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  1. #1
    Andrew Shepherd
    Guest
    The FCC is seeking comment on Cingular-AT&TWS' request for waiver of
    the Cellular cross-interest rule which prohibits a Cellular licensee
    from controlling greater than 5% attributable interest in the opposite
    license in the same Rural Service Area (RSA). Grant of the waiver
    will be required for AT&TWS to transfer Cellular license control to
    Cingular in the eleven RSAs in which AT&TWS' A-side Cellular
    Geographic Service Area (CGSA) & SBC or BellSouth's B-side CGSA
    overlap.

    Unfortunately, the cross-interest rule has already sunset for
    Metropolitan Statistical Areas (MSAs). A formal waiver is not
    required, thus the FCC is not seeking comment at this time on
    Cingular-AT&TWS aggregation of both Cellular licenses in markets like
    Dallas, Miami, or Oklahoma City, et al. However, despite the sunset,
    subsequent FCC &/or DoJ scrutiny of the merger is unlikely to give
    Cingular-AT&TWS a free pass in the coincident MSAs either.

    If you feel grant of the waiver for the RSAs would not be in the
    public good, if you oppose any precedent-setting dissolution of the
    Cellular duopolies - on anti-monopolistic competitive grounds, for
    public safety reasons, for further dwindling AMPS capacity concerns,
    etc. - I encourage you to personally submit a petition to deny.

    The Cingular-AT&TWS merger should be allowed to proceed to
    consummation but not w/o modest & reasonable concessions that would
    pose no direct harm to the synergies of the merger. The
    electromagnetic spectrum belongs to the people. Wireless companies
    are only licensees of that public property. Let the voice of public
    interest - particularly that of the wireless community - be heard loud
    & clear.

    Further background & instructions for submitting comment can be found
    in the following FCC document:

    http://hraunfoss.fcc.gov/edocs_publi...A-04-932A1.pdf

    Andrew
    --
    Andrew Shepherd
    [email protected]
    [email protected]
    http://www.ku.edu/home/cinema/



    See More: FCC seeks comment on Cingular-AT&TWS waiver




  2. #2
    N9WOS
    Guest

    Re: FCC seeks comment on Cingular-AT&TWS waiver

    > If you feel grant of the waiver for the RSAs would not be in the
    > public good, if you oppose any precedent-setting dissolution of the
    > Cellular duopolies - on anti-monopolistic competitive grounds, for
    > public safety reasons, for further dwindling AMPS capacity concerns,
    > etc. - I encourage you to personally submit a petition to deny.
    >
    > The Cingular-AT&TWS merger should be allowed to proceed to
    > consummation but not w/o modest & reasonable concessions that would
    > pose no direct harm to the synergies of the merger. The
    > electromagnetic spectrum belongs to the people. Wireless companies
    > are only licensees of that public property. Let the voice of public
    > interest - particularly that of the wireless community - be heard loud
    > & clear.


    My own opinion, based on the public safety, and AMPS capacity concerns,
    is that I support cingular getting both licenses because of them.

    On the pure spectrum issue, I think they should be treated the same as if
    they
    was two PCS bands.
    (ie) There is no current spectrum cap to worry about.

    There is good competition in those areas by PCS providers, so
    there is no monopoly worries.
    Florida is a well covered area by a number of companies.

    But on the AMPS concerns,
    The main area of impact will be on the remaining analog only phones.
    Verizon (a possible buyer) no longer supports credit card roaming
    by unactivated phone on their network, and will no longer activate any
    type of analog only phone on their network, under any plan.
    Most other possible buyers will not activate any analog only phone on their
    network.
    So the cellular AMPS capacity is of no real concern to them.
    And is, to some degree, a burden that they would have to support.

    Cingular still allows activation of analog only phones, to some degree.
    That being their prepaid service.
    And they have a complete and open credit card, and collect calling
    system for unsupported roamers, and any unactivated phone, analog or
    otherwise.
    So them having both bands will give more options to those types of users.
    But as far as the other potential buyers go, the AMPS capability will be of
    no real use.
    It would basically be giving the AMPS capable bands to the only company
    in those areas that still supports any new working service for analog only
    phones.
    That would be a good thing.

    The only other note, Alltel still will activate analog phones in some cases.
    But in most cases, an owner of an analog phone will get no where with them.

    IF the bands are sold, Alltel should be given first shot at the.
    But beyond that, cingular should not be forced to divest of them.





  3. #3
    N9WOS
    Guest

    Re: FCC seeks comment on Cingular-AT&TWS waiver

    > On the pure spectrum issue, I think they should be treated the same as if
    > they was two PCS bands.
    > (ie) There is no current spectrum cap to worry about.
    >
    > There is good competition in those areas by PCS providers, so
    > there is no monopoly worries.
    > Florida is a well covered area by a number of companies.


    And another note,
    In the MSAs and even some of the RSAs in question,
    the network for both cingular, and AT&T,
    are near full capacity, if not down right oversold.

    It would be stupid, if not down right ludicrous to take
    one of the two bands away from them, and tell them
    they have to support the customers from both companies.

    The customers would suffer horribly from the
    service of the one system that has enough users for two systems.






  4. #4
    XFF
    Guest

    Re: FCC seeks comment on Cingular-AT&TWS waiver

    "N9WOS" <[email protected]> wrote in message news:<[email protected]>...

    > There is good competition in those areas by PCS providers, so
    > there is no monopoly worries.


    That is definitely not true for the overlapping RSAs in Texas.
    Specifically, TX-18, TX-19, and TX-20 RSAs have no usable PCS service
    aside from the Interstate corridors covered by SPCS, VZW, and
    T-Mobile. There are huge areas in those RSAs that have no PCS
    coverage, in fact there are areas that barely have cellular coverage.
    The same is true for the portions of OK-3 and TX-11 RSAs that are
    overlapping. Florida's east coast is probably much better covered by
    PCS providers, so I could see your argument to hold validity there.



  5. #5
    N9WOS
    Guest

    Re: FCC seeks comment on Cingular-AT&TWS waiver


    > That is definitely not true for the overlapping RSAs in Texas.
    > Specifically, TX-18, TX-19, and TX-20 RSAs have no usable PCS service
    > aside from the Interstate corridors covered by SPCS, VZW, and
    > T-Mobile. There are huge areas in those RSAs that have no PCS
    > coverage, in fact there are areas that barely have cellular coverage.


    You don't want to confuse area covered and population covered.
    The FCC considers a service area as properly covered when
    the majority of the population is within the covered area.
    If 90% of the population is concentrated in 10% of the land area,
    you just have to cover 10% of the land area, and you have an easy majority.

    If the majority of the population live in those corridors, then the FCC
    will consider that those companies are adequately serving that area.

    I don't know about Oklahoma, and Texas at this point,
    I will take the time to look over them in a minute,
    but with the coverage that the sprint, verizon, and Nextel claim in Florida,
    any one of them easily cover the majority of the population in the Florida
    RSA's





  6. #6
    cledus
    Guest

    Re: FCC seeks comment on Cingular-AT&TWS waiver

    What good will all that AMPS spectrum do for you when AMPS phones have
    essential been phased out? It's doubtful any other carrier can make a
    profit trying to sell the old technology. Expecting some charitable org to
    step in and offer an obsolete service to people with old existing phones
    seems unlikely to me.


    "Andrew Shepherd" <[email protected]> wrote in message
    news:[email protected]
    > The FCC is seeking comment on Cingular-AT&TWS' request for waiver of
    > the Cellular cross-interest rule which prohibits a Cellular licensee
    > from controlling greater than 5% attributable interest in the opposite
    > license in the same Rural Service Area (RSA). Grant of the waiver
    > will be required for AT&TWS to transfer Cellular license control to
    > Cingular in the eleven RSAs in which AT&TWS' A-side Cellular
    > Geographic Service Area (CGSA) & SBC or BellSouth's B-side CGSA
    > overlap.
    >
    > Unfortunately, the cross-interest rule has already sunset for
    > Metropolitan Statistical Areas (MSAs). A formal waiver is not
    > required, thus the FCC is not seeking comment at this time on
    > Cingular-AT&TWS aggregation of both Cellular licenses in markets like
    > Dallas, Miami, or Oklahoma City, et al. However, despite the sunset,
    > subsequent FCC &/or DoJ scrutiny of the merger is unlikely to give
    > Cingular-AT&TWS a free pass in the coincident MSAs either.
    >
    > If you feel grant of the waiver for the RSAs would not be in the
    > public good, if you oppose any precedent-setting dissolution of the
    > Cellular duopolies - on anti-monopolistic competitive grounds, for
    > public safety reasons, for further dwindling AMPS capacity concerns,
    > etc. - I encourage you to personally submit a petition to deny.
    >
    > The Cingular-AT&TWS merger should be allowed to proceed to
    > consummation but not w/o modest & reasonable concessions that would
    > pose no direct harm to the synergies of the merger. The
    > electromagnetic spectrum belongs to the people. Wireless companies
    > are only licensees of that public property. Let the voice of public
    > interest - particularly that of the wireless community - be heard loud
    > & clear.
    >
    > Further background & instructions for submitting comment can be found
    > in the following FCC document:
    >
    > http://hraunfoss.fcc.gov/edocs_publi...A-04-932A1.pdf
    >
    > Andrew
    > --
    > Andrew Shepherd
    > [email protected]
    > [email protected]
    > http://www.ku.edu/home/cinema/






  7. #7
    N9WOS
    Guest

    Re: FCC seeks comment on Cingular-AT&TWS waiver

    > I don't know about Oklahoma, and Texas at this point,
    > I will take the time to look over them in a minute,
    > but with the coverage that the sprint, verizon, and Nextel claim in

    Florida,
    > any one of them easily cover the majority of the population in the Florida
    > RSA's


    After looking at those areas, I only see one service area that
    is kinda hanging out in the dry.
    That is the service area around Lufkin Texas.
    The only other provider that has any measure of
    coverage in that area is T mobile.

    All the other providers (verizon, sprint.... +others) have licenses, but
    they have never took the time to put any coverage down.
    ATT has moderate coverage in the top part,
    cingular shows the area as having relatively solid coverage.

    In and of it's self, the ATT coverage in that RSA doesn't really
    qualify as adequate coverage by it's self.
    If someone bought it, they wouldn't be buying much.
    And the buyer would have to change it over to CDMA,
    unless T mobile bought it, which is not going to happen.

    In my opinion.
    The other carriers would get better coverage by putting the money
    into the bands they already own in that RSA, not buying more to take care
    of.
    They would basically be buying a band with no equipment
    that is really useable on their network.
    That would be in addition to the band they already own
    that has no operating equipment.
    And they would get no new customers from the acquisition.

    Yes, a few towers, but with the 30 mill+ that it will take to get the RSA,
    you could build enough towers to totally cover the area with a PCS system.
    So selling that RSA would not be in the best interest of the users.
    tell the other providers to take any potential bid money and
    apply it to the bands they already own in that area.
    The users would be far better off.

    There is a reason CDMA providers normal don't buy out TDMA providers.
    (or vice versa)
    It is a waste of money.
    If they already own spectrum there, then it is a total waste of money.





  8. #8
    Steven J Sobol
    Guest

    Re: FCC seeks comment on Cingular-AT&TWS waiver

    In alt.cellular.sprintpcs Andrew Shepherd <[email protected]> wrote:
    > The FCC is seeking comment on Cingular-AT&TWS' request for waiver of
    > the Cellular cross-interest rule which prohibits a Cellular licensee
    > from controlling greater than 5% attributable interest in the opposite
    > license in the same Rural Service Area (RSA).


    Are they going to build out in those rural areas, something most larger
    carriers refuse to do? If they're going to actually build a network out there,
    I'd be 1000% in favor of waiving the rule.

    --
    JustThe.net Internet & New Media Services, Apple Valley, CA PGP: 0xE3AE35ED
    Steven J. Sobol, Geek In Charge / 888.480.4NET (4638) / [email protected]
    Domain Names, $9.95/yr, 24x7 service: http://DomainNames.JustThe.net/
    "someone once called me a sofa, but i didn't feel compelled to rush out and buy
    slip covers." -adam brower * Hiroshima '45, Chernobyl '86, Windows 98/2000/2003



  9. #9
    N9WOS
    Guest

    Re: FCC seeks comment on Cingular-AT&TWS waiver

    > Are they going to build out in those rural areas, something most larger
    > carriers refuse to do? If they're going to actually build a network out

    there,
    > I'd be 1000% in favor of waiving the rule.


    Good idea!!!!!!!!!

    Stipulation on them keeping both bands.
    .......................................................
    If they build out both bands to reasonably cover ALL the
    service area within the RSAs in which they own both
    cellular bands, they get to keep both bands, by default.





  10. #10
    XFF
    Guest

    Re: FCC seeks comment on Cingular-AT&TWS waiver

    "N9WOS" <[email protected]> wrote in message news:<[email protected]>...

    > And another note,
    > In the MSAs and even some of the RSAs in question,
    > the network for both cingular, and AT&T,
    > are near full capacity, if not down right oversold.
    >
    > It would be stupid, if not down right ludicrous to take
    > one of the two bands away from them, and tell them
    > they have to support the customers from both companies.
    >
    > The customers would suffer horribly from the
    > service of the one system that has enough users for two systems.


    Clearly, if one of the two licenses would have to be divested, the
    network infrastructure, stores, customers, and all other associated
    assets would be divested along with it.

    The same thing happened when the Airtouch/BAM/GTE merger forced the
    divestiture of certain markets. They didn't just sell the licenses,
    but all associated assets, including customers.



  11. #11
    N9WOS
    Guest

    Re: FCC seeks comment on Cingular-AT&TWS waiver

    > Clearly, if one of the two licenses would have to be divested, the
    > network infrastructure,


    Network infrastructure will about be worthless to most potential buyers.
    The tower it's self will be the only useable thing at the cell sites.
    The equipment will have to be totally replaced on the change over to CDMA.

    > stores,


    Not much to talk about in that type of area.
    Something that will be up for sale anyways.

    >customers,


    Which each and every one will have to have a new handset for cdma.
    Either the company buys each one a new handset for free, no contract,
    or the company forces them to sign a new contract for a new phone.
    If they do the latter, I don't think any of the customers will hang around
    for long.
    They will keep their old phone and go to T mobile or Cingular

    >and all other associated
    > assets would be divested along with it.


    Most of the other assets will be worthless to a CDMA carrier.
    They will be starting from square one, if they got one of the RSAs.
    There is not enough customers to justify keeping TDMA/GSM for a while,
    and there will be no customers left to talk about after they change to CDMA.

    > The same thing happened when the Airtouch/BAM/GTE merger forced the
    > divestiture of certain markets. They didn't just sell the licenses,
    > but all associated assets, including customers.


    The technology divide wasn't nearly as large as it is today.
    Today, the systems are almost totally incompatible.
    If there was other 800Mhz TDMA/GSM carriers around,
    then there would be basses for a divesture, but there is not.

    And another thing, ATT uses 1900Mhz GSM and 800Mhz TDMA/AMPS.
    The only customers that could even be argued to be customers of the 800Mhz
    block that will be divested is the older TDMA/AMPS customers.
    All the GSM users will go with the PCS block that will go to cingular.
    There will be no customers worth talking about that can be connected to
    the licenses.

    And on the towers that have both PCS and cell antennas.......
    Will they go to cingular because they go with the PCS band?
    Or will they go with the divesture, because they are part of the cell band?

    It is not as easy as it was with the air touch stuff.

    In the end, the only thing the company would really be buying is the
    spectrum.
    And they already have spectrum which they are not using, so they are buying
    nothing.
    All other assets are of nominal worth, or rendered worthless.





  12. #12
    N9WOS
    Guest

    Re: FCC seeks comment on Cingular-AT&TWS waiver

    > The technology divide wasn't nearly as large as it is today.
    > Today, the systems are almost totally incompatible.
    > If there was other 800Mhz TDMA/GSM carriers around,
    > then there would be basses for a divesture, but there is not.


    Well....... now that I think about it.... there is two
    Dobson cellular systems, for the Lufkin Texas.
    And US cellular for the RSA's around Dallas.
    That is the only carriers that could make use of that system "as is".





  13. #13
    Andrew Shepherd
    Guest

    Re: FCC seeks comment on Cingular-AT&TWS waiver

    "N9WOS" <[email protected]> wrote in message news:<[email protected]>...
    >
    > My own opinion, based on the public safety, and AMPS capacity concerns,
    > is that I support cingular getting both licenses because of them.
    >
    > On the pure spectrum issue, I think they should be treated the same as if
    > they
    > was two PCS bands.
    > (ie) There is no current spectrum cap to worry about.


    Indeed, the CMRS spectrum cap was raised to a consistent 55 MHz, then
    sunset entirely over a year ago on January 1, 2003. However, that is
    not to say that it is now open-season on spectrum accumulation.
    Quoted below is language from the FCC WTB's web site:

    "Instead of the bright-line rule limiting the amount of spectrum to
    preserve competition, the Commission opted going forward to analyze
    the competitive effects of transactions involving mobile telephony
    service providers on a case-by-case basis."

    To analogize, please show me any market where but one licensee
    controls 100% of all PCS spectrum - in parallel to your assertion that
    Cingular-AT&TWS should be able to retain both Cellular licenses in the
    affected RSAs - and I will completely agree w/ your contention. If
    the percentage comparison is not fair, show me a market where one
    licensee has managed to aggregate PCS spectrum totaling 50 MHz or
    more. On the latter count, you might be able to locate a few markets
    where one primary carrier plus its affiliates (read: AT&TWS) has
    assembled 50 MHz, 55 MHz, or even perhaps 65 MHz, but those markets
    are very few & far between, almost inevitably a combination of
    Cellular plus PCS spectrum. Allowing one licensee total control of
    all Cellular or all PCS spectrum in any given market would set a
    dangerous hegemonic precedent.

    To address Cellular specifically, Cellular licensees greedily want to
    have their cake & eat it too. They want the more laissez faire
    regulatory oversight like that of the PCS band as well as the superior
    propagation characteristics of 800/850 MHz spectrum. But the latter
    point in conjunction w/ the not-yet-sunset AMPS mandate and the two
    decade buildout legacy undeniably sets Cellular apart from PCS,
    positions Cellular in a special responsibility toward public service,
    and places the greater good ahead of Cellular's desires for further
    deregulation.

    > Cingular still allows activation of analog only phones, to some degree.
    > That being their prepaid service.
    > And they have a complete and open credit card, and collect calling
    > system for unsupported roamers, and any unactivated phone, analog or
    > otherwise.
    > So them having both bands will give more options to those types of users.
    > But as far as the other potential buyers go, the AMPS capability will be of
    > no real use.
    > It would basically be giving the AMPS capable bands to the only company
    > in those areas that still supports any new working service for analog only
    > phones.
    > That would be a good thing.


    Cingular has disclosed in its own regulatory filings that it typically
    maintains only six AMPS channels per sector in an N=4*3
    frequency-reuse pattern for a total AMPS bandwidth of ~4 MHz.

    6(30 + 30 KHz)(4 * 3) = 4.32 MHz

    If Cingular-AT&TWS were allowed to retain both Cellular licenses in
    any or all of the eleven RSAs, it could not entirely remove AMPS from
    either one of the coincident licenses (see below). The two Cellular
    licences will always remain technically distinct, even if both are
    ultimately controlled by a single licensee. But what would prevent
    Cingular-AT&TWS from maintaining Cingular's current ~4 MHz AMPS outlay
    by reducing capacity to three AMPS channels per sector per license or
    even to the bare minimum of only one channel? Such would be a great
    detriment to the public safety component of Cellular by potentially
    jeopardizing the wireless emergency ability of the majority CDMA/AMPS
    users.

    > The only other note, Alltel still will activate analog phones in some cases.
    > But in most cases, an owner of an analog phone will get no where with them.


    Contractual AMPS service is beside the point. In North America, AMPS
    is still the lingua franca - the lowest common language - the last
    line of defense - for roaming & wireless E911. And, like it or not,
    AMPS is still the only modulation that matters for AMPS regulatory
    concerns. Until 2008, all Cellular licensees' CGSAs (i.e. licensed
    coverage areas) will continue to be defined by the extent of their
    AMPS footprints. TDMA or CDMA or GSM or W-CDMA are simply irrelevant
    to that point. While the breadth of AMPS coverage will undoubtedly be
    preserved, the fact that the GSM-MAP declines to cooperate w/ IS-41
    AMPS is not an excuse to pare the depth of AMPS capacity to
    dangerously low levels.

    Andrew
    --
    Andrew Shepherd
    [email protected]
    [email protected]
    http://www.ku.edu/home/cinema/



  14. #14
    Andrew Shepherd
    Guest

    Re: FCC seeks comment on Cingular-AT&TWS waiver

    "N9WOS" <[email protected]> wrote in message news:<[email protected]>...
    >
    > And another note,
    > In the MSAs and even some of the RSAs in question,
    > the network for both cingular, and AT&T,
    > are near full capacity, if not down right oversold.


    And whose fault is that? Should the FCC & the American public bend
    over backwards to accomodate Cingular & AT&TWS because they - of their
    own volition - selected less efficient 3G migration paths that require
    the reinvention of their networks every few years in conjunction w/
    the maintainance of multiple legacy air-interfaces beyond AMPS?

    > It would be stupid, if not down right ludicrous to take
    > one of the two bands away from them, and tell them
    > they have to support the customers from both companies.
    >
    > The customers would suffer horribly from the
    > service of the one system that has enough users for two systems.


    Consolidation of both customer bases into one Cellular system will not
    be an issue. Cingular-AT&TWS should not be allowed to keep both sets
    of customers either. Just as in the detritus markets of the VZW
    merger or the original Cingular partnership, the subs in the markets
    affected by required regulatory divestiture will become transitioned
    customers of ALLTEL or USCC or WWC, etc.

    The FCC has prime opportunity to preserve the current levels of
    wireless competition in the applicable 11 RSAs by mandating
    single-side divestments to new entrants into the markets. If the
    merger is approved, as competition will be lost - a nod to big
    business, not to the consumer - in a plurality of markets nationwide,
    the least that can be done is to maintain the status quo in as many
    markets as possible - both RSAs & MSAs alike. Additionally, as the
    most interested parties in the divested licenses would likely be one
    or more of the three aforementioned above - all CDMA carriers -
    diversity of technology in the markets would be improved which would
    also be toward the greater public good.

    The airwaves are the dominion of all Americans. The burden of proof
    should be upon Cingular & AT&TWS to demonstrate that they are
    efficient & responsible public stewards of that very privileged
    resource. As it stands, their case for Cellular monopoly is less than
    compelling.

    Andrew
    --
    Andrew Shepherd
    [email protected]
    [email protected]
    http://www.ku.edu/home/cinema/



  15. #15
    N9WOS
    Guest

    Re: FCC seeks comment on Cingular-AT&TWS waiver

    > To analogize, please show me any market where but one licensee
    > controls 100% of all PCS spectrum - in parallel to your assertion that
    > Cingular-AT&TWS should be able to retain both Cellular licenses in the
    > affected RSAs -


    I don't really see the logic in that statement.
    The cellular blocks A and B should be considered part of the
    telephony band in the same group with the PCS bands.
    Same technology and application, just a separated by a large frequency
    margin.

    So, to have two Cellular bands is the same as having two PCS bands.
    To own the two cell bands is not owning all the telephony spectrum that is
    available.
    The cellular and PCS bands should be considered as one pool.
    Example.
    As long as there is three or more users with access to spectrum in an area,
    there should be no restriction on what part of the pool they own, as long
    as all three of them have a part of it, and provide good service.
    If they don't provide good service, then take some bandwidth away
    from them and sell it to someone that will.

    >and I will completely agree w/ your contention. If
    > the percentage comparison is not fair, show me a market where one
    > licensee has managed to aggregate PCS spectrum totaling 50 MHz or
    > more. On the latter count, you might be able to locate a few markets
    > where one primary carrier plus its affiliates (read: AT&TWS) has
    > assembled 50 MHz, 55 MHz, or even perhaps 65 MHz, but those markets
    > are very few & far between, almost inevitably a combination of
    > Cellular plus PCS spectrum. Allowing one licensee total control of
    > all Cellular or all PCS spectrum in any given market would set a
    > dangerous hegemonic precedent.


    I don't see the major difference between cellular and PCS licenses anymore.
    The only arguable difference is the amps capacity.
    But the FCC is no longer taking the AMPS subject very seriously any more.
    All new phone can use the cell and PCS bands with indifference.
    As long as other carriers have access reasonable access to that
    area, and they have systems to support the area, I see nothing wrong with
    it.

    > To address Cellular specifically, Cellular licensees greedily want to
    > have their cake & eat it too. They want the more laissez faire
    > regulatory oversight like that of the PCS band as well as the superior
    > propagation characteristics of 800/850 MHz spectrum. But the latter
    > point in conjunction w/ the not-yet-sunset AMPS mandate and the two
    > decade buildout legacy undeniably sets Cellular apart from PCS,
    > positions Cellular in a special responsibility toward public service,
    > and places the greater good ahead of Cellular's desires for further
    > deregulation.


    The AMPS mandate is something that the FCC is only for existing systems,
    and new systems don't even have to meet that mandate.
    As I said, the FCC is not taking the AMPS mandate with any vigor any more.
    And the FCC is getting to the point that they consider that PCS has had
    adequate
    time to build out in most heavily populated areas, and that cellular
    providers no
    longer have any arguable advantage.
    And if it is evident that the cellular providers no longer have an advantage
    in
    the RSA's, then they will wave any rules regarding cellular ownership.

    > Cingular has disclosed in its own regulatory filings that it typically
    > maintains only six AMPS channels per sector in an N=4*3
    > frequency-reuse pattern for a total AMPS bandwidth of ~4 MHz.
    >
    > 6(30 + 30 KHz)(4 * 3) = 4.32 MHz
    > If Cingular-AT&TWS were allowed to retain both Cellular licenses in
    > any or all of the eleven RSAs, it could not entirely remove AMPS from
    > either one of the coincident licenses (see below). The two Cellular
    > licences will always remain technically distinct, even if both are
    > ultimately controlled by a single licensee. But what would prevent
    > Cingular-AT&TWS from maintaining Cingular's current ~4 MHz AMPS outlay
    > by reducing capacity to three AMPS channels per sector per license or
    > even to the bare minimum of only one channel? Such would be a great
    > detriment to the public safety component of Cellular by potentially
    > jeopardizing the wireless emergency ability of the majority CDMA/AMPS
    > users.


    They keep enough channels to support the average users on the band.
    As they said, "typically"
    That is what they have found to be sufficient to do the job.
    If they have an area that has higher amps usage,
    they probably have a few more channels available to that area.
    The amps load would be balance between both bands,
    same as all the other system usage.
    All the other carriers also keep the minimum AMPS channels to provide
    service.

    > > The only other note, Alltel still will activate analog phones in some

    cases.
    > > But in most cases, an owner of an analog phone will get no where with

    them.
    >
    > Contractual AMPS service is beside the point. In North America, AMPS
    > is still the lingua franca - the lowest common language - the last
    > line of defense - for roaming & wireless E911. And, like it or not,
    > AMPS is still the only modulation that matters for AMPS regulatory
    > concerns.


    And the amps capability will be there, irrelevant of who owns the band.
    Cellular phone operation is not a requirement as far as the FCC is
    concerned.
    The only thing that is a requirement is that all carriers forward 911.
    If they thought universal roaming was a requirement,
    then it would be a law that all phones have AMPS.
    They don't.
    As long as the system will forward any 911 call from
    any phone that can connect to it, the FCC is happy..

    > Until 2008, all Cellular licensees' CGSAs (i.e. licensed
    > coverage areas) will continue to be defined by the extent of their
    > AMPS footprints.


    The coverage area will be what ever figure the company wants to make up.
    It could be based on a 3W bag phone, or .2W digi phone.
    There is a heavy fudge factor in that.
    But what difference does that make as for who can own the band?

    >TDMA or CDMA or GSM or W-CDMA are simply irrelevant
    > to that point.


    They are not irrelevant in today's world.

    > While the breadth of AMPS coverage will undoubtedly be
    > preserved, the fact that the GSM-MAP declines to cooperate w/ IS-41
    > AMPS is not an excuse to pare the depth of AMPS capacity to
    > dangerously low levels.



    Now.... I am a supporter of AMPS, that you must know,
    but that doesn't change the fact of the current cellular environment.
    I have generally accepted that, no matter how much I like my bag phone,
    AMPS should not have any part in the decision on the divesture of the bands.
    The AMPS concern is only going to be around for 4 years.
    The company must live with it for the rest of it's life.
    The users must put up with the service as long as they are there.
    Long after the AMPS mandates are long gone.
    The choice should be based on the questions of......
    Is there adequate competition provided by other service providers?
    And is the other providers covering the majority of the population,
    so that the majority of the population has a choice of what service provider
    to use?
    No about a mode that
    (no matter how much I hate to admit it)
    is not important any more.





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