ENDNOTES

 1.  The Omnibus Budget Reconciliation Act of 1993 requires
transfer of Federally-controlled spectrum to the FCC, and
provides other spectrum management guidance to both the FCC and 
NTIA. Omnibus Budget Reconciliation Act of 1993, Pub. L. No.
103-66, 107 Stat. 31 (1993) [hereinafter Budget Act of 1993]. 
The functions of NTIA were codified as a result of the National
Telecommunications and Information Administration Organization
Act.  National Telecommunications and Information Administration
Organization Act, P.L. 102-538, 106 Stat. 3533 (codified at 47
U.S.C. 901-904) [hereinafter NTIA Organization Act].

2.  NTIA Organization Act, supra note 1.

3.   International Trade Administration, U.S. Dep't of Commerce,
U.S. Industrial Outlook 1994 at 29-1 (1994). [hereinafter U.S.
Industrial Outlook 1994].

4.  Id

5.  Id. at 30-6 to 30-22.

6.  Cellular Telecommunications Industry Association, Fast Facts
(1994), at 1-2.

7.  National Telecommunications and Information Administration,
U.S. Dep't of Commerce, NTIA Special Publication 91-23, U.S.
Spectrum Management Policy:  Agenda for the Future 178 (1991)
[hereinafter NTIA Spectrum Policy Study].

8.  Budget Act of 1993, supra note 1.

9.  Current and Future Requirements for the Use of Radio
Frequencies in the United States, Notice of Inquiry and Request
for Comments, Docket No. 920532-2132, 57 Fed. Reg. 25,010 (1992)
[hereinafter Notice].

10.  Appendix A lists the commenters, along with their
abbreviated names.  The abbreviations are used herein for all
citations to comments and reply comments.  Commenters generally
expressed support for a re-examination of policies regarding
spectrum allocations and use.  The IEEE stated that improvements
in technology, frequency sharing strategies, and international
radio conferences could ease future demands on the spectrum. 
IEEE USA Comments at 6.

11.  In support of this inquiry, NTIA undertook two studies: one
addressing the future of the fixed service, Robert J. Matheson &
F. Kenneth Steele, A Preliminary Look at Spectrum Requirements
for the Fixed Services (National Telecommunications and
Information Administration, Institute for Telecommunication
Sciences Staff Study, 1993), the other addressing the land mobile
services, William D. Speights et al., National Telecommunications
and Information Administration, NTIA Technical Memorandum 94-160,
National Land Mobile Spectrum Requirements (1994).  The mobile
study was prepared by the Spectrum Engineering and Analysis
Division of NTIA's Office of Spectrum Management.

12.  Technology may impact spectrum requirements either by
producing new systems having new requirements, or by improving
spectrum efficiency, thus reducing spectrum requirements.

13.  National Telecommunications and Information Administration,
Manual of Regulations and Procedures for Federal Radio Frequency
Management , Section 6.1.1 at 6-10 (Jan. 1993) [hereinafter NTIA
Manual]. A land station is a station in the mobile service not
intended to be used while in motion (e.g., base, repeater,
control).

14.  Spectrum requirements for electronic news gathering are
discussed infra p. 76.

15.  Id. Section 6.1.1 at 6-8.

16.  Motorola estimates the number of land mobile users in the
United States will  jump from over 33 million today to over 150
million by the year 2000.  Motorola Comments at 5.

17.  Speights et al., supra note 11.

 18.  Commercial mobile services are those providing services for
a profit, would be interconnection to the PSTN, and would be made
available to the public.  

 19.  Cellular Telecommunications Industry Association, 1993 Data
Survey:  Industry Success Story Continues, 2 (Mar. 2, 1994) (on
file with NTIA).

20.  Speights et al., supra note 11, at 65.

21.  Spectrum requirements for private operational fixed services
are discussed infra p. 75.

22.  Budget Act of 1993, supra note 1.  Radio systems operated by
industrial, land transportation, and public safety licensees, as
well as a number of business systems, do not offer commercial
for-profit land mobile services and therefore would not be
classified as commercial mobile services under the recent
legislative changes.  These systems will continue to be regulated
as private land mobile services.

23.  The Location and Monitoring Service is discussed beginning
infra p. 19.

24.  Also included as eligible users are individuals and Federal
agencies.  See 47 C.F.R. Section 90.603 (c).

25.  SMR's also provide interconnection to the local land lines.

26.  TIA MCD Comments at 3.

27.  In addition, Department of Defense (DOD) aircraft use
frequencies in the 138-144 MHz and 148-149.9 MHz bands to
communicate with DOD ground forces in tactical scenarios. 

28.  The Interagency Cellular Working Group estimates about 5000
cellular telephones in use by the Federal Government (exclusive
of the DOD).  Letter from R. Otis and C. E. Cape, Co-chairmen,
Interagency Cellular Working Group, to David J. Cohen, NTIA (Mar.
3, 1993) (on file with NTIA).

29.  One reason for the slower growth in this band is that
numerous assignments are used for wide-area operations.

30.  Spectrum Efficiency in the Private Land Mobile Radio Bands
in Use Prior to 1968, Notice of Inquiry, PR Docket No. 91-170, 56
Fed. Reg. 31,097 (1991).

31.  Replacement of Part 90 by Part 88 to Revise the Private Land
Mobile Radio Services and Modify the Policies Governing Them,
Notice of Proposed Rule Making, PR Docket No. 92-235, 57 Fed.
Reg. 54,034 (1992).

32.   In this refarming, the proposed channeling plan would
eventually reduce channel spacing to 6.25 kHz or less.

33.  NTIA Organization Act, supra note 3.

34.  David J. Cohen et al., National Telecommunications and
Information Administration, NTIA Report 93-300, Land Mobile
Spectrum Efficiency (1993).

35.  In addition, 12.5 kHz radios are expected to be adopted as
the standard by Federal, state and local law enforcement agencies
to ensure baseline interoperability.  Id. at 12.  If the FCC
chooses a different channel width as a consequence of its
refarming initiative, NTIA will evaluate the impact of this
decision on Federal operations, spectrum-efficiency and cost
considerations.

36.  APCO represents state, county and city police, fire, highway
maintenance, emergency medical and local government functions. 
With a broad base international membership of over 9,500, it is
the largest public safety telecommunications organization.

37.  NASTD members are the Directors of Telecommunications for 49
states who are responsible for the planning and implementation of
critical state government and public safety telecommunications
systems.

38.  TIA represents manufacturers and suppliers of
telecommunications equipment.  TIA also develops and produces
technical standards for telecommunication systems.

39.  APCO Comments at 6.

40.  Deployment of digital technology has been delayed for
several reasons:  improvements in existing analog technology; the
recession, which has slowed the growth in usage, thereby reducing
the pressure to expand system capacities; and the controversy
over CDMA/TDMA.

41.  Narrowbanding is another technology within the cellular
industry. Current conventional analog systems operate at 30 kHz
channel bandwidth.  A technology called narrowband-advanced
mobile phone service (NAMPS), triples the capacity of a cellular
voice channel by splitting the current channel into 10 kHz of
channel bandwidth.  In early 1992, several cellular entities
urged TIA to adopt narrowband cellular technology as a standard. 
In November 1992, TIA released standards for narrowband analog
mobile phone service (IS-88, IS-89, and IS-90).

42.  Fleet Call Comments at 4.  Nextel also plans to construct
and operate these systems in other larger metropolitan areas in
the country.  Seth Malgieri, Wall Street Smiling on ESMR's after
Nextel-OneComm Merger, RCR Radio Communications Report, Aug. 1,
1994, at 23, 23.

43.  Fleet Call Comments at 4.

44.  U.S. Dep't of Transportation, IVHS Strategic Plan 48 (1992)
[hereinafter IVHS Strategic Plan].

45.  See Intermodal Surface Transportation Efficiency Act of
1991, Pub L. No. 102-240. Section 6052 (b), 105 Stat. 1914, 2189
(1991)  (ISTEA).  In this Act, Congress emphasized the importance
of ITS systems and provided substantial funding to plan, develop,
and deploy concepts and technologies for communications controls,
navigation, and information systems to reduce highway congestion,
improve highway safety, and render highway traffic more
compatible with the environment.  ISTEA authorized $660 million
over a six-year period.

46.  DOT used the National Highway Traffic Safety
Administration's IVHS Plan, National Highway Traffic Safety
Administration, IVHS Plan (1992), and IVHS AMERICA's Strategic
Plan, IVHS AMERICA, Strategic Plan for Intelligent Vehicle-
Highway Systems in the United States (1992), as inputs to develop
the DOT plan, IVHS Strategic Plan, supra note 44, at 1.

47.  ITS AMERICA (formerly IVHS AMERICA) is a Federal Advisory
Committee to DOT and is a non-profit educational and scientific
organization whose purpose is to coordinate and promote the
research and development of ITS in the United States.  Membership
ranges from federal, state, and local government to private
industry and academia.  IVHS AMERICA Comments at 1.

48.  IVHS Strategic Plan, supra note 44, at 51.

49.  LMS systems are used to locate and track vehicles using non-
voice methods and to relay information to and from vehicles.  In
the 902-928 MHz band, LMS systems operate on Part 90 or secondary
basis to Federal Government users and must also accept
interference from industrial, scientific, and medical devices.

50.  Pacific Telesis Comments at 16.

51.  This technology of reflecting energy back to a receiving
unit is often described as "modulated backscatter."  AMTECH
Comments at 2.

52.  Federal Highway Administration, U.S. Dep't of
Transportation, FHWA-SA-92-036, Intelligent Vehicle-Highway
System (IVHS) Projects in the United States 34 (1992)
[hereinafter IVHS Progress Report].

53.  Federal Highway Administration, U.S. Dep't of
Transportation, IVHS Program Progress Report 10 (1993).

54.  IVHS Progress Report, supra note 52, at 17, 19, 21, 22.

55.  The focus of WARC-92's attention to mobile services was on
Future Public Land Mobile Telecommunications Systems (FPLMTS). 
WARC-92 did not formally allocate any frequencies for FPLMTS, but
it did note that the 1885-2025 MHz and 2110-2200 MHz bands (a
total of 230 MHz) are intended for use by FPLMTS.  International
Telecommunication Union, Final Acts of the World Administrative
Radio Conference for Dealing with Frequency Allocations in
Certain Parts of the Spectrum (WARC-92) 59-60, 62 (1992)
[hereinafter WARC-92 Final Acts].

56.  It is not known how successful telepoint services will be in
the United States. In the United Kingdom, telepoint services
failed to attract many subscribers and the industry has recently
decided to terminate telepoint services in the United Kingdom. 
However, telepoint services in Hong Kong are doing satisfactorily
and has begun to make a profit, with a reported 70,000 plus
subscribers, compared to the 9,000 subscribers in the United
Kingdom.

57.  Arthur D. Little, Wireless/Personal Communications Services
IV (Conference, Washington, D.C., Mar. 10-11, 1992) (in Bell
Atlantic Comments at 6).

58.  Personal Communications Industry Association, 1994 PCS
Market Demand Forecast (1994) [hereinafter PCIA Market Forecast]. 
PCIA, formerly Telocator, is a national association representing
the mobile communications industry, including paging, cellular,
mobile telephone and PCS.

59.  The methodology used by PCIA tracks subscriptions to mobile
services, not individual subscribers. Subscriptions will always
be greater than subscribers because many individuals will
subscribe to multiple services.

60.  FWUF Comments at 2-3.  FWUF is intended to represent Federal
Government wireless telecommunication users.  Participation by
state and local government users, non-government users, as well
as the wireless telecommunications industry is encouraged.

61.  VA Comments at 2.

62.  See e.g., DOI Comments at 2; DOJ Comments at 2.

63.  DOE Comments at 1-4.

64.  Motorola Comments at 9.

65.  TIA MCD Comments at 2.

66.  See, Comments of LMCC (filed Jan. 15, 1992) in Spectrum
Efficiency in the Private Land Mobile Radio Bands in Use Prior to
1968, PR Docket No. 91-170.

67.  Fleet Call Comments at 2-3.

68.  APCO Comments at 2.

69.  Id. at 12.

70.  Future Public Safety Telecommunications Requirements, PR
Docket 84-232, FCC 85-329 (August, 1985).  APCO notes that this
study made 1992 projection on the number of licensed radio
stations that are 70 percent less than the actual number to date. 
APCO also notes that this study did not account for more recent
public safety radio spectrum uses, such as mobile data terminals. 
APCO Comments at 3.

 71.  Id. at 106 (Table 37).

72.  APCO Comments at 3.

73.  Id. at 5.

74.  Budget Act of 1993, supra note 1.

75.  Letter from Beverly Baker, Deputy Chief, Private Radio
Bureau to Richard Parlow, Associate Administrator, Office of
Spectrum Management, October 29, 1993 (on file with NTIA).

76.  Cohen et al., supra note 34, at 13.

77.  Association of Public-Safety Communications Officials
International, Inc., Public Safety Spectrum Needs Analysis and
Recommendations at 18 (Aug. 1994) (unpublished manuscript, on
file with NTIA) [hereinafter APCO].

78.  H.R. Conf. Rep. No. 213, 103rd Cong., 1st Sess., pt. 4, at 8
(1993).

79.  Hewlett-Packard Medical Products Group et al., Spectrum
Needs of the Biomedical Telemetry Industry (no date) (on file
with NTIA).

80.  DOJ Comments at 2.

81.  TIA MCD Comments at 9.

82.  LMCC Comments at 2.

83.  Coalition of Private Users of Emerging Multimedia
Technologies, Petition for Rule Making, Spectrum Allocations for
Advanced Private Land Mobile Communications Services (filed Dec.
23, 1993) [hereinafter COPE Petition].

84.  Id. at 16-20.

85.  Others have made predictions on the number of cellular
subscribers.  Donaldson, Lufkin and Jenrette estimate the number
of cellular subscribers (including PCN and ESMR's) are estimated
to be between 56.6 million to 67.6 million in 2000.  See Dennis
Leibowitz et al., The Wireless Communications Industry, Table 4
(Winter 1994).   Herschel Shosteck estimates the number of
cellular subscribers (including PCS and ESMR's) in 2004 will be
between 60-90 million.  See Herchel Shosteck Associates, Cellular
Market Forecasts, Figure 4-10 (1994).

86.  PCIA Market Forecast, supra note 58.

87.  Because most of the comments received in our Inquiry
contained only general information about spectrum requirements,
NTIA obtained copies of comments to the FCC in response to its
NOI's, NPRM's, Report and Orders, and other actions pertaining to
the land mobile services.

88.  In some instances, Federal non-military and military land
mobile communications cannot be satisfied through commercial
facilities unless those facilities can provide secure
communications when needed.  The Federal Agencies also operate in
remote areas in which the private sector may have no incentive to
provide communication services.  During emergencies, civil and
Federal demand for spectrum increase simultaneously.  Commercial
facilities may not have adequate reserve capacity.

89.  Comments of Motorola, Inc. (filed May 28, 1993) in
Replacement of Part 90 by Part 88 to Revise the Private Land
Mobile Radio Services and the Policies Governing Them, PR Docket
No. 92-235.

90.  There are some channels in these bands used for conventional
systems and are reflected as such in the amount of spectrum
available for conventional dispatch use.

91.  Amendment of the Commission's Rules to Establish New
Narrowband Personal Communications Services, First Report and
Order,  Gen. Docket No. 90-314, ET Docket No. 92-100 (1993).

92.  This includes Federal conversion schedules which are in some
cases longer than non-Federal schedules.

93.  Three-to-one and six-to-one TDMA systems have already been
fielded.  For estimation purposes, a nominal three-to-one
increase is used here.

94.  The Motorola Integrated Radio System (MIRS) is a six-to-one
TDMA system. This is the system that Nextel is using to establish
its wide-area ESMR network.

95.  IVHS AMERICA Comments at 4.

96.  Jim Chadwick, DOT/MITRE Corp., IVHS Spectrum Requirements
Summary, June 27, 1994.

97.  COPE Petition, supra note 83, at 1.

98.  APCO, supra note 77, at 18.

99.  PCIA PCS Technical and Engineering Committee,
TE/94-06-09/555, PCIA "2003" Spectrum Estimate Report (Draft June
9, 1994) [hereinafter PCIA].

100.  Telocator PCS Technical and Engineering Committee,
TE/92-5-28/076, Telocator Spectrum Estimates for PCS Report
(1992).

101.  PCIA Market Forecast, supra note 58.

102.   PCIA, supra note 99.

103.  Budget Act of 1993, supra note 1.

104.  The FCC will allocate and assign the frequencies made
available from the transfer of 200 MHz of Federal spectrum.  Id.,
Section 115.

105.  NTIA Manual, supra note 13, Section 6.1.1 at 6-1. While an
aeronautical station is usually located on land, it may, in
certain instances, be located on board a ship or on a platform at
sea.  Id. at 6-2 (defining an aeronautical station).

106.  Off-route services are "intended for communications,
including those related to flight coordination, primarily outside
national or international civil air routes."  Route services are
for "communications relating to safety and regularity of flight,
primarily along national or international civil air routes."  Id.
at 6-1 (defining the aeronautical mobile (OR) and aeronautical
mobile (R) services).

107.  Because HF propagation is dependent on time of day, time of
year, sunspot cycles, etc., it is common for airborne HF systems
to have multiple frequencies assigned during flight.   

108.  Though VHF radio is limited to LOS, modern aircraft fly at
altitudes where LOS can exceed 400 km. 

109.  Aeronautical Radio, Inc. (ARINC) is the communications
company of the air transport industry.  It is owned by members of
the civil aviation community and provides civil aviation with
communications services, planning, and management on a not-for-
profit basis.  ARINC also sponsors technical forums where
representatives of civil aviation meet to develop common
solutions to communications and avionics related issues.

110.  ARINC Comments at 4.  There are 39 airports in the United
States that are defined as critical by ARINC.  An ACARS customers
at a critical airport will be able to access the ACARS system 99
percent of the time.

 111.  WARC-92 allocated the 1670-1675 MHz band as a worldwide
ground-to-air communications paired with 1800-1805 MHz for air-
to-ground transmissions.  WARC-92 Final Acts, supra note 55, at
58 (International Footnote 740A).  The United States will
maintain its existing systems at 849-851 MHz and 894-896 MHz.

112.  Enroute services include the aircraft separation services,
traffic advisories, and weather information to pilots enroute
between airports, etc.  Terminal communications include the radio
communications in the airspace that immediately surrounds the
airport and on the ground.  Flight services include flight plan
filing, preflight and in-flight weather briefings, enroute
communications with pilots flying under visual flight rules, and
assistance to pilots in distress.

113.  National Telecommunications and Information Administration,
U.S. Dep't of Commerce, NTIA Technical Memorandum 89-141,
Spectrum Resource Assessment of Government Use of the HF (3-30
MHz) Band, at 67-68 (June 1989) [hereinafter HF Spectrum Resource
Assessment].

114.  DOD Comments at 5.

115.  An exception to this use is the 328.6-335.4 MHz band, which
is exclusively reserved for instrument landing systems (glide
paths) at airports worldwide.

116.  Although military ATC is part of the activity in the
225-400 MHz band, it is only a small part of the military
tactical and strategic communications in this band.  The major
role for this band includes a wide variety of systems, including
satellite links, air-to-air, vehicle-to-vehicle, and man-pack
equipment designed to operate under battlefield conditions. 
These systems typically include frequency-hopping and spread-
spectrum systems designed to be resistant to interception and
jamming.

117.  DOD Comments at 12.

118.  RTCA, Inc. is an association of aeronautical organizations
of the United States from both government and industry.  RTCA
seeks sound technical solutions to problems involving the
application of electronics and telecommunications to aeronautical
problems.

119.  Compression is discussed infra pp. 87, 207.

120.  Stewart D. Personick, Towards Global Information
Networking, Proceedings of the IEEE (Nov. 1993).

121.  ARINC Comments at 2.

122.  Id. at 3.

123.  DOD Comments at 3.

124.  FAA Comments at 1-2.

125.  Letter from Gerald J. Markey, Director, Office of Spectrum
Policy and Management, Federal Aviation Administration, to W.
Russell Slye, Program Manager, Strategic Spectrum Planning
Program, National Telecommunications and Information
Administration (NTIA), Enclosure at 4 (Oct. 18, 1994) (on file
with NTIA).

126.  Id.

127.  Letter from Joe Hersey, United States Coast Guard, to W.
Russell Slye, Program Manager, Strategic Spectrum Planning
Program, NTIA (March 11, 1994) (on file with NTIA).

128.  Id.  Since these requirements appear to be used in support
of aeronautical mobile operations, NTIA has included them within
the aeronautical mobile service.

129.  NTIA Manual, supra note 13, Section 6.1.1 at 6-9.

 130.  These frequencies support  long distance communications
and are therefore suitable for ocean-going vessels.  The use of
these frequencies for long distances is dependent on ionospheric
conditions and subject to interference and radio noise. 
Therefore, a set of frequencies may be needed over the course of
a day to maintain acceptable communications. 

131.  Digital selective calling is a synchronous system developed
to establish contact with a station or group of stations
automatically by means of radio.

132.  Narrow-band direct-printing (NBDP) is a form of telegraphy
for the transmission and receipt of data communications. 

133.  Appendix 18 of the ITU Radio Regulations describes the
function for each of the channels used in the maritime mobile
services.  International Telecommunication Union, Radio
Regulations app. 18 (1990) [hereinafter ITU Radio Regulations].

134.  47 C.F.R. Section 80.5 (1993).

135.  Cellular telephony is also discussed supra p. 11

136.  46 C.F.R. Section 28.245 (1993).

137.  Some entities feel that although cellular service is
becoming increasingly popular for marine communications because
it is much cheaper than marine radios and has automatic
interconnect, the issues of safety through cellular telephony is
a concern.  See, e.g., Reply Comments of Marine Telephone Company
at 3 & Mobile Marine Radio at 3 (filed June 1, 1993) in Amendment
of the Commission's Rules Governing Maritime Communications,
Notice of Proposed Rule Making and Notice of Inquiry, PR Docket
No. 92-257, 7 FCC Rcd 7863, (1992) [hereinafter Maritime NOI].

138.  Id.

139.  See Comments of Global Maritime Communications Systems,
Inc. at 1 (filed May 27, 1993), Ross Engineering Company at 1
(filed May 27, 1993), SEA, Inc. at 2 (filed May 26, 1993),
National Marine Electronics Association at 4 (filed May 31,
1993), KFS World Communications, Inc. at 3 (filed June 1, 1993)
in Maritime NOI, supra note 137.

140.  See Comments of Global Maritime Communications Systems,
Inc. at 3 (filed May 27, 1993), Ross Engineering Company at 3
(filed May 27, 1993), The Ohio River Company at 3 (filed June 1,
1993), National Marine Electronics Association at 8 (filed May
31, 1993), Mobile Marine Radio, Inc. at 4 (filed June 1, 1993) in
Maritime NOI, supra note 137.

141.  USCG Comments at 2.

142.  Id. at 1.  A 1989 NTIA report stated that U.S. requirements
(at WARC-87) were not completely satisfied for additional NBDP,
DSC, radiotelephone, and coast and ship wideband spectrum,
especially in the 4 MHz and 8 MHz bands, due to other countries'
interests in the fixed service.  This report also states that
there is a continuing requirement for maritime use of the 4 MHz
and 8 MHz shared bands.  HF Spectrum Resource Assessment, supra
note 113, at 22.

143.  Hersey, supra note 127.

144.  USCG Comments at 2.

145.  NTIA Manual,  supra note 13, Section 6.1.1 at 6-10.

146.  Mobile-satellite communications are rapidly becoming
necessary for U.S. military operations.  Vice Admiral Tuttle
(Retired), former Director of Space and Electronic Warfare,
Office of Chief of Naval Operations, said the next time the Navy
or Marines deploy to a war zone such as Somalia, they will bring
with them commercial (INMARSAT) MSS terminals, thus creating an
"infrastructure for peacekeeping".  Comm. Daily, Nov. 12, 1993,
at 2.

147.  A system used by commercial trucking companies makes use of
fixed-satellite transponders in the 11/14 GHz band.

148.  ARINC Comments at 5.

149.  FAA Comments at 3.

150.  Pacific Telesis Comments at 6.

151.  USCG Comments at 2.

152.  Bell Atlantic Comments at 8.

153.  DOD Comments at 6.

154.  DOE Comments at 5.

155.  DOD Comments at 6.

156.  Letter from Steven H. Proctor, Association of Public Safety
Communications Officials International, Inc., to Joe Camacho,
National Telecommunications and Information Administration (no
date, received Oct. 1994) (on file with NTIA).

157.  Geostationary satellites orbit approximately 35,800
kilometers above the equator so that the satellite appears
stationary with respect to a point on the Earth.  In non-
geostationary orbits, which are generally closer to the Earth,
the satellite does not appear stationary with respect to a point
on Earth.  Satellites in some highly elliptical non-GSO orbits
exhibit characteristics of GSO satellites at times during an
orbit.

158.  Comsat Comments at 2.

159.  AMSC also filed comments but did not quantify future MSS
requirements.  AMSC referred to the work of the ITU
Radiocommunications Sector in preparation for WARC-92.  The
CCIR's Joint Interim Working Party Report to WARC-92 indicates
that by the year 2010, 328.2 MHz will be needed for MSS.  AMSC
Comments at 8.

160.  The FCC has recently adopted an Report and Order that would
provide approximately 5 MHz initially for bi-directional TDMA
systems (e.g., IRIDIUM) and up to 25 MHz for the other
applicants, holding approximately 3 MHz in reserve.  Amendment of
the Commission's Rules to Establish Rules and Policies Pertaining
to a Mobile Satellite Service in the 1610-1626.5/2483.5-2500 MHz
Frequency Bands, Report and Order, CC Docket No. 92-166 (released
Oct. 14, 1994) [hereinafter Mobile Satellite Report and Order].

161.  With advancing technology, it is becoming more feasible to
use satellites operating in frequency bands above 3 GHz for
mobile applications.

162.  AMSC Comments at 11.

163.  AMSC Comments at 2.  Further, AMSC applied to the FCC for
authority to operate in the maritime mobile satellite portion of
the lower portion of the 1500-1600 MHz band.  This would provide
up to an additional 35 MHz for the U.S. system.  Comm. Daily,
Nov. 4, 1993, at 6.  However, it is not likely, given the present
use of these frequencies by INMARSAT, that a substantial amount
will be available for a U.S. system.

164.  AMSC Comments at 6.

165.  Comsat states that only 60 MHz allocated at WARC-93 is
suitable for MSS use on a worldwide basis.  Comsat Comments at 3.

166.  Additionally, it is not known how many of the potential MSS
providers will actually be financially able to establish mobile-
satellite systems.

 167.  However, while spectrum used by other countries for MSS
might not be usable for MSS in the United States, other uses may
be possible.

168.  Reuse is taken to be the amount of effective spectrum that
can be available, taking into account the design of domestic MSS
systems.  First-generation MSS systems will have limited reuse
capability, corresponding to multiplying the allocated spectrum
by an average reuse factor of 0.67.  Second-generation MSS
systems will have at least double the reuse.  For the purposes of
this analysis, the average reuse factor is taken to be 0.33 for
additional spectrum requirements.

169.  See supra note 99, at 5, where the total for PCS and
cellular subscribers is 83.3 million in 2003.

170.  See supra note 99 where PCIA estimates 4.11 million
satellite subscribers by 2003.

171.  Contribution to Report of Task Group 8/3 CPM '95, U.S. TG
8/3-22, Assessment of Spectrum Requirements for MSS Below 1 GHz
(Oct. 18, 1994) (U.S. input document to ITU-R Task Group 8/3) (on
file with NTIA).

172.  Candidate frequency bands include FSS bands below 15 GHz,
in the reverse direction, and the 20/30 GHz FSS bands.

173.  Mobile Satellite Report and Order, supra note 160, at 63.

174.  Contribution to Report of Task Group 4/5, U.S. TG 4/5-19,
Summary and Discussion of Three Analyses and Computer Simulations
to Assess Sharing Potential Between Multiple NGSO Feeder Link
Analysis (Oct. 19, 1994) (U.S. input document to ITU-R Task Group
4/5) (on file with NTIA).

175.  Radiocommunication Study Groups, International
Telecommunication Union, Document 8-3/TEMP/53(Rev.1)-E, Element
of CPM Report Non-GSO MSS Feederlink Spectrum Requirements (Nov.
24, 1994).

176.  NTIA Manual, supra note 13, Section 6.1.1 at 6-6.  

177.  Fixed service systems include point-to-point operations (a
single transmitter and a single receiver).  Fixed services also
include point-to-multipoint operations (a single transmitter and
many receivers), including multiple address service (MAS)
operations (two-way transfer of data between a master station and
multiple slave stations).  The fixed service differs from the
broadcasting service, in that the broadcasting service is one-way
and does not have specifically identified receivers.  Fixed
services differ from the mobile services because the fixed
service transmitters and receivers are stationary (i.e., fixed),
though fixed service stations may be transported between sites.

178.  Matheson & Steele, supra note 11.  This study considered 33
radio bands between 406 MHz and 30 GHz that are allocated to the
fixed services on a primary basis.  The opinions expressed in the
study are those of the authors and do not necessarily reflect
NTIA policies or planning.

179.  USCG Comments at 1.

180.  Federal participation involves 38 agencies with almost 1000
sites.

181.  An example of this is the Basic Exchange Telecommunications
Radio Service (BETRS).

182.  47 C.F.R. Section 94 (1993).

183.  The National Television Systems Committee (NTSC) modulation
format is used for TV broadcast signals in the United States and
many other countries.

184.  ICR is a broadcast industry term that includes FCC
designations for TV relay stations, TV microwave booster station,
and audio ICR. 

185.  The cable television relay service was originally called
the "community antenna relay service," hence the "CARS" acronym.

186.  DOE Comments at 6.

187.  Data on non-Federal fixed service licenses used throughout
this section was obtained from Comsearch, under contract to the
Department of Commerce.  The data gives the number of licenses on
December 31 of the respective years.  This data is extracted from
Matheson & Steele, supra note 11.

188.  Jonathan M. Kraushaar, Fed. Comm. Commission, Fiber
Deployment Update End of Year 1992 (1993).

189.  Matheson & Steele, supra note 11, at 7.

190.  A DS-3  link is equivalent to one TV channel, twenty-eight
T1 circuits, 762 voice channels, or 45 Mb/s.

191.  Pacific Telesis Comments at 7-11; Motorola Comments at
11-13; Digital Microwave Comments at 3; Harris Comments at 2-10;
Comsat Comments at 9; AT&T Comments,  Exhibit B at 5.

192.  Motorola Comments at 13.

193.  Comsat Comments at 9.

194.  SBCA Comments at 3.

195.  Kraushaar, supra note 188.

196.  Proactively Surviving "Fiber Fever", Dave Wand, U.S. West
Communications, National Wireless/Radio Engineers Conference,
Denver, Colo. (June 3, 1992).

197.  Alcatel Comments, Comments of Technical Staff at 10.

198.  AT&T Comments at 4.

199.  AAR Comments at 9; Southwestern Bell Comments at 7; DOI
Comments at 4.  See also Comments of the Utilities
Telecommunications Council at 54-61 (filed June 5, 1992) in
Redevelopment of Spectrum to Encourage Innovation in the Use of
New Telecommunications Technologies, ET Docket 92-9.

200.  DOD Comments at 7-8.

201.  See Matheson & Steele, supra note 11, at 79, 81.  Some of
the original graphs have been updated by adding licensed
frequency counts from 1992 and 1993.  Comsearch, under contract
to NTIA, supplied the additional data.

202.  Digital Microwave Comments at 4.

203.  Redevelopment of Spectrum to Encourage Innovation in the
Use of New Telecommunications Technologies, Third Report and
Order and Memorandum Opinion and Order, ET Docket No. 92-9, 8 FCC
Rcd 6589 (1993).

204.  See, e.g., Digital Microwave Comments at 3.

205.  Alcatel Comments, Comments of Technical Staff at 1-2.

206.  AT&T Comments, Exhibit B at 7.

207.  See, e.g., Cohen et al., supra note 34, at 60-64.

208.  DOD Comments at 6-8.

209.  See infra p. 87 for a discussion of very small aperture
terminal (VSAT) technology.

210.  Matheson & Steele, supra note 11, at 22-31.

211.  Id. at 43, 55, 59, 69.

212.  Harris Comments at 2-10.

213.  Bell Atlantic Comments at 16-19.

214.  FCC 93-350, second report and order, adopted July 15, 1993.

215.  Id. at 39, 45, 61.

216.  See infra p. 204 for a discussion of quadrature amplitude
modulation (QAM).

217.  Digital Microwave Comments at 3.

218.  Alcatel Comments at 1.

219.  AAR Comments at 8-10; Utilities Telecommunications Council
supra note 199.

220.  UTC Comments at 9.

221.  AT&T Comments at 4; Digital Microwave Comments at 3;
Alcatel Comments at 1.

222.  Matheson & Steele, supra note 11, at 123.

223.  Id. at 41, 63.

224.  The National Television Systems Committee (NTSC) signal
format is the standard for television in the United States and
numerous other countries.

225.  NAB Comments at 4.

226.  MSTV Comments at 10.

227.  NPR Comments at 9.

228.  Craig J. Brunet, Hybridizing the Local Loop, IEEE Spectrum,
June 1994, at 28-32.

229.  Matheson & Steele, supra note 11, at 73.

230.  Id. at 37, 57, 65.

231.  VA Comments at 3.

232.  DOE Comments at 6.

233.  FAA Comments at 4.

234.  NTIA defines the fixed-satellite service as "[a]
radiocommunication service between earth stations at given
positions when one or more satellites are used; the given
position may be a specified fixed point or any fixed point within
specified areas; in some cases this service includes satellite-
to-satellite links, which may also be effected in the inter-
satellite service; the fixed-satellite service may also include
feeder links for other space radiocommunication services.  NTIA
Manual, supra note 13, Section 6.1.1, at 6-6.  A feeder link is
"[a] radio link from an earth station at a given location to a
space station, or vice versa, conveying information for a space
radiocommunication service other than for the fixed-satellite
service.  The given location may be at a specified fixed point,
or at any fixed point within specified areas."  Id.

235.  Broadcasting involves signals "intended for direct
reception by the general public."  See id. Section 6.1.1, at 6-3
(defining the broadcasting and broadcasting-satellite services). 
Although the fixed-satellite service is not used for
broadcasting, it is used for point-to-multipoint distribution of
television programming to broadcasters and cable providers. 
Public reception of these signals was not the original intent.

236.  NASA Comments at 15.  LEO satellites can occupy much lower
orbits than geostationary satellites.  The resulting reduction in
time delay is critical for certain real-time two-way
communications (e.g., computer communications).

237.  The DOD MILSTAR system operates at 20/44 Ghz.

238.  Although some earth stations in the fixed-satellite service
are transportable, see, e.g., DOD Comments at 7, the users can
still erect directional antennas, though they may be smaller than
the antennas used at truly fixed sites.  The use of satellites in
low-Earth orbit for the fixed-satellite service would require
satellite tracking or less directional antennas, changing the
nature of the service.

239.  Footnote US245, which specifies this limitation, applies to
the 3600-3700 MHz and 4500-4800 MHz bands (space-to-Earth) and
the 5850-5925 MHz band (Earth-to-space).  NTIA Manual, supra note
13 , Section 4.1.3, at 4-69, -70, -72, -110.

240.  Philip Chien, INTELSAT 701 and Spot 3 Launched, Landsat 6
Lost, Via Satellite, Dec. 1993, at 63.

241.  Int'l Radio Consultative Committee, Int'l Telecommunication
Union, Handbook on Satellite Communications , Section 6.2.1.2(ii)
(1988) (summarizing the provisions of Article XIV d of the
INTELSAT Agreement).

242.  Daniel J. Marcus, PanAmSat's Global Satellite System, Via
Satellite, Oct. 1993, at 26.

243.  PanAmSat, Broadcasting & Cable, July 18, 1994, at 5
(magazine advertisement).

244.  PanAmSat Loses Atlantic Satellite in $214 Million Launch
Failure, Comm. Daily, Dec. 5, 1994 at 1 [hereinafter PanAmSat
Loses Satellite].

245.  Comm. Daily, Dec. 6, 1994 at 9.

246.  Marcus, supra note 242, at 26-28.

247.  Columbia's renewable lease with NASA expires at the end of
1997.  Theresa Foley, Is It Time to Change the Rules of the
Game?, Via Satellite, Dec. 1994 at 18.  TDRSS is discussed infra
p. 146.

248.  The use of privately-owned domestic satellites is not
limited to the private sector.  The FAA, for example, uses
satellites to link remote air-to-ground communications sites to
central air traffic control facilities in Alaska.  The FAA plans
to use a similar capability as a backup for terrestrial services
in the CONUS.  Markey, supra note 125, Enclosure at 6.

249.  John McNiff, Domestic Satellite Operators, Via Satellite,
Nov. 1993 at 26.  Recently, the distinction between international
and domestic U.S. satellites has blurred as Hughes Galaxy has
sought FCC permission to use its domestic satellites for
international traffic.  See PanAmSat Loses Satellite, supra note
244.  Columbia, meanwhile, is seeking to offer domestic services,
at least temporarily, to help offset a 4/6 GHz transponder
shortfall.  Foley, supra note 247, at 18.

250.   Direct broadcast satellite (DBS) systems, a new competitor
to the TVRO systems, are discussed infra p. 101.

251.  Grace Leone, U.S. Transponder Supply, Via Satellite, April
1993 at 24, 24-25.

252.  Id

253.  Unlike the satellite systems in the 4/6 GHz band, the 11/14
GHz domestic fixed-satellite service systems generally do not
share frequency bands with the terrestrial fixed service.  The
11/14 GHz systems therefore experience less interference.  They
also operate under fewer sharing constraints, such as those that
limit the power flux density of emissions from the satellites.

254.  DOD Comments at 7.

255.  Id

256.  The government fixed-satellite service allocations in the
7/8 GHz band are located at 7900-8400 MHz (Earth-to-space) and
7250-7750 MHz (space-to-Earth).  NTIA Manual, supra note 13,
Section 4.1.3, at 4-73 to 4-75.

257.  The frequency bands 20.2-21.2 GHz (space-to-Earth), 30-31
GHz (Earth-to-space), and 43.5-45.5 GHz (Earth-to-space) are
allocated to the fixed-satellite service for government use in
the United States, although the latter band is not allocated to
this service internationally.  Id. Section 4.1.3, at 4-88, -92,
-95.  The MILSTAR system operates at 20/44 GHz.  The planned
Joint Defense Broadcast System operates at 20/30 GHz.

258.  DOD Comments at 7.  The Department of Defense used
commercial satellites to meet part of its communications
requirements during Operation Desert Storm.  Id.

259.  Id. at 6-8.

260.  See supra note 234.

261.  Feeder links for the mobile-satellite service are discussed
supra p. 59.  Feeder links for the broadcasting satellite service
are discussed infra p. 103.

262.  See discussion supra p. 60.

263.  See infra p. 146 for a discussion of inter-satellite links.

264.  The effects of rain on satellite links are discussed infra
p. 195.

265.  U.S. Dep't of State, Pub. 9903, United States Proposals for
the 1992 World Administrative Radio Conference for Dealing with
Frequency Allocations in Certain Parts of the Spectrum 8 (1991)
[hereinafter U.S. Proposals for WARC-92].

266.  WARC-92 Final Acts, supra note 55, at 85, 87.

267.  Pacific Telesis Comments at 11.

268.  Southwestern Bell Comments at 7.

269.  Pacific Telesis Comments at 11.  Point-to-multipoint
service is in many ways similar to broadcasting.  Broadcasting,
however, involves signals intended for direct reception by the
general public.

270.  Karen JP Howes, Teleports, Via Satellite, Aug. 1993, at 26,
33-34.

271.  "If we're going to have quadruple the amount of satellite
use, then in my mind, we'll have quadruple the amount of
business;" Bob Doty, Jr., Director of Operations, Upsouth, quoted
in Howes, Teleports, supra note 270, at 34.

272.  AT&T Comments, Exhibit C, at 3-4.

273.  Chuck Emmert, VSAT Hardware, Via Satellite, Feb. 1993, at
26, 26-27.

274.  Id. at 27.

275.  Perhaps the most familiar example is two computers
exchanging data using telephone lines and modems.

276.  Howes, Teleports, supra note 270, at 27.  According to the
industry, a teleport is "an access facility to satellite or other
long-haul telecommunications media incorporating a distribution
network serving the greater regional community and often
associated with a related real estate or other economic
development;" Boeke, Teleports in the United States, Via
Satellite, Aug. 1992, at 24.

277.  Howes, Teleports, supra note 270, at 27.

278.  Karen JP Howes, Programmers   Customers or Competitors?,
Via Satellite, Aug. 1993, at 28.

279.  Some teleport operators are providing maritime services;
see Howes, Teleports, supra note 270, at 30.

280.  Comsat Comments at 10.

281.  Because of the shorter wavelength, 11/14 GHz earth station
antennas are smaller than 4/6 GHz antennas having the same gain. 
Increased satellite transmitter power further reduces the
required antenna diameter, since less antenna gain is needed to
meet performance criteria.  Although they are less susceptible to
terrestrial interference than systems in the 4/6 GHz band, 11/14
GHz systems are more susceptible to rain attenuation, see infra
p. 195.

282.  NASA Comments at 15.

283.  Emmert, supra note 273, at 29.

284.    Id. at 27.  This typical "star" configuration constitutes
a point-to-multipoint system.

285.  Howes, Teleports, supra note 270, at 27.

286.  NASA Comments at 15.

287.  Emmert, supra note 273, at 29.

288.  Id. at 28.

289.  Id. at 29.

290.  NASA Comments at 15; Comsat Comments at 10.

291.  NASA Comments at 16.

292.  See Comsat Comments at 11; NASA Comments at 15.

293.  NASA Comments at 15.  VSAT systems require very little
bandwidth compared to video systems.

294.  Id. at 4.

295.  Id.  See infra p. 147 for a discussion of the proposed
general-satellite service, which could accommodate such a system.

296.  Id. at 15-16.

297.  Id. at 16.

298.  Id.

299.  Southwestern Bell Comments at 7.

300.  Pacific Telesis Comments at 11.

301.  Id.  Comsat, however, believes that the overall use of the
fixed-satellite service will increase along with the growth of
fiber systems, though not as quickly for dense traffic routes. 
Comsat Comments at 11.

302.  See Comsat Comments at 11.

303.  Howes, Teleports, supra note 270, at 33.

304.  See supra p. 87.

305.  Comsat, which provides INTELSAT access for U.S. users,
believes that WARC-92's reallocation of the 13.75-14 GHz band to
the fixed-satellite service will satisfy short-term demands. 
However, they suggest that "additional spectrum could be needed
by the turn of the century." Comsat Comments at 11; but see
Pacific Telesis comments at 11 (stating that optical fiber will
have an advantage for international telecommunications and that
spectrum allocations will be adequate).  Also, the U.S.
Department of Defense expects to need additional spectrum to
support data and imagery requirements early in the next century. 
DOD Comments at 8.

306.  Pacific Telesis Comments at 11; DOD Comments at 8.

307.  See supra p. 60.

308.  The broadcasting service is "[a] radiocommunication service
in which the transmissions are intended for direct reception by
the general public.  This service may include sound
transmissions, television transmissions or other types of
transmissions."  NTIA Manual, supra note 13, Section 6.1.1, at
6-3.  The broadcasting-satellite service is "[a]
radiocommunication service in which signals transmitted or
retransmitted by space stations are intended for direct reception
by the general public.  In the broadcasting-satellite service,
the term 'direct
reception' shall encompass both individual reception and
community reception." Id. See infra p. 100 for a discussion of
TVRO systems operating in the fixed-satellite service.

309.  WARC-92 Final Acts, supra note 55, at 65, 76.

310.  Id. at 28 (International Footnote 529B).

311.  International broadcasting stations are defined as
broadcasting stations, employing frequencies allocated to the
broadcasting service between 5950 kHz and 26,100 kHz, whose
transmissions are intended to be received directly by the general
public in foreign countries.  NTIA Manual, supra note 13, Section
6.1.1, at 6-8.  See also 47 C.F.R. Section 73.701(a) (1993).

312.  For a further discussion of localism, see National
Telecommunications and Information Administration, U.S. Dep't of
Commerce, NTIA Special Publication 93-290, Globalization of the
Mass Media, 215-228 (January 1993).

313.  See 47 C.F.R. Section 73.701(a) (1993).

314.  Jacobs Comments at 4.

315.  The VOA Charter stipulates that the VOA will serve as a
consistently reliable and authoritative source of news and that
its news will be accurate, objective and comprehensive; represent
America, not any single segment of American society, and will
therefore present a balanced and comprehensive projection of
significant American thought and institutions; present the
policies of the United States clearly and effectively, and will
also present responsible discussion and opinion on these
policies. Foreign Relations Authorization Act, Fiscal Year, 1977,
22 U.S.C. Section 2689 (1976).

316.  Though this section covers international broadcasting
stations, it is relevant to note that VOA also transmits
television programs via UHF television (TV Marti) from the United
States to Cuba.

317.  AM broadcasting operations performed by VOA use frequencies
in the band 535-1705 kHz.  Marathon, Florida is the only site in
the United States for VOA AM broadcasting operations.  It is
primarily designed to serve a more local audience with groundwave
signals alone, as compared to its HF broadcast operations.  The
Marathon station transmits on 1180 kHz. 

318.  Surrogate broadcasting provides alternative sources of
accurate news and information to countries where the local media
cannot or does not carry out this function because of
authoritarian control.  Programming of surrogate stations
concentrates on news about the target country itself and strongly
promotes the concepts of democracy and free enterprise. 
Programming of the VOA is broader in scope.  Even though VOA
programming includes the concepts of democracy and free
enterprise, it puts relatively more emphasis on news and
information about general international developments, about the
United States, and U.S. policy than does the surrogate
programming.  See The Report of the President's Task Force on
U.S. Government International Broadcasting 32 (1991).

319.  Bureau of the Census, U.S. Dep't of Commerce, Statistical
Abstract of the United States 561 (1993).

320.  The World Almanac and Book of Facts 305 (1993).

321.  U.S. Industrial Outlook 1994, supra note 3, at 31-6.

322.  Id. at 36-16.

323.  47 C.F.R. Section 73.14 (1993).

324.  47 C.F.R. Section 73.21 (1993).

325.  This signal inferiority results from several factors. 
First, the amplitude modulation of the AM broadcasting signal is
more vulnerable to atmospheric interference and noise; second,
man-made radio noise, such as ignition systems and power lines,
emit radio waves that interfere with AM broadcast reception;
third, while AM stations occupy 10 kHz channels, FM channels are
200 kHz wide, permitting the broadcast of high fidelity stereo
programming; fourth, the widespread practice of "processing" or
boosting the higher frequencies of the broadcast signal by AM
operators has created excess interference; fifth, radio
manufacturers produce inexpensive AM radios with limited
frequency response and reduced bandwidth capability.

326.  Federal Communications Commission, Mimeo No.  51785,
Broadcast Station Totals as of December 31, 1994  (1994)
[hereinafter Broadcast Station Totals].

327.  The other is an "out-of-band" technology that would operate
outside the existing broadcasting allocation and would require
additional broadcast spectrum allocation.  The "in-band"
technology is commonly referred to as "in-band on-channel" (IBOC)
where the digital signal is transmitted with the analog AM
broadcast signal on a non-interfering basis.

328.  47 C.F.R. Section 73.201 (1993).

329.  47 C.F.R. Section 73.211 (1993).

330.  Broadcast Station Totals, supra note 326.

331.  47 C.F.R. Section 73.603(a) (1993).

332.   Broadcast Station Totals, supra note 326.

333.  ATV is generally defined as any television technology that
provides improved audio and video quality or enhances the
existing National Television Systems Committee (NTSC) television
broadcast system.  Reference Data for Engineers:  Radio,
Electronics, Computer, and Communications 35-43 (Van Valkenburg,
ed. 1993).

334.  The FCC in 1987 established an Advisory Committee on
Advanced Television Service (ACATS) to recommend a new television
standard for the United States.  Industry responded with over 20
systems that were eventually reduced to a smaller field of
feasible proponents after a thorough review.  These early systems
were either analog or hybrid analog and digital approaches.  The
FCC in early 1990 stated its desire for a simulcast HDTV system
and four digital HDTV systems were identified.  The competing
systems were officially tested and extensively analyzed during
1992 that led to an ACATS recommendation that a digital HDTV
system be adopted for the United States.  It was also recommended
that the competing systems should either be improved and
retested, or somehow combined.  In mid-1993, the four digital
HDTV proponents joined in a "Grand Alliance" that began a
collaborative effort with the ACATS to create the best possible
HDTV system for the United States.  On April 14, 1994, a System
Specification of the Grand Alliance HDTV System was published to
form the basis of the proposed digital HDTV standard.  Further,
the prototype hardware was expected to be delivered around March
1995 to the Advanced Television Test Center for verification of
the performance of the proposed Grand Alliance HDTV system
standard.

335.  Advanced Television Systems and Their Impact Upon the
Existing Television Broadcast Service, Notice of Proposed
Rulemaking, MM Docket No. 87-268, FCC Rcd 7024 (1991); Advanced
Television Systems and Their Impact Upon the Existing Television
Broadcast Service, Second Report and Order/Further Notice of
Proposed Rulemaking, MM Docket No. 87-268, FCC Rcd 3340 (1992);
Advanced Television Systems and Their Impact Upon the Existing
Television Broadcast Service, Second Further Notice of Proposed
Rulemaking, MM Docket No. 87-268, FCC Rcd 5376 (1992).

336.  VOA Comments at 7; NASB Comments at 2; Herald Broadcasting
Comments at 2; Jacobs Comments at 10.

337.  Herald Broadcasting Comments at 2; NASB Comments at 3.

338.  VOA Comments at 6.

339.  Id. at 1.

340.  NAB Comments at 5-6.

341.   Id. at 6.

342.  GM Comments at 2-3.

343.  NAB Comments at 3.

344.  Letter from Julian L. Shepard and A. James Ebel, Spectrum
Planning and Policy Advisory Committee, to Richard Parlow,
Associate Administrator, Office of Spectrum Management, National
Telecommunications and Information Administration, Enclosure at
3-5 (Aug. 19, 1994) (on file with NTIA).

345.  Japan Backs U.S. Design for High-Definition TV, Wash. Post,
Feb. 23, 1994, at A1, A22; EC Abandons Bid to Develop an HDTV
Standard, Int'l Herald Tribune, Feb. 21, 1993, at 20.

346.  Initially, the frequency bands allocated to the FSS carried
the bulk of television programming while BSS bands remained
virtually unused.  The ITU established and defined the BSS and
FSS as two distinct radio services.  Specific frequency bands
were allocated to the BSS and FSS around 1971.

347.  WARC-92 allocated the 24.75-25.25 GHz to the FSS (Earth-to-
space direction) for feeder links to support wideband HDTV,
thereby displacing the radionavigation allocation.  WARC-92 Final
Acts, supra note 55, at 26-27.

348.  Analog examples include the MUSE-E (multiple sub-Nyquist
sampling encoding) system developed in Japan, the HDBMAC (a high-
definition version of a particular multiplexed analog components
format) system in the United States, and the HDMAC system in
Europe.

349.  Id. at 76-77, 81.

350.  Mexico and Canada are planning to use 1452-1492 MHz for
their BSS-Sound systems.  Close frequency coordination will be
needed to ensure compatible operations along U.S. borders.

351.  New Digital Audio Radio Services, 60 Fed.  Reg.  8309
(1995) (to be codified at 47 C.F.R. Section 2).  "DARS" is an
all-inclusive term that encompasses both terrestrial DAB and
digital audio provided by satellite.

352.  NAB Comments at 3.

353.  Hubbard Comments at 6.

354.  NAB Comments at 3.

355.  The BSS is currently allocated in the 12 GHz and 17 GHz
bands.  It should be noted that the 12 GHz band contains three
segments that "overlap" each other without a common single
worldwide allocation (11.7-12.5 GHz for Region 1, 12.2-12.7 GHz
for Region 2, and 12.5-12.75 GHz for Region 3).

356.  Hubbard Comments at 5-6.

357.  SCDR Comments at 3.

358.  NASB Comments at 5.

359.  NTIA Manual, supra note 13, Section 6.1.1, at 6-12.

360.  Id.

361.  Id. at 6-14.

362.  Id. at 6-13.

363.  Id. at 6-12.

364.  U.S. Dep't of Transportation & U.S. Dep't of Defense, DOT-
VNTSC-RSPA-92-2/DOD-4650.5, 1992 Federal Radionavigation Plan
(1993) [hereinafter Federal Radionavigation Plan].

365.  Id. at 3-17.

366.  Id.

367.  Id. at 3-9.

368.  Id. at 3-21.

369.  Id.

370.  Id. at 3-36.

371.  Id.

372.  Id.

373.  R.O. DeBolt et al., NTIA Special Publication 94-30, A
National Approach to Augmented GPS Services xiv (1994).  This
report is discussed at length beginning infra p. 115.

374.  Although it is a part of NTIA, the Institute for
Telecommunication Sciences conducts contractual technical studies
whose results and recommendations are entirely separate and
distinct from the NTIA telecommunications policy making process.

375.  Id. at 3-21.

376.  Id. at 1-9.

377.  Markey, supra note 125, Enclosure at 8.

378.  Federal Radionavigation Plan, supra note 364, at 1-9.

379.  Memorandum from Nelson V. Pollack, Air Force Member,
Interdepartment Radio Advisory Committee (IRAC), to Chairman,
IRAC at 5 (Oct. 7, 1994) (on file with NTIA).

380.  "Government systems utilizing spread spectrum techniques
for terrestrial communications, navigation and identification may
be authorized to operate in the band 960-1215 MHz on the
condition that harmful interference will not be caused to the
aeronautical radionavigation service.  These systems will be
handled on a case-by-case basis.  Such systems shall be subject
to a review at the national level for operational requirements
and electromagnetic compatibility prior to development,
procurement or modification."  NTIA Manual, supra note 13,
Section 4.1.3, at 4-116.

381.  Federal Radionavigation Plan, supra note 364, at 3-28; FAA
Won't Delegate New Landing System, Wash. Post, June 3, 1994, at
F1 [hereinafter MLS Article].

382.  Markey, supra note 125, Enclosure at 8.

383.  Id.

384.  Philip J. Klass, Europe Seeks to Fill MLS "Gap" Left by
U.S., Aviation Week and Space Technology, Sept. 12, 1994, at 65.

385.  Federal Aviation Administration, U.S. Dep't of
Transportation, Aviation System Capital Investment Plan 2-4-4 to
2-4-5 (1991).

386.  Federal Radionavigation Plan, supra note 364, at 3-29.

387.  MLS Article, supra note 381, at F1.

388.  Markey, supra note 125, Enclosure at 2.

389.  Pollack, supra note 379, Enclosure at 9. 

390.  Markey, supra note 125, Enclosure at 10.

391.  International Civil Aviation Organization, Report
COM/MET/OPS/90, Report of the Communications, Meteorology, and
Operations Divisional Meeting, Appendix A to Agenda Item 1
(1990).

392.  Int'l Radio Consultative Committee, Int'l Telecommunication
Union, Report 1186, Use of the Frequency Band 4,200 to 4,400 MHz
By Radio Altimeters (1990).

393.  Markey, supra note 125, Enclosure at 10.

394.  Satnav Sanctioned, Aviation Week and Space Technology, Feb.
21, 1994, at 31.

395.  DOD Comments at 9.

396.  Federal Radionavigation Plan, supra note 364, at 3-31.

397.  DeBolt et al., supra note 373, at x.

398.  Id. at xiv.

399.  Id. at xv.

400.  Federal Radionavigation Plan, supra note 364, at 4-6.

401.  Id. at 4-12.

402.  Markey, supra note 125, Enclosure at 12.  

403.  Federal Radionavigation Plan, supra note 364, at 3-38.

404.  Letter from Michael Tom, Senior Scientist, Radar Systems
Group, Hughes Aircraft Co., to Fred Matos, National
Telecommunications and Information Administration (Jan. 14, 1994)
(on file with NTIA).

405.  FAA Comments.

406.  Letter from Arnold Aquilano, Federal Aviation
Administration, to Honorable Janice Obuchowski, Administrator,
National Telecommunications and Information Administration (Apr.
2, 1990) (on file with NTIA).

407.  The FAA subsequently provided more information on its
activities, stating that "[t]he 5150 5250 MHz band, which is
allocated worldwide for the aeronautical radionavigation service,
must be protected from encroachment by non-aeronautical services
to satisfy spectrum requirements for the pressing needs of a
modern, global, and compatible all-weather radionavigation
system. These requirements include spectrum for automatic
dependent surveillance, digital links to transmit differential
corrections for satellite navigation systems, expansion of the
Doppler weather radar program, and ground surface movement and
control." The FAA indicated that it has applied to NTIA for
spectrum certification for systems for these purposes using the
band. Letter from Don Willis, Federal Aviation Administration, to
Fred Matos, National Telecommunications and Information
Administration (Oct. 31, 1991) (on file with NTIA).

408.  NTIA conducted an extensive analysis of the 1605-2000 kHz
band in 1984-1985.  See R.E. Thompson et al., National
Telecommunications and Information Administration, NTIA Report
85-175, Spectrum Resource Assessment of the 1605-2000 kHz Band
(1985).

409.  Telephone Interview with Pat Matthews, Vice President -
Operations, Offshore Navigation, Inc. (Oct. 21, 1993).

410.  The only radiolocation service allocation in the 3-30 MHz
band is in the 3230-3400 kHz band discussed supra p. 122.

411.  M. Westlake, Research and Innovation: Beyond the Horizon,
Far Eastern Economic Review, Jan. 31, 1991, at 54; J. M.
Headrick, Looking Over the Horizon, IEEE Spectrum, July 1990, at
36-39; IEEE Journal on Oceanographic Engineering, April 1986,
passim.

412.  D. Hughes, Navy Installs ROTHR System in Alaska to Protect
Battle Groups in Pacific, Aviation Week and Space Technology,
Nov. 27, 1989, at 69-80.

413.  National Telecommunications and Information Administration,
IRAC Doc. 28039/1-1.14.10/6.14, Certification of Spectrum
Support, Mirage Systems Over-the-Horizon Radar (Nov. 25, 1992).

414.  Memorandum from M. Grunden, to the Secretary, Spectrum
Planning Subcommittee (SPS-9113) (May 6, 1992).

415.  NTIA Manual, supra note 13, Section 4.1.3 at 4-171.

416.  Id. Section 4.1.3 at 4-116.

417.  A.R. Francoeur, Naval Space Surveillance System (NAVSPASUR)
Solid State Transmitter Modernization, IEEE National Radar
Conference, Institute of Electrical and Electronics Engineers, at
147 (1989).

418.  DOD Comments at 9.

419.  Id. at 10.

420.  Markey, supra note 125, Enclosure at 13.

421.  DOC Comments at 9.

422.  Id.

423.  Pollack, supra note 379, Enclosure at 6.

424.  Amendment of Part 90 of the Commission's Rules to Adopt
Regulations for Automatic Vehicle Monitoring Systems, Notice of
Proposed Rulemaking, PR Doc. 93-61 (1993).

425.  Amendment of Part 90 of the Commission's Rules to Adopt
Regulations for Automatic Vehicle Monitoring Systems, Report and
Order, PR Docket No.93-61 (FCC 95-41) (released February 6,
1995), at 55.

426.  Id. at 4.

427.  Amendment of Section 2.106 of the Commission's Rule to
Allocate Spectrum for Wind Profiler Radar Systems, Notice of
Proposed Rule Making and Notice of Inquiry, ET Docket No. 93-59,
at 1 (1994).

428.  The radiolocation service is allocated on a primary basis
in the 1215-1300 MHz and 1350-1400 MHz bands, and on a secondary
basis in the 1300-1350 MHz band.

429.  For additional technical and operational details see R.J.
Lay et al, ARSR-4: Unique Solutions to Long-Recognized Radar
Problems, IEEE 1990 International Radar Conference, Institute of
Electrical and Electronics Engineers, at 6-11 (1990).

430.  Pollack, supra note 379, Enclosure at 6.

431.  Radar Forecast, Report on FPS-117(V), Forecast
International/DMS 1-7 (June 1993).

432.  POllack, supra note 379, Enclosure at 7.

433.  Aspects of Modern Radar 25-26 (E. Brookner ed. 1988)
[hereinafter Brookner].

434.  DOD Comments at 9.

435.  Id.

436.  Radar Handbook 1-13, 1-16 (M.I. Skolnik ed. 1970).

437.  Brookner, supra note 433, at 38.

438.  Radar Forecast, Report on TPQ-37(V), Forecast
International/DMS 1-5 (Aug. 1993).

439.  Radar Forecast, Report on SPS-48(V), Forecast
International/DMS 1-5 (Apr. 1993).

440.  Radar Forecast, Report on SPY-1(V), Forecast
International/DMS 1-8 (Apr. 1993).  For further information, see
Chapter 3, "The AEGIS System," by J. Sensi, Jr., in Brookner,
supra note 433, at 239-53.

441.  Memorandum from Bruce Swearington, Navy Member,
Interdepartment Radio Advisory Committee (IRAC), to Executive
Secretary, IRAC  (Oct. 12, 1994) (on file with NTIA).

442.  R.E. Thompson et al., National Telecommunications and
Information Administration, NTIA Technical Note 87-6C, Spectrum
Resource Assessment of the Radiolocation Bands from 1605 kHz to
Above 17.7 GHz,  at 2-6 (1987).

443.  DOD Comments at 9.

444.  Id. at 10.

445.  NTIA Manual, supra note 13, Section 4.1.3, at 4-106.

446.  Pollack, supra note 379, Enclosure at 6.

447.  Radar Forecast, Report on SPG-55(V), Forecast
International/DMS 1-3 (Jan. 1993).

448.  Radar Forecast, Report on SPS-55(V), Forecast
International/DMS 1-3 (June 1993).

449.  DOD Comments at 9.

450.  Radar Forecast, Report on TPQ-36(V), Forecast
International/DMS 1-6 (June 1993).

451.  Radar Forecast, Report on TPQ-37(V), Forecast
International/DMS 1-6 (Apr. 1993).

452.  Radar Forecast, Report on SDI Ground Based Radars, Forecast
International/DMS 1-7 (Sept. 1993).

453.  Id.

454.  Carl Kain, Remarks at the Federal Wireless Users Forum
(Oct. 6, 1994).

455.  Id.

456.  Letter from Michael Tom, Senior Scientist, Radar Systems
Group, Hughes Aircraft, to Fred Matos, National
Telecommunications and Information Administration (Jan. 14, 1994)
(on file with NTIA).

457.  DOD Comments at 9.

458.  Id.

459.  It is suggested that the DOD and the military agencies
review their research taking place in non-radiolocation bands. 
If the requirements are strong enough, then the United States
could advocate allocation changes in a future ITU radio
conference.

460.  Petition for Rule Making by General Motors Research
Corporation, RM-8308 (Oct. 13, 1993).

461.  Revision of Parts 2, 15, 21, 74, 78, and 94 of the
Commission's Rules to Stimulate Economic Growth by Permitting Use
of Radio Frequencies above 40 GHz for Access to the National
Information Infrastructure and for Other Communications
Applications, Notice of Proposed Rulemaking, ET Docket 94-124, at
10 (1994).

462.  Skolnik points out that a conventional radar might have a
wide absolute bandwidth and still be narrowband in the relative
sense.  For example, a short-pulse 10-GHz band radar with 500 MHz
bandwidth is "narrowband" in that its bandwidth is small compared
to its center frequency (5 percent).  However, a 500 MHz
bandwidth radar at UHF (500 MHz) has a wide relative bandwidth of
100 percent.  The definition of "impulse" is evolving, as
research has been conducted on a wideband radar that transmitted
two cycles of a sine wave.  See M.I. Skolnik, Naval Research
Laboratory, NRL Memorandum Report 6755, An Introduction to
Impulse Radar 1 (1990).

463.  DOD Comments at 10.  Radio astronomers are concerned with
the potential for interference due to UWB radar systems. 
Coordination between radio observatories and users of UWB devices
will be necessary to minimize the risk of interference. 
Memorandum from Andrew Clegg, National Science Foundation, to
Russell Slye, National Telecommunications and Information
Administration (Oct. 13, 1994) (on file with NTIA).

464.  Polarmetric radars process the polarization of the return
signal to determine the type of target as electromagnetic waves
are scattered by the object, their polarization changes.  The
changes are processed and compared with the characteristics of
known objects.

465.  J. Fleischman et al., Summary of Results from a Foliage
Penetration Experiment with a Three-Frequency Polarmetric SAR,
Surveillance Technologies II, Apr. 1992, at 151-60.

466.  Letter from James N. Scott, NASA Representative to IRAC
Spectrum Planning Subcommittee (SPS), to Arthur Gray, Secretary,
Spectrum Planning Subcommittee, SPS-9414 (Feb. 9, 1993).

467.  R. Sullivan et al., Environmental Research Institute of
Michigan, Results from ERIM/NADC Polarimetric X/L/C Band SAR 3
(undated).

468.  DOD Comments at 9.

469.  Id. at 10.

470.  E. Brookner and T.F. Mahoney, Derivation of a Satellite
Radar Architecture for Air Surveillance, Microwave Journal, Feb.
1986, at 173-91.

471.  Letter from Dr. Charles E. Weir, Principal Scientist, Space
Systems Division, Rockwell International, to Fred Matos, National
Telecommunications and Information Administration, Nov. 15, 1993
(on file with NTIA).

472.  J.C. Curlander & R.N. McDonough, Synthetic Aperture Radar
Systems and Signal Processing 39 (1991).

473.  Brookner, supra note 433, at 84.

474.  Curlander & McDonough, supra note 472, at 12.

475.  NTIA Manual, supra note 13, Section 4.1.3, at 4-147.

476.  John D. Morrocco and David A. Fulghum, Conferees Spare
Programs by Spreading Cuts, Aviation Week and Space Technology,
Oct. 3, 1994, at 30.

477.  The radar experts interviewed were Dr. Merrill Skolnik,
Superintendent, Radar Division, U.S. Navy; Mr. Robert T. Hill,
Consultant and former Navy Radar Scientist; Dr. David Barton,
Senior Radar Scientist, ANRO Co.; and Dr. Eli Brookner, Senior
Radar Scientist, Raytheon Corp.  The 15-20 year radar concept-to-
deployment cycle is essentially supported by Norman Augustine,
President, Martin Marietta Corp.  Augustine indicated that it
takes 14 years from major program inception to operational
capability.  See Electronic Industries Association, EIA Ten-Year
Forecast of Defense Electronic Opportunities (FY's 1993-2002),
28th Annual Report 520 (1992).

478.  NTIA Manual, supra note 13, Section 6.1.1, at 6-12

479.  The mobile-satellite service is discussed supra p. 52, the
fixed-satellite service supra p. 80, the broadcasting-satellite
service supra p.  100, the radiodetermination-satellite service
supra p. 142, the amateur-satellite service infra p. 163, and the
standard frequency and time signal-satellite service infra p.
169.

480.  The inter-satellite service is defined as "[a]
radiocommunication service providing links between artificial
satellites;" WARC-92 Final Acts, supra note 55, at 21.  Prior to
WARC-92, the ITU definition, incorporated in NTIA regulations,
specified "artificial earth satellites."  NTIA Manual, supra note
13, Section 6.1.1 at 6-8.  The U.S. proposed the change so that
the service would include links between data relay satellites and
either deep space spacecraft and spacecraft orbiting other
celestial bodies.  U.S. Proposals for WARC-92, supra note 265, at
12.  The service is allocated on a primary basis in several
frequency bands above 20 GHz.  The 5000-5250 MHz and 15.4-15.7
GHz frequency bands are also allocated to the inter-satellite
service to support aeronautical operations.  NTIA Manual, supra
note 13, Section 4.1.3 at 4-156 (International Footnote 797).

481.  Supra note 234.

482.  See discussion of spectrum requirements for MSS feeder
links supra p. 59.  Spectrum requirements for inter-satellite
links would presumably be similar to those for feeder links.

483.  NASA Comments at 23-24.

484.  DOD Comments at 15.

485.  NASA Comments at 5.

486.  Id. at 2.  The 23.55-23.6 GHz band is currently allocated
worldwide to the fixed and mobile services.  NTIA Manual, supra
note 13, Section 4.1.3 at 4-89.

487.  NASA Comments at 24.

488.  U.S. Proposals for WARC-92, supra note 265, at 8.  The
proposal defined the general-satellite service as "[a]
radiocommunication service using satellites for fixed and/or
mobile applications."  Id. at 12.

489.  Id. at 56, 61.

490.  WARC-92 Final Acts, supra note 55, at 79, 87.

491.  Id. at 80 (International Footnote 873B).

492.  Id. at 262-63 (Recommendation 719).

493.  NTIA Manual, supra note 13, Section 6.1.1 at 6-15.  Space
tracking is defined as the "[d]etermination of the orbit,
velocity or instantaneous position of an object in space by means
of radiodetermination, excluding primary radar, for the purpose
of following the movement of the object."  Id.  Space telemetry
is "[t]he use of telemetry for the transmission from a space
station of results of measurements made in a spacecraft,
including those relating to the functioning of spacecraft."  Id. 
Space telecommand is "[t]he use of radiocommunication for the
transmission of signals to a space station to initiate, modify or
terminate functions of equipment on a space object, including the
space station."  Id.  Interestingly, since the definition of
space telemetry includes the results of measurements, some
communications related to the spacecraft's mission can be
accommodated in the space operation service.  In its comments,
NASA suggested renaming the space operation service to "something
like the Space Command and Control Service" to better describe
its function.  NASA Comments at 25.

494.  While TT&C as used herein means tracking, telemetry, and
command (a variation on the "telecommand" in the definition of
the space operation service), the use of the acronym within the
space communications community is not consistent.  See, e.g.,
NASA Comments at 5 (telemetry, tracking, and command); id. at 24
(tracking, telecommand, and control); id. at 25 (tracking,
telemetry, and control); IEEE Standard Dictionary of Electrical
and Electronics Terms 1260 (Jay Frank ed., 1988) [hereinafter
IEEE Dictionary] (telemetry, tracking, and control). 
Fortunately, all use the same acronym and all refer to
essentially the same functions.

495.  NTIA Manual, supra note 13, Section 6.1.1, at 6-15
(defining the space operation service).

496.  NASA Comments at 24-25.

497.  Id. at 25.

498.  WARC-92 Final Acts, supra note 55, at 62-63.

499.  NTIA Manual, supra note 13, Section 4.1.3, at 4-69 to -70.

500.  NASA Comments at 2.

501.  Small satellites can also be economically launched as
secondary payloads on larger launch vehicles.  However, they are
then subject to the orbital specifications of the primary
payload.  See Orly Knig, OSC's Pegasus System The First Air-
Launched Booster, Via Satellite, Feb. 1994, at 124.

502.  Facsimile from Ruben Van Mitchell, Office of Commercial
Space Transportation, U.S. Dep't of Transportation, to Robin H.
Haines, Office of Spectrum Management, National
Telecommunications and Information Administration (Nov. 17, 1993)
(on file with NTIA).  See also U.S. Industrial Outlook 1994,
supra note 3, at 20-12 to -15.

503.  Mission Operations and Data Systems Directorate, Nat'l
Aeronautics and Space Admin., Mission Requirements and Data
Systems Support Forecast 92-95 (Feb./Mar. 1994).

504.  Mitchell, supra note 502.

505.  NASA Comments.

506.  Mitchell, supra note 502.

507.  Id.  Shuttle-sized payloads and those with foreign policy
implications may still be launched on the STS.

508.  Id.  OCST promotes and licenses commercial launch vehicles. 
Id.

509.  NTIA Manual, supra note 13, Section 4.1.3 at 4-120
(Footnote US276).  The six frequencies are 2312.5 MHz, 2332.5
MHz, 2352.5 MHz, 2364.5 MHz, 2370.5 MHz, and 2382.5 MHz.  NASA
still
maintains that existing government communications facilities and
frequency bands should support commercial launches.  NASA
Comments at 26.

510.  WARC-92 Final Acts, supra note 55, at 65.  The reallocation
leaves only 2364.5 MHz, 2370.5 MHz, and 2382.5 MHz available for
commercial launch telemetry.  The other three channels are
available on only a secondary basis and are not protected from
interference.

511.  Carl Rappaport, Office of Commercial Space Transportation,
U.S. Dep't of Transportation, Remarks at the NTIA Strategic
Spectrum Planning Seminar (Mar. 3, 1993).

512.  Mitchell, supra note 502.

513.  Rappaport, supra note 511.

514.  Mitchell, supra note 502.  For purposes of frequency
sharing, future commercial space operations may well have to be
limited to minimum power, range and use of select bands.  To
further reduce interference, particularly during down-range or
orbital operation, special modulation technique and launch
scheduling constraints may be required.  Id.

515.  Id.

516.  The space sciences are not limited to research activities. 
Remote sensing, for example, is becoming increasingly commercial.

517.  NASA Comments at 10-11.  WARC-92 also acknowledged the need
for 100 MHz worldwide at 2 GHz.  Id. at 11; cf. WARC-92 Final
Acts, supra note 55, at 62-63.

518.  NTIA Manual, supra note 13, Section 6.1.1 at 6-12.  NASA
suggested a modification of the definition to indicate that TT&C
is most often performed in the mission band.  NASA Comments at
25.

519.  Deep space is defined as "[s]pace at distances from the
Earth equal to or greater than 2   106 kilometers."  NTIA Manual,
supra note 13, Section 6.1.1 at 6-4.  Distances nearer the Earth
are described as "near-Earth."  NASA believes that "local
communications around non-terrestrial bodies do not require
regulation."  Rather, guidelines for these communications can be
developed in the Space Frequency Coordination Group, a consortium
of spectrum managers from the space agencies of various nations. 
NASA Comments at 19.

520.  NASA Comments at 3, 6.

521.  Id. at 6.

522.  WARC-92 Final Acts, supra note 55, at 18.  The distance
limitation is stated in RR651A.

523.  NTIA Manual, supra note 13, Section 4.1.3, at 4-56.

524.  NASA Comments at 2, 6.

525.  See supra p. 147.

526.  NASA Comments at 6.

527.  Id.

528.  WARC-92 Final Acts, supra note 55, at 62.

529.  NASA Comments at 2.  Although this band is close to the
bands proposed for PCS, NASA does not believe deep space uplinks
will cause significant interference to PCS.  The deep space
transmissions will occur only at Goldstone, California;
Vandenburg, California; Cape Canaveral, Florida; and at the Jet
Propulsion Laboratory at the California Institute of Technology. 
Of these four sites, only the Goldstone station will have high
power emissions (400 kW transmitted power and 63 dBi mainbeam
antenna gain) and its antenna will be limited to 5 minimum
mainbeam elevation.  Telephone Interview with David P. Struba,
IRAC Representative, NASA (Oct. 19, 1994).

530.  The former band is allocated under Footnote US251.

531.  NASA Comments at 2.

532.  NTIA Manual, supra note 13, Section 6.1.1, at 6-4 (defining
the earth exploration-satellite service).

533.  NASA Comments at 5.

534.  See supra pp. 147, 154.

535.  NTIA Manual, supra note 13, Section 6.1.1, at 6-9 to -10.

536.  See, e.g., id., Section 4.1.3 at 4-79 (showing the
8175-8215 MHz band allocated in the Earth-to-space direction).

537.  NASA Comments at 5; NOAA Comments at 3.

538.  NOAA Comments at 3.

539.  The 7450-7550 MHz band is allocated to the meteorological-
satellite service on a primary basis for Federal Government use. 
NTIA Manual, supra note 13, Section 4.1.3 at 4-78.  The 8025-8400
GHz band is likewise allocated to the earth exploration-satellite
service, which includes the meteorological-satellite service. 
Id. at 4-78 to -79.

540.  Radio astronomy and radar astronomy, which are terrestrial
forms of remote sensing, are discussed beginning infra p. 157.

541.  NASA Comments at 19.

542.  Id. at 21.

543.  Other applications of Earth-directed remote sensing are not
related to environmental concerns.  The U.S. Department of Energy
has remote sensing requirements related to nuclear explosion
detection and proliferation detection.  While not requesting
additional allocations, the Department of Energy is seeking
flexibility in the management of allocations to allow operation
of these systems outside of the bands allocated to the earth
exploration-satellite service.  Letter from Lawrence Wasson, IRAC
Representative, U.S. Dep't of Energy, to W. Russell Slye, Program
Manager, Strategic Spectrum Planning Program, National
Telecommunications and Information Administration (undated,
received Oct. 6, 1994) (on file with NTIA).

544.  NASA Comments at 5.

545.  Id. at 19.

546.  Id.  This is true partly because specific frequencies for
active and passive sensing of certain celestial bodies are still
to be identified.  Id.

547.  Id. at 21.

548.  NTIA Manual, supra note 13, Section 4.1.3, at 4-146. 
International Footnote 713 also includes the 8550-8650 MHz band,
which is not mentioned in the NASA comments.

549.  Id. Section 4.1.3 at 4-86.

550.  NASA Comments at 2.

551.  NTIA Manual, supra note 13, Section 4.1.3, at 4-160
(International Footnotes 851 and 852).

552.  NASA Comments at 2.

553.  NTIA Manual, supra note 13, Section 4.1.3, at 4-90.

554.  NASA Comments at 2.

555.  Int'l Radio Consultative Committee, Int'l Telecommunication
Union, Recommendation 314-7, Protection for Frequencies Used for
Radioastronomical Measurements (1990) [hereinafter Radio
Astronomy Frequencies].

556.  See supra p. 137.

557.  Clegg, supra note 463.

558.  NTIA Manual, supra note 13, Section 6.1.1 at 6-12.

559.  NSF gives the typical power flux density (PFD) of the
emissions studied (in the 1-10 GHz frequency range) as -250
dBW/m/Hz, though signals with a PFD below -300 dBW/m/Hz have
been studied.  In contrast, the PFD of satellite emissions are
typically -150 dBW/m/Hz to -200 dBW/m/Hz.  This means the power
of the satellite emissions is 50-150 dB greater than the desired
signal.  See NSF Comments at 4.

560.  NSF Comments at 4-5.

561.  Int'l Radio Consultative Committee, Int'l Telecommunication
Union, Report 852-2, Characteristics of the Radio Astronomy
Service and Preferred Frequency Bands (1990).  Thermal emissions
come from "hot ionized and neutral gas . . . solid bodies, and
the universal microwave background," while non-thermal emissions
are "mainly synchrotron radiation from relativistic electrons
spiraling in a magnetic field, but including gyro-synchrotron and
electron-cyclotron maser emissions, as well as plasma emissions
resulting from the scattering of plasma waves."   Id., Section
2.1.

562.  Id. Section 2.3.

563.  See NSF Comments at 17-20.

564.  Occasionally, observations at frequencies as low as 1.5 MHz
are possible.  NSF Comments at 5.

565.  Id. at 13-14.

566.  Id. at 13.  Because they use the band extensively, the
Department of Defense believes that radio astronomy of the
322-328.6 MHz band could have only secondary status and would
require local coordination.  Pollack, supra note 379, at 7.

567.  NSF Comments at 14.  The Department of Defense believes
some of these bands may be difficult to coordinate in some areas. 
For example, expansion of the 4990-5000 MHz band would limit use
of existing troposcatter systems and airborne data links in this
spectrum.  Pollack, supra note 379, at 7.

568.  NSF Comments at 17-18.  The list is included in
Recommendation 314 of the CCIR.  See Radio Astronomy Frequencies,
supra note 555.

569.  NSF Comments at 18-19; Electronic mail from Andrew Clegg,
National Science Foundation, to Robin H. Haines, National
Telecommunications and Information Administration (Oct. 31, 1994)
(printed copy on file with NTIA) (clarifying the need for the
frequency bands).

570.  NSF Comments at 6.

571.  NASA Comments at 18.

572.  Letter from Tomas Gergely, Electromagnetic Spectrum
Manager, National Science Foundation, to William Gamble,
Chairman, Interdepartment Radio Advisory Committee ( IRAC Doc.
28393) (Aug. 6, 1993) (on file with NTIA).

573.  NSF Comments at 3.

574.  ITU Radio Regulations, supra note 133, art. 1, Section
3.34.

575.  Within the United States, the purpose of the amateur
service is to provide to the public a voluntary, non-commercial
radio service, particularly with respect to providing emergency
communications; contribute to the advancement of the art; advance
technical and communications skills; expand the national pool of
trained radio operators and technicians; and enhance
international goodwill through amateur radio communications. 47
C.F.R. Section 97.1.

576.  ARRL Comments at 5. Comments of American Radio Relay
League, Inc. to National Telecommunications and Information
Administration, U.S. Dep't of Commerce, NTIA Special Publication
94-27, Preliminary Spectrum Reallocation Report (1994) at 10
(updating the current number of licensed U.S. amateurs).

577.  The Amateur Radio Emergency Service (ARES) and the Radio
Amateur Civil Emergency Service (RACES) provide local and
regional communications support to state and local governments on
a coordinated basis.

578.  This figure represents growth for 1993.

579.  ARRL Comments at 5.

580.  ARRL Comments at 21.

581.  The alignment of the 7 MHz band is consistent with
proposals made by the United States at WARC-92.

582.  NTIA Manual, supra note 13, Section 6.1.1 at 6-14.

583.  Id.

584.  NIST Comments at 1.

585.  Id. at 3.

586.  Id.

587.  See NTIA Manual, supra note 13, Section 6.1.1 at 6-9.

588.  In the course of a 24-hour-per-day, year-round operation,
the National Meteorological Center (NMC) receives approximately
50,000 surface observation reports daily from land stations,
3,000 reports from ships, 4,100 upper air observations, and
3000-4000 reports from aircraft.  Office of the Federal
Coordinator for Meteorology, National Oceanic and Atmospheric
Administration, U.S. Dep't of Commerce, FCM P1-1992, Federal Plan
for Meteorological Services and Supporting Research A-4 (1992).

589.  Id. at 108.

590.  A radiosonde is generally a balloon-borne meteorological
instrument consisting of sensors coupled to a radio transmitter
and assembled in a light-weight box used to measure the ambient
temperature, relative humidity, and barometric pressure of the
air through which it rises.  Wind velocity and direction are
determined due to the changes of its position and direction.

591.  See Office of the Federal Coordinator for Meteorology,
Nat'l Oceanic and Atmospheric Admin., U.S. Dep't of Commerce,
FCM-R13-1990, Federal Meteorological Requirements 2000 at 96
(1990).

592.  Footnote US316 further states that operations in this
service are limited to Government NEXRAD systems where
accommodation in the 2700-2900 MHz band is not technically
practical and are subject to coordination with existing
authorized stations.  NTIA Manual, supra note 13, Section 4.1.3
at 4-112.

593.  National Telecommunications and Information Administration,
Doc. SPS-7861/2, NTIA Preliminary Assessment of Federal Aviation
Administration (FAA) Terminal Doppler Weather Radar, Stage 4, at
1-2 (Mar. 7, 1988).

594.  Wind profilers can measure wind speed and direction,
vertical velocity, intensity of turbulence, and key precipitation
parameters with resolutions between 100 and 1000 meters from
about 200 meters to 18 or more kilometers above the surface.  The
Wind Profiler is a vertically oriented ground-based pulsed radar
that utilizes scattering from irregularities in the index of
refraction in the atmosphere to measure wind parameters in three
dimensions.  By transmitting pulses on sequential beams (e.g.,
east, north, and vertical) and processing the return signal,
profiles of the wind can be obtained faster and cheaper than by
radiosondes.  Range gate and Doppler radar principles are applied
to deduce the wind parameters from signals received from each of
the beam positions.  By integrating the backscatter signal pulses
at one beam position over a suitably long period of time (i.e., 2
minutes), it is possible to operate with very low signal-to-noise
ratios (e.g., -25 to -30 dB).

595.  The 5350-5600 MHz band is allocated to the aeronautical
radionavigation, radiolocation, and radionavigation services. 
The meteorological radars operate on a non-conformance basis.

596.  NOAA Comments at 2.

597.  FAA Comments at 5.

598.  Id.

599.  NOAA Comments at 3.

600.  NTIA Manual, supra note 13, Section 4.1.2.

601.  Allocation status is shown in the Table as either primary,
permitted, or secondary.  Services or uses may be allocated under
other bases, such as non-interference, by footnotes to the Table.

602.  National Telecommunications and Information Administration,
U.S. Dep't of Commerce, NTIA Special Publication 91-23, U.S.
Spectrum Management Policy:  Agenda for the Future 55 (1991)
[hereinafter Spectrum Policy Study].

603.  Id. at 5.

604.  Id. at 84.

605.  See 47 C.F.R. Section 2.1.  Three other services are
defined, i.e., the radiocommunications service, safety service,
and special service, but are not contained as allocated radio
services in the National Table of Frequency Allocations.

606.  Spectrum Policy Study, supra note 7, 602 at 82-83.

607.  Southwestern Bell Comments at 28.  Southwestern Bell
believes that technical standards should be defined in such a way
as to encourage future technological evolution in the
provisioning of new telecommunications services.

608.  DOJ Comments at 6. 

609.  DOD Comments at 15.  DOD states that "As a spectrum sharing
issue, receivers built to a higher, FCC-mandated performance
criteria will facilitate the measures that will be required to
attain optimum frequency and spatial sharing."  Id.

610.  Alcatel Comments at 11. 

611.  ARINC Comments at 8.  ARINC states that aviation safety
communications are vital to the safety of life and property in
the air, and rely on channel discipline.  Such discipline would
not be possible in many interservice sharing situations.  Id.

612.  Amendment of the Commission's Rules Concerning Maritime
Communications, Notice of Proposed Rule Making and Notice of
Inquiry, PR Docket No. 92-257, 7 FCC Rcd 7863 (1992).

613.  DOE Comments at 11.  "The demands on the future use of the
spectrum resources in the United States, already the highest user
in the world, require additional sharing between Government and
non-Government entities . . . ."  Id.

614.  IEEE USA Comments at 3.

615.  Harris Comments at 5.

616.  NASA Comments at 3.  Examples of commercial science include
biochemical manufacturing, crystallizations in space, and outer
space mining activities.  Id.

617.  APCO Comments at 9.

618.  DOE Comments at 12.  DOE states that trunked mobile systems
is one area in which band sharing is both feasible and practical,
particularly to facilitate mutual aid ventures between Federal,
state and local governments.  Id.

619.  InterDigital Comments at 3.

620.  DOD Comments at 18 (suggesting a spectrum sharing users
group under the IRAC); InterDigital Reply Comments at 5
(suggesting a spectrum sharing panel).

621.  NTIA Organization Act, supra note 1.

622.  Cohen et al., supra note 34.

623.  NASA Comments at 13.

624.  Id. at 21.

625.  SCS Comments at 7.  But see GTE Comments at 2, 9 (stating
that "stealth-like" sharing is not technically feasible for high
capacity applications like PCS); Apple Comments at 5 (stating
that fixed service users could not be assured the mobile,
unlicensed PCS systems would not cause them interference).

626.  For example, the 4990-5000 MHz band is allocated as a
passive band for radio astronomy and space research.

627.  NSF Comments at 6. 

628.  Id. at 6-7.

629.  CORF Comments at 4.

630.  NSF Comments at 10

631.  Pulson Comments at 5.

632.  MSTV Comments at 11.

633.  Pollack, supra note 379, Attachment at 2.

634.  AMSAT Comments at 3.

635.  Alcatel Comments at 6.

636.  SBCA Comments at 20.

637.  Pollack, supra note 379, Attachment at 5.

638.  DOD Comments at 5.

639.  DOD Comments at 4.

640.  Only Pacific Telesis Group commented explicitly on
technologies.

641.  T.E. Bell, Technology Directions 1993, IEEE Spectrum, Jan.
1993, at 81.

642.  CDMA and other spread spectrum systems, for example, were
developed with vacuum tube technology.  R.A. Scholtz, The Origins
of Spread-Spectrum Communications, IEEE Transactions on
Communications, May 1982, at 822.

643.  NSF Comments at 22-23.

644.  NASA Comments at 35-36.

645.  Brian Santo, Making Waves at 100, IEEE Spectrum, May 1988,
at 58, 60; K.L. Smith, Victorian Microwaves, Wireless World,
Sept. 1979, at 93, 93-95.

646.  See, e.g., Pacific Telesis Comments at 19; Alcatel Comments
at 11.

647.  E.J. Dutton & F.K. Steele, NTIA Report 82-107, Bibliography
and Synopsis of Literature Concerned with Microwave and
Millimeter Wave Propagation Effects (1982); S.J. Roome,
Bibliography on Propagation Factors Affecting Microwave Links
Operating the 10 GHz to 30 GHz Frequency Range, IEEE Proceedings,
Feb. 1986, Part H at 50, 50-56.

648.  Figure 8-1 is based on International Radio Consultative
Committee, Int'l Telecommunication Union, Report 719-3,
Attenuation by Atmospheric Gases Section 1, Figure 1 (1990).

649.  K. Krishen, Future Trends in Antennas and Propagation for
the US Space Program, IEEE Antennas & Propagation Magazine, Feb.
1994, at 32.

650.  H.K. Kobayashi, Atmospheric Sciences Laboratory, White
Sands Missile Range, Technical Report ASL-TR-0049, Atmospheric
Effects on Millimeter Radio Waves 13, 15 (1989).

651.  National Aeronautics and Space Administration, ACTS
Propagation Experiments Preparations Are Under Way, ACTS
Quarterly, Feb. 1993, at 14.

652.  J. Haddon & E. Vilar, Scattering Induced Microwave
Scintillations from Clear Air and Rain on Earth Space Paths and
the Influence of Antenna Aperture, IEEE Transactions on Antennas
& Propagation, May 1986, at 646; D. Vanhenacker et al., The
Effects of Atmospheric Turbulence on Broadband Communication
Channels Above 10 GHz, SUPERCOM '92, IEEE Conference on
Communications, 1992, at 1064.

653.  D.G. Sweeney & C.W. Bostian, The Dynamics of Rain-Induced
Fades, IEEE Transactions on Antennas & Propagation, Mar. 1992, at
275.

654.  J.C. Cardoso et al., Microscale Diversity in Satellite
Communications, IEEE Transactions on Antennas & Propagation, June
1993, at 801; M.J. Willis, Fade counter-measures applied to
transmissions at 20/30 GHz, IEE Electronics & Communication
Journal, Apr. 1991, at 88.

655.  H.J. Liebe et al., Millimeter-Wave Attenuation and Delay
Rates Due to Fog/Cloud Conditions, IEEE Trans. on Antennas &
Propagation, Dec. 1989, at 1617; T. Oguchi, Electromagnetic Wave
Propagation and Scattering in Rain and Other Hydrometeors,
Proceedings of the IEEE, Sept. 1983, at 1029.

656.  K.C. Allen, National Telecommunications and Information
Administration, NTIA Report 83-132, Attenuation of Millimeter
Waves on Earth-Space Paths by Rain Clouds 4 (1983).  For a moist
cumulus rain cloud,  = 12.9 wf2 /(14000 + f2), where  = 
specific attenuation (dB/km/g/m) at 2o C, w = liquid water
content (g/m3), and f = frequency (GHz).

657.  D. Chakraborty et al., The Ka-Band Propagation Measurements
Campaign at JPL, IEEE Antennas & Propagation Magazine, Feb. 1993,
at 7.  The table also lists the effect and remedy for other
hydrometeors, depolarization, scintillation, and excess noise
emission.

658.  D.P. Haworth et al., Relationship Between Electricity and
Microwave Radio Propagation, Nature, 1977, at 703; Yasuyuki
Maekawa et al., Ice Depolarizations on Ka Band (20 GHz)
Satellite-to-ground Path and Correlation With Radar Observations,
Radio Science, May-June 1993, at 249.

659.  M.M. Khardly & A.S. Choi, A Simplified Approach to the
Evaluation of EM Wave Propagation Characteristics in Rain and
Melting Snow, IEEE Transactions on Antennas & Propagation, Feb.
1988, at 282.

660.  M. Kachmar, NSF Workshop on EM Readies Its Report,
Microwaves & RF, May 1986, at 35-40.  Difficulty in modeling the
non-symmetrical electromagnetic field of a microstrip line may
also be a factor.  See A.J. Baden Fuller, Microwaves 268-271
(1979).

661.  A. Boulouard et al., Microstrip Antenna Modeling, Microwave
& RF, Jan. 1993, at 44-45.

662.  P. Bhartia & I.J. Bahl, Millimeter Wave Engineering and
Applications 341 (1984).

663.  National Institute of Standards and Technology, U.S. Dep't
of Commerce, NISTIR 4583, Measurements for Competitiveness in
Electronics 160 (1993); J.S. Mayo, Materials for Information and
Communication, Scientific American, Oct. 1986, at 59-65.

664.  National Institute of Standards and Technology, supra note
663 at 161 (1993); C. Huang, MMIC's Move Into New Marketplaces,
Microwave & RF, Sept. 1992, at 136.

665.  S. Rynas, Silicon MMICs Add Low-Cost Power to Wireless
Systems, Microwave & RF, May 1992, at 199.

666.  J. Browne, Tubes Continue the Chase for Power, Gain and
Bandwidth, Microwaves & RF, Mar. 1990, at 152; W.R. House,
Electron Tubes Serving Ku-Band Space Communications, Via
Satellite, Feb. 1991, at 42-43 (discussing the advantages of
improved TWT's); J. Auboin & W.R. House, DBS Satellite Tubes, Via
Satellite, July 1993, at 48 (stating that overall efficiency of
high-power tubes was increased from 40-45 percent to 62 percent
in early 1992).

667.  Pacific Telesis Comments at 20.  Semiconductor cryogenics
may eventually be practical for at least base (fixed) stations.

668.  Cryogenic Test Characterizes GaAs MESFET Noise Performance,
Microwaves & RF, Mar. 1993, at 62.

669.  Id.

670.  Jack Browne, HEMT Devices Fuel 26-40 GHz GaAs MMIC
Amplifier, Microwaves & RF, Mar. 1993, at 149.

671.  S.F. Su et al., A Review on Classification of Optical
Switching Systems, IEEE Communications Magazine, May 1986, at 50.

672.  Kenneth Crisler & Allen Davidson, Impact of 90's Technology
on Spectrum Management, IEEE International Symposium of
Electromagnetic Compatibility, Aug. 1993, at 401.  Improvements
in semiconductor technology is traced to spectrum efficiency,
primarily in land mobile radio.

673.  Kazuo Tsubouchi, Application of Spread Spectrum
Communication and Its Devices, Electronics and Communications in
Japan, Part 1, May 1992, at 62.  This article discusses spreading
and despreading techniques and devices.

674.  Cohen et al., supra note 34.  

675.  Timothy G. Twohig, How digital radio affects trunked radio
systems, Mobile Radio Technology, July 1992, at 26.

676.  Fleet Call Comments at 4.

677.  Alcatel Comments at 12.  Alcatel considers the development
of 256QAM to be optimal at the present time with little room for
improvement.  See also B. Manz, Digital Radio Advances to the
Next Plateau, Microwaves & RF, Dec. 1988, at 59 (comparing high-
level and low-level QAM and other modulations).

678.  Alcatel Comment at 12; Manz, supra note 677 at 63.

679.  Manz, supra note 677 at 74-75.

680.  For a digital data rate of 1 kb/s, the information
bandwidth would be about twice this rate or 2 kHz.  Spreading the
signal over 1 MHz (a typical low value for existing spread-
spectrum systems) yields a ratio of 500:1.

681.  E.g., Motorola Comments at 28; NSF Comments at 23-24.

682.  Motorola Comments at 28.

683.  GTE Comments, Attachment A at 9-10.

684.  See, e.g., SCS Comments at 2; Pinpoint Comments at 2.

685.  Pinpoint Comments at 1-4.  For another commercially
developed burst-signal CDMA vehicle tracking system, see B.
Xenakis & A. Evans, Vehicle Locator Uses Spread-Spectrum
Technology, RF Design, Oct. 1992, at 58-65.

686.    P.M. Schumacher, Understand the Basics of Spread-Spectrum
Communications, Microwaves & RF, May 1993, at 149.  "The number
of CDMA users of a communication channel . . . is directly
related to the process gain" wherein, process gain is defined as
the channel capacity divided by information volume.  Id.

687.  E. Worthman, The Spreading of Spectrum, Communications,
Jan. 1991, at 29.

688.  .  See, e.g., Fleet Call Comments at 4; Motorola Comments
at 7; Ericsson Comments at 3.  The merits of TDMA versus CDMA for
next-generation mobile communications (including cellular and PC
systems) was reviewed in Gen Marubayashi, Recent Research and
Development Activities on Spread Spectrum Communication Systems,
Electronics and Communications in Japan, Part 1, May 1992, at 54.

689.  DOD comments at 10; Pulson Comments, Exhibit C at 3.

690.    Bruce D. Nordwall, Swedish-Developed Radar to Penetrate
Foliage, Ground, Aviation Week & Space Technology, Jan. 18, 1993,
at 52.

691.  Pulson Comments, Exhibit C at 3.  The pulse is termed a
Gaussian monocycle because it is the first derivative of the
Gaussian function as opposed to one gated cycle of a sine wave.

692.  Pulson Comments at 4, 5.  A Modulating signal is made to
change the pulse repetition interval in proportion to its
strength.

693.  D. Lamensdorf & L. Susman, Baseband-Pulse-Antenna
Techniques, IEEE Antennas and Propagation Magazine, Feb. 1994, at
20.  According to the authors and others, frequency-domain
methods commonly used for narrow-band analysis are "questionable
for an instantaneous wide-band excitation.  Time-domain and/or
wide-band analyses can provide more insight and more effective
terminology."  Id. at 29.

694.  See, e.g., SBCA Comments at 15-16; GTE Comments, Attachment
5 at 2.  

695.  IEEE USA Comments at 2.

696.  J.D. Lakin, Dueling Digital Video Compression Products, Via
Satellite, Nov. 1991, at 60.

697.  Speights et al., supra note 11.

698.  See, e.g., DOD Comments at 14.  Trunking "is an excellent
example of the application of technology to substantially raise
the overall efficiency of spectral use."  Id. at 14.

699.  Twohig, supra note 675, at 26-27.

700.  Paul Nauman & Steve Norwood, A New Dimension in Trunking,
Global Communications, Nov.-Dec. 1992, at 25.

701.  Southwestern Bell Comments at 22, 23.

702.  The near-far problem within an all spread-spectrum system
is also an area of active research.  See, e.g., Yu-Dong Yao et
al., Near/Far Effects on Packet Radio Networks With Direct-
Sequence Spread-Spectrum Signaling, IEEE Pacific Rim Conference
on Communications, Computers & Signal Processing, June 1-2, 1989,
at 122.

703.  SCS Comments, Appendix C at 4-5.  This design developed for
PCS devices is called an "adaptive power control" (APC).  In
addition, SCS has patented a notch filter for excluding a spread
spectrum signal from designated narrowband frequencies.

704.  K.S. Gilhousen, Mobile Power Control for CDMA,
Communications Magazine, Jan. 1992, at 36.  The closed loop
signal-to-noise ratio (SNR) received at a cell is monitored and a
power command sent every 1.25 msec (800 b/s) to the mobile unit. 
The developer QUALCOM states that with a 24 dB dynamic range and
a 800 b/s bit stream, the loop can keep up with the fast
multipath changes induced by conventional Rayleigh fades.  A
coarser open loop control adjusts for different cell sizes and
cell-to-cell handoffs.

705.  J. Shapira, Channel Characteristics For Land Cellular
Radio, and Their Systems Implications, IEEE Antennas &
Propagation Magazine, Aug. 1992, at 7.

706.  Theodore S. Rappaport, Wireless Personal Communications: 
Trends and Challenges, IEEE Antennas & Propagation Magazine, Oct.
1991, at 27.

707.  DOD Comments at 14; DOJ Comments at 5.

708.  DOJ Comments at 5.  Chirp is the periodic linear sweeping
of the HF band for a fixed point-to-point HF link to establish
the maximum usable frequency (MUF) for the path.

709.  See, e.g., A.P. Clark & S. Hariharan, Efficient Estimators
for an HF Radio Link, IEEE Transactions on Communications, Aug.
1990, at 1173; D. Mark Haines & Bert Weijers,  Embedded HF
Channel Probes/Sounders, IEEE Proceedings of MILCOM'85, Oct.
20-23, 1985, at 12.1.1.

710.  Southwestern Bell Comments at 16.

711.   Southwestern Bell Comments at 23.

712.  IEEE USA Comments at 1, 2.  The Technologies part of the
comments was prepared by the IEEE Antennas & Propagation Society. 
Some advanced antenna technologies mentioned were electronic beam
steering (as opposed to mechanical motion), distributed power
sources in each array element rather than one source for the
array, and shaped-beam patterns permitting frequency reuse (i.e.,
orthogonal polarity isolation).  NASA Comments at 38.  Antennas
are mentioned by NASA with respect to beam-hoppers for the ACTS
satellite and phased-array antennas for mobile earth stations.

713.  James R. James, What's New in Antennas?, IEEE Antennas &
Propagation Magazine, Feb. 1990, at 6, 11.

714.  See, e.g., Wataru Chujo et al., Conformal Array Antenna for
Mobile Satellite Communications, Electronics and Communications
in Japan, Part 1, Aug. 1992, at 97.  A conformal array is one
that is aerodynamically shaped to fit on a moving body.

715.  IEEE Dictionary, supra note 494, at 53.

716.  IEEE USA Comments at 1-2; SBCA Comments at 19; Bell
Atlantic Comments at 9-10; GTE Comments, Attachment A at 9; NASA
Comments at 38; Pacific Telesis Comments at 25. 

717.  Irving S. Reed, Brief History of Adaptive Arrays,
Proceedings MILCOM '85, Oct. 20-23, 1985, at 28.1.1.

718.  See, e.g., J.P. Daniel et al., Research on Planar Antennas
and Arrays:  "Structures Rayonnantes", IEEE Antennas &
Propagation Magazine, Feb. 1993, at 14 (discussing integration of
planar arrays and MMIC design).

719.  P.S. Hall & S.J. Vetterlein, Review of Radio Frequency
Beamforming Techniques For Scanned and Multiple Beam Antennas,
IEE Proceedings-H, Oct. 1990, at 293, 301.

720.  P.V. Brennan, Low Cost Phased Array Antenna for Land-Mobile
Satcom Applications, IEE Proceedings-H, April 1991, at 131.  This
low-cost design is an example of a high-gain electronically
steerable array that may replace conventional low-gain vehicular
whip antennas.

721.  M.T. Moore & P. Miller, Microwave IC Control Components for
Phased-Array Antennas,  IEE Electronics & Communication
Engineering Journal, June 1992, at 123.

722.  Ovidio M. Bucci et al., Reconfigurable Arrays by Phase-Only
Control, IEEE Transactions on Antennas & Propagation, July 1991,
at 919.  This paper points to the possible attainment of
practical phase-only control in a few years.

723.  Future Directions of Satellite Communications Applications
and Technologies, J.W. Bagwell, Institute for Electrical,
Aerospace, and Electronic Engineers & George Washington
University, National Telesystem Conference, Washington, D.C. (May
19-20, 1993).

724.  Richard M. Davis et al., A Scanning Reflector Using an Off-
Axis Space-Fed Phased-Array Feed,  IEEE Transactions on Antennas
& Propagation, March 1991, at 391.

725.  V.H. Rumsey, Frequency Independent Antennas, IRE (IEEE)
National Convention Record, Part 1, 1957, at 114.  A broadband
antenna is taken to have a highest-to-lowest operating frequency
ratio of at least two to one.

726.  See, e.g., John Huang & Arthur C. Densmore, Microstrip Yagi
Array Antenna for Mobile Satellite Vehicle Application, IEEE
Transactions on Antennas & Propagation, July 1991, at 1924; John
Huang, Microstrip Yagi for mobile satellite service, Electronics
World, Feb. 1992, at 171.

727.  R.H.T. Bates & G.A. Burrell, Towards Faithful Radio
Transmission of Very Wide Bandwidth Signals, IEEE Transactions on
Antennas & Propagation, Nov. 1972, at 684.  A phase-corrected
conical monopole is proposed as a solution to the design of an
omnidirectional antenna focussed in the vertical plane.  James G.
Maloney & Glen S. Smith, Optimization of a Conical Antenna for
Pulse Radiation: An Efficient Design Using Resistive Loading,
IEEE Transactions on Antennas & Propagation, July 1993, at 940.

728.  Albert K.Y. Lai et al., A Novel Antenna for Ultra-Wide-Band
Applications, IEEE Transactions on Antennas & Propagation, July
1992, at 755.  This design employs a wideband slotline
transmission guide opening into bowtie antenna whose arms are
folded into a horn with a rolled edge. 

729.  Yasuto Mushiake, Self-Complementary Antennas, IEEE Antennas
& Propagation Magazine, Dec. 1992, at 23.

730.  See, e.g., IEEE USA Comments at 2 (pertaining to indoor
communication); DOE Comments at 9, 10 (multipath, channel
coherence, and other specifics); SBCA Comments at 11 (wide
coherent bandwidths).

731.  P. Knight & J.A.W. Robson, Empirical Formula For Groundwave
Field-Strength Calculation, Electronics Letters, Aug. 30, 1984,
at 740; International Radio Consultative Committee, International
Telecommunication Union, Recommendation 368-7, Groundwave
Propagation Curves for Frequencies Between 10 kHz & 30 MHz, at 48
(1992).

732.  M.H. Reilly et al., Updated climatological model
predictions of ionospheric and HF propagation parameters, Radio
Science, July-Aug. 1991, at 1017.

733.  R.B. Rose, PROPHET, an emerging HF technology, in Effect of
the Ionosphere on Radiowave Systems (J. Goodman ed., 1981).

734.  See, e.g., J.W. Wright, Ionogram inversion for a tilted
ionosphere, Radio Science, Nov.-Dec. 1990, at 1175; D.M Haines &
B. Weijers, Embedded HF Channel Probes/Sounders, Proceedings of
the IEEE MILCOM'85 Conference, Oct. 20-23, 1985, at 12.1.5.

735.  DOD Comments at 14; DOJ Comments at 5.

736.  National Telecommunications and Information Administration,
U.S. Dep't of Commerce, Microcomputer Spectrum Analysis Models
(MSAM), NTIS Order No. PB 94-501145 (1994).  The MSAM package
contains other programs useful for spectrum management. 
International Telecommunication Union, Catalogue of Software for
Radio Spectrum Management (1993).

737.  G.Y. Delise et al., Propagation Loss Prediction:  A
Comparative Study with Application to the Mobile Radio Channel,
IEEE Transactions on Vehicular Technology, May 1985, at 86.  In
comparing mobile models, the authors state that there is general
agreement among methods, but note that there is no one complete
model; however, existing ones can be complemented by the addition
of missing parameters.

738.  Joseph Shapira, Toward a Generalized Characterization of
the Mobile Channel, IEEE Antennas & Propagation Magazine, Aug.
1992, at 16.

739.  Manfred Lebherz et al., A Versatile Wave Propagation Model
for the VHF/UHF Range Considering Three-Dimensional Terrain, IEEE
Transactions on Antennas & Propagation,  Oct. 1992, at 1121.

740.  See DOJ Comments at 5; IEEE USA Comments at 2.

741.  See, e.g., Herbert K. Kobayashi & Gary Patrick, National
Telecommunications and Information Administration, NTIA Technical
Memorandum 92-155, Preliminary Building Attenuation Model (1992)
(featuring a literature review and application graphs); Raymond
C.V. Macario, How Building Penetration Loss Varies With
Frequency, IEEE Vehicular Technology Society News, Nov. 1993, at
26 (encompassing  the 30-3000 MHz band); Wolfhard J. Vogel &
Geoffrey W. Torrence, Propagation Measurements for Satellite
Radio Reception Inside Buildings, IEEE Transactions on Antennas &
Propagation, July 1993, at 954 (featuring original measurements
from 700-1800 MHz.

742.  D. Molkdar, Review on radio propagation into and within
buildings, IEE Proceedings-H, Feb. 1991, at 61; J. Lafortune & M.
Lecours, Measurement and Modeling of Propagation Losses in a
Building at 900 MHz, IEEE Transactions on Vehicular Technology,
May 1990, at 101-108; S.Y. Seidel & T.S. Rappaport, 914 MHz Path
Loss Prediction Models for Indoor Wireless Communications in
Multifloored Buildings, IEEE Transactions on Antennas &
Propagation, Feb. 1992, at 207; D.M.J. Devasirvatham, Time Delay
Spread and Signal Level Measurements of 850 MHz Radio Waves in
Building Environments, IEEE Transactions on Antennas &
Propagation, Nov. 1986, at 1300.

743.  Homayoun Hashemi, The Indoor Radio Propagation Channel,
Proceedings of the IEEE, July 1993, at 943.  The author alludes
to the heuristic nature of the models he has reviewed in his
recommendations for future work.

744.  Theodore S. Rappaport, Wireless Personal Communications: 
Trends and Challenges, IEEE Antennas & Propagation Magazine, Oct.
1991, at 19.

745.  Peter F. Driessen, Development of a Propagation Model in
the 20-60 GHz Band for Wireless Indoor Communications, IEEE
Pacific Rim Conference on Communications, Computers and Signal
Processing, May 9-10, 1991, at 59.

746.  See, e.g., Evan J. Dutton et al, An Improved Model for
Earth-space Microwave Attenuation Distribution Prediction, Radio
Science, Nov.-Dec. 1982, at 1360 (presenting a model developed by
ITS requiring specific meteorological inputs); International
Radio Consultative Committee, International Telecommunication
Union, Handbook on Satellite Communications, Annex I Propagation
551 (1988) (showing a widely-used model incorporating global
climatological data).

747.  S.K. Johnson, ISDN Experimenters Meet, ACTS Quarterly, May
1993, at 12. 

748.  D. Vanhoenacker et al., The Effects of Atmospheric
Turbulence on Broadband Communication Channels Above 10 GHz,
SUPERCOM'92, IEEE Conference on Communications, 1992, at 1064;
L.J. Ippolito, Propagation Considerations for Emerging Satellite
Communications Applications, Proceedings of the IEEE, June 1993,
at 923; W.L. Stutzman, Prolog to The Special Section on
Propagation Effects on Satellite Communication Links, Proceedings
of the IEEE, June 1993, at 830.

749.  See, e.g., International Radio Consultative Committee,
International Telecommunications Union, RPN Series, Propagation
in Non-Ionized Media, Recommendations 214 (1992).

750.  J.W. Rush, Microwave Path Availability at 19 and 23 GHz,
Microwave Journal, Aug. 1992, at 165.

751.  Progress in Atmospheric Propagation Modeling at Frequencies
Below 1000 GHz, Hans J. Liebe et al., 1992 Battlefield
Atmospherics Conference, El Paso, Tex. (Dec. 1992); Hans J.
Liebe, An Atmospheric Millimeter-Wave Propagation Model,
International Journal Infrared & Millimeter Waves, 1989, at 631
(presenting a detailed  model for non-precipitation conditions
available in IBM PC-compatible software).

752.  NSF Comments at 24.  See also NASA Comments at 45.

753.  See Bell Atlantic Comments at 8 (showing a preference for a
4-year cycle).

754.  NSF Comments at 25.  But see NASA Comments at 45 (giving
advantages and disadvantages of having a permanent chair).

755.  IEEE USA Comments at 5.

756.  Harris Comments at 8.

757.  Motorola Comments at 31.

758.  Hubbard Comments at 7; Digital Microwave Comments at 7.

759.  IEEE USA Comments at 5.

760.  Convention of the Additional Plenipotentiary Conference,
Dec. 22,1992, Int'l Telecommunication Union, art. 30.

761.  Bell Atlantic Comments at 17.  See also NASA Comments at
43; NSF Comments at 24-25; AT&T Comments at 8.

762.  See IEEE USA Comments at 5.  See also AT&T Comments at 7.

763.  NASA Comments at 43.

Return to Report Table of Contents.

Proceed to Appendix - List of Commenters.