September 29, 1998

Mr. Richard B. Engelman
Chief, Planning & Negotiations Division
International Bureau
Federal Communications Commission
2000 M St. N.W. Suite 800
Washington, D.C. 20554.

Subject: Report No. IN 98-48, Spectrum Issues Related To Third Generation Wireless/IMT-2000, August 26, 1998

Dear Mr. Engelman:

I am writing on behalf of the CDMA Development Group (CDG) to express our views on Report No. IN 98-48, Comments On Spectrum Issues Related To Third Generation Wireless/IMT-2000, August 26, 1998. Enclosed is our response to this document. We have also made certain our membership is aware of the FCC report and have provided our members with a template to assist them with their responses to the FCC.

We appreciate the opportunity to provide input to the FCC in your efforts to address the spectrum impacts of IMT-2000. We are available any time to discuss this important issue. I can be reached at 714-545-5211.

Sincerely,

CDMA Development Group

Perry LaForge
Executive Director

Enclosures:

1. CDG Response to Report No. IN 98-48, Spectrum Issues Related To Third Generation Wireless/IMT-2000, August 26, 1998
2. CDG Background Information

Introduction

The CDMA Development Group (CDG) is an international industry association of 100 companies, including the world’s leading manufacturers and operators of digital cellular and PCS communications systems. The CDG is chartered to develop and promote cdmaOne^TM (IS 95-CDMA). Since its commercial introduction three years ago, cdmaOne has become the world’s fastest growing wireless technology. The rapid adoption of this advanced technology is due to cdmaOne’s inherent advantages to provide a higher quality voice signal over a wider coverage area, with much greater capacity and lower operational and deployment costs than other technologies.

It is because of these fundamental advantages that all of the leading third generation standards are based on CDMA. Given our experience with CDMA, it fitting that we participate in the discussions about spectrum allocation.

Background

Through our Advanced Systems initiative, the CDG has been involved deeply in the spectrum allocation issues and challenges of IMT-2000. Our Executive Board issued a spectrum policy statement in July emphasizing the principles the CDG believes are important with respect to existing and future digital cellular/PCS systems. The CDG policy states that:

1. Cellular and PCS spectrum allocations should continue to occur expeditiously to promote economic opportunity and public benefit through the deployment of today’s sophisticated, proven digital wireless technologies. These current allocations should be defined in a technology-neutral manner so that true market forces determine the most appropriate access technology; this same philosophy should also be applied to global allocations of IMT-2000 spectrum.
2. cdmaOne systems will follow an in-band evolution toward third generation (3G) systems. Third generation services will be defined for existing worldwide cdmaOne band classes to provide operators with flexibility in deploying these services.
3. The ITU’s Family of Systems concept will provide a model for ensuring interoperability among networks of different spectrum plans and standards. The CDG supports this model for integrating networks to facilitate global roaming where a single subscriber unit of multiple spectrum bands, and modes, may not be commercially feasible.
4. Analysis of spectrum requirements for 3G systems continues in parallel with expeditious cellular and PCS allotments. If studies determine that more spectrum is needed, then harmonization between PCS plan countries and other regions of the world will be considered. Harmonization of such spectrum may reduce equipment complexity and create economies of scale benefits. Furthermore, the CDG is assessing options for new allocations in the United States. Should new allocations be deemed necessary in the United States, the CDG will work with appropriate government entities to develop guidelines that maximize participation in such allocations and provide the greatest benefit to the end customer.

Discussion

To date, mobile communication has been dominated by an explosive demand for voice services by consumers. A small but growing category of services is messaging and data, although these services currently have little impact on spectrum utilization . The CDG believes that this scenario will continue to exist in both developed and developing countries. The CDG has committed to introducing a compatible evolution from the current cdmaOne standards to the 3G CDMA2000 standard to meet these evolving demands. This evolutionary transition to CDMA2000, which should begin within the next 18 months, will more than double the voice capacity of exist cdmaOne networks while increasing data throughput by more than six times. The significance of this achievement for the purposes of this inquiry is fairly profound. Put another way, if demand was stabilized at the current levels, the mobile industry would in essence need half the spectrum as a result of this significant achievement. The reality is, however, that demand for basic mobile services is far from stable and the industry is still growing rapidly.

If the issue at hand were merely to characterize the demand for future services, the industry could provide a reasonable extrapolation of demand. History has shown, however, that even these extrapolations can lead to significant margins of error, particularly as technology achievements improve the cost or convenience of services. Furthermore, as we look toward IMT-2000, the Internet and new packet-based services will have a dominant impact on spectrum utilization. We are just beginning to understand how these services may be characterized. All of these issues lead to a degree of uncertainty in trying to estimate spectrum requirements for IMT-2000.

While the CDG recognizes the need to understand how existing spectrum allocations in the US will be affected by the introduction of IMT-2000 services, we believe it is difficult to arrive at an accurate determination of additional spectrum requirements at this time. It is clear from our perspective that operators, and not just those that are CDG members, have yet to quantify the market and specific capabilities needed for IMT-2000 services. It is therefore difficult to determine the amount of spectrum operators will require to deploy 3G. We encourage the FCC to take this under consideration and allow for flexibility in revising spectrum estimates over the next several months.

As stated in the four principles cited above, the CDG is proceeding with an in-band migration approach to IMT-2000 service deployment. We are in the process of assessing what additional spectrum might be necessary for these deployments. Should additional spectrum be required in the US, the CDG would like to work closely with the FCC in outlining creative ways to maximize industry involvement. To that extent, we recommend the FCC revisit the guidelines and process for allocating spectrum.