Comments on the Personal Mobile Service in the 'C' Band  |
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Anatel
The CDMA Development Group (CDG) is pleased to provide these comments in the Public Consultation 294 of April 25, 2001 regarding the proceeding for Personal Mobile Services - C band. In the interest of harmonizing at least part of the third generation spectrum, the CDG recommends that Anatel should consider reserving the C band for possible IMT-2000 use. The frequencies included in the C band, 1725-1740 MHz/1820-1835 MHz are currently being discussed as options for IMT-2000 deployment in the region and licensing the C band at this time may preclude its use for IMT-2000 in the near term. With the expected build-out requirements that will be imposed by Anatel, the SMP carriers will only be able to utilize second generation equipment in that band as it is currently configured. If Anatel holds the band in reserve, Brazil will support the deployment of third generation systems in a manner consistent with most of the region and contribute to the effort of establishing some regional harmonization in the 1.7 GHz band for third generation. The CDG The CDG is a non-profit international trade association of over 100 companies, including the world's leading manufacturers and operators of digital cellular and personal communications services (PCS) systems based on Code Division Multiple Access (CDMA) technology. The CDG's mission is to lead the rapid evolution and deployment of CDMA-based systems, based on open standards and encompassing all core architectures, to meet the needs of markets around the world in an emerging, information-intensive environment. CDMA is the newest of the digital wireless interfaces and now, after six years of commercial deployment, reaches over 81 million subscribers, including over 22 million data and Internet users. From 1999 to 2000, the number of subscribers increased by over 70 percent. CDMA technologies are licensed to over 95 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 were implemented last year by Korea's SK Telecom and KT Freetel and are CDMA2000 systems. These systems are being deployed in the 1740-1770 MHz/1840-1870 MHz frequency bands.1 Beyond the networks already operating in Korea, additional CDMA2000 systems are expected to begin operations this year in Brazil, Argentina, Australia, Canada, China, United States, Japan, and Malaysia. These systems include or will include the following key capabilities and services:
Anatel should reserve the C Band for third generation services Although certain CDG members have deployed CDMA technology in the 1.7 GHz band, the CDG urges Anatel to consider reserving the C Band for third generation services rather than auctioning this spectrum at this time. The CDG fully understands Anatel's desire to create a competitive market, and applauds its efforts to do so. The four mobile licenses per region that have been issued by Anatel are bringing mobile services to an unprecedented number of consumers in Brazil. Competition will be further increased in the wireless market when wireless local loop licensees will be able to apply for authorization for full mobility after 1 January 2002. Given this level of competition, the current state of discussions taking place on spectrum regionally and internationally, and the consequences of licensing second generation technology in spectrum that is likely to be used for third generation within the region, Anatel should consider delaying its proceeding on the C Band in this instance. In the Americas, the first third generation implementation will be in the 800 MHz and 1.9 GHz bands. In Brazil, Telesp is planning to deploy IMT-2000 later this year in its cellular bands.2 In the United States, Verizon is also planning on deploying IMT-2000 in its cellular (and PCS) bands later this year. The Korean companies that have deployed cdmaOne system in PCS spectrum to IMT-2000 starting later this year through the middle of 2002. However, because no third generation equipment is available for the C band as of yet, a decision by Anatel to proceed with the auction for the C band at this time will limit bidders' choices to utilizing second generation equipment in a band that may well have third generation capabilities deployed throughout the region within a few years. By licensing the C band now and requiring the usual build-out and implementation of systems within the very short-term, Anatel will preclude the possibility of implementation of third generation technologies that are not available at this time in the C band, but are likely to be available in the next few years. Auctioning the band now would force any company that wins the C band license to make costly investments for a second generation system, the only technology currently available in that band, and then to make even more investments to upgrade to a third generation system once the equipment becomes available, as some of its competitors deploy IMT-2000 due to early availability in other bands. In addition, the second generation systems being deployed in the D and E bands throughout the country provide no roaming in the region. By reserving the C band for third generation, Anatel can promote regional roaming and can continue to be consistent with positions taken by Brazil at international treaty conferences, as well as regional fora that discuss spectrum issues such as CITEL. Along with most countries from the region, Brazil was a strong proponent of the 1710-1850 MHz band for third generation at the 2000 World Radiocommunication Conference (WRC-00) of the International Telecommunication Union (ITU). Even after a WRC-00 and the auctions for the D and E bands, Brazil submitted a proposal at CITEL proposing that the frequencies included in the C Band be used for IMT-2000.3 In fact, every country in the Americas that has taken a position on IMT-2000 allocations at CITEL has supported the 1725-1740 MHz frequencies as part of the uplink frequencies for third generation systems (3G).4 (See attached chart.) Even the United States, which is in the middle of its regulatory proceeding to determine frequencies for third generation, has identified that part of the band as the uplink band in four of its five proposals. Given that the Federal Communications Commission has a congressional mandate to auction that spectrum by September 2002, it is very probable that the 1725-1740 MHz frequencies will be chosen for advanced communications services in the United States. A delay in licensing the 1725-1740 MHz/1820-1835 MHz frequencies of the C band would also give Brazil the opportunity to consider another option being considered by the region. In addition to regional efforts to include the 1725-1740 MHz frequencies as part of the uplink band for IMT-2000, there are many countries favoring pairing the 1710 MHz band with the 2110 MHz band. Argentina5, Chile, Guatemala, and Mexico have all supported consideration of this particular band pairing option, and it is one that is also being considered by the United States. For Brazil, such band pairing would be ideal for the 1725-1740 MHz band because it would maximize use of the 2100 MHz band that is currently allocated partially to wireless local loop. The advantages to Brazil in pairing the 1710 MHz band with the 2110 MHz band would be:
CITEL continues to review options for IMT-2000 band pairing, as does the ITU's Working Party 8F, but work remains and no decisions have been made yet. Because these decisions have not been made yet on a regional and ITU level, Anatel's decision to delay the C band auction will preserve many more options for IMT-2000 spectrum in Brazil giving Anatel a wide variety of alternatives to consider when conducting Brazil's own national determination regarding third generation frequencies. Conclusion Brazil has the opportunity to reach a unique accommodation and to maintain its leadership in implementation of IMT-2000 in the region, but only if it reserves the C band for auction at a later date. By remaining flexible on licensing the C band and delaying the proceeding, Anatel will greatly facilitate its effort concerning allocation of IMT-2000 spectrum. The CDG also believes that by reserving the C band for advanced communications services, the spectrum will have more inherent value to operators since their consumers will be able to roam throughout the region on a third generation platform rather than on another second generation system that has no clear migratory path to third generation. For these reasons, the CDG respectfully requests that Anatel delay its proceeding regarding of the C band at this time. Sincerely, René Link Regional
Band Pairing Options for IMT-2000 in the Americas 1To clarify, the Korean PCS band does not correspond with the
SMP band of Brazil. There are 100 MHz of separation between the uplink and the
downlink in Korea, whereas in Brazil there are 95 MHz of separation.
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