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Re: Amendments of 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)

While I support this decision and look forward to the upcoming licensing of more fixed wireless spectrum in the 24 GHz band, I would have preferred to take further steps that could serve to foster fixed wireless build-out in America's smaller cities and rural areas. In particular, I would have licensed one or two of the five 24 GHz license blocks in smaller geographic areas.

The record here reflects several parties' conviction that spectrum in smaller cities and rural areas may lay fallow when bundled in geographic licenses with urban areas. Simply put, a winning bidder today may concentrate its investment and build-out in dense urban areas despite holding a license that covers smaller cities and rural areas. While our rules allow for partitioning and disaggregation of spectrum, this policy has produced mixed results at best. By making one or two of the five licenses available in smaller geographic blocks, we could have offered an opportunity for providers with a small city/rural focus to bid at auction for the spectrum necessary for their business plans. A fixed wireless offering, after all, need not have a regional or national strategy in order to succeed. At the same time, providers with a regional or nationwide business strategy could aggregate these licenses for a larger footprint.

The fixed wireless industry is a wonderful example of intermodal competition. However, I would have preferred one extra step to promote widespread deployment. Nonetheless, I believe fixed wireless providers offer great promise as competitive entrants in large urban settings and beyond and I support this item.