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 SEPARATE  STATEMENT  OF  COMMISSIONER  JONATHAN  S.  ADELSTEIN 
 Re:  Report  and  Order  in  the  Matter  of  Service  Rules  for  Advanced  Wireless  Services  in  the  1.7  GHz  and  2.1  GHz  Bands 
 Today  is  a  banner  day  for  wireless  service  in  the  United  States.  By  adopting  service  and  technical  rules  for  Advanced  Wireless  Services  in  the  1.7  and  2.1  GHz  bands,  we  are  moving  a  step  closer  to  seeing 
 a  new  generation  of  wireless  services  in  this  country,  including  the  so-  called  third  generation  or  3G  mobile  systems.  I  think  our  item  represents  just  the  right  framework  for  further  innovation  in  the  wireless 
 arena  by  promoting  continued  industry  development  while  employing  a  light  regulatory  touch. 
 Determining  a  band  plan  is  an  inexact  science,  at  best.  I  believe  that  the  Commission  should  continue  to  improve  the  availability  of  spectrum  to  those  providers  who  want  to  serve  smaller  areas. 
 Though,  we  have  been  making  great  strides  in  this  area  recently  through  such  work  as  our  rural  wireless  NPRM  and  our  secondary  markets  proceeding. 


 I  have  been  concerned  that  large  license  areas  raise  auction  prices  so  high  that  many  companies  that  want  to  serve  smaller  areas  cannot  even  afford  to  make  a  first  bid.  Large  service  areas  also  can  have 
 the  effect  of  creating  swaths  of  fallow  spectrum  in  areas  outside  of  our  nation’s  populated  service  areas.  Licensees,  no  matter  how  large  their  service  areas  are,  understandably  focus  their  resources  on  serving  the 
 more-  populated  metropolitan  areas. 
 I  certainly  recognize  that  there  is  value  in  offering  larger  service  areas  for  economies  of  scale  and  to  facilitate  larger  scale  deployments.  Indeed,  one  of  the  noteworthy  developments  of  the  wireless 
 industry  over  the  past  several  years  is  the  development  of  the  so-  called  “nationwide”  carriers.  However,  I  believe  we  should  find  a  balance  in  developing  a  band  plan,  and  I  am  pleased  to  note  that  a  diverse  group 
 of  commenters  in  this  proceeding  supported  different  sizes  of  license  areas  for  different  blocks  of  the  spectrum. 


 I  believe  we  got  the  balance  right  here.  I  am  especially  pleased  that  the  band  plan  we  adopt  today  not  only  provides  for  several  licenses  to  be  available  on  a  Regional  Economic  Area  Grouping  basis,  but 
 also  provides  for  a  2x5  MHz  block  of  spectrum  on  a  RSA/  MSA  basis  and  a  2x10  MHz  block  of  spectrum  on  an  Economic  Area  basis. 


 In  providing  a  balance  of  smaller  and  larger  areas,  we  hopefully  offer  something  for  everyone. 
 Finally,  I  also  am  pleased  to  support  the  technical  and  service  rules  that  are  in  this  item.  In  combining  the  flexibility  of  Part  27,  with  the  proven  technical  rules  of  Part  24,  I  believe  that  we  have  put 
 in  place  just  the  right  regulatory  framework.  I  said  back  in  April  that  our  PCS  service  rules  should  prove  a  model  for  our  future  regulatory  efforts  for  licensed  mobile  services,  and  am  pleased  to  support  this 
 aspect  of  our  item  today. 
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