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Re: Amendment of Part 2 of the Commission's Rules to Allocate Spectrum Below 3 GHz for Mobile and Fixed Services to Support the Introduction of New Advanced Wireless Services, including Third Generation Wireless Systems, Memorandum Opinion and Order and Further Notice of Proposed Rulemaking, ET Docket No. 00-258, ET Docket No. 95- 18, IB Docket No. 99-81, RM-9498, and RM-10024

The future deployment of increasingly advanced wireless services is challenging and critical. Technological innovation and new service offerings are fueling a period of exploding growth in the demand for mobile telephone, Internet, and data applications. According to at least one study, more than one-third of us will be on the "wireless web" by 2005.

If we are to meet this anticipated demand, we must develop a broad spectrum management policy that ensures efficiency and flexible use, and we must also continue to work to make additional spectrum available for 3G use. This item moves us forward in that direction. As we debate where to find the spectrum to meet this demand, we should keep in mind that the amount of available spectrum and our ability to use it is ultimately limited only by technology. Indeed, I am hopeful that future technological development will allow us to make more efficient use of current spectrum allocations, and make further use of additional frequency bands. With such developments, spectrum may no longer be viewed as a scarce natural resource. Today, however, we face practical limitations, and, as a result, our spectrum management policies are critical.

In the coming months, we should challenge ourselves to make decisions that will best promote the highest valued use of the spectrum currently available. We should work toward policies that allow the free market to meet demand, thus offering increased flexibility and regulatory certainty, while still respecting the rights of current license holders.

Providing regulatory certainty is particularly important for systems in the 2500-2690 MHz band, which the Commission has been considering using for 3G allocation for over a year. In March, Commission staff prepared an exhaustive report analyzing whether to relocate incumbents in this band. The report concluded that relocation of incumbent licensees in this band would cause significant economic and technical difficulties for the ITFS/MDS community. The report explained that relocation would require considerable time and costs to reengineer and deploy systems in alternate frequency bands, which, in turn, would delay delivery of the valuable services provided in this band. The report also recognized that there is a great deal of variation in the architectures and technical characteristics of systems in this band and concluded that there is no readily identifiable alternate frequency band that can accommodate a substantial relocation of the incumbent operations.

In light of this report, I have serious concerns about relocating the incumbents in this band. At the very least, we should try to resolve this issue as soon as possible to provide current licensees the regulatory stability they need for investment in new technologies and service offerings. While I am disappointed that we were not able to do so in this item, I look forward to working with the Chairman and other Commissioners to resolve this issue in the near future.