Industry Canada's Comments on the United States Consultations for the Allocation of Spectrum for Third-Generation (3G) Mobile Services
February 22, 2001
Mr. Richard C. Beaird
Acting Deputy Assistant Secretary for International
Communications and Information Policy
Department of State
2201 C Street, Room 4826
Washington, D.C. 20520
Dear Mr. Beaird:
I am writing in response to a communication from the United States Embassy inviting Canadian comments to the government of the United States during your consultations regarding the allocation of spectrum to support the introduction of new advanced wireless communication services, including third generation (3G) mobile services. Canada has had a long history of working cooperatively with the United States in the area of radiofrequency spectrum planning and management, and we welcome the opportunity to provide our views. We will greatly appreciate your bringing this letter to the attention of the appropriate authorities in the United States Administration involved in consideration of this important issue.
It is Canada’s view that a significant amount of additional spectrum will soon be required for advanced mobile services including 3G. Administrations, along with regional groups and the International Telecommunication Union (ITU), should move aggressively to accommodate this requirement. The growth of cellular and PCS has already been significant in our two countries, and the rate of adoption by consumers has accelerated dramatically in the last year, following the trend seen in other countries. As our countries consider allocating further spectrum to advanced mobile services, we must be prepared to facilitate the introduction of these enhanced services and remain abreast of developments in other parts of the world by ensuring that adequate spectrum is made available.
An important aspect in achieving this objective, in our view, is to adopt the use of frequency bands and band plans that have the greatest potential for commonality on a regional basis and, in the longer term, on a global basis. Such commonality reduces equipment complexity and generates substantial economies of scale, resulting in lower subscriber equipment costs. The telecommunication industry can thereby substantially reduce their subscriber acquisition costs and become more competitive. Commonality also enables subscriber roaming, which generate large revenues without the expenditure involved in acquiring new customers.
Among the additional bands identified by the World Radiocommunication Conference (WRC) in 2000, the band 1710-1850 (1885) MHz1 is the one that has the greatest potential for achieving this goal in a suitable time frame. This was the basis for Canada’s proposal to the WRC-2000, and was also the basis of the proposals of many other administrations, notably in the Americas. Canada was pleased that the United States included this entire band 1710-1850 (1885) MHz as part of its proposal to the Conference.
On the other hand, the release of spectrum in the band 2500-2690 MHz would not promote the goal of achieving commonality. Canada, along with many other countries of the Americas, indicated their difficulties in reusing this band for advanced mobile services in the near to mid term, due to its current use by service operators and users. As well, we note that the earliest timetable for deployment in Europe for the use of this band is not until 2008. The use of this band has the added disadvantage that it is not in immediate proximity to the currently used PCS band. Finally, we are concerned that this band has increased propagation and building losses compared to the use of the 1710 MHz band.
Consequently we recommend that the United States release the entire band 1710-1850 MHz for advanced mobile services in preference to the band 2500-2690 MHz. This would enable the symmetrical pairing of a significant amount of spectrum from within the band 1710-1850 MHz. The remainder of the spectrum in this band can be paired with spectrum immediately above 2110 MHz. It is our view that choosing to make available spectrum from 1710-1850 MHz within a suitable time frame will have the best potential to facilitate the development of 3G services regionally in the Americas. Making that entire band available would also be compatible with current European and Asian usage and could eventually lead to global harmonization.
Canada will be initiating a domestic process of public consultation on this matter shortly, with the intention of licensing spectrum in the 2002-2003 time frame. As our process develops in Canada, we will be following with great interest the progress of the United States government discussions of how best to accommodate advanced mobile communications systems. In that context, we will look forward to any comments you may wish to submit either in response to this letter or as a contribution to our public consultation.
Thank you again for the invitation to express the Canadian view for your consideration.
Assistant Deputy Minister
Spectrum, Information Technologies
1 The sub-band 1850-1885 MHz has already being deployed for PCS in Canada, as in the United States.
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