BellSouth, Nucentrix Broadband Networks, Sprint, WorldCom and Wir...

at 1710-1770 MHz, now occupied by mostly military users, and 2110-2170 MHz could be reallocated for advanced wireless services. MDS Ch. 1 and 2 now occupy 2150-2162 MHz. While MDS industry has “strong preference” for remaining in band, licensees told FCC Chmn. Powell that proponents of relocating those incumbents hadn’t yet offered viable relocation plan. “Meanwhile, the continuing uncertainty over the future of the 2150-2162 MHz band is impeding the development of advanced MDS technology for these channels,” letter said. Companies that signed letter said proposal wasn’t perfect, but would be “acceptable compromise” if done quickly. Proposal involves: (1) Relocation of MDS Ch. 1 to 1910-1913/1990-1993 MHz and moving MDS Ch. 2/2A to 1913-1916/1993-1996 MHz bands. (2) Allocation involving 1910-1916 MHz that would allow fixed and mobile services in line with recent FCC decision allowing both uses of MDS channels at 2.5 GHz. (3) 1916-1920 MHz could be reallocated for unlicensed PCS under existing rules applicable to 1920-1930 MHz band. One trade-off to avoid introducing unacceptable interference to adjacent PCS and mobile satellite service (MSS) operations could be that MDS operators would have to give up design flexibility they have in current band, letter said. MDS operations in new bands would be subject to more stringent power and field strength limits of PCS rules and frequency stability and other requirements imposed on PCS operations, letter said. “The proponents of reallocating more spectrum for 3G win the contiguous spectrum they covet for a 1.7/2.1 GHz band pair, the MDS industry wins regulatory certainty and the public wins because the Commission will have created an environment in which new services can flourish, without any adverse impact on any incumbent stakeholder,” MDS said. Letter touted compromise solution as only “workable approach” in clearing 2150-2162 MHz for 3G. Factors that MDS operators said minimized disruptions of their plan include: (1) Fact that 1910-1916 MHz was allocated for asynchronous PCS use and there was no unlicensed PCS use of this band. (2) Extent to which 6 MHz at 1990-1996 MHz to be reallocated for MDS could be taken from 7 MHz of spectrum in 1990-2025 MHz MSS uplink band that hadn’t yet been licensed for MSS. (3) Likelihood that lower part of 1990-2026 would be “orphaned and unavailable for MSS anyway, as it is paired with 2165-2170 MHz MSS downlink band that the Commission has proposed to reallocate for 3G.” Elimination of system design flexibility for MDS licensees that would relocate under plan would avoid interference to adjacent PCS and MSS services, letter said: “As the quid pro quo for that sacrifice in flexibility, it offers the MDS industry an opportunity to escape the regulatory uncertainty that has dogged the 2150-2162 MHz band and to develop advanced services by building on existing technologies that operate near 2 GHz.”