3G Americas' Spectrum Position

Identification and Allocation of New Spectrum to Support Global Implementation of Advanced Mobile Wireless Services

3G Americas, LLC supports a policy of free market choice for the allocation of spectrum and the freedom of operators to choose their preferred technologies in the allocated bands as being in the best interests of consumers, service providers, manufacturers and the economy. It recognizes that the explosive growth of wireless services in the Americas has made significant contributions to national universal service goals, and that further contributions depend on a supply of spectrum consistent with the constantly expanding demand for mobile wireless services.

Specifically, in concern with the current spectrum issues and opportunities in the United States of America, 3G Americas, LLC endorses the Cellular Telecommunication and Internet Association's (CTIA) "Win-Win" Spectrum Proposal to the United States Government of February 15, 2002, for the identification and allocation of the 1710-1770 MHz paired with the 2110-2170 MHz for use for advanced mobile wireless services. Furthermore, 3G Americas, LLC encourages administrations throughout the Americas to designate common paired spectral bands for advanced mobile wireless services because they are essential to the provision of the highest levels of cost-effective service to current and future wireless consumers at every socio-economic level. Such a designation will allow service providers, applications developers, and manufacturers to realize the highest economies of scale within the bounds of a vibrantly competitive and extensive market. Thus, in consideration of global market requirements for additional spectrum to support the introduction of advanced mobile wireless services based on implementation of an IMT-2000 technical option, the 3G Americas respectfully recommends that:

• Administrations take due consideration of the global competitive marketplace and provide additional spectrum in the Americas for the mobile wireless industry evaluating: demand for growth of current commercial wireless services, transition to new wireless services, regional and global interoperability, economies of scale and increased bandwidth requirements for new advanced communication services like IMT-2000 in both existing and planned new spectral bands

• 3G Americas endorses the identification of 120 MHz of additional spectrum for IMT-2000 in the United States. Specifically, as outlined by the CTIA "Win-Win" Spectrum Plan, 3G Americas supports the following bands as candidates for possible common identification for the Americas for a total of 120 MHz of additional spectrum:

  1710 - 1770 paired with MHz, 2110 - 2170 MHz.

• Administrations continue to allow use of spectrum currently in use and already identified for IMT-2000 for advanced wireless services without additional licensing requirements. In particular, administrations should allow the deployment of advanced applications in the existing "cellular" bands (i.e. 824 - 849 MHz and 869 - 894 MHz) and "PCS" bands (i.e. 1850 - 1910 MHz and 1930 - 1990 MHz). This is consistent with ITU-R RR S5.388 principles for current IMT-2000 spectrum, and provides a global option for migration to, deployment of, and service interoperability with, global advanced wireless data services. Similarly, administrations should allow deployment of advanced applications in any additional spectrum identified for IMT-2000 and other advanced communications applications, and provide similar competitive market options for migration and interoperability with advanced wireless data services on a global basis.