Before the FEDERAL COMMUNICATIONS COMMISSION  |
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COMMENTS OF THE CDMA DEVELOPMENT GROUP, INC. (CDG) Background CDMA is the newest of the digital wireless interfaces and now, after six years of commercial deployment, reaches over 71 million subscribers. From 1999 to 2000, the number of subscribers increased by over 70 percent. CDMA technologies are licensed to over 75 leading communications manufacturers worldwide. CDMA technology has been adopted by both the U.S. and European standards-setting bodies as an enabling access technology for International Telecommunication Union's (ITU's) IMT-2000. The first commercial third-generation networks in the world, which have been implemented by Korea's SK Telecom and KT Freetel, are CDMA2000 systems. Beyond the networks already operating in Korea, additional CDMA2000 systems are expected to begin operations this year in the United States, Canada, Australia, New Zealand, Brazil, Argentina and Japan. These systems include or will include the following key capabilities and services:
Technological Capabilities CDMA technology makes highly efficient use of available radio spectrum by using spread spectrum transmission techniques. A CDMA network places both voice and data communications into encoded data strings or packet data that are then spread across a range of frequencies for transmission utilizing a code unique to each user. All CDMA packets are fully protected against noise on the radio link with error correction and error detection applied to all information bits in each packet. The packets can be reassembled and sent to a circuit switch, or the data packets can be maintained and sent to a packet switch or standard IP router. Because of limited packet data throughput achievable through other technologies and ease of upgrading a CDMA network, manufacturers and operators are increasingly pursuing CDMA's spectrally efficient solutions for the implementation of next generation systems. In the United States, the Telecommunications Industry Association, in conjunction with the Third Generation Partnership Project 2 (3GPP2), developed a third generation CDMA standard referred to as the Multi-Carrier (MC) mode (also known as CDMA2000) and the European Telecommunication Standards Institute (ETSI) proposed another CDMA-based standard referred to as the Direct Spread (DS) mode (also know as W-CDMA). The CDMA2000 standard includes both a 1X version, employing the standard 1.25 MHz radio carrier bandwidth and a 3X version designed for a 5 MHz bandwidth that is like the DS mode. As noted earlier, the first commercial third generation systems,
CDMA2000 1X systems, are already operating in the Republic
of Korea. In the United States, operators Qwest Wireless,
Sprint PCS and Verizon Wireless began field testing CDMA2000
last year. These operators are expected to deploy commercial
CDMA2000 systems in the second half of 2001. With regard to the ability for first generation and second generation service providers to use its existing spectrum to provide advanced services, CDMA technology provides an option for these operators. The CDMA2000 standard was developed with a philosophy of spectrum independence, and can be used in current bands (e.g., PCS, cellular, NMT) as well as IMT bands. CDMA2000 1X, with its 1.25 MHz bandwidth, can be used to upgrade any existing cellular system without denying services to customers and 1X will nearly double capacity of cdmaOne voice networks. W-CDMA, with its 5 MHz bandwidth, will in most cases require the licensing of new spectrum. With regard to what appropriate steps should be taken, the Commission should be commended for its flexible regulatory policies regarding cellular and PCS that have allowed operators to upgrade their existing networks to meet consumer's demands. The Commission's flexible use policies will likely result in the United States becoming one of the first countries to introduce third generation services to certain segments of the market. This approach is in stark contrast to many other countries that place strict service criteria on a particular band of radio spectrum. An example is Europe's decision to assign particular mobile bands of radio spectrum to specific technologies, thus particular spectrum bands are reserved for second-generation mobile systems (i.e., GSM) and other bands for third generation wireless systems. In the United States, second-generation systems for cellular and PCS systems can upgrade their systems to third generation wireless systems without coming back to the regulator for approval or to pay additional fees. The operator can upgrade its system as the market demands because of the FCC's flexible regulatory approach. The Commission should continue to follow the approach that allows consumers to benefit from technology upgrades without requiring burdensome and lengthy regulatory processes to introduce advanced services. As the Commission examines new technologies for meeting demand for new data services in its decision making process, it must have a clear understanding of the current available technology, what capabilities technologies will offer in the immediate future, and what capabilities are far from being available in the marketplace. The Commission must filter "hype" from reality. Migration Capabilities of CDMA Technology The evolution of the air interface, capability of the core network (ANSI-41), and spectrum flexibility assure that cdmaOne operators with immediate needs for third generation services can deploy them but allows other operators to wait until the market demand exists. The packet data design, which was included in the IS-95 standard from the very beginning, makes the cdmaOne base stations and CDMA handsets packet-data capable today. Thus, CDMA systems do not face the expensive packet data implementation that other technologies face. Additionally, systems are backward compatible and are planned to preserve operators' investments every step of the way. CDMA requires no expensive 2.5 generation interim networks that must be replaced by new third generation systems. Moreover, new CDMA2000 1X handsets enable seamless roaming from network to network and between second generation and third generation systems. One CDG member carrier envisions that it will be able to deploy the technology ubiquitously by simply plugging in new third generation channel cards to its existing base stations and adding software enhancements to base station controllers and base transceiver stations. This U.S. carrier expects that its costs to upgrade its national cdmaOne network to CDMA2000 1X will be a comparatively low $700-800 million dollars. Due to the added voice capacity -- double the second generation capacity of cdmaOne network, as well as higher data rate services, the investment is expected to be recouped quickly because of greater consumer usage and extended business applications. This is far lower than the costs for deploying entirely new third generation networks. Mobilcom of Germany expects to be able to reach 50 percent of the German population with investments of 1.6 billion euros (US $1.405 billion). Considering the difference in size of a national network that covers the United States and one that reaches half the population of Germany, this is a striking difference. Because of the evolutionary path of cdmaOne systems to CDMA2000, operators will be able to upgrade to third generation in their current bands. The CDG recognizes that sizeable investments have already been made in PCS and cellular spectrum bands and believes that in-band evolution to third generation with CDMA technology brings benefits to all operators including greater economies of scale, reduced complexity, reduced time to deployment, and simplified roaming. Operators deploying CDMA technologies will be able to deploy
CDMA2000 in existing bands, as well as new bands, which will
allow operators to save potentially billions of dollars on
new spectrum until their customer base outgrows the spectrum
available. Some of the proposed third generation technologies
need completely new spectrum because there is no evolutionary
path for their current second generation systems. This is
simply not the case for CDMA2000 systems, which can also be
deployed in current bands or in newly identified bands. The
advantage of CDMA technology is hat it provides operators
with maximum flexibility in deploying services. In the NPRM,
the Commission notes that a CDMA system could upgrade their
technology to IS-95B technology. In fact, many CDMA operators
are skipping the IS-95B stage and are In addition to being able to operate in all bands, CDMA2000
can be implemented by both TDMA and GSM carriers. CDMA and
TDMA share the ANSI-41 standard for their network backbone.
Any wireless operator using ANSI-41 as its network standard
can deploy a CDMA2000 system. This is an extremely viable
option for TDMA carriers who are operating under licensing
frameworks that do not mandate specific technology choices.
For example, after initially deploying TDMA digital technology
in November 1993, Bell Mobility of Canada decided to deploy
CDMA technology rather than continuing to incrementally improve
its TDMA system. Bell Mobility is continuing to deploy cdmaOne
and has completed 1X field trials to deliver voice and data
speeds of up to 144 Kbps in Ontario and will begin commercial
deployment of third generation capabilities in late 2001.
Standards Global Roaming and Spectrum Bands Global roaming within the U.S. cellular and PCS frequency bands, which were included in the bands identified by the ITU for IMT-2000, will be difficult to achieve because the use of these particular bands differs across various regions. Many countries in the Americas will allow cellular and PCS operations in the 800 MHz and 1850-1990 MHz bands to upgrade their systems to third generation in those bands as market needs arise (e.g., Argentina, Canada, Chile, Mexico, and Peru). It is important to ensure that these allocations continue. Consumers in these countries will enjoy regional roaming in their current bands for third generation services as operators around the region, including the United States, overlay the advanced systems on their cellular and PCS networks. In addition, many countries in the Americas are considering using the 1710-1850 MHz band for additional frequencies for IMT-2000, although some countries are considering pairing portions of that band with the 2110-2200 MHz band. Although this would enable a "global" downlink in the 2110-2200 MHz band, the problem that arises is that the integrity of the European DCS-1800 band, and any in-band pairing associated with that band, would be lost. Much of the decision of whether pairing that follows the European DCS-1800 band plan is chosen for the United States depends on the availability of the U.S. Government parts of the band (1755-1850 MHz). Thus, to facilitate global roaming and gain economies of
scale, it is critical that spectrum decisions in the United
States be aligned as much as possible with national decisions
that will result from WRC-2000. To this end, the CDG urges
the Commission to identify the maximum amount of spectrum
that is harmonized within our region and throughout the world.
Respectfully submitted, CDMA DEVELOPMENT GROUP, INC. Perry M. LaForge
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