Dear Editor:
I’d like to offer a short response to Scott Adam’s letter to the editor in your Nov. 8 edition, “Protected spectrum counters efficient use of spectrum.”
I believe Mr. Adams is much closer to AMTA’s position than he realizes. The purpose of the petition for rule making to which he refers is to provide future opportunities for just the sort of system he describes, not large cellular-like services. And as he upgrades his own system on channels below 512 MHz, he’ll find that the future will require some changes to the rules in order to allow the kind of regional service he’d like to provide and that his customers will demand.
Mr. Adams rather quickly asserts “license UHF channels as a `YG’ designator, and you don’t have any sharing.” But while AMTA was instrumental in getting the UHF trunking rules changed to make that process easier, we’ve found that it’s still nearly impossible to create a viable trunked UHF business in any but the most rural areas. Add the continuing press of users (and some limited channel splitting won’t fix that because the rules don’t require incumbents to replace their 30-year-old wideband equipment) and increasing interference from an increasing variety of equipment and a bad situation will only get worse. That shouldn’t be the only option for this industry.
We agree with Mr. Adams that spectrum auctions increase costs to the end user, and they’re certainly not our first choice for licensing. AMTA was on record for years as opposing auctions for non-consumer wireless, especially on already-licensed or shared spectrum. However, the FCC has made it abundantly clear that an auction is the only way that a commercial operator (and possibly even a non-public safety private user) will be allowed to acquire spectrum. With analog subscribership in a decline (as the Strategis Group has found in its 1999 survey of the dispatch industry), we’re not willing to throw away the future of the non-consumer wireless industry merely to avoid auctions.
AMTA’s many members who have participated in FCC auctions will tell you that if the rules are set up properly, with small channel blocks, small amounts of geography and bidding credits for small business, it’s possible to succeed without having to charge cellular-like prices for service. That’s the kind of spectrum opportunity we keep asking for. Our petition goes even further, asking that businesses be limited to just one initial license per market so that no one can dominate the band.
Mr. Adams, AMTA understands your dislike of spectrum auctions and your concerns for the UHF bands. We’re more or less on the same wavelength-we just ask that you look a little further into the future before you dismiss our petition.
Alan R. Shark
President & CEO
American Mobile Telecommunications Association
