*Pages 1--1 from  Microsoft Word - 45785.doc*
 SEPARATE  STATEMENT  OF  COMMISSIONER  MICHAEL  J.  COPPS 
 Concurring 
 RE:  Improving  Public  Safety  Communications  in  the  800  MHz  Band  (Supplemental  Order  and  Order  on  Reconsideration;  adopted  December  22,  2004). 


 In  this  order  the  Commission  resolves  many  important  issues  related  to  our  effort  to  reduce  interference  to  public  safety  in  the  800  MHz  band.  I  am  pleased  that  we  are 
 taking  this  step  and  support  the  result  of  this  order,  which  moves  us  significantly  closer  to  the  initiation  of  a  successful  rebanding  process. 


 I  am  uncomfortable,  however,  the  decision  to  change  the  valuation  of  Nextel’s  spectrum  by  close  to  half  a  billion  dollars  --  an  increase  of  nearly  twenty  percent.  While  I 
 believe  that  Nextel  has  demonstrated  that  its  spectrum  holdings  are  different  than  the  assumption  we  made  in  the  original  order,  I  am  concerned  that  the  process  that  the 
 Commission  has  used  here  to  determine  value  has  become  too  imprecise.  Given  the  short  time  available,  I  do  not  believe  that  the  Commission  had  the  capacity  to  independently 
 pinpoint  the  exact  nature  of  Nextel’s  holdings,  as  we  do  here  but  did  not  do  in  the  previous  order.  Additionally,  if  we  must  reassess  the  value  of  Nextel’s  spectrum,  I  would 
 have  preferred  to  reassess  the  MHz/  POP  multiplier  that  we  employ  in  light  of  changes  in  the  marketplace  and  transactions  that  occurred  after  we  adopted  our  first  order.  Given  the 
 magnitude  of  the  valuation  at  issue,  I  will  therefore  concur. 
1