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 SEPARATE  STATEMENT  OF  COMMISSIONER  MICHAEL  J.  COPPS  Approving  in  Part,  Dissenting  in  Part 
 Re:  Amendment  of  Part  2  of  the  Commission’s  Rules  to  Allocate  Spectrum  Below  3  GHz  for  Mobile  and  Fixed  Services  to  Support  Introduction  of  New  Advanced  Wireless 
 Services,  including  Third  Generation  Wireless  Systems;  ET  Docket  No.  00-  258  The  Establishment  of  Policies  and  Service  Rules  for  the  Mobile-  Satellite  Service  in  the  2 
 GHz  Band;  IB  Docket  No.  99-  81(  Adopted  January  29,  2003) 
 I  write  separately  because  I  believe  that  the  Commission  should  not  abandon  a  substantial  amount  of  rare  globally  harmonized  satellite  spectrum. 


 In  today’s  Order  the  Commission  decides  to  reallocate  10  MHz  of  globally  harmonized  spectrum  as  part  of  a  reallocation  of  a  total  of  30  MHz  from  mobile  satellite 
 services  (MSS)  to  advanced  wireless  services  (AWS).  I  fully  support  the  goal  of  providing  adequate  spectrum  to  new  terrestrial  services,  and  would  have  provided  exactly 
 the  same  amount  of  spectrum  for  AWS.  My  preference,  however,  was  to  choose  less  problematic  frequencies. 


 The  United  States  led  the  fight  to  win  globally  harmonized  MSS  spectrum  in  1992.  Soon  thereafter,  however,  the  Commission  abandoned  the  plan  to  have  a  world-wide 
 MSS  band  and  allocated  10  MHz  to  PCS.  This  reduced  by  one-  third  the  globally  harmonized  spectrum  available  to  fledgling  MSS  operators,  although  it  provided  much-needed 
 spectrum  to  PCS  operators.  This  action  engendered  significant  international  disappointment  and  injured  U.  S.  spectrum  planning  credibility. 


 Now  we  reallocate  50  percent  more  of  the  remaining  globally  harmonized  MSS  spectrum  to  AWS,  leaving  MSS  licensees  with  only  a  third  of  what  was  originally  fought 
 for  by  U.  S.  negotiators.  This  will  raise  costs  of  satellite  design  and  construction,  make  trans-  national  interference  coordination  more  difficult,  especially  where  satellite  and 
 terrestrial  licensees  must  coordinate,  and  may  further  erode  U.  S.  credibility  internationally  when  we  next  fight  for  harmonized  spectrum. 


 Maintaining  MSS  use  of  this  spectrum  certainly  has  costs.  The  majority  believes  that  abandoning  globally  harmonized  spectrum  is  necessary  to  reduce  possible  future 
 interference.  Reducing  potential  interference  both  to  PCS  and  MSS  is  critically  important.  However,  claims  of  potential  interference  were  raised  extremely  late  in  this 
 proceeding  and  the  effect  on  interference  of  our  decision  is  poorly  understood,  at  best.  If  concerns  about  interference  exist,  we  should  confront  them  directly,  seeking  the  efficient 
 level  of  protections  and  a  solution  that  doesn’t  do  damage  to  our  standing  in  the  international  community,  if  possible.  For  me,  the  values  described  above,  and  hard-  won, 
 globally  harmonized  spectrum,  are  just  too  valuable  to  walk  away  from. 
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