SECTION 3: FEDERAL GOVERNMENT REALLOCATION COSTS AND OPERATIONAL IMPACT

INTRODUCTION

Title VI addresses the concern of avoiding excessive costs and minimizing the operational impact on Federal Government missions during the reallocation process. Title VI provides five criteria for selecting frequency bands for reallocation from Federal Government to non-Federal sector use. Of the five band selection criteria specified in Title VI, three include a specific Federal Government cost or operational impact factor that must be considered, including the following specific requirements:

   o "...the Secretary shall ...seek to avoid ...serious
      degradation of Federal Government services and operations
      [and] excessive costs to the Federal Government
      and users of Federal Government services,"
  
   o "...the Secretary shall ...consider the immediate and
      recurring costs to reestablish services displaced by the
      reallocation of spectrum," and
  
   o "...the Secretary shall ...[recommend] for reallocation
      bands of frequencies ...the transfer of which (from
      Federal Government use) will not result in costs to the
      Federal Government, or losses of service or benefits to
      the public, that are excessive in relation to the benefits to
      the public that may be provided by non-Federal licensees."[EN1]
 

All of the bands being considered for reallocation are used by Federal Government agencies, in varying degrees, to support Congressionally mandated missions. Thus, all reallocation options will entail cost and/or operational impact to the Federal Government agencies. For example, the Federal Government has invested over $9 billion[EN2] in radiocommunications equipment capable of operating in the bands identified in the preliminary reallocation plan. In general, alternative bands entail even higher investment costs. Simply identifying the bands that have a minimum impact on the Federal Government agencies would not meet the intent of Title VI with regard to the public benefit. The final spectrum reallocation plan must strike a reasonable balance with respect to the impact on Federal Government users and potential benefits to the public. However, Federal Government agencies must continue to perform their mandated missions.

The final spectrum reallocation plan must ensure that the bands identified meet the Title VI selection criteria. However, the displaced Federal Government functions that result are to be preserved in other frequency bands at considerable cost to the Federal Government. The costs associated with this reaccommodation were addressed in the Preliminary Report in general terms, since the data required for a detailed evaluation was not then available. Subsequent to the release of the Preliminary Report, the Secretary of Commerce asked that each Federal Government agency affected by the preliminary reallocation plan provide cost estimates for reallocating the candidate bands. The cost impacts are preliminary estimates only based on the reallocation of frequency bands recommended in the Preliminary Report. Final cost impacts will be determined based on the final spectrum reallocation plan, extensive engineering studies and cost analysis on data provided by the Federal Government agencies.

This section documents the available data regarding specific Federal Government costs and/or operational impact associated with the spectrum reallocation process. While the data addresses only the bands identified in the preliminary plan, the data can also serve, in some cases, to extrapolate the results to other bands. The discussion that follows draws from information provided in the Preliminary Report as well as from the specific data provided during the public comment period. An overview of Federal Government reallocation costs is provided first, followed by an in-depth, band-by-band discussion of Federal Government reallocation impact and costs.

OVERVIEW OF FEDERAL GOVERNMENT REALLOCATION COSTS

Ten Federal Government agencies, including a joint DOD input, responded to the Secretary's request for cost data. TABLE 3-1 summarizes the data provided.In some cases where specific reallocation cost data were not available, agencies provided additional data on investment costs that is not reflected in this table. It should be emphasized that this table addresses only direct costs and does not address additional operational impact, program delays, etc., that may also result. These factors are discussed in more detail in the subsequent portions of this Section.

===================================================================================================== 
TABLE 3-1: Summary of Federal Government Reallocation Costs Data for the Bands
           Identified in the Preliminary Report
=====================================================================================================
                  
                  Frequency     Costs Data
  Agency          Band (MHz)    (Millions)
=====================================================================================================
Agriculture       1710-1755        48
Air Force         All bands        60 [a]
Air Force/FAA     1390-1400        35 [b]
Army/ACE          1710-1755 &      33
                  4635-4685 
Commerce          1670-1675        35-55
Energy            1710-1755        2.4-9.8 [c] 
Interior          1710-1755        8-13 
Justice           1710-1755        144  
NASA              1710-1755 &      0.04
                  4660-4685 
Navy              Various bands    30-113 [d]
Treasury          1710-1755        0.5 
Transportation    1390-1400 &      115
                  1710-1755        
------------------------------------------------------------------------------------------------------

[a] Costs could increase by up to $123 million if unacceptable interference to or from non-Federal systems necessitates major hardware changes or replacement of Air Force telemetry and data link systems.

[b] Costs could increase by up to $500 million if unacceptable interference to or from non-Federal users necessitates major hardware changes or replacement of joint FAA/AF ARSR-4 radars.

[c] The higher range is required if an exception is not provided to other Federal agencies carrying DOE electrical power distribution information.

[d] Costs could increase by up to $63 million if unacceptable interference to or from non-Federal users necessitates retrofit of Navy carrier landing system radars. ======================================================================================================

In general, reallocation costs to the Federal Government can be reduced through a variety of approaches, such as: (1) reallocating only portions of bands and retuning existing equipment into the remaining portions of the band, where possible; (2) reallocating only portions of bands and retuning some existing equipment into the remaining portions of the band, and relocating the remaining equipment to other bands, where possible; (3) retaining Federal Government assignments in bands reallocated for mixed use, in critical geographic areas; and (4) adopting reallocation timetables based on the useful remaining life of the equipment.

Unlike some other radiocommunications functions that might use commercial alternatives, the functions performed by radio astronomy, radars, and military tactical radio systems cannot be replaced by commercial resources. Many of the latter (non-military) requirements, formerly met by specialized systems, may be met by new and emerging commercial technologies, including digital cellular and PCS systems. However, certain tactical communications functions, which include point-to-multipoint, priority access, wide-area coverage, and security, cannot be supported by the existing commercial services. Until these capabilities can be demonstrated there still exists a requirement for the continued use of specialized systems for tactical communications.

FEDERAL GOVERNMENT OPERATIONAL IMPACT AND COSTS ASSESSMENT

This subsection contains a description of the Federal Government systems that are potentially impacted because of the reallocation process. The discussion is based on data provided in the Preliminary Report, additional Federal Government agency inputs provided during the public comment period, and views expressed by IRAC members.

1390-1400 MHz Band

An overview of the Federal Government agencies affected by the proposed reallocation of the 1390-1400 MHz band segment, the types and functions of the systems operating in the band, the reallocation impact, and the reallocation approach to be taken by the agencies is given in TABLE 3-2. The following paragraphs will discuss the reallocation impact and options for each of the agencies affected by the reallocation of the 1390-1400 MHz band segment.

=====================================================================================================================================
TABLE 3-2: Overview of Reallocation Impact for the 1390-1400 MHz Band
=====================================================================================================================================

 AGENCY                                     # OF   TUNING RANGE       REALLOCATION              REALLOCATION
AFFECTED    TYPE           FUNCTION         UNITS      (MHZ)             IMPACT                  APPROACH
=====================================================================================================================================
  AF      FPS-117      air defense radar     32     1215-1400    radar sites are       Radar operations can continue in
                                                                 protected in Alaska   Alaska on a secondary basis, how-
                                                                                       ever if interference occurs, mod-
                                                                                       ification or replacement may be
                                                                                       necessary. The modification costs 
                                                                                       are estimated at $100M and will take 
                                                                                       5 years. Repaacement costs are esti-
                                                                                       mated at $350M and will take 15 years.
--------------------------------------------------------------------------------------------------------------------------------------
  AF      FPS-124      air defense radar     42     1218-1398     radar sites are      Radar operations can continue in
                                                                 protected in Alaska   Alaska on a secondary basis, how-
                                                                                       ever if the radars must be replaced,
                                                                                       their cost is estimated to be between
                                                                                       $100-130M, and will take 5 years.
---------------------------------------------------------------------------------------------------------------------------------------
  AF      PPQ-2(V)1    tactical radar        11     1220-1400    loss in tuning range  Redesign radar to operate in the 1220-
                                                                                       1390 MHz band. R&D will require an
                                                                                       estimated $5M in FY96.
--------------------------------------------------------------------------------------------------------------------------------------- 
  AF      ARSR-1,2,3   air traffic control   113    1215-1350    design & install      The design frequency range for these
            TPS-63     & air defense radars                          filters           radars is 1215-1350 MHz. These radars
        FPS-20,90,93A                                                                  are scheduled to be replaced by the
                                                                                       ARSR-4 radars.
----------------------------------------------------------------------------------------------------------------------------------------
  AF         CAMS      wireless maintenance   1     1215-1400   vendor must relicense  Vendor to relicense this equipment.
                           system                                                      Estimated cost is $50,000.
----------------------------------------------------------------------------------------------------------------------------------------
  AF        NGTCS      target control system  5     1350-1400            none          Still in the design phase. Cost impacts
                                                                                       may arise due to the 1390-1400 MHz loss
                                                                                       but specific costs are unknown at this time.
-----------------------------------------------------------------------------------------------------------------------------------------
  AF         NDS       nuclear detonation     24    1381.05              none          Receiver tunes at 1381.05  2 MHz.
                           system                     2 MHz
==========================================================================================================================================
  N          MK-23      shipborne radar       58    1215-1400    loss in tuning range  Restrict tuning to below 1390 MHz.
------------------------------------------------------------------------------------------------------------------------------------------
  N         TPS-59       tactical radar       15    ---------    loss in tuning range  Restrict tuning to below 1390 MHz.
==========================================================================================================================================
  AR        MPQ-49       tactical radar      180    ---------    loss in tuning range  Restrict tuning to below 1390 MHz.
            TPQ-32
------------------------------------------------------------------------------------------------------------------------------------------
  AR        GSS-1     transportable radar     10    1215-1400    loss in tuning range  Restrict tuning to below 1390 MHz.
------------------------------------------------------------------------------------------------------------------------------------------
AR &      GRC-226,    tactical radio relay   2650   1350-1850    loss in tuning range  Federal operations eill continue at 17
  AF                                                                                   locations listed in the Preliminary Report.
                                                                                       Modifications to restrict tuning in the
                                                                                       reallocated band segment will cost $125,000
                                                                                       per radio relay as needed.                                                                                       
===========================================================================================================================================
  T         L-88       aerostat raddar        15    1215-1400    loss in tuning range  Restrict tuning to below 1390 MHz.
===========================================================================================================================================
 FAA     ARSR-1,2,3   air traffic control    200    1215-1350      need new filters    Design and install filters if interference
                           radar                                                       develops.
-------------------------------------------------------------------------------------------------------------------------------------------
FAA &     ARSR-4     air traffic control &    44    1215-1400    available channel     Reallocation will, at a minimum, require software 
 AF                  air defense radar                           pairs reduced by 4    modifications estimated at $35M. If available
                                                                                       frequencies cannot support the dual-channel hopping
                                                                                       requirement, hardware modifications estimated at
                                                                                       $525M and taking 5 years to complete will be
                                                                                       necessary.
===========================================================================================================================================
 AF       RAJPO      air/ground datalink      18    1350-1400    loss in tuning range  Hardware modification may be necessary if spectrum 
                                                    1427-1435                          loss limits schedule for test events. Estimated cost
                                                                                       is $23M and will take 5 years.
============================================================================================================================================
 NSF        RA         spectral line           4    1350-1400          none            Include reallocation constraints from the Preliminary
                       observations                                                    Report to restrict adjacent band emissions.
============================================================================================================================================

Navy. The reallocation of the 1390-1400 MHz band segment will primarily impact Navy shipboard radars, resulting in a 6% loss of frequencies available for operation. The reaccommodation approach that could be taken by Navy is to retune within the 1215-1390 MHz frequency band. The overall economic impact of restricting the tuning range of these radars cannot be measured simply by the initial spectrum loss. Reducing the available bandwidth will reduce the anti-jamming/interference margin of the radar and make it more susceptible to interference from new and existing systems within the remaining portion of the band. The high-power requirements of shipboard radars, combined with the physics of over-water radio propagation, result in an interference range extending several hundred kilometers. The resulting increase in radar-to-radar interference would reduce the number of ships that could operate in close proximity within Naval task force formations. Engineering studies would be necessary to analyze the specific impact and provide guidance on measures to avoid electromagnetic interference.

Navy presented an example of the types of interference problems that can occur as a result of the loss of the 1390-1400 MHz band. Navy's MK 23 Target Acquisition System (TAS) provides target information to the NATO SEASPARROW Surface Missile System (NSSMS). Navy states that the proposal to reallocate the 1390-1400 MHz band segment will reduce the number of available unique channels for TAS from 28 to 25 in blue water operations, and to as few as two channels in operations within 200 nautical miles (nmi) of the United States. The Navy states also that "The reduction of available channels when operating within 200 nmi off shore is because of radiation restrictions already imposed on MK 23 TAS to prevent interference to FAA air traffic control radars."

The Navy further states that the impact of reallocating additional spectrum in the 1350-1390 MHz band is particularly severe if two or more of the ships are operating within 200 nmi of each other. According to the Navy, electromagnetic (EM) energy from one MK 23 TAS [the EM interference (EMI) source] couples into the receiver of another MK 23 TAS (the EMI victim) and the interference can be of such severity as to render the MK 23 TAS incapable of detecting targets and performing its mission.

The Navy also reports that there are many systems operated by Navy and DOD that have a war reserve mode. Although there is an occasional need to test this mode in peacetime, it is particularly important that the wartime mode of operation be taken into account so as to preclude disruption of any vital civil services that may be placed into the reallocated bands, as a result of Title VI.

Army. The Army uses the 1350-1400 MHz band mainly for tactical transportable radio relay systems linking the various headquarters and functional nodes into an area-wide integrated network, for such systems as MSE and TRITAC. The loss of 1390-1400 MHz will have a long-term impact on military training using tactical radio relay systems at most Army bases. Previous reallocation has effectively re-moved land forces tactical networks from two of the six bands normally used. Options of moving operations into one of the other bands are extremely difficult, because these bands are also fully used and very congested.[EN6]

The tactical radio relay systems used by the Army are tunable over the entire 1350-1850 MHz frequency range. Although the proposed reallocation of 1390-1400 MHz represents only a small portion of the operational bandwidth of these systems (2%), the availability of authorized frequencies has continued to dwindle.[EN7] The reallocation approach that could be taken by Army is to restrict tuning in the reallocated band segment (1390-1400 MHz). In order to lock-out the reallocated band segment, modifications will have to be made to technical specifications and software support for each radio relay system. Detailed cost estimates for these modifications were not available.

Air Force. The Air Force operates an extensive network of radars that have the capability to tune in the 1215-1400 MHz band. The various radars are used for search, acquisition and surveillance, perimeter defense of the United States and Canada, drug interdiction support, and tactical command and control. The Air Force states that, "the 1215-1400 MHz portion of the spectrum is ideal for long-range radar propagation and target detection. Other portions of the spectrum do not have the electromagnetic wave physics necessary to perform this function effectively."[EN8]

Two Air Force radars that could be impacted by the reallocation of 1390-1400 MHz are the AN/FPS-117 and AN/FPS-124. Together these systems form an array of radars stretching across North America from Alaska via Canada to Greenland, and are designed to provide long-range detection and coverage against hostile low-flying aircraft and missile attacks. Due to the extreme northern locations of these radars, the physics of radiowave propagation is even more critical.[EN9] In an attempt to avoid unnecessary and costly disruption of Federal operations in remote locations, the Preliminary Report recommended that the Federal radiolocation service will continue on a secondary basis in Alaska.[EN10] Air Force states that operation of the AN/FPS-117 in the 1390-1400 MHz band segment on a secondary basis is an acceptable option only if interference is not likely to occur. If this is not possible, Air Force states that the following transition actions will be necessary:[EN11]

       Transmission requirements. The last two of the 19 channels will be affected by the
        reallocation of the 1390-1400 MHz band segment. Software modifications will be required
        to disable these two channels.
  
       Reception requirements. A hardware modification will be required to select filters that
        eliminate the 1390-1400 MHz band segment.
  
       Mission requirements. Target detection will not be affected by civil sources transmitting
         in 1390-1400 MHz; however, commercial sources could possibly be reported as false
        detections. If this occurs, a hardware modification will be required to eliminate the
        problem.
  
       Calibration and maintenance requirements. The loss of 1390-1400 MHz band segment will
        require modification of the software used for calibration, monitoring, and fault isolation.

Radar operations can continue in Alaska on a secondary basis; however, air force states that if interference occurs, modification or replacement will be necessary. The modification cost is estimated at $100 million and will take 5 years. Replacement cost is estimated at $350 million and will take 15 years.[EN12]

The AN/FPS-124 is a multichannel frequency-agile radar also supporting the Alaskan air defense network. This radar is located in Alaska (3 units) and in Canada (39 units). In the joint DOD response to the Preliminary Report, Air Force states that the loss of 1390-1400 MHz band segment reduces the probability of target detection resulting in redesign of the radar. Loss of spectrum in this band will also make interference resolution with similar systems in Canada and Iceland more difficult. Radar operations can continue in Alaska on a secondary basis; however, if replacement is deemed necessary the estimated cost will be between $100-130 million, and will take 5 years.[EN13]

The RAJPO is a new data link in the 1350-1400 MHz band that Air Force began using in January 1994. This data link rebroadcasts real-time position information of high-velocity manned and unmanned airborne platforms during test and training operations. RAJPO is critical to ensuring the safety of personnel during these operations, and is designed to be interoperable at all Air Force, Army, and Navy test installations.[EN14] A total procurement of 719 units has been authorized for use at 18 sites throughout the United States and possessions. Each airborne RAJPO unit rebroadcasts satellite-derived time and location information via a pair of frequencies in the 1350-1400 MHz and/or 1427-1435 MHz bands. The two frequencies are required to support the probability of reception especially in test areas over large bodies of water, where multipath effects may be more pronounced. The number of channel pairs required varies with the scale of the operations.

The Air Force believes that Federal investment in RAJPO will be jeopardized if continued access to the entire 1350-1400 MHz band is not available. Spectrum for RAJPO operation will remain only in the 1350-1390 MHz band after the reallocation. The western United States presents the most critical RAJPO operation area. There are six sites within range of each other, thus six frequency pairs for simultaneous operations. The reallocation could limit the ability to effectively schedule test events, and hardware modifications would be required. Costs due to delays in aircraft testing can exceed $1 million per occurrence. Flight test and range personnel, as well as specialized hardware, must be idle during delays in testing. Estimated costs for various platforms are: Advanced Range Instrumentation Aircraft (ARIA), $5,000/hour flying time ($1 million minimum); B-1, $1 million if 3-4 hour delay causes missions cancellation; B-2, $500,000/day (delay); F-15, $4,500/hour plus $4,000 range cancellation; and F-16, $5,000-$10,000.[EN15] Modifications will result in an estimated nonrecurring cost of $10 million and an estimated recurring cost totaling $13 million, and will take 5 years.[EN16]

Federal Aviation Administration. The ARSR-4 is the newest radar in the nationwide Joint Surveillance System (JSS) providing air defense and air traffic control for the continental United States, Guam, and Hawaii. The ARSR-4 is being fielded through a Congressionally-mandated joint FAA and Air Force program. The radar has an operational frequency range of 1215-1400 MHz and uses dual-channel frequency hopping technology for long-range anti-jam search and tracking, and is capable of detecting small objects by minimizing clutter, and weather and multipath effects. The radar supports defense of the national airspace and provides initial coastal civil air traffic control.[EN17]

As stated in the joint DOD response, reallocation of the 1390-1400 MHz band segment reduces the number of available channels by four out of the 44 frequency pairs. With the additional loss of frequencies to other systems, the reallocation of 1390-1400 MHz will impact the dual-channel frequency hopping capability that is key to the ARSR-4 design. Reallocation will, as a minimum, require software modifications. If available frequencies cannot support the dual-channel hopping requirement, hardware modifications will be required.[EN18] FAA stated in their comments to the Preliminary Report, that the reallocation of a smaller portion of the band will have a lesser, yet significant impact on ARSR-4 operations, particularly in high-density environments.[EN19] Reallocation will, as a minimum, require software modifications estimated to cost $35 million. If the available frequencies cannot support the dual-channel hopping requirement, hardware modifications estimated at $525 million and taking 5 years to complete will be required.[EN20]

Another concern expressed by FAA relating to the loss of the 1390-1400 MHz band segment is the existing spectrum congestion in the 1215-1400 MHz band.[EN21] This congestion is, in part, a function of the choice of power output tube used in the radar design, and by any post-power tube output filtering. The measured ARSR emission spectrum illustrates this fact well. The ARSR-1 and 2, which use crossed-field amplifiers (amplitrons) as their final output stage, produce relatively high-amplitude extended emission spectra, measurable at frequencies up to 4400 MHz. These radars utilize output filtering after the amplitron stage to improve their spectral occupancy characteristics. The ARSR-3, in contrast, uses a klystron amplifier and produces a much lower-amplitude extended emission spectrum. The ARSR-4, which utilizes solid-state technology, is expected to also produce a low-amplitude extended emission spectrum. The Air Force states that FAA and DOD have firm plans to replace aging ARSR-1,2,3 joint surveillance radars with the ARSR-4. The Air Force states also that "the ARSR-1,2,3 radars are currently beyond their design life and are maintained only at great effort and expense."[EN22]

The spurious emissions of all existing FAA radar systems in the 1215-1400 MHz band are high and the radio frequency filters for these radars use an upper band edge cut-off of 1400 MHz. Reallocation of the 1390-1400 MHz portion of the band will require that these radars be retrofitted with new filters. The cost would be at least $6 million, depending on the radio service allocated in the adjacent-band.

A concern in reallocating this band for commercial or public-safety applications is that high-power radar systems will be in the adjacent band. Numerous case histories exist of interference from adjacent-band, high-power, radar systems due to insufficient receiver selectivity. In general, the FCC declines to establish receiver standards, opting to let the marketplace determine the receiver design. This approach is in contrast to the approach taken by the Federal Government and by most governments worldwide, where receiver interference immunity standards are commonplace. The Federal Government has recognized the importance of having receiver standards for the effective management of spectrum resources, and has adopted receiver standards for most Federal radio systems.

Treasury. Treasury maintains 13 tethered aerostats along the southwest border from Arizona into the Caribbean. Each aerostat includes an L-88 radar with a tuning range of 1215-1400 MHz.[EN23] From a review of the Government Master File (GMF)frequency assignment data base, it was determined that all of Treasury's aerostat radars operate below 1314 MHz, and will not be directly impacted by the 1390-1400 MHz reallocation. However, the loss of spectrum may contribute to the overall congestion currently experienced in the 1215-1400 MHz band, and electromagnetic interference may become more prevalent among systems in the remaining spectrum. Engineering studies may be required to analyze the impact in detail, and provide guidance to resolve any interference problems.

Energy. The Global Verification and Locations System (GVLS) is a new system being developed under DOE's Satellite Instrumentation Program. The main purpose of this program is to develop, design, implement, and support space-based nuclear explosion sensors for detection, identification, location, and characterization of nuclear detonations in the atmosphere and in space. GVLS is being developed to perform the nuclear explosion detection function and to augment the DOD's Nuclear Detonation System. GVLS discrete frequencies have not been selected as yet but the frequency preferences include: 1371 MHz, 1373 MHz, and 1377 MHz. The reallocation of the 1390-1400 MHz band segment could impact future GVLS operation.[EN24]

National Science Foundation. As stated in the Preliminary Report, the 1350-1400 MHz band is important for radio astronomy observation of red-shifted hydrogen spectral lines. Most of the galaxies detected using the hydrogen spectral line and the associated red-shift frequency occur in the 1350-1400 MHz region of the spectrum. Spectral lines, by their nature, are tied to specific frequencies; therefore, reaccommodation of radio astronomy observations to other bands is not a feasible option.[EN25]

Although radio astronomy observations using the 1350-1400 MHz band are on an unprotected basis, the band is nevertheless extremely important to the success of many domestic and international scientific studies. To reduce the impact on important Federal and university radio astronomy operations, the Preliminary Report concluded that the reallocation of the 1390-1400 MHz band for non-Federal use must include restrictions on space-to-Earth links, and footnote US311 from the National Table of Frequency Allocations must remain in effect. Provided that these restrictions are observed, NSF expects no major operation or economic impact as a result of reallocating the 1390-1400 MHz band segment.[EN26]

Summary for the 1390-1400 MHz Band. The reallocation options for Army and Navy systems with tuning capability in the 1350-1400 MHz portion of the band will be to restrict tuning to frequencies below 1390 MHz. Initially the impact may appear to be minimal, but over the long-term, crowding among spectrum users may result in an increase in interference problems. It is not possible to determine the full scope of the problem at this time, but agency funding to analyze and solve the interference problems resulting from reallocation of the 1390-1400 MHz band segment will be required.

The impact to the joint FAA /DOD ARSR-4 radar is more severe because this system was not designed to be easily retuned. The ARSR-4's simultaneous dual frequency design [Dual frequencies separated by 83 MHz] and predefined channel plan spans the entire 1215-1400 MHz band, making reallocation of even the upper 10 MHz difficult if system performance is to be fully met. Two issues that are directly related to the loss of the 1390-1400 MHz band segment are: interference from adjacent ARSR-4 radars and the inability to assign frequencies for proper operation in high density areas. The reallocation of the 1390-1400 MHz band segment will at a minimum require software modifications.

Additional reallocation costs will include modification of FAA's ARSR-1,2,3 radars with new radio frequency filters to reduce spurious emissions to a yet-to-be-determined adjacent non-Federal service. The estimated cost to retrofit the ARSR-1,2,3 radars with the new filters is $6 million. Reallocating the 1390-1400 MHz band segment for non-Federal use will also require long-term planning by the Federal Government to re-engineer the existing U.S. channeling arrangement and frequency assignments to accommodate the radars operating in the remaining 1215-1390 MHz potion of the spectrum.

In addition, to achieve a satisfactory commercial service that is immediately adjacent to a band used by megawatt radar systems, the adoption of effective interference immunity standards for non-Federal receivers operating in this band is essential.

1427-1432 MHz Band

The Federal Government agencies primarily affected by the proposed reallocation of this band are Navy, Army, Air Force, and the National Science Foundation. The following paragraphs describe the systems operating in the band and transition plans, costs, and options for each of the affected agencies.

Army. The Army uses the fixed service in this band primarily in support of proficiency training and other Army operations using tactical radio relay equipment for such systems as MSE and TRITAC systems for the active Army, National Guard, and Army Reserves, and at most Army bases. These tactical radio relay systems have tuning ranges in the 1350-1850 MHz band. Frequencies in the 1427-1432 MHz band are deemed by Army as critical to the flexibility of the MSE and TRITAC equipment because of the ability to pair these frequencies for duplex operations.

The Army cautioned that "at a minimum the Army must have secondary use [of the 1427-1432 MHz band]."[EN27] Problems associated with reallocation of the wider 1350-1850 MHz band were described by Army as follows: " ...Options of moving operations into one of the other bands are extremely difficult and not operationally sound. Other bands are fully used and very congested. Moving to a lower band creates technical problems from bandwidth requirements, and further complicates the cositing technical parameters of a congested band. Moving to a higher band creates similar problems and affects the transportability from an increase in antenna size and power ...Further loss or erosion of authorized frequency resources would adversely affect military land forces' ability to provide an adequate command, control communications network."[EN28] Specific Army reallocation options, transition plans, or reallocation cost estimates for this band were not available.

Navy. The Navy operates a number of mobile communications systems in this band whose functions include: command, control, and telemetry links for remotely piloted vehicle (RPV) operations; airborne missile command and guidance; and ship sensor and navigation accuracy verification. Specific Navy reallocation options, transition plans, or reallocation cost estimates for this band were not available. However, a comprehensive reallocation cost between $30 to $113 million was provided by the Navy for the various frequency bands for reallocation. This cost could increase by up to $63 million if unacceptable interference to or from non-Federal users necessitates retrofit of Navy systems in some of the bands for reallocation.

Air Force. The Air Force operates a number of mobile communications systems in this band whose functions include: telecommand of RPV systems, aeronautical telemetry and control links, missile command/guidance links, remote controlled excavation, perimeter defense and target scoring systems. The Air Force states that reallocation of this band would result in the need to retune or replace in other bands a number of these systems at an estimated cost of $24,000 to $100,000.[EN29]

One of the major systems in this band is the $70 million DOD-sponsored RAJPO GPS Data Link. Initiated in January 1994, RAJPO is being installed at 18 sites throughout the United States and its possessions. The Air Force believes that reallocation of the full 1427-1435 MHz band would severely limit its ability to effectively schedule test-range events.[EN30] Redesign of the system in an alternative band to regain full capability is estimated to cost DOD $23 million over 5 years.[The proposal in the Preliminary Report to reserve the 1432-1435 MHz portion of the band for continued exclusive Federal use is designed to minimize these operational and cost impacts.]

National Science Foundation. The National Science Foundation (NSF) operates radio astronomy receivers in the lower adjacent band. NSF expects no major operational or economic impact as a result of the reallocation, provided that the restrictions identified in the Preliminary Report are observed.

Summary for the 1427-1432 MHz Band. NSF has indicated that no significant operational or economic impact would result from implementation of the preliminary reallocation plan. Air Force transition plans call for retuning or replacing its current equipment in this band at a minimum cost of $24,000 to $100,000. Transition costs for the DOD-sponsored RAJPO system, if replacement is found to be necessary, are an estimated $23 million. Also, significant impact on the training of Navy and Air Force pilots in the use of sophisticated weaponry will occur, unless operations are permitted to continue at test and training ranges specified in Appendix F.

1670-1675 MHz Band

The Federal Government agencies primarily affected by the reallocation of this band are the Department of Commerce, Air Force, and NSF. The following paragraphs describe the systems operating in the band and transition plans, costs, and options for each of the affected agencies.

Commerce. Most of the 111 frequency assignments in this band are for radiosonde stations operated by NOAA. The preliminary reallocation plan for this band recommends that agencies redesign, procure, and deploy a national radiosonde network that will operate solely within the 1675-1690 MHz band. A minimum reallocation delay of 5 years was stated as a sufficient amount of time to accommodate the change-over.

In order to achieve the frequency stability necessary to permit radiosonde operation in the smaller reallocated band, the new radiosondes would need to use crystal-controlled transmitters and a new type of modulation.[EN31] The technology needed to make these changes is reported by NOAA as available, but the increased cost has historically made the new technology impractical. NOAA estimates the increase in yearly recurring costs for the 80,000 radiosondes launched each year to be $1 million.[EN32] NOAA also notes that the impending presence of non-radiosonde emitters within what is now the radiosonde band requires replacement of the radiosonde ground tracking equipment as well. NOAA expects that the 3 types of radiosonde ground tracking equipment currently used in this band could be replaced by a common system for a one-time cost of $20-40 million, and will require up to 5 years to design, procure, and deploy.[EN33] NOAA estimates the 15-year cost for all of the necessary changes is $35-55 million.[EN34]

Termination of the GOES weather satellite transmissions is not feasible and continued operation of the Earth stations in Alaska and Virginia is required at least through the completion of the GOES-NEXT program.

Air Force. The Air Force reports that it operates an undetermined number of radiosondes (including AN/GMD-5 receivers) and seven Mark IVB Meteorological Satellite Ground Terminals in this band. The cost to modify the AN/GMD-5's and all radiosondes in order to comply with the reallocation plan is approximately $500,000. The estimated total cost to retune the Mark IVB receivers is $15,000.

National Science Foundation. NSF expects no major operational or economic impact as a result of the reallocation, provided that the restrictions on airborne and space-to-Earth links identified in the Preliminary Report are observed.

Summary for the 1670-1675 MHz Band. NSF indicated that no significant operational or economic impact would result from implementation of the preliminary reallocation provided the restrictions identified for this band are observed. NOAA estimates that it will cost $35-55 million over the next 5 years to implement the changes required as a result of the reallocation plan for this band. The Air Force estimates that it will cost $515,000 to make the necessary modifications for this band.

1710-1755 MHz Band

The 1710-1755 MHz segment of the 1710-1850 MHz band is currently allocated to the Federal Government exclusively for fixed and mobile services on a primary basis. Being extensively used by the Federal Government, reallocation will impact, in varying degrees, most major Federal Government agencies. The following paragraphs describe the systems operating in the band and transition plans, costs, and options for each affected agency. Appendix A provides a broad examination of the feasible transition options to implement reallocation of this band.

Army. Among the three DOD services, Army is the most significantly impacted by the potential reallocation of the 1710-1755 MHz band. The ACE uses the 1710-1755 MHz frequency range for its fixed microwave radio systems serving backbone communications in the Continental United States Engineer Districts. Functions include remote controlled hydropower generating stations; communications support of the Federal Emergency Management Agency (FEMA) and emergency civilian relief; flood control and sensor telemetry; and maintenance and traffic control along 50,000 km of inland waterways, harbors, locks and dams.

Although the ACE is not a Federal power agency (FPA), as defined by Title VI, the functions they perform in this band are viewed by Army as similar to that of an FPA. Because of this, Army suggests that, "the Corps of Engineers should be afforded the same power agency protection [and] that [their] assignments shall not be modified nor receive unacceptable interference from future non-Federal users." If such protection is not adopted, Army estimates the cost to recrystal and realign approximately 260 sites to operate in the remaining 1755-1850 MHz portion of the band to be in excess of $23 million. [EN35]

The second major Army use of the band is to support its tactical radio relay proficiency training activities. Specifically, Army uses the 1710-1755 MHz frequency range extensively for headquarters nodal connectivity within their area-wide integrated communications networks. The Army reports that this equipment is transportable to support a fast moving network and flexible to the tactical tempo and operational conditions. Lightweight, transportable equipment is stated by Army to be a fundamental requirement for rapid installation, break down, and camouflage. The transmitter power, propagation, available bandwidth, and other technical factors support 1350-1850 MHz as the optimum band for use on the dynamic air-land battlefield. The Army further states, "Options of moving into one of the other bands are extremely difficult and not operationally sound... . Further loss or erosion of authorized frequency resources would adversely affect military land forces' ability to provide an adequate command, control communications network." While noting the equipments' 1350-1850 MHz tuning range, Army states, "This 10% loss is significant because it compresses the authorized frequency bands and complicates the tactical frequency assignments." Specific costs associated with this 10% loss in tuning flexibility were not available.

Air Force. Air Force microwave operations in this band include provisions for communications link connectivity between geographically separated gap-filler radar sites, medical facilities and test or training areas. In addition, encrypted communications links connectivity are employed for command and control of forces between headquarters and wing commanders. A secure communications system employed by Air Force in the 1710-1755 MHz band is the Weapon Control Data Link System which provides a two-way anti-jam data link for command signals and video data. A microwave system used to conduct air traffic control at Hill AFB would also be affected by the reallocation with an estimated total retuning costs in excess of $20,000. A less impacted Air Force operation is the narrowband air-to-ground telemetry link that provides control communications between airborne and ground equipment via the TARS. The Aerostats could be retuned to other portions of the band. The Air Force estimates the cost to reallocate the 1710-1755 MHz band to non-Federal use in excess of $8.3 million.

This band is also utilized for guided weapon missile systems. These systems are used to provide radionavigation, radiolocation, and guidance of Air Force weaponry. Air Force reports that reallocation of this band could reduce the anti-jamming capability by almost 40%, and render the guidance links useless in the presence of jammers should modifications to the system be necessary. A total re-engineering of approximately 1000 units would be required at an estimated cost of over $100 million.

Transportation. FAA and the United States Coast Guard (USCG) enforce rules and safety for air and waterways navigation. These agencies provide not only navigational aids but assist or support in missions such as emergency rescue. FAA uses fixed microwave links in this band as part of a nationwide radiocommunication link network to interconnect the nation's air traffic control facilities. The 1710-1755 MHz frequency range is used by the USCG for vessel traffic control and safety operations, communications support of the VHF National Distress System, and remote distress and safety communications and control networks.

The reallocation cost for FAA alone to relocate its existing fixed microwave stations in the 1710-1755 MHz band to the 7/8 GHz band is estimated at $96 million.[EN36] For the CG, the most probable cost impact from the reallocation process is the loss of its microwave links in the 1710-1755 MHz band. CG provides an estimated relocation cost at $10.6 million non-recurring and $2.3 million recurring costs.[EN37] However, both FAA and USCG reallocation costs for the 1710-1755 MHz band could be reduced if they are allowed to retain certain frequencies in the band.

Interior. DOI operates about 110 fixed microwave links in this band for a variety of functions including: control of land mobile radio systems necessary in firefighting, law enforcement, disaster control within national forest and parks, communications services to Indian reservation areas, and earthquake monitoring and hazards mitigation. In accordance with Federal regulations, Federally owned communications are used only where commercial service is not available, not technically adequate, or significantly more expensive. In the 1710-1755 MHz frequency range, DOI shares some frequencies with DOE for the distribution and maintenance of electrical power energy. The DOI estimated the direct dollar costs associated with implementing Title VI is in the range of $8-13 million.[EN38] The variation in the estimated reallocation costs is a function of whether: (1) microwave frequencies will be available within the remaining segment (i.e., 1755-1850 MHz) at specific locations; (2) new frequencies in the band 2200-2290 MHz can be coordinated; or (3) new fixed microwave links in the 7/8 GHz band can be engineered and installed. Other tangibles associated with the costs include: purchase of interim equipment to temporarily maintain microwave links during 2 to 4-weeks factory modification periods at locations where "hot-standby" equipment is not installed; and cost of contracted technical assistance to augment limited staff personnel.

DOI manages its natural resource programs using radiocommunication to accomplish Congressionally-mandated missions. These operations are spread throughout the United States, in suburban, urban, and rural areas, some of which are remote and almost inaccessible areas where commercial service is not currently available. Some of DOI's communication systems encompass only a few buildings in a city or a small wildlife refuge where commercial service is not always reliable. Others encompass large geographical areas, such as national forests and Indian reservations. Because of its diverse mission requirements and the need for coverage in unpopulated areas, the use of currently available commercial services to provide cost effective communication services was not considered a viable option by DOI for these applications.

Energy. The majority of DOE's fixed microwave operations in the 1710-1755 MHz frequency range are in support of the Electrical Power Marketing Program. FPAs use this portion of the spectrum for wide-area fixed networks to support the supervision, control, and protection of electrical power transmission. The channels are used for high-speed relaying, supervisory control, load control, telemetering, data acquisition, land-mobile radio dispatching, operations and maintenance. Some of the present FPA systems connect, via wireline and radio, all Federal power marketing control facilities in certain regions of the United States. Common equipment exists between the Federal and non-Federal users allowing interconnectivity for critical communications dealing with all aspects of generating and distributing power. Title VI includes a specific provision that frequencies assigned to these FPAs may only be eligible for reallocation on a mixed use basis, and any non-Federal user shall not cause harmful interference to existing FPA operations. In complying with this provision, reallocation of the band on a mixed use basis will not result in operational or cost impact to any existing FPA uses.

The other DOE fixed microwave operations are in support of the National Defense and Petroleum Reserve Programs with a variety of functions such as remote keying of high frequency transmitters, backbone, and security, and remote control of robots, cranes and alarms.

Noting the protected status of FPA operations, DOE estimates that there will be minimal impact on existing and planned operations as a result of reallocating the bands identified in the Preliminary Report. DOE estimates that the reallocation cost to replace non-FPA systems in the 1710-1755 MHz band with equipment in the 7/8 GHz band is $2.4 million and can be accomplished within the timeframe proposed in the Preliminary Report. However, DOE states that there are areas of concern with the proposed reallocation plan that may increase this estimated reallocation cost by an additional $7.4 million.[EN39] This additional cost would result if the ACE and the United States Bureau of Reclamation frequencies in the 1710-1755 MHz band supporting power transmissions are not exempted for reallocation. Although the FPAs were granted an exception from Title VI and will receive protection from the emerging wireless telecommunications technologies, increased usage in the 1710-1850 MHz band by these new technologies in the future may require more effective national regulatory procedures to ensure continued use of this band by FPAs. The cost impact to DOE if these microwave systems are not protected and must be relocated to another frequency band or transmission media in the future will be greatly increased. Also, because planned additions will have to be located in the remaining portion of the 4400-4990 MHz band or the 7/8 GHz band, additional costs will be required. Microwave systems whose links are scattered across various frequency bands may result in lower reliability and higher costs.

Justice. DOJ makes broad use of radio frequencies in the 1710-1755 MHz band for Congressionally-mandated enforcement programs, including the continuity of law enforcement and National Security Emergency Preparedness telecommunications services. The principal bureaus affected by the potential reallocation of this band are the Federal Bureau of Investigation (FBI), Immigration and Naturalization Service (INS), and Drug Enforcement Administration (DEA). FBI has 427 microwave sites operating in this band to relay land-mobile radio traffic throughout its district communications networks. INS operates 90 fixed point-to-point digital microwave systems in the band to support the interconnect requirements of INS Encrypted Voice Radio Program. DEA uses the 1710-1755 MHz frequency band to support their video transmission systems, and operates approximately 500 transportable video transmission links for nationwide law enforcement activities.

Bureaus within DOJ have proposed a variety of transition options to effect the reallocation of the 1710-1755 MHz band. For example, FBI began a program in 1991 to convert its microwave links in the 1710-1850 MHz band to leased wireline. FBI estimates the 15-year costs for the conversion of the 427 sites operating in the 1710-1755 MHz portion of the band to exceed $121 million.[EN40] INS proposes to relocate the existing point-to-point microwave systems to higher frequency bands (e.g., 7/8 GHz band) at an estimated cost of $23 million. DEA proposes to recrystal and realign its communications links at an estimated per unit cost of $350 for a total cost of $180,000. Summing these costs, the total DOJ estimated reaccommodation cost of its operations in this band exceeds $144 million.

Several factors dictate that certain land mobile communications requirements of Federal law enforcement agencies cannot be met by existing commercial services. First, most Federal law enforcement communications must be immediate; the delays associated with call setup of the commercial Public Switched Telephone Network is unacceptable in certain life-threatening situations. Second, most Federal law enforcement agencies have area offices that are responsible for activities throughout a large geographic area, in many cases where commercial services are not available. Finally, Federal law enforcement systems require secure communications. The monitoring of clear voice commercial communications by the general public, the news media, foreign intelligence agents, and criminals has disrupted investigations and caused life-threatening situations for law enforcement personnel. As stated earlier, FBI is currently converting to leased wireline services that will replace its fixed microwave backbone network.

Treasury. The United States Customs Service of the Department of Treasury (Treasury) operates and maintains an inter/intra-island backbone fixed microwave system between the Hawaiian Islands commonly known as the Rainbow Microwave System. This fixed microwave system, which includes two of the longest known over water fixed links in the world, cannot be technically supported at higher frequency bands. Treasury reports that the system was reconfigured from the 7/8 GHz band to the 1710-1850 MHz band to achieve the required reliability. The system evolved from a few user owned fixed microwave links connected back-to-back into a conglomerate of shared Federal Government and non-Federal sector segments which now constitute a 120-channel backbone system. It provides complete inter and intra-island linkage of multiple Federal, state and local law enforcement, maritime safety, and public service systems. The system carries USCG search, rescue, calling and distress traffic, Emergency Medical Service Support traffic, fire, police, National Weather Service, and Civil Defense emergency communications. It also carries high priority communications pertinent to agent safety related to drug interdiction, counterfeit, fraud, and forgery investigations, and protective communications required for visits by the President or Vice President and their families as well as foreign heads of state and government. Although replacement could conceivably cost upwards to $25 million,[EN41] Treasury emphasizes that alternatives such as use of higher frequency bands, satellite links, or undersea cable are not technically or economically viable. Treasury urges that this system be included in the list of Federal stations that will remain in the band and protected from interference under the mixed use criteria as mandated in Title VI. The most critical discrete frequencies used for the over water fixed links are 1711, 1719, 1729, and 1735 MHz.

Treasury also uses the band for a variety of other functions including aerostat data links, and air-to-ground video links used in surveillance operations. Treasury estimates the reallocation cost impact on these systems is approximately $500,000.

At this time, it is not known whether the microwave links that comprise the essential Rainbow Microwave System could be technically or economically substituted with commercial satellite communications services. However, since this system represents the only linkage of multiple Federal/state/local law enforcement, maritime safety, and public service systems, resulting in a requirement for a high reliability of service, the replacement of this system by a currently available commercial service is not seen as acceptable option by Treasury.

Commerce. NOAA is responsible, inter alia, for the collection of meteorological data and the preparation of weather forecasts that affect the health, safety and economic well being of the public. NOAA's data collection efforts involve weather radars and other ground-based systems, as well as meteorological satellites. NOAA operates eleven microwave links in the 1710-1755 MHz band for tsunami warning, radar-remoting and other meteorological purposes. Detailed NOAA cost impact data for this band was not available.

Agriculture. The Forest Service of the USDA is one of the Federal Government's largest users of the 1710-1850 MHz radio band. Reallocation of the 1710-1755 MHz band will impact 40% of the 1,370 Forest Service fixed microwave radio sites, the majority of which were installed between 1981 and 1986. These sites provide backbone communications links supporting land mobile radio systems on National Forest and other lands managed by USDA for the public. The backbone links provide the primary radio interconnection between mountaintop radio repeaters and the base stations, which further interconnects with either mobile or portable hand-held radios. These systems are essential for law enforcement, firefighting, and emergency preparedness disaster control (e.g., earthquake, volcanic eruption and hurricane) communications. Some USDA microwave links are shared with other Federal agencies such as the DOJ. In order to meet the requirements of the proposed reallocation plan, USDA recommends obtaining new frequencies in other bands such as the 4.4/4.99 GHz or 7/8 GHz bands and procuring new equipment at an estimated cost of $48 million.[EN42] Other alternatives that would have involved acquisition of commercial leased services, or modification of existing equipment for operation in the 1755-1850 MHz portion of the band, were deemed by USDA as unacceptable.

As stated in the comments submitted by USDA, "The fixed microwave systems under consideration were reviewed under the OMB Circular No. A-76 process to assess if there were reasonable commercial services available in place of Federal owned facilities. All systems installed met the criteria allowing for Federal owned procurement. One of the major decision factors was that the systems are in remote National Forest areas having a single user (USDA Forest Service) controlling remote land-mobile radio communications systems. Commercial investments are predominantly associated with dense population in order for there to be financial incentive. As a result, commercial suppliers were unable to cost effectively provide acceptable facilities. Except for a small number of locations, the original decision criteria remains unchanged." Based on these factors, USDA indicates that they will not obtain leased services.

Summary for the 1710-1755 MHz Band. The 1710-1755 MHz segment of the 1710-1850 MHz band is currently allocated to the Federal Government exclusively for fixed and mobile services on a primary basis. This band segment is used, in varying degrees, by all major Federal Government agencies for medium-capacity (e.g., 24-300 voice channels) fixed microwave communications, as well as a variety of special fixed and mobile applications. Tactical radio relay systems are also used extensively in this band to support proficiency training and to maintain combat readiness. The majority of the fixed microwave systems operated by the Federal Government agencies for voice, data, and/or video communications are located in remote areas where commercial service is unavailable, excessively expensive, or cannot meet required reliability. There are, however, some heavy uses by DOJ, FAA, USCG and Army in certain urban areas. The majority of the Federal Government fixed microwave systems employed in the 1710-1755 MHz band are commercial off-the-shelf systems.

Although there are mobile systems that will be impacted, the predominant direct costs will result from the potential displacement of the fixed microwave systems because of their preponderance in this band. There are approximately 1,700 affected fixed microwave stations supporting critical and important Federal Government missions such as national defense, law enforcement, provision of navigation services to ships and planes, management of public forests and parks, military command and control communications network, and the control links for wide-area networks for various power, land and water management systems. While most major Federal Government agencies will be affected, the agencies potentially most significantly affected will be Army, USDA, DOI, DOT, DOJ, DOE and Air Force. Estimated costs for implementing the reallocation vary from $343 million to nearly $356 million.

2300-2310 MHz Band

An overview of the Federal Government agencies affected by the reallocation of the 2300-2310 MHz band for non-Federal sector use is given in TABLE 3-3. The following paragraphs will discuss the reallocation impact and the options for each of the agencies affected by the loss of 2300-2310 MHz band.

=========================================================================================================================================
  TABLE 3-3:  Overview of Reallocation Impact for the 2300-2310 MHz Band
=========================================================================================================================================

AGENCY                                     # OF   TUNING RANGE       REALLOCATION             
REALLOCATION
AFFECTED    TYPE           FUNCTION         UNITS      (MHZ)             IMPACT                 
APPROACH
=========================================================================================================================================
N & AF      MPS-38      radar simulator       3     2300-2450     loss in tuning range     Restrict 2300-2310 MHz band use to
                                                                                           coordinated operations at selected test ranges.
=========================================================================================================================================
  AF        DSQ-X        miss distance        4     2300-2450     loss in tuning range     Restrict tuning in the 2300-2310 MHz band
                          measurement                                                      segment.
-----------------------------------------------------------------------------------------------------------------------------------------
  AF        NAVS      test & evaluation      100     900-3000     loss in tuning range     Contractor plans to use bands below 2300 MHz.
                                                                                           Estimated reallocation impact is expected to
                                                                                           be minimal.
-----------------------------------------------------------------------------------------------------------------------------------------                                                                                           
  AF       RDAVS      test & evaluation      132    2300-2450     loss in tuning range     The equipment will have to be tuned to the
                                                                                           2360-2390 MHz band which will require mod-
                                                                                           ification of internal components and new
                                                                                           crystals. At least 60 beacons will have to be
                                                                                           replaced. Estimates are $300,000 for modifi-
                                                                                           cations and $665,000 to replace beacons. A
                                                                                           more advenced system is planned to replace
                                                                                           RDAVS in FY98.
-----------------------------------------------------------------------------------------------------------------------------------------
  AF       test       misc. test range &      36    2300-2450     loss in tuning range     Restrict tuning in the 2300-2310 MHz band
                     telemetry equipment                                                   segment.
=========================================================================================================================================
NASA       DSN      Deep Space Network &       3    2390-2300            none              Include reallocation constraonts in the Pre-
                    associated satellites                                                  iminary Report to restrict adjacent band
                                                                                           emissions. If the new non-Federal service is
                                                                                           compatible, the reallocation cost will be
                                                                                           minimal.
-----------------------------------------------------------------------------------------------------------------------------------------
NASA     research   planetary mapping radar    1      2320               none              Include reallocation constraonts in the Pre-
                                                                                           liminary Report to restrict adjacent band
                                                                                           emissions.
=========================================================================================================================================

Air Force and Navy. The 2300-2310 MHz band is used primarily for radar target scatter and identification systems, and threat simulators and test equipment used in training exercises. This band is also adjacent to the band used for the Air Force Satellite Control and Defense Meteorological Satellite networks. The Air Force and Navy systems that use this band are primarily located on various military test ranges throughout the United States.[EN43]

The radar target scattering test systems operating in the 2300-2310 MHz band can be tuned over a wide range of frequencies and are thus capable of operating in other bands. However, data across a broad range of frequencies is required for certain target scattering studies. Radar simulators are also tunable, but frequencies that are required for testing are determined by the threat emission being simulated.[EN44]

The Non-cooperative Airborne Vector Scorer (NAVS) is a new system, with more than 100 units scheduled to be fielded in 1997. This system will detect scoring for live-fire test and evaluation against aerial targets. The equipment tunes from 900 MHz to 3000 MHz. The reallocation of the 2300-2310 MHz band will have little operational impact on this system.[EN45]

The Recovered Doppler Airborne Vectoring Scoring (RDAVS) System is used exclusively to support Advanced Medium Range Air-to-Air Missile (AMRAAM) testing at the USAF Air Warfare Center. The system, which tunes over the 2300-2390 MHz range, consists of a drone-mounted receiver and a missile-mounted beacon. Currently there are 22 aircraft and 110 beacon units. Some of the beacon units are fixed-tuned to the 2300-2310 portion of the band. Reallocating 2300-2310 MHz will require these equipment to be retuned to the remaining 2310-2390 MHz band segment. Retuning will require modifi- cation of internal components and new crystals. The reallocation costs are estimated at $20,000/unit for modifications of all beacon units, if it is determined to be necessary. Because of funding constraints, receivers may have to be reduced to 15 units by January 1996 for a total cost of $300,000. However, an additional 60 units will be in stock and usable if normal operations are not allowed while the beacons are phased out. The total expense considering only rework and loss/acquisition of beacons is in excess of $1.63 million. A more advanced system is planned to replace RDAVS in the FY98 time frame. If RDAVS is permitted to be phased out, no costs will be incurred due to the reallocation of the 2300-2310 MHz band.[EN46]

National Aeronautics and Space Administration. The main concern expressed by NASA regarding the reallocation of the 2300-2310 MHz band is the potential interference from a yet to be determined non-Federal application to adjacent-band Federal operations. NASA operates a Planetary Radar at 2320 MHz and the Deep Space Network (DSN) radar receiver at 2290-2300 MHz, both located in Goldstone, California. The very low received signal levels and the state-of-the-art sensitivity limits of these receivers make them extremely susceptible to interference from even low-level radio frequency signals. This high susceptibility dictates that even distant interference must be taken into consideration when selecting the commercial applications that are to operate in the reallocated 2300-2310 MHz band.

During discussions with NASA representatives, it was stated that NASA's position regarding the 2300-2310 MHz band continues to be that DSN operations can co-exist with certain types of commercial applications. For example, aeronautical or space-to-Earth links will have a high probability of causing harmful interference. Conversely, low-power, licensed, terrestrial applications can be coordinated and are not expected to be a problem. Given that the restrictions identified in the Preliminary Report are observed, and adequate consideration is given to the type of non-Federal applications implemented, NASA anticipates no major operational or economic impact from the proposed reallocation of the 2300-2310 MHz band.[EN47]

Summary for the 2300-2310 MHz Band. Federal Government usage of the 2300-2310 MHz band is light compared to many of the other Federal Government bands. Therefore the disruption of Federal government operations resulting from the reallocation of this band to non-Federal sector use is expected to be minimal. The Air Force and Navy systems that occupy this band are primarily used for research and development and test purposes, and by the nature of their design have a great deal of flexibility in frequency selection. However, DOD needs to have continued use of this spectrum at selected locations because it is critical for National Security. Provided that adequate consideration is given to the type of non-Federal applications implemented and the restrictions on airborne and space-to-Earth links are observed, NASA expects no major operational or economic impact as a result of the proposed reallocation of the 2300-2310 MHz band.

2390-2400 and 2402-2417 MHz Bands

An overview of the Federal Government agencies affected by the reallocation of the 2390-2400 and 2402-2417 MHz bands for non-Federal sector use is given in TABLE 3-4. The following paragraphs will discuss the reallocation impact and the options for each of the agencies affected by the loss of the 2390-2400 MHz and 2402-2417 MHz bands.

 
=========================================================================================================================================
  TABLE 3-4:  Overview of Reallocation Impact for the 2390-2400 AND 2402-2417 MHz Bands
=========================================================================================================================================

 AGENCY                                     # OF   TUNING RANGE       REALLOCATION              REALLOCATION
AFFECTED    TYPE           FUNCTION         UNITS      (MHZ)             IMPACT                  APPROACH
=========================================================================================================================================
   N       MPS-38       radar simulator       5     2300-2450     loss in tuning range     Restrict tuning in the reallocated band
                                                                                           segments.
-----------------------------------------------------------------------------------------------------------------------------------------
   N       DSQ-50       miss-distance        200    2300-2400     loss in tuning range     Restrict tuning in the reallocated band
                        measurements                                                       segments.
-----------------------------------------------------------------------------------------------------------------------------------------
   N       CTS-515      telemetry            200    2300-2450     loss in tuning range     Restrict tuning in the reallocated band
                        measurements                                                       segments.
=========================================================================================================================================
   A       APR-9B       aircraft radar         1    2390-2400              none            Reallocation will have minimal impact.
                       warning receiver
=========================================================================================================================================
  AF     range test       telemetry           34    2300-2450     loss in tuning range     The conversion of 36 telemetry receivers and
         equipment                                                                         4 auto tracking antenna systems is estimated
                                                                                           to cost $2.5M. Nodification and/or replacement
                                                                                           of various telemetry equipment is estimated at
                                                                                           $600,000, and $650,000 to replace each Range
                                                                                           Data and Range Timing system.
-----------------------------------------------------------------------------------------------------------------------------------------
  AF    URQ-30, 38   airborne interrogator   199     2412.4 &   interrogator transmitter   CIRIS interrogators will require redesign.
                             CIRIS                    2347.2       impacted                Estimated reallocation cost: FY94-$125,000;
                                                                                           FY95-$450,000; FY96-$10M; FY97-$14M; and 
                                                                                           FY98-$11M.
-----------------------------------------------------------------------------------------------------------------------------------------
  AF    URQ-30, 38   ground transponder      199     2347.2 &     transponder receiver     CIRIS interrogators will require redesign.
                             CIRIS                    2412.4         impacted              Estimated reallocation cost: FY94-$125,000;
                                                                                           FY95-$450,000; FY96-$10M; FY97-$14M; and 
                                                                                           FY98-$11M.
-----------------------------------------------------------------------------------------------------------------------------------------
  AF    MST-T1A           training            36    2300-2450     loss in tuning range     Modifications to electronic warfare equipment
                                                                                           to lock-out the band segments planned for
                                                                                           reallocation are estimated to total $1M in
                                                                                           software changes.
=========================================================================================================================================
 NSF    research     planetary mapping radar   1      2380                none             Include reallocation constraints in the Pre-
                                                                                           liminary Report to restrict adjacent band em-
                                                                                           missions in the vicinity of the observatory.
=========================================================================================================================================    
 

Air Force and Navy. The 2390-2400 MHz band is primarily used by Air Force and the Navy for target identification, range telemetry and measuring systems, radar target scattering measurements and threat simulator radars. The lower adjacent band of 2360-2390 MHz is used exclusively for telemetry. The Federal Government primarily uses the 2402-2417 MHz band for test and training range instruction, telemetry control and data links, and threat simulation.[EN48]

Target scattering and identification radars as well as radar simulators in the 2390-2400 MHz and 2402-2417 MHz bands are tunable. However, specific frequencies are required for obtaining quantifiable data, and simulating threat emissions. Modifications to electronic warfare equipment to lock-out the band segments planned for reallocation are estimated to total $1 million for software changes.[EN49]

Ground-based telemetry systems are capable of being tuned. Flexibility in airborne units is limited and will require redesign or recrystallization in most cases. The conversion of telemetry receivers and autotracking antenna systems will cost approximately $2.5 million.[EN50] Modification and/or replacement of various telemetry equipment is estimated at $600,000.[EN51] The Completely Integrated Reference Instrumentation System (CIRIS) is used by DOD to certify navigation systems. It is the only source of continuous (i.e., range dependent) time, space and position information (TSPI) for DOD test programs. In addition, CIRIS is reported by Air Force as the only real-time source of velocity reference data with an accuracy of 0.1 feet per second.[EN52] CIRIS is fixed-tuned on 2412.4 (interrogator) and 2347.2 MHz (transponder). Reallocation of the 2402-2417 MHz band segment will impact the CIRIS interrogators. Estimated reallocation costs are: FY94-$125,000; FY95-$450,000; FY96-$10 million; FY97-$14 million; FY98-$11 million.[EN53]

National Science Foundation. The 2390-2400 and 2402-2417 MHz bands are adjacent to the 2370-2390 MHz band used for planetary radar research. NAIC operates a planetary research radar at Arecibo, Puerto Rico, on the frequency of 2380 MHz. Research conducted with the Arecibo radar has resulted in major contributions to knowledge of the solar system, including most recently the mapping of the surface of Venus. This installation is one of the few available worldwide to keep watch on near-Earth objects posing a potential threat to the Earth. The Arecibo planetary radar operates at 2380 MHz with a required bandwidth of 20 MHz.[EN54] The radar detects extremely weak return signals; consequently, it is extremely vulnerable to spurious emissions from systems operating in adjacent bands that fall within the radar's bandwidth.

As stated in the Preliminary Report, the 2390-2400 and 2402-2417 MHz bands are available for immediate reallocation for exclusive non-Federal use.[EN55] Unrestricted use of the 2390-2400 MHz and 2400-2410 MHz bands could necessitate retuning the NAIC Arecibo Planetary radar to a different operating frequency. The cost of this shift is currently estimated to be $4 million. However, if restrictions similar to those proposed for the 2300-2310 MHz band are observed, impact on the facility should be minimal.[EN56]

Summary for the 2390-2400 & 2402-2417 MHz Bands. The Air Force and Navy systems that occupy this band are primarily used for research, development, test, and evaluation purposes and, by the nature of their design, have some flexibility in the selection of operating frequencies. The Air Force and Navy usage and investment in the 2390-2400 and 2402-2417 MHz bands is light compared to many of the other Federal Government bands. The major system impacted by the reallocation is the CIRIS. The 15-year costs reported by Air Force and Navy to implement the reallocation plan is approximately $40 million.

The 2390-2400 MHz and 2402-2417 MHz bands are adjacent to the Arecibo planetary radar system operating at 2380 MHz. Reception of the very weak signals inherent to this type of work are vulnerable to out-of-band emissions from adjacent bands. However, if constraints on airborne and space-to-Earth links are observed, the impact on this important research tool should be minimal.

3650-3700 MHz Band

An overview of the Federal Government agencies affected by the reallocation of the 3650-3700 MHz band segment is given in TABLE 3-5. The following paragraphs will discuss the reallocation impact and options for each of the agencies affected by the loss of the 3650-3700 MHz band segment.

=========================================================================================================================================
  TABLE 3-5:  Overview of Reallocation Impact for the 3650-3700 MHz Band
=========================================================================================================================================

 AGENCY                                     # OF   TUNING RANGE       REALLOCATION              REALLOCATION
AFFECTED    TYPE           FUNCTION         UNITS      (MHZ)             IMPACT                  APPROACH
=========================================================================================================================================
   N       SPN-43       shipborne radar      45     3590-3700             none             Re-engineer channel plan for the band.
-----------------------------------------------------------------------------------------------------------------------------------------
   N       SPN-6        shipborne radar       1     3600-3700             none             SPN-6 being replaced by the SPN-43.
-----------------------------------------------------------------------------------------------------------------------------------------
N & AF     SPQ-11       shipborne radar       1     2400-4000             none             Restrict tuning in the reallocated band
                                                                                           segment.
=========================================================================================================================================
  AR      various        ground based       1680    3675-3700             none             Intercept receivers have an operational tuning
                          equipment                                                        range of 500-40,000 MHz and ECM intercept rec-
                                                                                           eivers have an operational tuning range of
                                                                                           20-4000 MHz. The spectrum reallocation will
                                                                                           have minimal impact on these systems.
=========================================================================================================================================
  AF     training       ECM training        ---     3625-3650      loss in tuning range    Restrict tuning in the reallocated band seg-
                                                                                           ment. This frequency band is utilized by sev-
                                                                                           eral ECM training devices. These devices are
                                                                                           crucial to maintain the combat readiness of
                                                                                           our pilots. It would cost Edwards AFB $100,000
                                                                                           to perform studies required to ensure compati-
                                                                                           bility of conduction ECM in spectrum adjacent
                                                                                           to reallocated spectrum.
------------------------------------------------------------------------------------------------------------------------------------------
  AF     HySTP           research           ---     3600-4200      loss in tuning range    Restrict tuning in the reallocated band seg-
                                                                                           ment. This band is used by the Hypersonic
                                                                                           system technology program (HySTP). HySTP will
                                                                                           telemeter data from the experimental vehicle
                                                                                           and track the flight with radar. The realloca-
                                                                                           tion will reduce the HySTP's ability to acquire
                                                                                           data. The necessary frequency bandwidth might
                                                                                           not be available in another band on the Western
                                                                                           Range.
===========================================================================================================================================

Navy. The major systems operating in the 3600-3700 MHz band are Navy shipborne radars that serve as the primary ATC radar aboard aircraft carriers, and also serve as an interface with other precision carrier approach radars for carrier landing operations. The AN/SPN-43 radars have a tuning range of 3590-3700 MHz. The 45 operational radars have a scheduled equipment life that extends to at least 2010.[EN57] An additional factor limiting non-Federal sector use of this band is the Navy's AEGIS AN/SPY-1 high powered radar. Although the AN/SPY-1 operates in a lower frequency band and complies with the radar engineering spectrum requirements of the NTIA Manual of Regulations and Procedures for Radio Frequency Management, it makes use of this band impractical for many commercial purposes within a considerable distance of the coast. Satellite receivers operating above 3700 MHz, without adequate desired signal margins and interference rejection mechanisms, presently suffer interference from AEGIS operating at distances as great as 160 km. As stated in the Preliminary Report, reallocation of the entire 3600-3700 MHz band is not considered feasible because of the daily need for carrier take-off and landing proficiency training operations involving the radar controllers and aircraft pilots. However, as stated in the Preliminary Report, the reallocation of the 3650-3700 MHz band on a mixed use basis is possible and provides a reasonable compromise between the needs of the non-Federal users and the requirements by Navy to use the radar in this band. The cost of replacement radars operating in an alternative band, if one is available, is estimated to be $350 million.[EN58] The use of the 3650-3700 MHz band on a mixed use basis would eliminate need for replacement of the radars, but would require detailed engineering analysis to re-design the Navy's current channeling plan for the 3590-3700 MHz band. The implementation of new operating procedures for Navy radars operating in coastal waters and the modification of documentation including, logistics plans, training, and operator manuals will also be necessary. The proposed five-year delay in reallocation for the 3650-3700 MHz should provide sufficient time for the DOD budget cycle to provide funding to accomplish the necessary engineering studies and operational changes. It also provides time for the development of non-Federal receiver standards and criteria to allow non-Federal sharing of the band without further restrictions on Navy operations. In addition, to lessen the impact to the Navy, radar operations in the 3650-3700 MHz band will continue at three specified locations given in the Preliminary Report.[EN59]

Two additional shipborne radar units operated by Navy in this frequency range, an AN/SPN-6 and an AN/SPQ-11, are not expected to be impacted by the reallocation.

Army. The Army has approximately 1700 equipment operating in this band. The systems primarily operating in this band are intercept receivers that are able to tune from 500 MHz to 40 GHz. Most of this equipment is restricted to operating on Army bases throughout the United States and should not be impacted by the reallocation of the 3650-3700 MHz band segment.[EN60]

Summary for the 3650-3700 MHz Band. The Navy shipboard radars that operate in the 3590-3700 MHz band perform essential mission functions that cannot be eliminated. Reallocation of the 3650-3700 MHz band segment for non-Federal sector use is a reasonable compromise between the needs of the Federal Government users and those of future non-Federal sector users. The reallocation of the 3650-3700 MHz band segment instead of the entire 3600-3700 MHz band eliminates procuring a new radar system in another frequency band to perform this function and will allow Navy to continue operations. Funding for engineering studies to develop new channeling plans, analyze potential interference problems with other systems operating on the same ship, and implement changes to Navy operating procedures and manuals will be required. The delayed mixed use reallocation schedule of five years will give Navy and the DOD budget cycle time to apportion funding and implement these changes with minimal impact to daily Navy carrier operations and allow development of non-Federal standards and limitations to allow compatible sharing in this band.

4635-4660 and 4660-4685 MHz

The Federal Government agencies primarily affected by the reallocation of these bands are Air Force, Army, Navy, Treasury, and DOE. The following paragraphs describe the major systems operating in these bands and transition plans, costs, and options for each of the affected agencies.

Treasury. Treasury operates nine aerostat wideband downlinks in the 4635-4660 MHz band: four in Texas and one each in Puerto Rico, Arizona, Louisiana, Florida, and the Bahamas. Treasury expects that the costs for changeout of frequencies at these sites will be negligible if substitute frequencies within the tuning range of the equipment can be successfully coordinated, as is anticipated.

Energy. DOE uses the 4400-4990 MHz band for operations of the NEST equipment during emergencies in any operating environment throughout the United States and possessions. DOE has also recently received NTIA approval for microwave systems in support of a new large trunked land- mobile system. They indicated that the cost to retune these and other equipments to operate in the remaining portions of the 4400-4990 MHz band would be $600,000 and could be accomplished prior to the proposed January 1997 reallocation schedule.

Army. The Army reports that this band is important for its area-wide integrated communications networks. Land forces command, control and communication systems tie the various operational and functional nodes into an integrated area-wide network. Tactical radio relay systems, using both line-of-sight and tropospheric scatter propagation, are extensively used within the United States for comprehensive realistic training, humanitarian relief, natural disaster operations, and to maintain combat readiness. The Army states, "options of moving into one of the other bands are extremely difficult and not operationally sound. Other frequency bands are fully used and very congested. Moving to a lower band creates technical problems from larger bandwidths and operational distance requirements. Moving to a higher band creates similar problems... Further loss or erosion of authorized frequency resources would adversely affect military land forces' ability to provide an adequate command, control communications network." Reallocation options, transition plans, or specific reallocation cost estimates for these systems were not available.

The Army also operates an unmanned aerial vehicle and mobile video system at the National Training Center in Ft. Irwin, California. Preliminary Army cost estimates of the reallocation impact to this system are in excess of $10 million.

Navy. Major Navy programs that have frequency assignments in these bands include the LAMPS III and RPV control systems such as the Integrated Target Control System, and similar control systems for the PIONEER RPV. Also being developed for this band is the next-generation wide band anti-air warfare and ship defense system. Reallocation options, transition plans, or specific reallocation cost estimates for these systems were not available; although, a significant amount has been spent for the research, design and early development of this defense system.

Air Force. Air Force frequency assignments in this band primarily support point-to-point tactical line-of-sight and troposcatter systems whose functions include testing, training, and tactical communications. Video links, data links, and threat simulators are also used in these bands. The Air Force states that reallocation of this band would require retuning one video downlink communications system, ten microwave telemetry and control systems for its TARS, one over-the-horizon (OTH) tropospheric radio system, an undetermined number of digital tactical tropospheric systems, and to relocate its TOSS equipment to the 7/8 GHz band, if possible.

The Air Force estimates that retuning its digital tactical tropospheric systems will cost $3.5 million, retuning its OTH tropospheric radio system will cost $120,000 and relocating its TOSS systems will cost $30,000. Retuning costs for the video downlink and TARS systems are expected to be minimal.

Summary for the 4635-4660 & 4660-4685 MHz Bands. DOE and Treasury operate a limited number of fixed microwave and aeronautical mobile systems in these bands. DOE requires $600,000 to retune its equipment in these bands while Treasury has indicated that no significant economic impact would result from implementation of the preliminary reallocation plan for these bands. Army estimates a $10 million impact to its unmanned aerial vehicle and mobile video units at the National Training Center. The Air Force estimates that retuning various tactical tropospheric and target scoring systems will cost $3.7 million.

===================================================================================================================================
ENDNOTES FOR SECTION 3

      
       Requests for copies of references from Federal departments and agencies should
       be referred to the originating organization. Parts of the reference material
       may be exempt from public release.
 
 
 
     1.   Omnibus Budget and Reconciliation Act, Title VI,  6001(a)(3), Pub. L.
        No. 103-66, 107 Stat. 379,  113(c)(1)(C)(i) & (ii), (c)(2)(D), and (a)(4),
        respectively (codified at 47 U.S.C.  923(c)(1)(C)(i) & (ii), (c)(2)(D),
        and (a)(4), respectively (Supp. V 1993)).
     
     2.   Nat'l Telecommunications and Info. Admin., U.S. Dep't of Commerce, Special
        Publication 94-27, Preliminary Spectrum Reallocation Report,
        at 5-14 (Feb. 1994) [hereinafter  Preliminary Report and all comments cited
        refer to this report, unless otherwise stated].
     
     3.   Fax from B. Swearingen (Naval Electromagnetic Spectrum Ctr) to E. Drocella
        (NTIA), Subject: Additional Bands Proposed for the Final Spectrum Reallocation
        Report, at 8 (Dec. 5, 1994).
     
     4.   Id.
     
     5.   Letter from Deborah R. Castleman, Deputy Assistant Secretary of Defense for
        Command, Control, and Communications, U.S. Dep't of Defense, to Richard Parlow,
        Assoc. Adm'r Nat'l Telecommunications and Info. Admin. (Sept.1 1994)
        [hereinafter Joint DOD Response], U.S. Dep't of the Navy Enclosure at
        1 (May 18, 1994).
     
     6.   U.S. Dep't of the Army Comments, at 5 (May 9, 1994), in Joint DOD Response,
        supra note 5.
     
     7.   Id. at 7.
     
     8.   U.S. Dep't of the Air Force Enclosure, at 2 (June 8, 1994), in Joint DOD
        Response, supra note 5.
     
     9.   Id.

   10.   NTIA Preliminary Report, supra note 2, at 5-4.
     
   11.  Air Force Enclosure, supra note 8, at 2.

   12.   Id. at 3.

   13.   Id. at 4.

   14.  Air Force Enclosure, supra note 8, at 5.

   15.  Air Force Comments on Title VI of the Omnibus Budget Reconciliation Act
           (OBRA) of 1993, at 4-3 (Jan. 5, 1995). 

   16.   Air Force Enclosure, supra note 8, at 6.

   17.   Id. at 3.

   18.   Id. 

   19.   NTIA Preliminary Report, supra note 2, at 4-11.

   20.   Air Force Enclosure, supra note 8, at 4.
       
   21.   Dep't of Transportation (DOT) Comments, at 1 (June 1, 1994).

   22.   Air Force Enclosure, supra note 8, at 11 ATTACHMENT A.

    23.   Treasury IRAC Representative, U.S. Dep't of Treasury, Subject:
           Emerging Telecommunications Technology Act of 1993, at 3 (Oct. 25, 1993).

    24.   U.S. Dep't of Energy Briefing, Remote Sensing Systems Research and
           Development Programs, Bob Waldron (June 1, 1994).

    25.   Nat'l Science Foundation (NSF) Comments, at 1 (Apr. 15, 1994).

    26.   Id.

    27.   Army Comments, supra note 6, at 5.

    28.   Id. at 6.

    29.   Air Force Enclosure, supra note 8, at ATTACHMENT 2,  6-7.

    30.   Id. at ATTACHMENT 2, 6.

    31.   Meeting between NTIA and Nat'l Oceanic and Atmospheric Admin.
           (NOAA), on June 27, 1994.

    32.   U.S. Dep't of Commerce Comments, at 2 (May 11, 1994).

    33.   Id.

    34.   Id.

    35.   Army Comments, supra note 6, at 5.

    36.   Fax from D. Willis (FAA/Office of Spectrum Policy and Management,
           ARS-1) to E. Cerezo, (NTIA) Subject: FAA Reallocation Cost in the
           1710-1755 MHz Band, at 3 (Jan. 25,1995).
     
     37.  Fax from E. Brady (USCG/Chief, Frequency Assignment Staff) to E.
         Cerezo, (NTIA) Subject: USCG Reallocation Cost in the 1710-1755 MHz
         Band, at 4 (Feb. 1, 1995).
     
     38.  U.S. Dep't of Interior Comments, at 2 (May 4, 1994).

     39.  U.S. Dep't of Energy Comments, at 1 (May 19, 1994).

     40.  U.S. Dep't of Justice Comments, at 4 (May 31, 1994).

     41.  U.S. Dep't of the Treasury Comments, at 2 (May 10, 1994).

     42.   U.S. Dep't of Agric. Comments, at 3 (May 11, 1994).

     43.   NTIA Preliminary Report, supra note 2, at 4-15.

     44.   AF Frequency Management Agency, U.S. Dep't of the Air Force,
           Air Force Band Use Analysis, at A-21, (Nov. 5, 1993).
     
     45.  Air Force Enclosure, supra note 8, at 10.

     46.  Id. at 11.

     47.  NTIA Preliminary Report, supra note 2, at 14

     48.  Id. at 4-14.

     49.  Air Force Band Use Analysis, supra note 42, at A-22.

     50.  Id. at A-23.

     51.  Air Force Enclosure, supra note 8, at 1.

     52.  Id. at 11.

     53.  Id.

     54.  The Nat'l Astronomy and Ionosphere Ctr. Comments, at 5 (May 9, 1994).

     55.  NTIA Preliminary Report, supra note 2, at 5-9.

     56.  NSF Comments, supra note 24, at 1.

     57.  NTIA Preliminary Report, supra note 2, at 4-18.

     58.  Id.

     59.  Id. at 5-9.

     60.  Letter from U.S. Dep't of the Army, to IRAC, Doc. 28510/1, Subject:
           Army Comments on NTIA Report, at 8 (Oct. 21, 1993). 

Return to Report Table of Contents.
Proceed to Section 4, Assessment of Reallocation Proposals.