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One FS commenter, APCO, states that the 21102145 MHz band should not be  |$allocated to BAS, but rather to FS for advanced public safety microwave communications, to  |$compensate FS for its loss of the 21652200 MHz band. APCO advocates requiring BAS to  |$_operate in the remaining 85 megahertz of the BAS band. In support of this proposal, APCO  |$points out that the National Telecommunications and Information Administration (NTIA) reports  X4that 50 megahertz of additional spectrum is needed for public safety FS communications.? {O' |$ #C\  P6QIP#э See APCO Comments at 35 (citing NTIA, U.S. National Spectrum Requirements: Projections and Trends, Spec. Pub. 9431 at 38 (1995)).  G6!25. In its reply comments, MSTV argues that a channel width of 12 megahertz, as  X4 |$lsuggested by COMSAT, is not feasible.n@j  {O '#C\  P6QIP#э See MSTV Reply at 410.n SBE states that a reduction of one megahertz per  X4 |$/channel would be tolerable when more spectrumefficient hardware is available.lA  {On#'#X\  P6G;IP#э See SBE Reply at 25.l In response  |$cto Motorola's suggestion that we move BAS out of the 2 GHz band entirely, MSTV asserts that  |$the 7 and 13 GHz bands are unsuitable for mobile ENG activity. MSTV also states that Motorola  |$significantly underestimates the cost of relocating BAS, which MSTV and SBE place at  |$approximately $171 million. This estimate includes the costs of replacing or retrofitting"e A,-(-(ZZ"  |$transceiver equipment and antennas for all BAS licensees nationwide. MSTV supports our  |$proposal to reallocate the 21102145 MHz band to BAS, which would then have available 120  X4 |$megahertz of spectrum at 20252145 MHz.hB {OK'#C\  P6QIP#э See id. at 1114.h SBE also opposes the idea of freezing BAS license  |$applications or establishing a date after which BAS licensees would no longer be compensated  |$for relocation, because such measures would give MSS licensees incentive to avoid bargaining  X4in good faith on relocation issues.lCZ {O'#C\  P6QIP#э See SBE Reply at 25.l  G6!26. In its reply comments, COMSAT states that BAS should reduce its bandwidth  |$requirements in anticipation of digital technology, because the cost of relocating BAS to the  |$l21102145 MHz band, with the attendant cost of clearing that band, would make global MSS  X 4 |$Vfinancially infeasible. LQP calls for a FAC to study and implement a transition plan.lD  {O'#C\  P6QIP#э See LQP Reply at 68.l PCSAT  |$supports voluntary negotiations on relocation for 70 days or until a solution is reached and,  |$failing resolution, supports LQP's proposal of a FAC. PCSAT contends that relocation costs  X 4would cripple the nascent MSS industry.nE ~ {O'#C\  P6QIP#э See PCSAT Reply at 45.n  X 4 G6!27. In supplemental comments, the MSS CoalitionF  yOh' |$ #C\  P6QIP#э "MSS Coalition" is a collective name for supplemental comments filed jointly by Celsat, COMSAT, ICO, Hughes, and PCSAT. recommends a twophase plan to  |$compress BAS spectrum. In the first phase, the Commission would require licensees in BAS  |$ychannel A1 (19902008 MHz) to vacate by January 1, 2000, either retuning equipment for all  |$BAS channels to use channel bandwidths of 14 or 15 megahertz, or moving to other spectrum.  |$In the second phase, the Commission would require licensees in BAS channel A2 (20082025  |$VMHz) to vacate by January 1, 2005, again either retuning all channels to bandwidths of 12 or 13  |$megahertz, to take advantage of digital compression techniques, or relocating to another band.  |$Under this MSS Coalition plan, BAS would bear the expense of its own relocation. The MSS  |$Coalition claims that ordinary equipment replacement schedules will allow most BAS licensees  |$8to retune or replace equipment, or to relocate with minimal additional expense above normal  |$cequipment replacement. To support this plan, the MSS Coalition urges us to freeze immediately  X4 |$}all new BAS licensing in channels A1 and A2.Gh  {O"'#C\  P6QIP#э See MSS Coalition Supplemental Comments at 1416, 22. LQP supports the MSS Coalition plan, but with  |$three modifications. LQP urges that first, all BAS license applications and renewals should be  |$frozen immediately, to avoid further complications in the band clearing process. Second, it  |$argues that we should adopt an ending date for BAS primary operations of January 1, 2005, in  |$order to give BAS licensees incentive to seek new spectrum and to allow MSS to plan on the  |$basis of unrestricted use as of that date. Third, it urges us to allocate replacement BAS spectrum"7 G,-(-(ZZ_"  |$cfor the 19902025 MHz band, and suggests as a possibility the 36503700 MHz band, which will  X4be reassigned from Government to nonGovernment use in 1999.|H {Ob'#C\  P6QIP#э See LQP Supplemental Comments at 49.|  G6!28. In response to the MSS Coalition proposal, MSTV states that the spectrum allocation  X4 |$}proposal of the Notice is sound and is the only plan that would be effective, given the heavy and  |$still growing use of BAS. According to MSTV, the MSS Coalition plan is unrealistic, given the  |$current state of the art in BAS equipment; and we should not adopt a plan that relies on  |$canticipated but uncertain future advances in the state of the art. SBE states that channels of 15  |$megahertz are possible, but that narrowing BAS channels must be accompanied by new  |$'equipment capable of tuning to the narrower channels and having narrower intermediate  X 4frequency bandpass to avoid degradation in adjacentchannel rejection.|I Z {O' '#C\  P6QIP#э See SBE Supplemental Comments at 13.|  G6!29. One MSS proponent, Iridium, objects to the MSS Coalition's twophase plan, stating  |$cthat it is inconsistent with the international allocations of the bands. Iridium claims that, globally,  |$the Coalition's Phase One uplink band of 19902008 MHz would be paired with two different  |$Vdownlink bands: 21652185 MHz in Regions 1 and 3, and 21802198 MHz in Region 2. Iridium  |$cstates that the MSS Coalition's proposal does not include a coherent plan for the downlink band.  |$+Further, Iridium claims that the MSS Coalition's plan would probably only allow operation of  |$None MSS system in the Phase One period, and that system would have an overwhelming  XM4competitive advantage flowing from its fiveyear head start.JM {O'#C\  P6QIP#э See Iridium Supplemental Comments at 36.  X4 G6![30. Decision. Based on the record, we conclude that it is necessary to relocate BAS in  X 4 |$order to accommodate MSS in the 19902025 MHz band. As we indicated in the Notice, and the  |$3commenting parties agree, BAS and MSS cannot share the spectrum without unacceptable mutual  |$<interference. Therefore, to reallocate the 19902025 MHz band to MSS, it will be necessary to clear this band of BAS.  G6!31. We reject Motorola's suggestion that we remove BAS from the 2 GHz band entirely.  |$#We agree with commenters who point out that the 2 GHz band has ideal propagation  |$characteristics for mobile services including BAS, which must transmit along unengineered paths from unpredictable locations.  G6!h32. BAS currently operates with 17 and 18megahertz wide channels. Comments from  |$both MSS interests and broadcasting interests lead us to believe that BAS may not need channels  |$this wide, especially in light of the fact that advances in radio technology since the current  |$<channelization of BAS was established could make it possible for BAS to transmit contribution |$quality signals in somewhat narrower channels. On the other hand, we do not agree with the  |$position of the MSS community that we should reduce BAS to 12 and 13megahertz channels"!~J,-(-(ZZ? "  |$pand mandate a switch to digital transmission. We believe that a reduction of five megahertz per  |$channel is too severe to permit FM analog contributionquality BAS signals, and we do not  |$believe that this is the appropriate proceeding to determine whether or when BAS should convert  |$/to digital format in conjunction with the development of digital television. Some representatives  X4 |$Mof both industries, however, agree that BAS may be able to operate with 15megahertz channels.K {O'#X\  P6G;IP#э See, e.g., MSS Coalition Supplemental Comments at 1416; SBE Comments at 8.  |$We conclude that the best solution for BAS relocation is to reduce the BAS band at 2 GHz from  |$y120 to 105 megahertz, and relocate the band from 19902110 MHz to 20252130 MHz. This  |$would allow the resultant BAS band to be divided into seven channels of 15 megahertz each, thus  |$retaining the current capacity of the BAS band. This solution is more spectrumefficient than our  X14 |$Vprimary proposal in the Notice of simply relocating the 120megahertz BAS band upward by 35  X 4 |$megahertz, and also more feasible than our alternate proposal of reducing the BAS band to 85  |$Imegahertz. Further, this solution will require the relocation of FS users from only 20 megahertz  |$yat 21102130 MHz, rather than 35 megahertz at 21102145 MHz, as in our primary proposal.  |$uHowever, we merely note here that a BAS band of 105 megahertz will allow seven BAS  |$channels. Rather than mandating channels in the new band, we explore possible alternate  X 4channelizations in the Further Notice of Proposed Rule Making (Further Notice), below.  G6!J 33. Relocating BAS will require retuning of BAS equipment, and in many if not most  |$cases replacing equipment or retrofitting equipment to allow improved intermediate frequency  XO4 |$bandpass and adjacentchannel rejection, as pointed out by SBE.|LOZ {OZ'#X\  P6G;IP#э See SBE Supplemental Comments at 13.| Because the new BAS band  |$is in the same region of the spectrum as the current BAS band, we anticipate that no new  |$facilities will need to be constructed. We do not foresee that there will be any need physically  |$Ato relocate or rebuild any facilities. We are confident that the reaccommodation of BAS  |$<operations can be accomplished by simply replacing or retrofitting current equipment. The cost  |$of all steps necessary for clearing the 19902025 MHz band for MSS operations will be borne  X4 |$"by MSS operators. The Further Notice of Proposed Rule Making (Further Notice), below, proposes rules and policies for clearing the 19902025 MHz band for MSS.  X4C. Relocation of Existing 21652200 MHz Band Services.  XV4 G6!!34. The 21652200 MHz band is currently allocated to private and commercial FS, but  X?4 |$has been reserved for emerging technologies, such as MSS.sM? {O!'#C\  P6QIP#э See Notice at  14.s In the Notice, we stated that five  |$higher bands have already been allocated during our Emerging Technologies proceeding for  X4 |$/reaccommodation of the FS incumbents.N\~ {OB%' |$ #C\  P6QIP#э See id. at  11. In the Emerging Technologies proceeding, we allocated the 37004200 MHz, 59256425  |$  MHz, 10.5510.68 GHz, and 10.711.7 GHz bands to private FS and the 65256875 MHz band to commercial FS  {O&'on a primary basis. See Emerging Technologies, Second Report and Order, 9 FCC Rcd 6495, 6523 (1993). We inquired whether sharing between MSS and FS"N,-(-(ZZ"  |$lwould be feasible, and whether FS incumbents should be relocated. Finally, we proposed to  X4require that MSS pay the costs of relocating FS incumbents, where necessary.jO {Ob'#C\  P6QIP#э See id. at  13.j  X4 G6!_"35. Comments on MSS/FS Spectrum Sharing. In general, the MSS community advocates  X4 |$Esharing between FS and MSS, at least in the early stages of MSS deployment.PZ {O'#C\  P6QIP#э See Celsat Comments at 810; COMSAT Comments at 1721; LQP Comments at 1416. COMSAT  |$presents studies which purport to demonstrate that sharing between FS and MSS downlinks in  |$"the 21652200 MHz band is feasible. Based on these studies, COMSAT claims that relocation  Xa4 |$Iof FS incumbents in the band is unnecessary.}Qa {O '#X\  P6G;IP#э See COMSAT Comments at 18, Appendix 2.} Constellation states that the Commission should  |$lconduct technical studies to determine the feasibility of sharing in the 2 GHz band, especially  X34 |$with respect to CDMA systems which have low power levels.wR3~ {Ob'#X\  P6G;IP#э See Constellation Comments at 3.w LQP also asserts that it has  |$conducted studies that demonstrate that MSS/FS sharing is feasible, and urges us to convene a  X 4FAC to resolve transition issues, including spectrum sharing.nS  {O'#X\  P6G;IP#э See LQP Comments at 16.n  G6!#36. Motorola, however, states that COMSAT's model has several shortcomings which  |$4must be addressed before we can confidently conclude that MSS downlink/FS sharing is  X 4 |$feasible,sT  {O'#C\  P6QIP#э See Motorola Reply at 1623.s a position which API and AAR share, arguing that COMSAT's sharing model does not  |$cdemonstrate the feasibility of sharing between MSS and FS, because it assumes too high a level  X{4 |$gof acceptable interferencelU{4  {O`'#C\  P6QIP#э See API Reply at 68.l and neglects a fading model and degradation criteria.V{  {O'#C\  P6QIP#э See AAR Reply at 24. See also UTC Reply at 9. Motorola goes  |$on to state that it believes that sharing is not possible in the long term, and cites the conclusions  XM4 |$of the Report of the Conference Preparatory Meeting for WRC95, which rates the feasibility of  |$ MSS downlink/FS sharing as "ModeratePoor." Motorola therefore advocates immediate clearing  X!4 |$<of the 21652200 MHz band.W!X  {O*"'#X\  P6G;IP#э See Motorola Comments at 1518 (citing CPM Report). AFCCE and CBT also state that sharing between MSS and FS  X 4is not feasible, and that relocation of FS licensees is necessary.X  {O$'#X\  P6G;IP#э See AFCCE Comments at 2; CBT Comments at 7. "|X,-(-(ZZ"Ԍ G6!$37. In supplemental comments, the MSS Coalition states that MSS and FS will be able  |$pto share spectrum for several years, and therefore proposes that a gradual transition plan for FS  X4incumbent relocation be adopted.Y {OK' |$3 #C\  P6QIP#э See MSS Coalition Supplemental Comments at 4, 810, 1722. See also LQP Supplemental Comments at 4. Hughes favors the MSS Coalition MSS/FS sharing plan.}Z" {O'#C\  P6QIP#э See Hughes Supplemental Comments at 2.}  G6!`%38. The majority of FS commenters argue that there are inadequacies in the MSS  X4 |$Coalition's sharing study.S[Z {O ' |$ #C\  P6QIP#э See AAR Supplemental Comments at 6; APCO Supplemental Comments at 46; Dr. Bellamy Supplemental  |$ Comments at 1; California Supplemental Comments at 2, 4; CBPC Supplemental Comments at 1; UTC Supplemental Comments at 46. S TIA states that WRC95 only set out the criteria for MSS/FS sharing  Xv4 |$studies and then encouraged others to conduct the studies.|\v {O'#C\  P6QIP#э See TIA Supplemental Comments at 79.| API, Alcatel, and TIA contend that  X_4 |$MSS/FS sharing criteria should not be based on international standards.]_h  {Ox' |$/ #C\  P6QIP#э See Alcatel Supplemental Comments at 23; API Supplemental Comments at 78; TIA Supplemental Comments at 23. TIA and Alcatel in  XH4 |$<particular point out that there are differences between U.S. and international FS systems,^H  {O'#C\  P6QIP#э See Alcatel Supplemental Comments at 23; TIA Supplemental Comments at 23. and  |$API states that U.S. interference standards are stricter than international standards; therefore, they  X 4 |$_urge us to rely upon U.S. criteria.|_ T  {O'#C\  P6QIP#э See API Supplemental Comments at 78.| API, APCO, and Alcatel suggest that we rely on TIA's  X 4 |$8TR14.11 committee to do any necessary MSS/FS sharing studies.`  {O' |$ #C\  P6QIP#э See API Supplemental Comments at 78; Alcatel Supplemental Comments at 23; APCO Supplemental Comments at 46. The State of California  |$}(California) points out that COMSAT's proposal fails to take into account those highly populated  |$areas where interference is likely to occur sooner, and that the proposal fails to recognize  X 4 |$yinterference from MSS space or earth stations.a @ {O'#C\  P6QIP#э See California Supplemental Comments at 25. UTC states that the MSS Coalition fails to  X 4 |$ provide any details of how MSS and FS can share in the 2 GHz band.|b  {O*"'#C\  P6QIP#э See UTC Supplemental Comments at 46.| The Central Iowa Power  |$Cooperative (CIPCO) states that some of its FS paths are over 18 miles in length. If sharing  |$4were required then CIPCO would have to lower the operating power of its equipment to  |$accommodate MSS, increasing the chances that its FS operations would receive unacceptable  XK4interference.|cKd {O`''#C\  P6QIP#э See CIPCO Supplemental Comments at 4.|"Kc,-(-(ZZQ"Ԍ X4 G6!ԙ&39. Comments on Relocation. If sharing proves to be infeasible, MSS interests generally  |$advocate a gradual transition of FS incumbents to other spectrum, with FS incumbents paying all  X4 |$or most of the costs of their relocation.d {OM'#C\  P6QIP#э See Celsat Comments at 810; COMSAT Comments at 1721; LQP Comments at 1416. For example, PCSAT advocates relocation of FS over  |$a gradual transition period so as to require FS licensees to pay for their own relocation as they  |$amortize their equipment. In the alternative, PCSAT states that we should limit the compensation  X4 |$ from MSS to FS to the incremental replacement costs of FS equipment.reZ {O'#C\  P6QIP#э See PCSAT Comments at 610.r LQP suggests creating  Xx4 |$a FAC to resolve transition issues, such as the apportionment of FS relocation costs.qfx {O '#C\  P6QIP#э See LQP Comments at 1819.q TRW  |$notes that part of the recently allocated PCS spectrum (19701990 MHz) had been internationally  |$allocated to MSS, and if MSS had received this allocation domestically instead of PCS, FS would  |$not have to be relocated because of MSS. Therefore, TRW concludes, PCS operators should  X 4 |$have to pay at least part of the relocation costs of FS.og ~ {OK'#C\  P6QIP#э See TRW Comments at 79.o Iridium proposes that we adopt a sunset  |$policy on compensation for FS relocation similar to that used in our 1982 Digital Broadcasting  |$3Service proceeding. During the sunset period MSS would compensate FS licensees for relocation,  X 4 |$but after this period, FS licensees would have to pay their own relocation expenses.h^  {O' |$Q #C\  P6QIP#э See Iridium Comments at 12 (citing In re Inquiry into the Development of Regulatory Policy in Regard to  {Ob' |$ Direct Broadcast Satellites for the Period Following the 1983 Regional Administrative Conference, GEN Docket No.  {O,'80603, FCC 82285, Report and Order, 90 F.C.C.2d 676 (1982)). Celsat  X 4suggests allowing MSS to relocate FS incumbents in increments as MSS needs more spectrum.si 6  {O'#C\  P6QIP#э See Celsat Comments at 810.s  G6!''40. API and APCO, on the other hand, recommend that FS not be relocated for fear of  |$Idisruption of safetyrelated services provided by private FS licensees, claiming that relocation is  |$ha difficult and timeconsuming process with inherent uncertainty and risk. If relocation is  XM4 |$necessary, they recommend that provisions to effect the relocation be made without delay.jM  {O'#C\  P6QIP#э See API Comments at 914; APCO Comments at 23.  |$Southwestern Bell stresses that reallocation of FS from the 21602180 MHz band to higher bands  |$would harm cellular service providers, because of the resultant need for shorter paths for cellular  X4 |$service backhaul links and increased equipment costs.}kZ  {O#'#C\  P6QIP#э See Southwestern Bell Comments at 13.} All of the FS commenters agree with  X4our proposal in the Notice that our Emerging Technologies rules should be followed.l {O%' |$ #C\  P6QIP#э See API Comments at 1214; AAR Comments at 25; APCO Comments at 23; BellSouth Comments at 34; UTC Comments at 12. "Fl,-(-(ZZ"Ԍ G6!(41. In supplemental comments, the Corn Belt Power Cooperative (CBPC), APCO and  |$the Minnesota Department of Transportation (MDOT) point out that the MSS Coalition's plan  |$to relocate FS over a tenyear period by allowing FS incumbents to amortize their equipment and  X4 |$&replace it with the appropriate equipment at their own expense is unrealistic.m {O4'#C\  P6QIP#э See MDOT Supplemental Comments at 23; APCO Supplemental Comments at 34. MDOT states that  |$uit uses its equipment for up to 30 years, and to amortize its current equipment will take 20  X4 |$years.}nZ {O'#C\  P6QIP#э See MDOT Supplemental Comments at 23.} APCO states that the average life of microwave equipment is 1520 years, and that  |$some private FS licensees have new equipment which would not be amortized until the decade  X_4 |$of the 2010s.}o_ {O '#C\  P6QIP#э See APCO Supplemental Comments at 34.} Ameritech points out that WRC95 moved up the date MSS is to have primary  |$access in the 2 GHz spectrum from the year 2005 to the year 2000, making COMSAT's tenyear  X14 |$plan unrealistic.p1~ {O`'#C\  P6QIP#э See Ameritech Supplemental Comments at 35. The Los Angeles County Sheriff's Department (L.A. Sheriff) asserts that  |$public safety FS incumbents should not have to pay any direct or indirect cost associated with  X 4 |$relocation, because otherwise this burden would be passed on to taxpayers.q  {O'#C\  P6QIP#э See L.A. Sheriff Supplemental Comments at 2. The majority of  |$FS commenters and other commenters advocate applying the Emerging Technologies rules  X 4adopted in ET Docket No. 929.rZ  {O(' |$* #C\  P6QIP# See API Supplemental Comments at 1011; Ameritech Supplemental Comments at 35; AAR Supplemental  |$ Comments at 24, 911; APCO Supplemental Comments at 34; BellSouth Supplemental Comments at 6; CIPCO  yO'Supplemental Comments at 5; UTC Supplemental Comments at 34.Ė  X 4 G6!)42. Decision. We will provide for MSS sharing with, and any necessary relocation of,  |$qFS incumbents in accordance with the policies set forth in our Emerging Technologies  |$proceeding. It is our policy to encourage spectrum sharing between emerging technologies  Xd4 |$Vservices and incumbent 2 GHz FS operations whenever technically feasible.sd  {O' |$ #X\  P6G;IP#э See, e.g., Emerging Technologies, First Report and Order and Third Notice of Proposed Rule Making at   yO'29. Our rules do not  |$require relocation of incumbents unless and until the incumbents will receive harmful interference  |$from, or cause harmful interference to, a new technology service. COMSAT and LQP have  |$provided studies indicating that sharing is possible on at least a shortterm basis. At the same  |$time, Motorola and some FS service representatives have criticized these studies, claiming that  |$they fail to account for important factors. MSS and FS industry groups are currently working  |$under the auspices of TIA to resolve differences over sharing models and adopt a set of mutually  |$@agreed sharing criteria. We encourage these efforts, and will consider the product of these efforts  |$for inclusion in our rules as the standard for evaluating the likelihood of unacceptable MSS/FS  |$<interference. MSS cannot begin operations until its spectrum is cleared of all FS licensees who"s,-(-(ZZ"  |$<would receive harmful interference from MSS, but MSS will not be required to relocate any FS  |$incumbent with whom it can successfully share spectrum. If a specific FS operation does not  |$receive unacceptable levels of interference until several years after the beginning of MSS operations, MSS will not be required to relocate the FS licensee until that interference occurs.  G6!*43. Where sharing proves infeasible, however, we will allow the MSS operator to relocate  |$cthe incumbent FS operation to bands above 5 GHz. We will address the precise mechanism for  X_4relocation in the Further Notice, below.  X34D. Technical Parameters for MSS Systems.  X 4 G6!+44. In the Notice, we proposed to make the newlyallocated MSS bands available for both  |$&GSO and LEO use; otherwise, we did not propose specific technical parameters for MSS systems  |$in the 19902025 MHz and 21652200 MHz bands. We requested comment, however, on  |$}whether these proposed new MSS bands should be limited to either exclusive GSO or LEO use;  |$Ion whether minimum geographic coverage requirements or a particular access method, such as  |$cCDMA, should be mandated for all MSS licensees; on what power limits should be imposed; on  |$Celsat's proposal to share spectrum with PCS at 19701990 MHz in order to provide a hybrid  |$PCS/MSS system; and on whether there is a need to allocate spectrum for feeder links to support  XQ4 |$2 GHz MSS.mtQ {O'#C\  P6QIP#э See Notice at  16.m These issues were addressed primarily by commenters who are potential MSS service providers or MSS equipment manufacturers.  X 4 G6![,45. Comments. With regard to orbital geometries,u Z yO'#C\  P6QIP#э Orbital geometries are the type of orbits satellites describe, such as GSO or LEO. Celsat advocates reservation of the  |$entire 70 megahertz of spectrum for GSO systems, because MSS spectrum in the 1.6/2.4 GHz  |$3band is reserved exclusively for LEO systems and licensed to MSS providers using these systems.  |$Reserving the spectrum at issue to GSO systems, according to Celsat, will ensure diversity of  X4 |$Iservice providers and encourage competition.qv {OM'#C\  P6QIP#э See Celsat Comments at 11.q COMSAT and others disagree, stating that we  |$should mandate no orbital geometry now, and that we should either allow the market to decide  X4 |$/what is the best orbital geometryw| {O ' |$ #C\  P6QIP#э See COMSAT Comments at 33; Ericsson Comments at 13; Newcomb Comments at 27; TRW Comments at 25. or wait until after an allocation plan is finished to decide this  Xm4 |$Vissue.qxm {O#'#C\  P6QIP#э See LQP Comments at 2023.q In its reply comments, LQP asserts that we should reject Celsat's attempt to close this  |$spectrum to current MSS licensees employing LEO systems by mandating GSO, because the  |$Commission can encourage competition, as Celsat urges, by licensing multiple systems, and because current satellite providers are in the best position to improve service."(h x,-(-(ZZ""Ԍ G6!ԙ-46. With regard to access methods, Celsat states that we should mandate use of CDMA  |$ytechnology, which it claims will allow many licensees to share the same spectrum and permit  |$&more energyefficient coding, greater tolerance for interference from incumbent licensees, greater  |$gprotection from interference to incumbent licensees, and greater frequency reuse, as well as avoid  X4 |$hmutual exclusivity in licensing.y {O'#C\  P6QIP#э See  Celsat Comments at 1118. See also TRW Comments at 24. Newcomb adds a recommendation that we either adopt  |$uCDMA, or split the band into subbands of 17.5 megahertz in each direction, for separate  Xv4 |$"assignment to GSO and LEO systems.szvZ {O '#C\  P6QIP#э See Newcomb Comments at 79.s LQP argues that we should wait until after we finish  X_4 |$+allocating spectrum to MSS to take up technical issues.q{_ {O '#C\  P6QIP#э See LQP Comments at 2023.q Other commenters disagree with  |$/Celsat, stating that we should remain technologically neutral and allow the market to decide the  X14 |$best access methodology.|1~ {O`'#C\  P6QIP#э See COMSAT Comments at 3334; Ericsson Comments at 13; Motorola Comments at 1114. In its reply comments, LQP adds that CDMA is superior to time  |$division multiple access (TDMA) in terms of multiple entry, capacity, and spectrum efficiency,  X 4but continues to advocate waiting until after the allocation is made to decide the issue.n}  {O'#C\  P6QIP#э See LQP Reply at 1618.n  G6!.47. With regard to geographic coverage requirements, COMSAT advocates the imposition  X 4 |$of the same requirements as those imposed on Big LEOs, i.e., coverage of the entire globe from  X 4 |$70-N to 55-S for 75% of each day, stating that these would provide effective global coverage  X4 |$while containing costs.q~ {O'#C\  P6QIP#э See COMSAT Comments at 34.q LQP, PCSAT, and TRW argue that imposing no coverage standard will  X{4 |$allow for more varied and flexible MSS system design.{4  {O`'#C\  P6QIP#э See LQP Comments at 2023; PCSAT Comments at 45; TRW Comments at 25. Motorola states that LEO and GSO  |$systems should be assigned to separate bands, with GSO systems allowed to provide coverage  XM4 |$8only in regions they choose to serve.vM  {O'#C\  P6QIP#э See Motorola Comments at 1011.v In its reply comments, Celsat argues that we should  |$allow for GSObased domesticonly service in at least part of the band, stating that this will allow  |$lowercost domestic systems that will not have to pay for the capacity needed for international  X4coverage.qX  {O#'#C\  P6QIP#э See Celsat Reply at 1417.q  G6!=/48. With regard to power limits, COMSAT argues that there is no reason to limit the  |$power from MSS handsets, except to the extent necessary to meet existing RF hazard guidelines",-(-(ZZ"  X4 |$ for handheld transmitters.q {Oy'#X\  P6G;IP#э See 47 C.F.R.  2.1093.q COMSAT further argues that coordination with other services in the  X4 |$downlink band is preferable to setting absolute power limits.tZ {O'#C\  P6QIP#э See COMSAT Comments at 3536.t Motorola states that no power  X4 |$limit should be placed on the band,v {Oo'#C\  P6QIP#э See Motorola Comments at 1114.v and LQP believes that the issue should be taken up later.w~ {O '#C\  P6QIP#э See LQP Comments at 2023.w  |$Only TRW advocates a specific power limit, stating that in order to maximize capacity and  |$minimize interference, we should specify a maximum power flux density from each space station  X4of 137 dB(W/m2/4 kHz).n {ON '#C\  P6QIP#э See TRW Comments at 26.n  G6!049. With regard to feeder link spectrum, COMSAT asserts that 2 GHz MSS should be  |$allowed to use any FixedSatellite Service (FSS) bands allocated by WRC95 for MSS feeder  X14 |$links.q1 {O'#C\  P6QIP#э See COMSAT Comments at 37.q PCSAT states that feeder link spectrum in the 11 GHz and 13 GHz bands, currently  |$yallocated to FSS, should be authorized for MSS use, and points out that the American Mobile  X 4Satellite Corporation's first generation MSS system already uses these bands for feeder links.o 4  {O'#C\  P6QIP#э See PCSAT Comments at 5.o  G6!150. Finally, with regard to Celsat's proposal to allow these bands to be used to create a  |$hybrid PCS/MSS system, in which a single handheld earth terminal could access either terrestrial  X 4 |$cPCS or MSS,r  {O'#C\  P6QIP#э See Notice at