed (OC3) connection between the LEC and the Internet Service Provider. Residential subscriber acquisition cost: $700 for CPE initially, declining to $350 in the tenth year; and $350 for installation, declining to $200 in the tenth year. Commercial subscriber acquisition cost: $700 for CPE initially, declining to $350 in the tenth year; and $500 for installation, declining to $300 in the tenth year. While it is not possible to estimate what the above costs would be in other bands, it is likely that in general they would be higher in the 37004200MHz band, and significantly higher above 6GHz. Because of poorer propagation in higher bands, more cells would have to be added to maintain the same quality of service, and such an addition would cause investment costs to be multiplied by however many additional cells were required. Additionally, subscriber acquisition costs would likely be higher in each of the candidate relocation bands. Further, since all of the candidate relocation bands are heavily utilized, secondary relocation costs would have to be taken into account, i.e., incumbents in the relocation bands would themselves have to be relocated to accommodate ITFS/MDS users. We believe that these secondary costs can be very roughly estimated by looking at past and anticipated future relocation costs for fixed, mobile, and GSO satellite systems. We estimate these costs as follows: for fixed pointtopoint systems, we use a cost of $250,000 per link; for fixed pointtomultipoint systems, we use a cost of $3,500 per link; for mobile systems, we use a cost of $150,000 per link; and for GSO satellite systems, we use a cost of $450million per satellite. These cost assumptions result in the following total relocation cost estimates for each band, except for the 71258500MHz band, which is used by Federal Government systems. 37004200MHz band: Total relocation estimate is approximately $10.625billion. Fixed Systems (approximately 11,000 pointtopoint links)$2.75billion; Satellite Systems (35 GSO satellites)$15.75billion, including companion 59256425MHz band, or $7.875billion per band. 59256425MHz band: Total relocation estimate is approximately $17.5billion. Fixed Systems (approximately 38,500 pointtopoint links)$9.625billion; Satellite Systems (35 GSO satellites)$15.75billion, including companion 37004200MHz band, or $7.875billion per band. 64257125MHz band: Total relocation estimate is approximately $10.2billion. Fixed Systems (approximately 32,000 pointtopoint links)$8billion; Mobile Systems (approximately 2,800 links)$0.4billion; Satellite Systems (4 satellites) $1.8billion. 10.713.25GHz band: Total relocation estimate is approximately $30.4billion. Fixed Systems (approximately 34,000 pointtopoint links at $8.5billion and approximately 145,000 pointtomultipoint links at $0.5billion)$9.0billion; Mobile Systems (approximately 4,500 links)$0.7billion; Satellite Systems (46 GSO satellites)$20.7billion. SUMMARY Deployment of both 3G and fixed wireless broadband systems will provide considerable benefits to prospective users and the national economy. Implementation of either the segmentation or relocation options analyzed in this band study, however, would significantly affect ITFS/MDS deployment and impose considerable costs on both private entities and the public. Segmentation would require considerable time and costs to reengineer and deploy systems utilizing much less spectrum than is now allocated. Furthermore, delivery of fixed wireless broadband services to the public and educational users would be delayed and, in rural areas or smaller markets, may never be realized. Relocation also would require considerable time and costs to reengineer and deploy systems in alternate frequency bands. Again, delivery of service would be delayed or never realized. The relocation option also would require other services to relocate, and the time and costs to move those additional services would be significant.  FCC Staff Releases Its Interim Report on Spectrum Study of the 25002690MHz Band (ET Docket No. 00232), Public Notice, DA 002583 (rel. Nov. 15, 2000); See Federal Operations in the 17551850MHz Band: The Potential for Accommodating Third Generation Mobile Systems, Interim Report, NTIA Special Publication 0141 (rel. Nov. 15, 2000). The NTIA report is available on the internet at  HYPERLINK http://www.ntia.doc.gov/osmhome/reports/imt2000/ http://www.ntia.doc.gov/osmhome/reports/imt2000/.  The Cellular Telecommunications & Internet Association, Personal Telecommunications Industry Association, and Telecommunications Industry Association, which represent a majority of the United States wireless industry established the Industry Association Group. See Industry Association Group Comments at ii.  Id.  Amendment of Part 2 of the Commissions Rules to Allocate Spectrum Below 3GHz for Mobile and Fixed Services to Support the Introduction of New Advanced Wireless Services, including Third Generation Wireless Systems (ET Docket No. 00258), Notice of Proposed Rulemaking, FCC 00455 (rel. January 5, 2001) (hereinafter Advanced Wireless Services NPRM).  Other international organizations that have worked with and through the ITU have proved instrumental in beginning to establish characteristics of 3G systems. These organizations include the Telecommunications Industry Association (TIA), the Third Generation Partnership Project (3GPP), the Third Generation Project 2 Partnership (3GPP2), the Internet Engineering Task Force (IETF), the Universal Wireless Consortium (UWC), the CDMA Development Group (CDG), the European Telecommunications Standards Institute (ETSI) and others.  We note that IMT2000 is intended to encompass both terrestrial and satellite services. For purposes of this study we are only considering terrestrial services. Also, we have taken the liberty to use the terms IMT2000 and 3G synonymously, although we recognize that 3G terrestrial wireless systems include those terrestrial wireless systems identified by the ITU as IMT2000 systems.  See, e.g., Vocabulary of Terms for International Mobile Telecommunications2000 (IMT2000), Recommendation ITUR M.1224 (1977), International Telecommunications Union, and Key Characteristics for the IMT2000 Radio Interfaces, Recommendation ITUR M.1455(2000), International Telecommunications Union.  See Detailed Specifications of the Radio Interfaces of IMT2000, Recommendation ITUR M.1457 (2000), International Telecommunication Union. A more comprehensive list of the technical characteristics for each of these interfaces is included in Appendix 2.1, which repoduces the 3G Industry Association Groups Report on 3G Characteristics.  See Report ITUR M.2023, Spectrum Requirements for International Mobile Telecommunications2000 (IMT2000).  The WRC adopted two key resolutions concerning the terrestrial component of IMT2000: Resolution 223 (WRC2000), Additional frequency bands Identified for IMT2000, which addresses frequency bands above 1GHz; and Resolution 224 (WRC2000), Frequency bands for the terrestrial component of IMT200 below 1GHz, which addresses frequency bands below 1GHz. See Resolutions 223 and 224, Final Acts of WRC2000, 2nd ed., Istanbul, Turkey, June 2000.  See Resolution 223, Final Acts of WRC2000, Istanbul, Turkey, June 2000.  Due to the fact that the terms MDS and MMDS are often used interchangeably, some clarification is necessary with respect to use of those terms in this Report. In fifty markets in the country, Multipoint Distribution Service or MDS utilizes two 6megahertz channels (Channel Nos.1 and 2) in the 21502162MHz band (in the rest of the country, the 6megahertz No. 2 channel is replaced by a 4megahertz No. 2A channel (21562160MHz)). The shared spectrum between 2500 and 2690MHz is referred to as the Multichannel Multipoint Distribution Service or MMDS. For purposes of this Report, the term MDS will not only refer to the Nos. 1, 2, and 2A channels located in the 21502162MHz spectrum, but also the channels located in 25002690MHz spectrum. When the terms "MDS systems" or "ITFS/MDS systems" are referenced throughout this paper, licensees may be using the MDS channels in the 21502160MHz spectrum.  In addition to ITFS and MDS use, thirtyeight fixed stations are licensed to two entities in this band under the Fixed Microwave Service rules in Part 101. Although the band also is allocated to Fixed Satellite and Broadcasting Satellite Services, there are no users of this band in those services. Finally, the Radio Astronomy service is allocated on a secondary basis and there are a few stations in use around the country.  An ITFS licensee is required to be an educational institution or governmental body engaged in the formal education of enrolled students. In addition, nonprofit organizations formed to provide instructional material to enrolled students and entities eligible to be licensees of noncommercial educational broadcast television stations are eligible to become ITFS licensees.  See In the Matter of the Request for Declaratory Ruling on the Use of Digital Modulation by Multipoint Distribution Service and Instructional Television Fixed Service Stations, 11 FCC Rcd 18839 (1996).  See The Mass Media Bureau Implements Policy for Provision of Internet Service on MDS and Leased ITFS Frequencies, 11 FCC Rcd 22419 (1996).  See TwoWay Order,13 FCC Rcd 19112 (1998), recon., 14 FCC Rcd 12764 (1999), further recon., FCC 00244 (released July 21, 2000). In the TwoWay Order, the Commission decided to: (1) permit both MDS and ITFS licensees to provide twoway services on a regular basis; (2) permit increased flexibility on permissible modulation types; (3) permit increased flexibility in spectrum use and channelization, including combining multiple 6megahertz channels to accommodate wider bandwidths, dividing 6megahertz channels into smaller bandwidths, and swapping licensed MDS and ITFS channels; (4) adopt a number of technical parameters to mitigate the potential for interference among service providers and to ensure interference protection to existing MDS and ITFS services; (5) simplify and streamline the licensing process for stations used in cellularized systems; and (6) modify the ITFS programming requirements in a digital environment.  See Public Notice, Report No. 148 (MMB November 29, 2000).  See Public Notice, Report No. 164 (MMB February 1, 2001).  See Public Notice, DA 01751 (MMB March 26, 2001).  See Sprint Comments at 3. Throughout this Final Report, references to comments refer to those received in response to the Advanced Wireless Services NPRM, unless otherwise noted.  Id. at 8.  Sprint Rolls Out Wireless DSL in Phoenix, Communications Daily, May 9, 2000.  See Worldcom Comments at 6. See also, Annual Report and Analysis of Competitive Market Conditions With Respect to Commercial Mobile Services, Fifth Report, FCC 00289, rel. Aug. 18, 2000 at E5 (Fifth Report).  See Worldcom Comments at 6.  See Worldcom Comments at 6. See also, Greg Keizer, EGoals for 01, Small Business Advisor from ZDWire, Dec. 28, 2000, available in 2000 WL 31553911.  Id. See also, Matt Moore, WorldCom Seeking Licenses for FixedWireless Services, Associated Press Newswires, Aug. 15, 2000.  Paul Kagan Associates, Inc., Wireless/Private Cable Investor, Mar. 9, 2000, at 1. WorldCom has stated that its capital expenditures for rolling out MMDS services are approximately $2000 per square mile. Telephony, Communications Daily, Mar. 8, 2000.  Nucentrix Broadband Networks Announces Effectiveness of Shelf, Business Wire, Dec. 17, 1999.  Vector Orthogonal Frequency Division Multiplexing supports nonline of sight operation, which can significantly improve signal coverage in a market.  Nucentix and Cisco Extend Broadband Wireless Trial in Amarillo, News Release, Nucentrix Broadband Networks, Feb. 2, 2001.  Nucentix and Cisco Extend Broadband Wireless Trial in Amarillo, News Release, Nucentrix Broadband Networks, Feb. 2, 2001.  Nucentrix Broadband Networks Announces FCC Notice of Fixed Wireless Applications, News Release, Nucentrix Broadband Networks, Inc., Nov. 30, 2000.  See LMA web page at http://www.lmasys.com/homepage.htm.  See http://www.microtimes.com/newsfeeds/julyfeeds%2000/july10.html.  See  HYPERLINK http://www.cabledatacomnews.com/wireless/cmic12.html http://www.cabledatacomnews.com/wireless/cmic12.html for a listing of wireless broadband trials and deployments.  See 47 C.F.R. 21.901. See also footnote  NOTEREF _Ref509113314 \h  \* MERGEFORMAT 12, supra.  Subchannelization is the division of a standard channel of fixed bandwidth into multiple, although not necessarily equal, channels of lesser bandwidth. Superchannelization is the aggregation of multiple contiguous channels of standard bandwidth into channels of larger bandwidth.  See 47 C.F.R. 74.939 (providing that the 26862690MHz is divided into 31 narrowband (125kHz) response station channels).  See 47 C.F.R. 74.990, 74.991, 79.992; Amendment of Parts 21, 43, 74, 78, and 94 of the Commissions Rules Governing Use of the Frequencies in the 2.1 and 2.5GHz Bands, 6 FCC Rcd 6792, 680106 (1991). The rules provide that an MDS operator may be licensed on ITFS frequencies in areas where at least eight other ITFS channels remain available in the community for future ITFS use. In addition, no more than eight ITFS channels per community may be licensed to MDS operators. To be licensed on ITFS channels, an MDS applicant must hold a conditional license, license or a lease; must have filed an unopposed application for at least four MDS channels to be used in conjunction with the facilities proposed on the ITFS frequencies; and must show that there are no MDS channels available for application, purchase or lease. Finally, ITFS entities have the right to demand access to ITFS channels licensed to MDS operators.  Basic Trading Areas (BTAs) are based on the Rand McNally 1992 Commercial Atlas & Marketing Guide, 123rd Edition, at pages 3839, with the following additions: American Samoa (492), Guam (490), Northern Mariana Islands (493), San Juan, Puerto Rico (488), Mayagez/ AguadillaPonce, Puerto Rico (489), and the United States Virgin Islands (491). For extensions and revisions by the Federal Communications Commission, see 59 FR 46195 (September 7, 1994); see also, http://www.fcc.gov/oet/info/maps/areas/.  Since the auctions concluded in 1996, there have been bankruptcy defaults for 4 of the auctioned BTAs. In 1997, the Commission adopted default orders for two of the BTAs, Hickory, NC and Hagerstown, MD. Commission action for two additional BTAs, York, PA and Reading, PA, is pending.  As explained above, all receive sites within 56.3 kilometers (35miles) of the main station transmitter are protected from interference whether they are registered or unregistered. Receive sites that are further than 56.3 kilometers from the main transmitter site are only protected from interference if they are registered.  Cable Datacom News presents an overview of wireless broadband technology and serices and wireless broadband network diagrams on their web site at http://www.cabledatacomnews.com/wireless/.  Sue O Keefe, MMDS: From Back Burner to Center Stage, Telecommunications, Sept. 1, 1999.  Wireless OnLine Adds Vice President of Product Management, PR Newswire, Jan. 5, 2000.  NextNet, Inc., Products (visited Jan. 20, 2000) http://www.netwnetworks.com/products_prod_botton.html.  Regional Wireless Operators Select Hybrid Networks 2Way Today Solution to Launch Multiple Markets, PR Newswire, Jan. 10, 2000.  Cliff Edwards, Cisco Hopes Advances New Wireless Technology for Internet, AP Newswires, Dec. 2, 1999.  Id.  Nucentrix Files for FCC Approval to Launch Broadband FixedWireless Services, News Release, Nucentrix Broadband Networks, Inc., Aug. 21, 2000; Nucentrix Successfully Completes Initial Field Trial of Cisco Broadband FixedWireless Solution, News Release, Nucentrix Broadband Networks, Inc., Aug. 15, 2000.  MCI WorldCom Adds Dallas to Fixed Wireless Service Trials, News Release, WorldCom, Inc., Apr. 5, 2000.  See 47 C.F.R. 21.902, 21.909, 21.913, 21.933, 21.937 and 21.938.  See 47 C.F.R. 74.903, 74.939, 74.949 and 74.985.  See Appendix D, Report and Order on Reconsideration In the Matter of Amendment of Parts 1, 21 and 74 to Enable Multipoint Distribution Service and Instructional Television Fixed Service Licensees to Engage in Fixed TwoWay Transmissions, MM Docket 97217, 14 FCC Rcd 12764 (2000) (hereinafter Methodology) for details. The Methodology is periodically refined to accommodate realworld technical concerns. See, e.g., Public Notice, Commission Amends Methodology Used for Calculation of Interference Protection and Data Submission for MDS and ITFS Station Applications for TwoWay Systems, DA 00938, released April 27, 2000. A copy of the most recent version of the Methodology can be found at  HYPERLINK http://www.fcc.gov/mmb/vsd/files/methodology.doc http://www.fcc.gov/mmb/vsd/files/methodology.doc.  Id.  See 47 C.F.R. 21.902, 21.909, 21.913, 74.903, 74.939, and 74.985. See also, Section 3 supra regarding ITFS/MDS Interference Protection Standards.  ITFS/MDS receivers, for purposes of this interference analysis include not only response station receivers located at commercial customer premises and registered ITFS receive sites, but also the main station receivers associated with the main station transmitters. Main station receivers receive signals on 125kilohertz response channels associated with each 6megahertz channel.  The Industry Association Group 3G Technical Characteristic Report is included as Appendix 2.1. There are only minor differences between the characteristics listed in the ITU documents and those presented in the Industry Association Group Report.  Because mobile units could potentially operate at any location at any time, a complete analysis of the effect of multiple 3G mobile stations would require assumptions regarding their level of deployment within an area. Such assumptions are beyond the scope of this Final Report. For example, such assumptions may include statistics regarding how many mobile units may be operating in any given area at any one time and the calling patterns of users.  ITFS/MDS services in the 25002690MHz band tend to fall within one of four distinct architectures: 1) downstream analog video; 2) downstream digital video; 3) downstream digital data; and 4) downstream/upstream digital data. Although variations exist, a substantial number of technical characteristics are consistent across the four different architectures.  47 C.F.R. 21.904 and 74.935.  See 47 C.F.R. 21.902, 21.909, 21.913, 74.903, 74.939, and 74.985.  The minimum distance separation is rounded to the nearestkilometer. Additional data is available in Tables 4C 4E of Appendix 4.1.  See 47 C.F.R. 21.902 and 74.903.  Id.  The minimum distance separation is rounded to the nearestkilometer. Additional data is available in Tables 4F4H of Appendix 4.1.  George W. Harter, MSI, Feasibility Study on Spectrum Sharing between Fixed Terrestrial Wireless Services and proposed Third Generation Mobile Services in the 25002690MHz Bands October 2000. See Appendix 4.2.  For example, ITUR Recommendaiton 1457, Detailed Specifications of the Radio Interfaced of International Mobile Telecommuications2000 (IMT2000).  For example, the value for receiver sensitivity for CDMA2000 1x used in the Interim Report was 107 dBm and the Industry Association Group updated this value to 104 dBm total received power in a fully loaded system. The updated Report also shows that the value of this parameter is 119.6 dBm for a single 9600 bit per second (bps) traffic channel in additive white gaussian noise (AWGN) for 1% frame error rate (FER).  See e.g., Sprint Comments at 1718; Verizon Comments at 19.  George W. Harter, MSI, Interference to 3G Systems from ITFS/MDS Systems Sharing the Same Frequencies. See Appendix 4.3.  The study used the center city coordinates and list of cities currently in the FCC rules for Part 90 licensees. See 47 C.F.R. 90.741. We also confirmed that the list of 50 most populated cities had not changed significantly by comparing this list with 1999 data from the United States Bureau of the Census.  The exception is Salt Lake City where 5channels currently are not licensed, although applications have been tendered for 4 of the 5 channels.  Our analysis reflected the 56.3kilometer (35mile) radius protected service area provided for in the FCCs rules, rather than a minimum distance separation zone as shown in tables 4.1 and 4.2. Maintaining the standard protected service areas set by our rules provides a very conservative estimate of the potential unencumbered geographic areas for the 25002690MHz band and recognizes the potential for engineering solutions that might permit sitings closer than the separation distances calculated above.  Partitioning is the assignment of a portion of a geographic service area to another entity. The partitionee becomes the licensee for the spectrum in the partitioned area.  The circles are drawn with radius 217kilometers (135miles) rather than 161kilometers (100miles) to ensure that receivers located at the edge of the 56.3kilometer (35mile) protected service area are protected.  A guard band ensures interference free operations between adjacent services by providing a buffer zone in which outofband emissions can attenuate to a point where their liklihood of producing adjacent channel interference is minimized.  See Verizon Comments at 23.  Id. at 25.  See VoiceStream Reply Comments at 4.  A duplexer is a device that permits simultaneous transmission and reception with a common antenna.  An estimate of the amount of spectrum needed for a guard band is presented later in this Section.  An architecture which uses a single main transmitter, sometimes referred to as a supercell, uses a single base station to provide service over the entire service area. It is usually characterized by a tall tower and relatively high power. A cellular configuration, sometimes referred to as a minicell system, uses many cells to serve a geographic area. They will often use low towers and low power.  We note that the Interim Report incorrectly concluded that the 3G spectrum under this option could not be paired for FDD operation.  Id.  The database showed that on average over 4,000 transmitters are licensed nationwide on any given 6megahertz ITFS/MDS channel. Since 15 channels equates to 90megahertz of spectrum, over 60,000 (15 channels * 4, 000 transmitters per channel) transmitters would be affected.  The limit on the number of customers that a twoway MDS system can accommodate cannot readily be estimated. It depends on the amount of spectrum available, the level of service each individual customer contracts for as well as the usage patterns in any specific area.  MPEG is the Motion Picture Experts Group, which has been working to produce standards for digital compression of video signals.  See, e.g., Advanced Television Systems And Their Impact Upon The Existing Television Broadcast Service, MM Dockt No. 87268, Fourth Report and Order, 11 FCC Rcd. 17,771 (1996) at 5.  In general, the compression ratios for program material such as sports for which high quality is desired and which has lots of action and constantly changing video content is much less than what can be achieved for a talk show, where the background does not change much and picture quality is not as important.  See Footnote  NOTEREF _Ref509496766 \h  \* MERGEFORMAT 73, supra.  See Nucentrix Comments at 11.  See Cisco Comments at 5. See also, Footnote  NOTEREF _Ref509496868 \h  \* MERGEFORMAT 30, supra.  See Worldcom Comments at 1718. Station downconverter overload was explained in the Interim Report. ITFS receive stations are vulnerable to interference from digital MDS response stations. Such interference, intermittent and noiselike in nature, could occur if a transmit site is located nearby an ITFS receive site regardless of the frequency separation between the stations. This situation was addressed in the TwoWay Order and certain coordination requirements were placed on MDS licensees to minimize this possibility. See Twoway Order at 4547 and 56. The effect of this situation on 3G systems is that under the contemplated segmentation options, even if there is frequency separation between 3G and ITFS stations, this type of interference could occur from the 3G system to the ITFS system and render it unusable.  See Worldcom Comments at 18.  See WCA Comments at Appendix B, page 5. Sprint concurs that this is an accurate estimate. See Sprint Comments at 22.  See Cisco Comments at 7.  See Appendix 2.1 for IMT2000 technical characteristics.  See 47 C.F.R. 21.902, 21.909, 21.913, 74.903, 74.939, and 74.985.  See 47 C.F.R. 21.904(b) and 74.935(b). Additionally, for completeness, we assume 125kilohertz bandwidth for the hub receiver bandwidth because many stations continue to use these channels for voice channels on the path. Analysis of these stations using the maximum 6megahertz allowed under the rules (to accommodate twoway systems) would produce results similar to the results shown for the 6megahertz response stations.  A more detailed table is provided in Table 5A in Appendix 5.3.  In the planning factors tables, we assume, that the interference immunity attainable by greater frequency separation is 40 dB permegahertz (based on FCC Laboratory measurements of television receivers). Because received power is proportional to  EQ  EQ \F(1,distance^2) , eachmegahertz reduces the distance by 20 dB or a factor of 100.  A more detailed table is provided in Table 5B in Appendix 5.3.  Interference due to the energy from the signal centered in the adjacent channel that is actually transmitted in the desired channel. This is also referred to as front end overload.  More detailed tables are provide in Tables 5C and 5D in Appendix 5.3.  See Verizon Comments at 14 and Appendix A.  See Cisco Comments at 910.  Id.  See Worldcom Comments at 18.  See Verizon Comments at Appendix A. See also, 47 C.F.R. 21.908(d) for a description of the emission limitaitons.  See Cisco Comments at 10.  See WCA Comments at Appendix B, Page 17. These are the data rates offered to each customer. The channel can support higher data rates. Data rates for commercial customers are higher: 1,024kbps downstream and 512kbps upstream.  See Deployment fo Advanced Telecommunications Capability: Second Report, Federal Communications Commission, rel. August 2000 at C1. This report is available on the internet at:  HYPERLINK http://www.fcc.gov/broadband http://www.fcc.gov/broadband.  Id. at C2.  Id. at C5.  Id.  This figure was provided by Worldcom in a presentation to the FCC on October 11, 2000. It has been used with the permission of Worldcom.  In this case, the MDS operator needs appoximately 160MHz total (32miles x 32miles x ( =3217 squaremiles x 0.05megahertz/squaremile) to serve customers in this cell. The 160megahertz compares favorably with the commenters statements that approximately 156megahertz of spectrum is needed.  160megahertz is used for our analysis rather than the full 202megahertz available to ITFS/MDS serivces (190megahertz available in the 25002690MHz band and 1012megahertz available in the 21502160/62MHz band). According to commenters this is typical of the amount of spectrum they have available in each market.  This assumes leaving the existing transmitter in its current location. However, it may be possible to reduce this to 23 additional transmitter sites, if the existing transmitter is relocated. HAI, in its study, determined that a 90MHz reduction in spectrum available to MDS would increase the number of cell sites by a factor of 2.7 for the larger markets. See WCA Comments at Appendix B, page 25.  See Cisco Comments at 10.  Id.  Id.  See ITFS/MDS Channel Licensing on page  PAGEREF _Ref510332039 \h 33.  See Amendment of Section 2.106 of the Commission's Rules to Allocate Spectrum at 2GHz for Use by the Mobile Satellite Service, ET Docket No. 929, Second Report and Order, 8 FCC Rcd 6495 (1993) ("Emerging Technology Proceeding").  ITFS/MDS currently occupies a total of 202megahertz of spectrum (12megahertz from 21502162MHz and 190megahertz from 25002690MHz).  See 47 C.F.R. 2.106.  There are also proposals to use Fixedsatellite networks to provide internet services to rural and unserved areas directly to end users. See FWCC Request for Declaratory Ruling on PartialBand Licensing of Earth Stations in the Fixed Satellite Service that Shared Terrestrial Spectrum, IB Docket No. 00203, Notice of Proposed Rule Making, 15 FCC Rcd. 23127 (2000). (FWCC/ONSAT NPRM)  The purpose of registration is to receive protection from interference from terrestrial Fixed service operations. Receiveonly earth stations used for cable headends and feeds to terrestrial broadcast networks are registered particularly in congested urban areas to avoid the possibility of receiving interference that would result in disruption of service to their end users.  See Emerging Technology Proceeding.  See Request of Declaratory Ruling and Petition for Rule Making filed on May 5, 1999 by the Fixed Wireless Communication Coalition, RM9649; see also, Notice of Proposed Rule Making, IB Docket No. 00203, 15 FCC Rcd 23127 (2000).  The greatest impact of using higher frequencies would be on the return link from the subscriber location, particularly in rural deployments where longer distance communication is necessary. We note that the higher frequency bands support various fixed services that are different from the residential and educational services provided by ITFS/MDS, especially in rural areas and smaller markets.  See Emerging Technology Proceeding.  See 47 C.F.R. 2.106.  See Emerging Technology Proceeding.  See Amendment of Parts 2,25, and 97 of the Commissions Rules with Regard to the Mobile Satellite Service above 1GHz, ET Docket No. 98142, Notice of Proposed Rule Making, 13 FCC Rcd 17107 (1998). (MSS FeederLlinks)  See Assessment for bands 37004200 and 59256425MHz, as discussed above.  See MSS Feeder Links.  Id.  See NTIA Report 00378, Spectrum Usage for the Fixed Services, March 2000.  See 47 C.F.R. 2.106.  See Appendix 6.3, footnote NG41.  See Amendment of Part 2 and 25 of the Commissions Rules to Permit Operation of NGSO FSS Systems CoFrequecy with GSO and Terrestrial Systems in the KuBand Frequency Range, et al, ET 98206, First Report and Order and Further Notice of Proposed Rule Making, 66 Fed. Reg. 10601 (February 16, 2001). (NGSO FSS Proceeding)  See 47 C.F.R. 2.106, footnote NG104.  The GSO FSS operations in the 10.710.95GHz and 11.211.45GHz bands must adhere to the requirements specified in Appendix 30B of the ITU Radio Regulations and are referred to as "planned band" operations. GSO FSS operations are typically less extensively deployed in the Appendix 30B planned bands, as compared to nonplanned bands. See 47 C.F.R. 2.106 of the Commission's Rules, footnote 792 A; and ITU RR Footnote No. S5.441 and Appendix 30B of the ITUR Radio Regulations Provisions and Associated Plan for the FixedSatellite Service in the Frequency Bands 45004800MHz, 67257025MHz, 10.7010.95GHz, 11.2011.45GHz and 12.7513.25GHz. Use of these frequency bands is also governed by Resolution 130 (WRC97).  The GSO FSS operations in this band perform TT&C communications to provide data on the spacecraft's functions via a twoway telemetry link between the satellite and the controlling earth station. TT&C communications are used throughout the satellite's life, including the launch and deployment phase. The TT&C function allows the earth station to control both the physical orbital position and internal functioning of the spacecraft.  See NGSO FSS Proceeding.  See Amendment of Section 2.106 of the Commission's Rules to Allocate Spectrum at 2GHz for Use by the Mobile Satellite Service, ET Docket No. 929, Second Report and Order, 8 FCC Rcd 6495 (1993) ("Emerging Technology proceeding"). See also First Report and Order & Further Notice of Proposed Rule Making, ET Docket No. 9518, 12 FCC Rcd 7388 (1997) ("2GHz MSS allocation proceeding").  See 47 C.F.R. 101.147(p).  See NGSO FSS Proceeding.  See also Petition for Rulemaking To Amend Eligibility Requirements in Part 78 Regarding 12GHz Cable Television Relay Services, CS Docket No. 99250, Notice of Proposed Rule Making, 14 FCC Rcd 11,967.  See ITU Radio Regulations, Appendix 30B and 47 C.F.R. 2.106 footnote NG104. We note that there is one licensee using the U.S. Appendix 30B assignment in this band for domestic feeder links for a GSO MSS system.  Our database indicates that there are 9 authorizations issued for GSO FSS earth stations in the 12.7513.25GHz band. These authorizations do not indicate the actual number of earth stations or antennas that a licensee might deploy. Additionally, this number may not include several international earth station authorizations issued before 1995 when the IBFS database was created.  All the bands studied have a satellite allocation (i.e., fixedsatellite or broadcastingsatellite), except the band 70757125MHz. See Table 6.1, supra.  See Section 1, supra.  See, e.g., 47 C.F.R. 101.69101.83.  Sprint has spent $1.24billion to acquire MDS licenses in 90 markets; WorldCom has spent $1.1billion to acquire licenses in 78 markets.  The National ITFS Association (NIA) estimates that typical lease arrangements between ITFS licensees and MDS operators could generate earning of approximately $7.2billion over the next 15 years for ITFS licensees. See NIA Supplemental Comments (filed March 20, 2001) at 67.  This information is available at the CBOs webpage,  HYPERLINK "http://www.cbo.gov." www.cbo.gov.  See 47 U.S.C. 309(j).  See Military, Industry Not In Lockstep On 3G Spectrum Issue Communications Daily, February 16, 2001. The article states that the Senate Budget Committee bulletin this week said Congressional Budget Office (CBO) had dramatically raised its estimate of spectrum auction receipts by $10billion over previous baseline. CBO increased baseline 55% to $28billion over 20022007. It attributed change to market enthusiasm for 3G and cited $17billion generated by FCC's Cblock auction last month.  This auction was for C and F Block broadband PCS licenses that were in default. The auction began on December 12, 2000 and closed on January 26, 2001. See http://www.fcc.gov/wtb/auctions/  See Annual Report and Analysis of Competitive Market Conditions with Respect to Commercial Mobile Services, Fifth Report (Fifth Competition Report), FCC00289, released August 18, 2000.  Id. at 3435.  See The Economic Impact of ThirdGeneration Wireless Technology.  Analysts estimate that for a variety of technical, financial and operations reasons, cable modem and xDSL services cannot or will not meet the increasing demand for broadband by themselves. See, e.g., The Wall Street Journal, [t]he cable industrys rush to wire up America with highspeed Internet access is running into a serious problem: Too many heavy Internet users are crowding online at once, in some cases creating major bottlenecks and slowdowns. Cauley, Heavy Traffic is Overloading Cable Companies New Internet Lines, The Wall Street Journal, at B1, B16 (Mar. 16, 2000). In addition, the need for cable operators to upgrade their plant for twoway capability (particularly in less densely populated areas) and the business strategies of the large cable MSOs suggest that cable modem service will not be ubiquitously available. See Broadband!  A Joint Industry Study by Sanford C. Bernstein & Co., Inc. and McKinsey & Company, Inc., at 2526 (January 1999). (The nature of smaller and more rural systems  often with less access to capital; less threat of competition; and less dense and, therefore, more expensive plant to upgrade  keeps our forecast for [nonMSO] systems at about 15% upgraded. . . Its worth pointing out that many of the cable upgrades to date appear to be targeted at the most attractive neighborhoods (i.e., high densities and high household incomes). On a homespassed basis, we estimate that about 60% (12million) of all highincome households in the U.S. are passed by upgraded cable plant.) (the Bernstein/McKinsey Study). Ubiquitous xDSL services are unavailable due to factors that include loop length (if loops are too long), presence of nonDSL compatible remote terminal technology (such as nearly all the legacy variety of digital loop carrier systems) as well as other aspects of deployed line electronics, such as load coils and bridge taps. Bernstein/McKinsey Study at 25. Indeed, it has been estimated that existing telephone plant is DSL capable in only 44% of the residential market. Id. at 26. See also NextGeneration Networks Exploit LastMile Bandwidth, TRs LastMile Telecom Report (Feb. 24, 2000) (quoting officer of Bell Atlantic Network Services as referring to DSL as an interim strategy); Cauley, For Phone Companies Wiring the Web, a Surprising Speed Bump, The Wall Street Journal, at B1 (Feb. 17, 2000).  The Broadband Fixed Wireless Services Market Gains Momentum, According to IDC, PR Newswire (Dec. 13, 1999). All totaled, it has been estimated that by the year 2005, seventy percent of the nearly 10million estimated fixed wireless broadband subscribers will be served via ITFS/MDS.  Smith, Wireless Rides To The Rescue, Wireless Week, at 16 (Feb. 7, 2000).  See, e.g., Comments filed by The Wireless Communications Association, Inc. (WCAI), Sprint Corporation (Sprint), Cisco Systems, Inc. (Cisco). WCAI submitted a study prepared by HAI Consulting, Inc. titled MDS/MMDS/ITFS TwoWay Wireless Broadband Service; Spectrum Requirements and Business Case Analysis (HAI Study).  The Association of American Public Television Stations (APTS) states that WITF, a public television ITFS licensee in Pennsylvania with 16 ITFS channels and 4 sites, calculates that its total costs to relocate would be $420,500. This includes the cost of transmitters, combiners, feed lines, antennas, and receive equipment. APTS states that because these costs represent only replacing certain analog equipment, they do not necessarily provide a complete assessment of the equipment costs that would be incurred upon relocation of an ITFS licensee to some other band where equipment has not yet been developed and propagation characteristics and other engineering factors may be different. Also, APTS states that there may be additional relocation costs attributable to professional or other personnel costs; securing additional transmitter sites, transmission equipment and backhaul links, or more expensive receive site equipment; loss of operational and maintenance support; lost revenues from the invalidation of excess capacity agreements that would otherwise be used to support a stations educational mission; and costs related to the impairment of the stations educational services during the time of transition and thereafter. See APTS ex parte communication, ET Docket 00258, March 20, 2001.  Cisco estimates that guardbands could reduce spectrum availability for ITFS/MDS by up to 54megahertz.  See, e.g., Cisco Comments at 911. Cisco states that its equipment, which was designed without taking into account adjacent mobile operations, would need 18megahertz of guardband and thus would have to be reengineered.  See, e.g., Cisco Comments at 10. Cisco cites the need to redesign both hardware and software; revisit component supply chains and partner agreements; duplicate lab and field trials; and reinitialize manufacturing plants.  See, e.g., Cisco Comments at 11.  See, e.g., HAI Study at 6.  See Cisco Comments at 1113.  See, e.g., Comments filed by WCAI, Cisco, Sprint and WorldCom.  The sample markets, based on BTA population, ranged in size from 100,000 to 18,750,000 POPS and from 38,206 to 7,156,489 households.  As noted in Section 5, HAI assumed that 158megahertz of spectrum (26 sixmegahertz channels, plus an additional 2megahertz) would be available to each ITFS/MDS twoway system. Reducing the amount of available spectrum by 90megahertz reduces the available spectrum to 11 sixmegahertz channels. See HAI Study at 56. Cisco states that its network design assumed 162megahertz of spectrum available in dense urban markets using a microcell architecture, and 132megahertz in small markets using a single supercell configuration. See Cisco Comments at 7.  In the large market they studied, Cisco found that base station deployment would triple. See Cisco Comments at 12.  See HAI Study at 2428.  See WCA Supplemental Comments, March 21, 2001, at 45.  See Cisco Comments at 12.  See, e.g., 47 C.F.R. 101.75. See also 47 C.F.R. 101.79, which specifies sunset provisions for incumbent licensees in the 18501990MHz, 21102150MHz, and 21502160MHz bands. In those bands, emerging technology licensees are not required to pay relocation costs to incumbents ten years after the voluntary negotiation period begins for the first emerging technology licensees.  See NIA Supplemental Comments of March 20, 2001, at 4.  NIA states that 2400 existing ITFS stations account for 8000 licensed ITFS channels with 8000 transmitters, 2000 combiners (one for every four channels), and 1200 transmission lines and antennas (two for each site). NIA also states that there are approximately 700,000 ITFS receive sites. Id.  Id.  Id. at 34.  Id. at 56.  Id. at 67.  See HAI Study at 9; Cisco Comments at 14.  Cisco Comments at 13.  Id. at 1314.  Id. at 15.  See HAI Study at 1922.  This estimate includes towers, antennas, transmission lines, transmitter combiners, receive multicouplers, duplexers, backup power, network management and monitoring equipment, and IP switching/routing. Id. at 19.  This estimate includes towers, antennas, transmission lines, transmitter combiners, receive multicouplers, duplexers, backup power, network management and monitoring equipment, and fixed investment for the radio system. Id. at 20.  For fixed pointtopoint links, we use the $250,000 per link figure specified for Personal Communications Services relocation; see 47 C.F.R. 24.243(b). For fixed pointtomultipoint links, our research indicates that the cost of approximately 7072 pointtomultipoint links equals the cost of one pointtopoint link, and $250,000 divided by 7072 equals about $3,500. For mobile links, our research indicates that such links are generally about $100,000 less expensive than fixed pointtopoint links; therefore, we use a figure of $150,000 per mobile link. For GSO satellite systems, our research indicates that an average system costs about $400500million to construct and launch; therefore, we use a figure of $450million per GSO satellite. All of these figures are rough approximations that we feel are adequate for the purposes of this report, but that should not be used in other contexts where greater accuracy is required.  This estimate does not include an estimated cost of a number of lowearth orbit and digital audio radio satellite services feeder links that operate in the 67007075MHz band, which would be significant.  We note that this number includes 25 satellites that operate in the 11.712.2GHz band, which is paired with the 14.014.5GHz band. 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