September 18, 1998

Superintendent of Radio Frequency and Taxation
ANATEL
SAS Quadra 6 Bloco H2° andar – Biblioteca
70313-900-Brasilia-DF

Subject: Public Consultation No. 68, August 27, 1998 "Directives For Allocation Of Frequency Bandwidths For Wireless Access Systems, For Rendering Of STFC"

Dear Sir/Ma’am:

I am writing on behalf of the CDMA Development Group (CDG) to express our views on the Public Consultation No. 68, August 27, 1998 "Directives For Allocation Of Frequency Bandwidths For Wireless Access Systems, For Rendering Of STFC" issued recently. The CDG is an international industry association of 100 companies, including the world’s leading manufacturers and operators of digital cellular and PCS communications systems. We have enclosed additional information about the CDG for your information.

The CDG supports ANATEL’s plans to allocate spectrum consistent with the Personal Communications (PCS) band for Fixed Wireless Access (FWA) services. As you may be aware, there is a great deal of commercial capability available for this band that enables significant benefits to the industry, including:

• Greater economies of scale by taking advantage of a broader supplier base
• Reduced complexity by reducing the number of bands required
• Reduced time-to-deployment by taking advantage of existing capability
• Greatly simplified roaming resulting from band consistency (particularly throughout the Americas)

With respect to Public Consultation 68, the CDG strongly endorses ANATEL’s plans for the following allocations:

• 1850 MHz-1855MHz paired with 1930 MHz -1935 MHz
• 1865 MHz-1870MHz paired with 1945 MHz -1950 MHz

We are concerned, however, about the potential interference effects on the first band from the 1910 MHz - 1930 MHz allocation. These interference effects can be minimized by:

1. Reserving the band for low powered W-PBX applications
2. Using sufficiently sized guardbands
3. Establishing geographic exclusion zones (e.g., FWA for under-served or non-served rural loop applications and low powered W-PBX applications in urban locations.)
4. Implementing a combination of approaches 2 and 3

In addition, we support a technology-neutral approach to awarding licenses for all of the bands cited in the Consultation. This further maximizes competition, resulting in the most cost-effective deployments..

The CDG also recognizes the need to address IMT-2000 allocations. It is our viewpoint that IMT-2000 services will be developed and offered in existing cellular and PCS bands, as well as new bands that are designated as IMT-2000. We have a large membership with significant investments in the PCS and cellular bands that will be deploying IMT-2000 services. The CDG issued a policy statement in July to address this topic. We have enclosed a copy of that policy statement for your information.

The CDG applauds ANATEL’s proposal to include PCS allocations in Public Consultation 68. We look forward to working with ANATEL closely as Brazil progresses in this exciting stage of wireless communications development. 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: CDG Background Information
CDG Spectrum Policy Statement