CONCURRING STATEMENT OF 
             COMMISSIONER HAROLD FURCHTGOTT-ROTH 
            
  Re In the Matter of Amendments to Parts 1, 2, 87, and 101 of the Commission's Rules to
  License Fixed Services at 24 GHz, WT Docket No. 99-327 (rel. July 31, 2000).
  
       I support today's decision to promptly make available spectrum in the 24 GHz
  band.  The fixed wireless industry has experienced exponential growth in recent years
  and today's decision will provide still more spectrum for this rapidly developing industry
  segment.  In this context the precise contours of the fixed wireless industry continue to
  evolve.  Unlike PCS, where the majority of service providers have developed national
  footprints, it is not clear today how fixed wireless service fits into the marketplace.  Will
  it become a largely urban and local service, or will a regional approach prevail? 
  Alternatively, will fixed wireless at 24 GHz become a nationwide service offering?  From
  the Commission's standpoint there is no "right" answer.  Instead, the FCC must attempt
  to develop a flexible spectrum policy that is "business plan neutral."
  
  Accordingly, I am intrigued by the prospect of utilizing smaller service areas for
  some of these licenses.  The size of the initial license areas should not matter.  Our
  disaggregation and partitioning rules should facilitate a secondary market that permits
  licensees to slice and dice spectrum for the highest-valued use.  However, our
  partitioning and disaggregation rules have a mixed record and appear to create substantial
  transaction costs.  These apparent difficulties create increased pressure on the
  Commission to craft initial license allocations that respond to market demand.  Here,
  numerous parties requested smaller service areas.  In response I would have considered
  subdividing one or two of the five licenses into smaller licensing units in order to meet
  this apparent demand.  Smaller license areas may also facilitate the deployment of
  competitive services to underserved areas and permit the development of business plans
  based on a more localized strategy.  Going forward, rather than assuming all services are
  going to be "national," I believe it is important that we closely examine our initial license
  allocation strategy in each service to permit a whole range of business plans to audition
  in the marketplace.