CONSULTA PÚBLICA No. 198/December 3, 1999

Portuguese

 

Table of Contents

1. Executive Summary ………………………………………………………………………………………….. 1

2. Key Factors Affecting Spectrum Allocation ………………………………………………………………. 3

2.1. Market for Mobility Services …………………………………………………………………………….. 3

2.2. Roaming ……………………………………………………………………………………………………. 4

2.3. Economic and Industrial Considerations …………………………………………………………………. 7

2.4. Regulatory and Standards Issues …………………………………………………………………………. 9

2.5. Product Availability ………………………………………………………………………………………. 10

2.6. Spectrum Utilization and Efficienty ……………………………………………………………………… 13

2.7. Evolution of Technologies ………………………………………………………………………………… 13

2.8. Future Implementation of IMT 2000 ……………………………………………………………………… 14

3. Recommendation …………………………………………………………………………………………….. 17

Appendix 1 - Recommended Subdivision of PCS Band ……………………………………………………… 18

Appendix 2 - 1.9 GHz Digital Networks in the Americas ……………………………………………………. 22

Appendix 3 - Operators Offering 1.9 GHz Digital Services in the Americas……………………………….. 23

Appendix 4 - cdmaOne and GSM Cities in the Americas…………………………………………………….. 24

Appendix 5 - Network Maps of the World ……………………………………………………………………. 25

Appendix 6 - CITEL 1900 MHz PCS Spectrum Recommendations .. …………………………………………27

Appendix 7 - CITEL IMT-2000 Spectrum Utilization Principles……………………………………………. 28

Appendix 8 - Handset Price Points …………………………………………………………………………….. 29

Appendix 9 - Licensed Suppliers …………………………………………………………………………….. 30

 

1.0 Executive Summary

The purpose of this report is to present to ANATEL the CDMA Development Group's (CDG) position concerning the allocation of Personal Communications Services (PCS) in Brazil. The following points are discussed in detail, in the order indicated by ANATEL:

1. Market for Mobility Services
2. Roaming
3. Economic and Industrial Considerations
4. Regulatory and Standards Issues
5. Product Availability
6. Spectrum Utilization and Efficiency
7. Evolution of Technologies
8. Future implementation of IMT-2000

These comments are submitted in support of the CONSULTA PÚBLICA Nº 198 process, dated 3 December 1999, to provide ANATEL with industry input relative to which band of PCS spectrum should be allocated by the Brazilian government for terrestrial mobile services, under the premise that it will benefit the public by increasing market competition through the introduction of a third operator. More specifically, ANATEL has requested comments and suggestions on which of the following two possible sub ranges should be considered;

Possibility 1: 2 x 55 MHz in the 1710 - 1785 MHz and 1805 - 1880 MHz ranges, or
Possibility 2: 2 x 40 MHz in the 1870 - 1910 MHz and 1950 - 1990 MHz ranges.

The CDG believes that it is of the best interest of ANATEL and the Brazilian populace to allocate the bands 1850-1910/1950-1990 to increase market competition within Brazil's telecommunications industry. We believe that awarding this spectrum best supports the following objectives:

1) Maximizes roaming, both on a national basis and a regional basis, while later supporting a future global roaming footprint under IMT-2000.
2) Aligns with the PCS spectrum recommendations adopted by CITEL that promotes competition, regional roaming and economies of scale for PCS in the Americas and to the benefit of the Brazilian market; in addition, supports continued regional coordination and harmonization in the use of spectrum within Region 2.
3) Creates an opportunity for service providers to have the flexibility and technological options that maximize their ability to deploy PCS systems in a commercially successful way (i.e. a technology-neutral approach that maximizes market competition by offering operators a variety of technology alternatives).
4) Supports a wide variety of innovative and competitive services (i.e. high-speed data, telematics, global positioning location services, video, etc.) at the earliest opportunity.
5) Supports the purchase of locally available, competitively priced, commercially proven wireless infrastructure networks and ancillary systems.
6) Supports the industry base of locally produced infrastructure and consumer terminal products for the purpose of creating economies of scale and export opportunities.
7) Maximizes the number of wireless devices (handsets) that are configured and commercially available for the PCS band and that can roam on existing IS-41 digital/analog networks.
8) Supports an economic and backward compatible migration path from 2G services to 3G IMT-2000 services.
9) Allows new operators the opportunity to compete against the incumbent operators with a flexible choice of technologies and national/regional roaming footprints.
10) Allows new operators to begin to offer service more quickly and cost effectively by allowing their customers to roam on existing cellular networks before PCS build-out is complete.

Although the CDG does not encourage ANATEL to make spectrum allocations that require the use of cdmaOne or any other specified standard, our organization does believe that cdmaOne is the most appropriate technology to use in the future, considering the explosive demand worldwide for wireless communications.

The CDG believes that the objectives listed above are not met by allocating spectrum in the 1710-1850 MHz band. As will be discussed in greater detail in this document and its appendices, the auctioning of the 1710-1850 MHz band carries the following implications:

1) Interrupts roaming on a national, regional and global basis.
2) Is inconsistent with CITEL's spectrum principles and recommendations for Region 2.

3) Allocates a band that is not being considered as an IMT-2000 band in the near term.
4) Eliminates the possibility of deploying commercially available cdmaOne and TDMA systems.
5) Eliminates the possibility of allowing existing cellular operators, who wish to obtain PCS licenses, to offer integrated services in both the cellular (800 Mhz) and PCS (1900 MHz) bands.
6) Limits the operators' choice of commercially available wireless terminals that are capable of roaming on multiple air interface modes.
7) Limits the growth, economies of scale and export opportunities for products produced by telecommunications manufacturers in Brazil.
8) Eliminates the possibility of deploying an air interface that will have the highest spectral efficiency for voice and high-speed data throughputs.
9) Eliminates the option of selecting an affordable, seamless and evolutionary process to 3G that conserves an operator's investment in the newer technology and minimizes the risk of introducing new services which may be based on uncertain demand.
10) Delays the introduction of 3G related services into Brazil.

Thus, by limiting competition amongst the new and existing Brazilian operators, this allocation would limit the introduction of lower cost basic and advanced telecommunications services to the Brazilian industry and its consumers.

In Europe, the CEPT has indicated that 3G services will be made available in the DCS1800 band only in the long term after it is re-farmed and after the provision for 3G services in the additional IMT-2000 spectrum become available around the year 2010 (Ref: PCC.III/inf. 1458/99).

It is extremely uncertain when and if systems based on DCS1800 will evolve to 3G. Therefore, new operators using the DCS1800 band for PCS in Brazil could be competitively disadvantaged in the near-term and the foreseeable future. It is understood that ANATEL, as the agency responsible for allocating Brazil's spectrum, seeks to ensure that all factors affecting and resulting from the allocation of spectrum are considered. Hence, this document presents a variety of factors for ANATEL's consideration that are deemed important by the CDG and its members.

CONCLUSION

The CDG considers that it is in the best interest of the Brazilian industry, and the general public, to select the 1870-1910/1950-1990 MHz band for PCS services, as presented in this document and its appendices. This allocation supports the deployment of all technologies, including cdmaOne - a leading technology for PCS systems. It allows operators the flexibility to choose the technology they wish to deploy to best meet their unique business objectives. This recommendation is supported by a number of telecommunications companies including VÉSPER, Lucent Technologies, QUALCOMM, Leap Wireless International and Ericsson do Brasil, among others.

The CDG believes when regulation allows the market to approach the maximum number of operators, the larger number of participating operators will maximize the model for approaching perfect market competition, thus distancing itself from the current oligopoly model which is sub-optimal. Therefore, instead of allocating 2 x 20 MHz blocks, the CDG proposes allocating 2 x 5 MHz and 2 x 15 MHz blocks for a total of four blocks arranged in accordance with the channeling plan that is presented in Appendix 1.

2.0 Key Factors Related to the Allocation of PCS Spectrum

The following factors elaborate on the key issues presented for ANATEL's consideration with regard to the allocation of PCS spectrum. Each factor addresses fundamental advantages of allocating the 1900 MHZ band, rather than the 1800 MHz band, for the introduction PCS mobile services in Brazil.

2.1 MARKET FOR MOBILITY SERVICES:
The introduction of PCS services must adequately support the expected growth in demand for mobile telecommunications services in Brazil. In the month of December of 1999, it is forecast that over 1 million new subscribers will be activated in Brazil, mostly due to the popularity of prepaid services (Ref: Global Mobile Daily, December 2, 1999). By the end of the year, Brazil will have as many as 15 million wireless subscribers.

This explosive growth is driving the demand for additional network capacity and the need to allocate additional spectrum for mobile services. Allowing operators to select a wireless technology that utilizes spectrum in the most effective way to meet the demands of the market is a key consideration in the allocation of additional spectrum in Brazil.

Brazilian consumers will also want to take advantage of the new data services that will be enabled through the introduction of IMT-2000 services. The PCS allocation process should therefore ensure that the identified spectrum will allow for the timely migration to these services.

We wish to inform ANATEL that CDMA at 1900 MHz is uniquely suited to accommodate increased demand for services, because it is more spectrally efficient than other digital technologies. The higher order modulation schemes used in the evolution of cdmaOne to high data rate technologies and 3G will enable substantial capacity advantages not achievable with other wireless technology modulation schemes.

By contrast, an allocation in the 1800 MHz band would accommodate only the introduction of GSM technology, which is less spectrally efficient than CDMA IS-95 (cdmaOne) or TDMA IS-136.

With respect to data, the introduction of CDMA services in the 1900 MHz band will ensure a seamless migration to IMT-2000 services. In the United States, as in other markets in the Americas and Asia, cdmaOne operators can evolve their networks to provide IMT-2000 Multi-Carrier1X (MC1X), which has been approved by the ITU as an IMT-2000 standard. MC1X is designed to double an operator's capacity for voice communications and support data transmission speeds up to 144 kilobits per second (kbps). MC1X will be trialed next year by several operators and should be commercially deployed in the year 2001, making it the first commercially available IMT-2000 standard.

By contrast, 1800 MHz spectrum is not even being considered as an IMT-2000 band in the near term. CEPT's contribution to CITEL's PCC 3 meeting in San Diego supported "identification of the GSM 900 and GSM 1800 bands as IMT-2000 expansion bands, to enable refarming of these bands in Europe for IMT-2000 in the longer term."

2.2 ROAMING:
Most Brazilian consumers value the benefit of roaming foremost on a national basis, secondarily on a regional basis and lastly on a global basis. The 1900 MHz band is the only band of spectrum that allows seamless roaming in Brazil and the rest of the Americas.

National Roaming: Brazil currently has an extensive network of Analog, TDMA and cdmaOne base stations in its cities and along the majority of its highways providing Brazilians with close to unlimited roaming within the country. With the allocation of 1900 MHz spectrum, Brazilians subscribing to the PCS service may have the opportunity to purchase one of several handsets:

1) Dual-band digital handsets to roam on the existing digital cellular (800 MHz) networks,
2) Dual-mode/Dual-band handsets to roam on the existing Analog networks, or
3) Tri-mode handsets to roam on the Analog and digital (800 MHz) networks.

Nearly 30 handsets accommodating one or more of these requirements are commercially available at the present time (see section 2.5 Product Availability).

By limiting the allocation for PCS to the 1800 MHz band, Brazilians will be limited to using only the PCS network and possibly the Analog network if GSM handset vendors begin offering dual-mode/dual-band handsets. To date, however, no manufacturer has marketed an integrated handset that accommodates both the GSM-MAP and ANSI-41 network protocols to facilitate roaming between GSM and either IS-136 (800 MHz) or AMPS (800 MHz). Nokia offers the Nokia 6190, but that handset requires the attachment of an external battery-like module accessory that provides the user with AMPS service when outside of the GSM service area.

New PCS operators will require a substantial amount of time and investment to duplicate the level of national coverage that exists in the Analog and Digital Cellular networks currently in operation in Brazil. Allocation of the 1900 MHz band will allow PCS to provide roaming onto cellular networks while they continue to build out their PCS network.

Regional Roaming: By allocating PCS spectrum that is compatible with the spectrum that is currently being utilized and deployed in the Americas, Brazilians will be able to roam seamlessly throughout South America, North America and the Caribbean.

Seventeen Region 2 countries have already allocated or intend to allocate the 1.9 GHz PCS band for mobile and WLL services and 24 operators have already deployed PCS services in this spectrum (See Appendices 2 and 3). No country within the Americas has allocated 1800 MHz spectrum

There are also more cities within Region 2 that offer cdmaOne services in the PCS and Cellular bands than GSM services (See Appendix 4). With the use of trimode cdmaOne handsets, users will be able to roam on the Analog and digital 800 MHz networks.

Global Roaming: By allocating the 1800 MHz frequency band, Brazil will be auctioning a band that is not currently being used on a worldwide basis for 2G services and will not support the evolution to 3G services, in the near to medium term. This will eliminate the possibility of uninterrupted global roaming and isolate Brazil from the rest of the world. Therefore, the key question ANATEL must consider is whether Brazil should take advantage of the worldwide market benefits that are emerging from PCS and IMT-2000, or possibly bear the cost of deploying an isolated system within the Americas that would transform Brazil into an "island."

Because the 1900 MHz band falls within the spectrum identified by the ITU's WARC-92 for IMT-2000, most ANSI PCS operators are planning to use this band to upgrade their 2G networks to provide 3G/IMT-2000 services. By using forward and backward compatible handsets, their roaming agreements will remain intact and their existing base of customers will continue using their 2G handsets in the same spectrum being used to introduce the new 3G services (rather than become stranded due to re-farming spectrum to accommodate a 3G service that uses a different modulation scheme). These 1900 MHz operators will also have access to the newest technologies, innovations and services such as IMT MC (CDMA2000) phases 1X and 3X, well before any 1800 MHz PCS operator will. Please refer to section 2.8, Future Implementation of IMT-2000, for a description of the migration path leading to the near-term availability of these advanced services.

The deployment of 1900 MHz cdmaOne/IS-41 networks is more prevalent than 1800 MHz GSM/MAP networks (See Appendix 5). The majority of 1800 MHz GSM/MAP networks are being deployed in Europe to alleviate congested 900 MHz GSM/MAP networks.

According to Embratur, in 1998 more Brazilians traveled to the United States than any other country in the world (see Figure 1). Furthermore, travel within the Americas surpassed European destinations. Therefore, the importance of having a handset that can roam automatically across the entire Region 2 is substantial. Overall, more Brazilians travel to foreign countries that offer mobile services in the 1900 MHz band, than in the 1800 MHz band.

Figure 1
Brazilian Travel Destinations
(Most Frequently Visited Countries)

To offer global roaming using the GSM standard, the 1900 MHz band will support this service in those countries in the Americas that use the GSM standard and a "SIM" card will permit roaming between 1900 MHz networks and 1800 MHz networks in Europe.

In contrast, a Brazilian operator that deploys a 1800 MHz PCS network will not be compatible with any AMPS network, further limiting national, regional and global roaming. Since roaming is a key factor in obtaining sales, an 1800 MHz operator will be rendered non-competitive with other mobile services who can easily offer expanded roaming services. Therefore, using the 1900 MHz band, which offers automatic roaming within all of Region 2, is fundamental.

2.3 ECONOMIC AND INDUSTRIAL CONSIDERATIONS:
The economic benefits obtained from economies of scale, the preservation of investments and the cost of upgrading a 2G network to provide 3G services are serious factors any operator must consider before purchasing any spectrum.

Economies of Scale: Economies of scale are understood as the savings an operator can obtain by taking advantage of common infrastructure, resources and services for the provision of new telecommunications services. For example, common infrastructure for cellular and PCS operators includes: cell sites, buildings, real estate, towers, power, network management systems, MSC, BSCs, BTSs, and backhaul. Common resources include: management, trained network engineers, consultants, third party product & service providers, test equipment, etc.

Economies of scale are also found in operational expenses such as support organization, network planning, leasing, testing, training, maintenance, transportation and marketing. Allocating spectrum that allows the above economies of scale to be utilized will provide the most competitive service possible. PCS operators deploying an IS-41 based network will be able to immediately obtain equipment for the rapid deployment of their PCS network, draw from the available human resources that are knowledgeable about the technology and, most importantly, reduce their operational expenses to remain competitive.

Handset Price Points: When addressing handset pricing, the commercial availability of the appropriate type of handset must first be addressed. Today, GSM 1800/AMPS handsets do not exist for the Brazilian market. And, when they do become available they will most likely be more expensive than the GSM 1800 handsets currently being used in Europe.

Today in the United States, the wholesale cost of the most popular GSM handsets are approximately equal to the wholesale cost of the most popular cdmaOne handsets. Also, cdmaOne is a maturing technology that will continue to experience cost reductions. The cost of cdmaOne handsets has dropped significantly within the past six months and will continue to drop due to fierce competition from multiple vendors.

As shown in Appendix 8, the majority of the licensed cdmaOne manufacturers are consumer electronic companies that are based in Asia. Because there are substantially fewer GSM and TDMA manufacturers competing for the same market share, those terminal vendors will not witness the same competitive pressure to reduce terminal pricing as will the multitude of cdmaOne terminal vendors who are competing for their own share of a smaller market. Differences in economies of scale are no longer driving the difference in handset pricing.

Investment Preservation: Technologies being deployed in the 1900 MHz PCS band will eventually provide 3G related services such as high-speed data and video. The standards for medium and high-data rates (higher than 14.4 kbps) on a cdmaOne platform are clearly defined. Several operators in Brazil have already deployed IS-95A (14.4kbps circuit and packet data) networks. IS-95B networks that support data transfer speeds up to 64kbps are already commercially available in Korea and Japan. MC1X networks, based on the TIA IS-2000 Release 0 standard, will begin trials in early 2000 and become commercially available in early 2001. This IMT-2000 standard supports vehicular data rates up to 144kbps.

In contrast to the ongoing standards work on both DS and MC3X CDMA, the standard for MC1X is already complete and will therefore be the first 3G technology deployed anywhere in the world. And, it is forecasted that MC3X networks (the evolutionary follow-on phase to MC1X) will begin trials in the year 2002. The availability of the other IMT-2000 standards has not been established yet and could potentially be delayed until the year 2004. The migration from IS-95A (2G) to MC1X/3Xis an evolutionary process that preserves an operator's investment and minimizes the risk of introducing new services that may be based on uncertain demand. The handsets and data devices used on each network are also forward and backward compatible, preserving the investment made by the users of these networks.

Operators that deploy MC1X networks, using a single 1.25 Mhz band, will exceed the ITU's 3G requirements for data rates in pedestrian and indoor/outdoor environments. These MC1X networks will also give operators up to twice the overall capacity available on IS-95A and IS-95B networks for voice communications, up to a 50% increase in handset standby time, a full Internet protocol suite, voice recognition and many other features.

Operators that deploy MC3X networks, using a 5 MHz carrier, will easily and effectively evolve their 3G products and services based on local market requirements and deliver a new breed of feature-rich, voice and data-centric wireless devices to their subscribers.

By contrast, it is not clear that GSM 1800 operators will be in a position to evolve their networks to IMT-2000 functionality. As previously noted, CEPT has decided that the 1800 MHz band cannot be a candidate for IMT-2000 services until current licenses expire and member governments re-farm and then re-allocate the spectrum.

Future Economic Considerations: The cost of installing a 2G wireless network to support 3G services is a key consideration for any operator intending to purchase new spectrum. A recent economic study compared the 5-year cumulative capital expenditures (CapEx) and Operating Expenditures (OpEx) associated with migrating from cdmaOne to IS-2000 (MC1X) versus GSM to GSM/EDGE. The study compared the two network scenarios using geographical data and traffic levels (voice/fax/web/data/e-mail) expected in a large city like Geneva between the years 2000 and 2005.

The cost model considered CapEx items such as sites, base stations, base station controllers, mobile switching center and the core network, as well as site acquisition and installation costs. The cost model also considered OpEx items such as planning, engineering, site rental, leased lines, maintenance costs, site utility costs and the subsidization of handsets.

The results demonstrated that the cdmaOne/IS-2000 (MC1X) migration path holds significant economic benefit over the GSM/EDGE migration path. An operator can save approximately 70% in capital expenditures and 80% in operating expenditures over 5 years by migrating to IS-2000 (MC1X), as compared to GSM/EDGE.

2.4 REGULATORY AND STANDARDS ISSUES:
An allocation of spectrum that is consistent with existing regulatory recommendations and allows an operator the flexibility to select from a variety of network and air interface standards will maximize the ability to deploy a competitive PCS service within Brazil and the Americas.

Regulatory Recommendations: Brazil has historically taken a leadership role in determining the allocation of spectrum within the Americas and has been actively involved in the IMT-2000 standardization process. In fact, Brazil chaired the CITEL Working Group that adopted Recommendation PCC.III/REC.8(III-95) which proposes the use of the 1850-1990 MHz band for Personal Communications Services. Brazil also agreed to harmonize their standards and spectrum as much as possible under the Organization of America States (OAS) agreements (e.g. Under the Summit of the Presidents in 1992).

Pursuing the appropriate band of PCS spectrum would facilitate these agreements and help provide the benefits envisaged by the agreements for the benefit of Brazil and the countries of the region. Brazil's continued leadership and support for these agreements is important to the economic vitality of the region. The CDG applauds Brazil's participation in these processes and welcomes the opportunity to provide industry input to support the allocation of PCS spectrum in Brazil.

Allocating spectrum within the 1870-1910/1950-1990 MHz band is consistent with the recommendations and spectrum utilization principles set forth by CITEL for the implementation of the terrestrial component of PCS and IMT-2000. These recommendations and principles, presented in Appendix 6 and 7, considered all of the regional coordination and harmonization issues related to allocating spectrum in Region 2 and the rest of the world. They clearly state that the 1850-1990 MHz PCS band can be allocated for PCS and IMT-2000 terrestrial mobile services even though it is part of the core IMT-2000 band.

It is also worth mentioning that the Brazilian administration has set a precedent by allocating spectrum within the 1900 MHz band to the consortia that have purchased mirror licenses to offer basic telephony services using Wireless Local Loop (WLL) technology. In the year 2002, these companies have the option to request mobility licenses. When they do, they will want to be assured that they will have the opportunity to establish roaming agreements with those PCS operators that will be operating in adjacent geographical regions. They will not be able to do so if the new PCS operators have deployed services in the 1800 MHz band.

Technology Neutral Alternatives: Allocating spectrum in a technology-neutral manner that supports the largest number of wireless technology choices will provide the best opportunity to enhance competition. Operators should be assured of having the benefit of readily available, competitively priced, commercially proven wireless infrastructure systems and handsets for immediate deployment in Brazil. Allocation of the CITEL 1900 MHz PCS band provides this opportunity for each of the three most widely deployed wireless standards in the world; GSM, cdmaOne and TDMA. Allocation of the European DCS 1800 MHz PCS band provides only one widely used technology option, GSM, which currently lacks a seamless migration path towards IMT-2000 services.

The CDG does not encourage ANATEL to allocate spectrum that will require the selection of any specific standard, but our organization does want to stress that CDMA is one of the technologies selected for 3rd generation services and that it will be the basis for most future wireless communications. For this reason, the PCS allocation in 1900 MHz band will allow new operators to deploy the technological and economic benefits of cdmaOne technology earlier, rather than later with 3rd generation services.

2.5 PRODUCT AVAILABILITY
The near-term availability of a wide selection of network equipment, handsets, test equipment and ancillary products is critical for any operator who is considering the deployment of a mobile communications service.

Strong Industry Base: Allocating spectrum that could utilize Brazil's industrial base of local manufacturers who are producing IS-41 based equipment will accelerate the deployment of new PCS services and introduce additional economies of scale. By leveraging this industry base, operators will be able to enter the Brazilian market sooner, offer lower service prices, remain competitive with existing wireless operators and reach wider segments of the Brazilian population.

The number of cdmaOne users in service has exceeded 41 million subscribers worldwide, 157% higher than last year. In Brazil alone, over 2 million cdmaOne subscribers are in service today. Several vendors, such as NEC do Brasil, Motorola, Lucent, Samsung and Nokia are manufacturing cdmaOne network equipment and handsets locally. As shown in Appendix 9, and summarized in the table below, the technology is supported by a significant number of manufacturers worldwide.

Table 1: Comparison of Licensed Manufacturers

Table 2 shows the 1900 MHz and 1800 MHz infrastructure manufacturers which have no network deployments in Brazil yet.

Table 2 Manufacturers with no deployment in Brazil

 

 

The number of TDMA users in service has exceeded 30 million subscribers worldwide and, in Brazil alone, close to 3 million TDMA subscribers are in service today. Several vendors, such as Ericsson, Nortel and Nokia are manufacturing TDMA network equipment and handsets locally.

The number of GSM users in service has exceeded 215 million subscribers worldwide; however, there are no users or industry base in Brazil supporting this technology. The introduction of a manufacturing base for GSM-MAP technology, required by the DCS 1800 MHz band, will increase an operators risk of failure if the production of GSM equipment cannot be sustained. As a result, R&D and all other investments will be much smaller as compared to those made by established IS-41 based manufacturers. Even though the companies that support the production of 1800 MHz equipment insist on the possibility of exporting GSM equipment to the entire world; reality will prove that Brazil will not only lose the possibility of exporting 1900 MHz equipment to neighboring countries, but will also become a major importer of GSM equipment from Europe and Asia. Thus, the industrial base, as well the Brazilian trade balance, will be affected.

By contrast, the availability of IS-41 based equipment is abundant in Brazil. Increased economies of scale will continue to exist because the procurements being made by Telefonica, Telesp, BCP, ATL, Ameritech, Global Telecom, Vesper, etc. will continue to allow their existing suppliers to meet the future demand for wireless communications through realistic investment plans that use their own existing industrial base.

Also, 1900 MHz PCS networks will become available and delivered much sooner than any other equipment that is based on a foreign technology. The new PCS operator will be able to capitalize on the advantages of a quick deployment strategy that will maximize capacity and coverage. For example, Global Telecom rolled-out their cdmaOne network in Brazil in less than three months because the equipment and network planning resources they needed were available locally and they required less cell sites to provide coverage equivalent to that of their competitor.

Regarding CDMA, the number of licensed suppliers of cdmaOne equipment is much greater than that of GSM (See Appendix 9). Therefore, cdmaOne suppliers that develop products based on the IS-95 open standard are assured of providing interoperable equipment, increasing competition and offering the carrier less dependence upon a single supplier.

Handset Availability: The commercial availability of handsets is a crucial factor when considering the allocation of spectrum. Operators who have purchased PCS licenses or have merged with another operator that has a PCS license are demanding the delivery of dual-mode/dual-band and tri-mode handsets to allow their subscribers to roam on both the Analog and digital cellular (800 MHz) networks. Dual-mode/dual-band handsets allow users to access digital PCS and Analog (800 MHz) networks. Tri-mode handsets allow users to access digital PCS, digital cellular and Analog networks.

Today, there are more than fifteen dual-mode/dual-band cdmaOne handsets, zero dual-mode/dual-band TDMA handsets, and only one dual-mode/dual-band GSM handset. The single dual-mode/dual-band GSM handset, the Nokia 6190, is configured for the 1900 MHz PCS band and requires the attachment of a bulky and expensive Analog module to provide the dual-mode/dual-band service. All of the cdmaOne handsets integrate the multi-mode service into the handset's internal circuitry.

There are seventeen tri-mode TDMA handsets, nine tri-mode cdmaOne handsets and zero tri-mode GSM handsets commercially available today.

So in effect, there are zero GSM multi-mode handsets available today that operate in any cellular band (Analog or digital) and the 1800 MHz band. In fact, one leading handset vendor has dropped its long-awaited multi-mode handset from its product line because it was considered too large, unattractive and would impede its other handset sales. In conclusion, while the 1900 MHz band offers a variety of commercially available handsets, the 1800 MHz band only offers uncertainty and the promise of future developments, which inevitably will require the transfer of these development costs to the consumer.

Export and Trade: Because there are several manufacturers producing CDMA and TDMA equipment in Brazil, the allocation of 1900 MHz spectrum will allow them to expand their operations and consider exporting their goods to Mercosul and other foreign countries. With regard to trade, this would be a healthy alternative since Brazil's largest trading partners are the United States and Latin America. Trade with the United States and many other countries within Latin America who have implemented the CITEL PCS band, account for close to 60% of Brazil's exports and 40% of its imports (See Figure 2).

GSM equipment is almost entirely manufactured outside of the Americas. The equipment will need to be imported most likely from Western Europe and China.

Figure 2:
1998 Brazil Export Volumes

Source: Siscomex 1998

 

2.6 SPECTRUM UTILIZATION AND EFFICIENCY
Spectrum Utilization: The terrestrial component of IMT-2000 is intended to operate worldwide in the 1885-1980 MHz and 2110-2170 MHz band. Several Region 2 countries have already auctioned parts of this frequency band to provide their constituents with mobile PCS and WLL services. Current PCS operators who intend to offer IMT-2000 services in the future will incorporate 3G technologies and services in their existing networks.

Clearing of Spectrum: The need to clear spectrum depends on whether there is interference from adjacent-band radio frequency services, point-to-point/multipoint microwave systems, or the existence of pirates illegally using the band. For instance, Embratel has a point-to-point and point-to-multipoint microwave systems operating in the 1.8 GHz band and does not want to be forced to refarm. On the other hand, because the mirror companies offering WLL services in the 1910-1930 MHz band will need to clear spectrum for their service; by default, their efforts will also clear spectrum in the adjacent 1.9 GHz PCS bands.

Spectrum Efficiency: As mentioned previously, another major consideration in the allocation of spectrum is the efficient use of this scarce resource. Spectral efficiency is achieved primarily through the use of spectrally efficient technologies. For example, the Enhanced Voice Rate Vocoders (EVRC) used in cdmaOne networks are more spectrally efficient and provide the best clarity in communications and call handling. The evolution of cdmaOne towards higher order modulation schemes that are used in MC1X, and other CDMA based 3G technologies will enable substantial capacity advantages not achievable with other wireless technology modulation schemes.

2.7 EVOLUTION OF TECHNOLOGIES:
The evolution of wireless technologies in Brazil is being driven by a variety of factors. Most operators will prefer to have an economic and backward compatible migration path from 2G services to 3G services to preserve their investments and reduce their risks. To ensure that IMT-2000 standards met operators business needs, the Operators Harmonization Group (OHG) established a set of requirements for IMT-2000. The OHG requirements related to spectrum issues are:

1. Maximize ability of customers to roam with their services across regions, countries and systems.
2. Provide a smooth and compatible evolution path from existing infrastructures.
3. Accommodate regional needs for different spectrum allocations.

These requirements were incorporated into the ITU's development of the IMT-2000 Recommendations and Family of Systems concept that supports evolution of 2G networks and ensures interoperability among networks, different spectrum plans and standards.

Based on public announcements to date, market trials of MC1X and MC3X will occur in 2000. As such, 3G services should be commercially available in the 1900 MHz band by the year 2001.

Consequently, after the year 2005, the number of subscribers using cdmaOne and 3G CDMA (IMT-2000 MC and DS) handsets will surpass the number of subscribers using GSM handsets. Within the first six years of the 21st century, CDMA will become the dominant air interface and will remain so well into the next millenium. Figure 3 presents the future market share of the major wireless air interfaces.

Figure 3
Market Share of Air Interfaces

 

2.8 FUTURE IMPLEMENTATION OF IMT-2000:
The future implementation of IMT-2000 is a key consideration in the allocation of additional spectrum. Most operators will want to be assured that they will have the ability to offer IMT-2000 services as soon as possible to build and maintain their competitive posture. Several proposals are being considered by member states, regulatory bodies, service providers and manufacturers to lay the groundwork for a well-coordinated and harmonized approach to meeting this objective.

During WARC 1992, the ITU identified the ranges of 1885 MHz to 1980 MHz and 2110 MHz to 2170 MHz for terrestrial IMT-2000 services (formerly FPLMTS), but did not preclude evolution to IMT-2000 in other frequency ranges. Subsequent to this, CITEL/PCC.III further recommended that each member state adopt evolution strategies for IMT-2000. Ongoing work is taking place at the present time to reach a regional position on spectrum allocation for WRC-2000.

An allocation in the 1900 MHz band would facilitate the introduction of both CDMA IS-95 and TDMA IS-136 based terrestrial systems, which would not be available at 1800 MHz. These standards are forward-compatible with two of the modes of the proposed IMT-2000 standard, and will allow Brazilian PCS operators to quickly deploy third-generation services in a cost-efficient manner. Figure 4 illustrates an example of how cdmaOne will evolve to the CDMA MC IMT-2000 mode that would be available to a Brazilian operator with a 1900 MHz license:

Figure 4
cdmaOne to 3G CDMA MC (3X) MIGRATION PATH

 

The IMT-2000 MC1X standard has already been completed by the Telecommunications Industry Association (TIA) and has been recommended by TG 8/1 for adoption next year by the ITU-R. It will be the first IMT-2000 standard deployed, with trials scheduled for early in the year 2000.

Within the next few months, various cdmaOne operators will launch commercial operations, using the IS-2000 standard, using a 1.25 MHz band within the UMTS spectrum for IMT-2000. In 2002, these same operators and many others who obtain 3G IMT-2000 licenses, will be able to commercially launch 3G MC 3X services using a 5 MHz band within the existing cellular band, 1900 MHz PCS band and any other frequency band that has been identified for the future provisioning of IMT-2000 services.

The commercial rollout of 3G MC 3X services in the 1900 MHz PCS band will exist in Asia and the Americas (including Brazil) before the availability of 3G DS (W-CDMA) services in Asia (i.e. NTT DoCoMo) and much earlier than 3G DS services in the 1800 MHz band, as shown in Figure 5.

Figure 5
Rollout of 3G Services

 

Conversely, if the 1710-1785/1805-1880 MHz band were allocated for PCS Brazilian operators would be limited to 2G or 2.5G mobility technologies which are less attractive than the CDMA evolution to IMT-2000. Thus, the differentiation of services implied in this decision would actually decrease the amount of spectrum available for IMT2000 in Brazil. The reason for this is the GSM standard - the only technology that could be deployed at 1800 MHz - utilizes a TDMA radio interface that is not as spectrally efficient as the IS-95 CDMA radio interface. Within the 1900 MHz PCS band, the spectral efficiency of cdmaOne using an EVRC vocoder is 9.5 Erlangs/Sector/MHz, as compared to 4.0 Erlangs/Sector/MHz for TDMA and 1.4 Erlangs/Sector/MHz for GSM using a 3-sector deployment and N=7 frequency reuse pattern for GSM1900 and TDMA1900.

With respect to the availability of 3G services, ORANGE, a leading GSM operator in the United Kingdom, recently stated that GPRS would not be commercially available until the very end of 2000, and then offer only 14.4 Kbps speeds for data. Orange also stated that "EDGE" services would follow "in 2002 or 2003" and DS CDMA would not be rolled out until "2005 at the earliest." (Global Mobile Daily 12/8/99)

At a time when the world's major operators and vendors are moving their R&D efforts toward CDMA an allocation that only allows for a TDMA-based network would appear to be short-sighted, particularly given these conservative claims regarding "2.5G" product availability and quality.

While the WRC-2000 is considering the identification of additional spectrum for IMT-2000, there exists a clear agreement amongst the specialists that the identification of a single band of spectrum that will support global roaming should not exclude Europe and the United States.

In this regard, the 1800 MHz band is considered as an attractive band for IMT-2000 by many Region 2 countries. However, in its contribution to the XIV meeting of PCC 3, CEPT stated that it would support identifying 1800 MHz for IMT-2000 "in the longer term" once existing licenses have expired and the frequencies have been re-farmed by governments. Given the length of existing licenses and the length of time required to re-farm and re-issue licenses for IMT-2000, it would appear that IMT-2000 would not be deployed in this band until after 2010.

Therefore, it is suggested that the 1710-1785 MHz allocation can wait until the international community, including WARC and CITEL, agrees on a 3G-migration plan for this lower frequency band.

3.0 Final Recommendation

In conclusion and based on all of the reasons presented above, the CDG recommends that ANATEL allocate the 1870-1910 MHz and 1950-1990 MHz band for PCS systems in Brazil and maximize the number of new operators by allocating up to 80 MHz of bandwidth in 2 x 5 MHz and 2 x 15 MHz blocks, perAppendix 1. We also recommend to reserve the band 1710-1850 MHz for a future use, since the issues related to the identification of this band are defined at the level of CITEL and WARC.

Appendix 1 - Recommended Band Plan for Subdivision of the 1850-1990 MHz Band Where Used For PCS

BACKGROUND:
ANATEL, the Brazilian Regulatory Commission, called on December 6, 1999 for a public consultation on frequency allocation for terrestrial mobile communications with an emphasis on PCS. The agency seeks to optimize the use of the spectrum and the decisions taken by the International Telecommunications Union (ITU) and Inter-American Telecommunications Commission (CITEL).

At the WARC 1992, the ITU identified the ranges of 1885 MHz to 1980 MHz and 2110 MHz to 2170 MHz for terrestrial IMT-2000 services, formerly FPLMTS. Subsequently, supporting the evolution of existing (pre-IMT-2000) systems, the ITU developed ITU-R M.1308 that addressed coexistence issues, compatibility between second and third generation systems and the need for flexibility to provide for multi-environment, multi-mode and multi-band capabilities.

At the 1995 Meeting in Mexico City, a CITEL/PCC.III study group chaired by Brazil reached regional agreement on identifying the range of 1850 MHz to 1990 MHz for PCS in the Americas, and recommended an FDD channeling plan based on allocations of 2 x 5 MHz and 2 x 15 MHz (reference). To date, multiple countries and operators in Region 2 have implemented PCS systems in the 1850-1910/1930-1990 MHz frequency range and many others are planning to follow (See Appendices 2 and 3). CITEL/PCC.III has further recommended that each member state adopt evolution strategies for IMT-2000, and ongoing work is currently taking place to reach a regional position on spectrum allocation to WARC.

In 1998, when Brazil auctioned its B-Band cellular licenses, the Brazilian government made the decision to delay licensing the use of PCS spectrum for mobile services until the year 2000 to encourage build-out of the new cellular infrastructure. Today, a year and a half later, ANATEL is proceeding forward with the process of allocating additional PCS mobility licenses, under the premises that it will benefit the public by increasing market competition and counteract inefficiencies created by a duopolistic industry structure.

In the public consultation, the agency wants to verify the possibility of using the following two sub ranges:
Possibility 1: 2x55 MHz in the 1710 MHz to 1785 MHz and 1805 MHz to 1880 MHz ranges, or
Possibility 2: 2x40 MHz in the 1870 MHz to 1910 MHz and 1950 MHz to 1990 MHz ranges.

RECOMMENDATION:
For a number of reasons that have been stated in Section 2.0 of the document and in the ensuing discussion, the CDG considers that it is in the best interest of the Brazilian industry, and the general public, to select the 1,870 MHz to 1,910 MHz and 1,950 to 1,990 MHz ranges and allocate up to 80 MHz of bandwidth in 2 x 5 MHz and 2 x 15 MHz blocks.

It is the CDG's belief that if a spectrally efficient technology like cdmaOne or IMT-2000 MC1X were to be deployed in the PCS band, an operator will have enough capacity to provide service to as many as 6 times more subscribers in the smaller 80 MHz bandwidth (2 x 40 MHz possible in the 1.9 GHz band) than an operator deploying GSM in the larger 110 MHz bandwidth (2 x 55 MHz possible in the 1.8 GHz band), assuming a 3-sector, N=7 reuse pattern.

The CDG also suggests that the spectrum allocation rules be written such that the number of operators that can utilize the spectrum be maximized. A larger number of participating operators will maximize the model to approach perfect market competition and distance itself from the current oligopoly model which is sub-optimal. Therefore, instead of allocating 2 x 40 MHz blocks, the CDG proposes allocating 2 x 5 MHz and 2 x 15 MHz blocks for a total of four blocks arranged in accordance with the following channeling plan. This would provide operators the flexibility to obtain either 5, 10,15, 20 or 25 MHz of paired spectrum, according to their specific needs.

CDMA DEVELOPMENT GROUP RECOMMENDED CHANNELING PLAN

• Band 1870-1885/1950-1965 MHz (PCS band B/B') for the new PCS operator
• Bands 1885-1890/1965-1970 MHz & 1890-1895/1970-1975 (PCS bands E/E' & F/F') for the 2 incumbents
• Band 1895-1910/1975-1990 MHz for a second/future PCS operator if/when market allows (or IMT-2000 reserve) Note: 5 MHz, protection guardbands may be required within the 1910-1930 MHz WLL band.

The above 1.9 GHz channeling plan considers the following spectrum allocation decisions already made and in consideration by ANATEL:

• FDD WLL in PCS bands 1850-1855/1930-1935 MHz (A/A') allocated for the incumbent, 1855-1860/1935-1940 MHz for incumbent expansion.
• Bands 1865-1870/1945-1950 MHz (D/D') allocated for the mirror company, 1860-1865/1945-1950 MHz for mirror expansion.
• Band 1915-1920 MHz for the mirror company, 1910-1915 MHz for mirror expansion: only if coexistence with FDD occurs, otherwise becomes protection guard band.
• Band 1920-1925 MHz for the incumbent, 1925-1930 MHz for incumbent expansion: only if coexistence with FDD occurs, otherwise becomes protection guard band.

Representing the joint interests of its constituency, the CDG considers that it would be premature for the regulatory process to designate spectrum within the 1710 MHz to 1785 MHz and/or 1805 MHz to 1880 MHz ranges. CITEL has not reached a consensus about the use of these bands for mobile services in the Americas. Furthermore, such a measure would be sub-optimal and would limit the objectives of promoting fair competition amongst the new and existing Brazilian operators, which in turn will limit the introduction of lower cost basic and advanced telecommunication services to Brazilian consumers.

Portions of the 1850 MHz to 1990 MHz range has already been allocated in Brazil for the concessioned and authorized WLL companies. Brazil has already allocated 1850-1870/1930-1950 MHz and 1910-1930 MHz spectrum for WLL -- deployment of which is currently underway. And in the future, mobile/fixed wireless convergence will position this platform for PCS services.

The PCS systems available in the 1870-1910/1950-1990 MHz bands are compatible with the WLL systems operating in the range 1850-1870/1930-1950 MHz. The TIA, the ANSI accredited standards body responsible for those standards that are used for the PCS systems and their WLL applications, have analyzed and approved recommendations to ensure compatible operation of these systems in adjacent bands. With respect to the operation of WLL in the 1910-1930 MHz band and PCS systems operating in the adjacent bands, CITEL has conducted studies and developed a report that can be used to ensure compatible adjacent band deployment of these two applications.

In the CDG's view, the allocation of the band 1870-1910/1950-1990 MHz for PCS would be the most effective way for Brazil to utilize these frequency bands in both the nearer and longer terms. Because of the current and future allocation of this band for PCS and IMT-2000 in other countries, the CDG does not expect that there would be other alternative applications commercially available for use in this band.

The proposed frequency plan in the 1870-1910/1950-1990 MHz band promotes fairness and competition, as well as provides a level playing field for the new PCS operators. Brazil would find it difficult at this point to change the path already started in 1.9 GHz and depart to a more risky position based on 1.8 GHz that would be limited by the existing UMTS artificial separation of service modes among different mobility bands. An in-band migration strategy for the 1.8 GHz band to third generation is being positioned in Europe for the distant future. CEPT has indicated that 3G services will be made available in the DCS1800 band after it is refarmed and after the provision for additional IMT-2000 spectrum becomes available in the year 2010 time frame.

The availability of spectrum efficient technologies today, makes the 1870-1910/1950-1990 MHz band a more valuable option. The 1710-1785 MHz allocation can wait until the international community, including WARC and CITEL, agrees on a 3G-migration plan for this band. Although the US government activities are seeking to expand the existing mobility spectrum, today only the 1710-1755 MHz range is planned to be available for commercial services in that country and the future 1755-1850 MHz range is still being studied because of its current use by the US government.

The 1710-1785/1805-1880 MHz range if allocated for PCS would be limited to 2G/2.5G mobility technologies - the differentiation of services implied in this decision would actually decrease the amount of spectrum available for IMT-2000 in Brazil. Conversely, if regulators categorize IMT-2000, PCS and Cellular as equivalent services; the entire 50 MHz bandwidth of cellular spectrum in the 800 MHz band plus the entire 120 MHz bandwidth of 1.9 GHz FDD can provide 170 MHz of total evolutionary IMT-2000 spectrum.

Furthermore, an allocation in the 1710 MHz to 1785 MHz and 1805 MHz to 1880 MHz ranges would carry the following disadvantages: deviate from CITEL's PCS spectrum allocation recommendations for Region 2; limit operators' choice of different wireless technologies to the benefit of a reduced number of manufacturers; increase costs of roaming on a global, regional and national basis; delay the introduction of 3G related services into Brazil indefinitely; and finally, limit the trade potential for products produced by Brazilian telecommunications manufacturers.

Appendix 2 - 1.9 GHz Digital Networks in the Americas

Region 2 Countries Considering/Deploying 1.9GHz Digital Networks

 

Appendix 3 - Operators Offering 1.9 GHz Digital Services in the Americas

Status of Operators in Region 2 Offering 1.9 GHz Digital Services

 

Appendix 4 - cdmaOne and GSM Cities in the Americas

Appendix 5 - Network Maps of the World

 

Appendix 6 - Subdivision of the 1850-1990 MHz Band Where Used For Personal Communications Services

PCC.III/REC.11(III-95)

SUBDIVISION OF THE 1850-1990 MHz BAND WHERE USED FOR PERSONAL COMMUNICATIONS SERVICES

The Third Meeting of the Permanent Consultative Committee III: Radiocommunications,
Considering:
That PCC.III has adopted Recommendation PCC.III/REC.8(III-95) relating to the use of the band 1850-1990 MHz for Personal Communications Services;

That in order to promote the orderly development and licensing of PCS within this band, it would be useful to identify specific sub-bands along with recommended pairing designations;

That introduction of PCS and the consequential coordination and/or relocation of existing services within the band 1850-1990 MHz will be facilitated by the use of common sets of sub-bands within this range.

Recommends:
That where CITEL member countries are planning introduction of PCS in the bands 1850-1990 MHz, they should be encouraged to consider the sub-band designations indicated in the "Annex" to this recommendation.

Instructs the Executive Secretary of CITEL:
To distribute this Recommendation to all the members of PCC.III.

Annex

* Notes:
1. Some countries use this band for low power stations.
2. Some countries do not require license to operat these bands.

 

Appendix 7 - CITEL Spectrum Utilization Principles for the Terrestrial Component of IMT-2000

The following principles were documented in CITEL's Final Report from the XI Meeting of the Permanent Consultative Committee III: Radiocommunications, Sep. 14, 1998, Lima, Peru. These principles state that the 1850-1990 MHz PCS band can be allocated for terrestrial mobile services even though it is part of the core IMT-2000 band.

1. Since most of the Personal Communications System's (PCS) bands lie in frequency spectrum already identified for IMT-2000 use, they can be considered as core IMT-2000 bands in the countries that chose to use the PCS bands.

2. Depending on market demand, a future worldwide IMT-2000 band could be considered to satisfy WRC-99/00 agenda item 1.6.1, while recognizing the need to avoid disrupting other radio services

3. All existing frequency bands allocated to the mobile service for which first or second generation mobile (cellular and PCS) systems are in operation could be used for IMT-2000 in allocation within the Radio Regulations.

4. The use of spectrum for IMT-2000 systems should continue to be at the discretion of Administrations.

5. There should be no distinction or prioritization within the Radio Regulations about the use of spectrum for IMT-2000 systems.

6. Some future IMT-2000 applications may require very high data bit rates where the user is likely to be stationary. For such applications, it may be possible to utilize frequency bands above 3GHz, if the results of TG 8/1 studies demonstrate that spectrum will be required for these applications.

7. Given limitations in available frequency spectrum for IMT-2000, it should be determined whether certain IMT-2000 applications can share with other IMT-2000 operating environments and/or other radio services.

 

Appendix 8 - HANDSET PRICE POINTS

Appendix 9 - CDMA, GSM and TDMA Licensed Suppliers cdmaOne - Licensed Suppliers

cdmaOne Licensed Suppliers
Infrastructure	Subscriber Equipment		Test Equipment
Ericsson	ACER	Mitsubishi	Advantest
Fujitsu	Alps	Motorola	Ando
Hitachi, Ltd.	Appeal	NEC	Anritsu Corporation
Hughes Network Systems	Asuka	Neopoint	Comarco Wireless
Hyundai	AT&T	Nixxo	Grayson Electronics
LGIC (Goldstar)	Casio	Nokia	Hewlett-Packard
Lucent Technologies	Compal	OKI	IFR Systems
Motorola	Denso	Pantech	Japan Radio Co., LTD.
NEC Corporation	Ericsson	Philips	LCC
NORTEL	Fujitsu	QUALCOMM	Marconi
QUALCOMM	GTRAN	Samsung	Motorola
Samsung	Haita	Sanyo	QUALCOMM
	Hanwha	Seiko	Racal Instruments
	Hitachi	Sewon	Rohde Instruments
	Hughes	Sharp	Safeco
	Hyundai	Siemens	Sage Instruments
	Kenwood	Sierra Wireless	Tektronixs
	Kokusai	SK Telecom	Wavetek
	Kyocera	Sony
	LG Electronics	Tellit
	LGIC (Goldstar)	Telson
	Lucent	Toshiba
	Matsushita	Uniden
	Maxon	United Computer & Telecom

GSM - Licensed Suppliers
Infrastructure	Subscriber Equipment
Alcatel	Alcatel	Motorola
Ericsson	AEG	NEC
Lucent	Ascom	Nokia
Motorola	Benefon	Nortel
Nokia	Dancall	Orbitel
Nortel	Ericsson	Panasonic
Siemens	Hagenuk	Philips
	HFCL	Sagem
	Matsushita	Samsung
	Maxon	Siemens
	Mitsubishi	Sony

TDMA - Suppliers*
Infrastructure	Subscriber Equipment
Ericsson	Ericsson
Lucent	Gradiente
Nortel	Lucent
	Motorola
	Nokia
	Sony
* TDMA - No license required.