To: Jeff Vayda who wrote (28563 ) 4/21/2012 1:19:36 PM From: pcstel Read Replies (1) | Respond to of 29987 Thus it seems pretty clear that deployment of new (small, lower cost?) cell sites for capacity enhancement is working very well to accommodate increasing amounts of data traffic, without imposing any significant burden on the wireless operators. Indeed, with the operators apparently able to include on-net WiFi traffic in the data they report to CTIA, as AT&T is probably doing , the need for more licensed spectrum may be reduced even further.” Simple solutions for those that already possess required spectrum. Unfortunately, for those companies that do not have licensed spectrum. Access to affordable spectrum rights looks increasingly bleek, as the incumbent CMRS providers continue to dominate spectrum auctions. Mr. Farrar has over the last 3 years, incorrectly in my opinion, claimed that the "spectrum crisis" is a farce, and that there actually is no real threat of insufficient spectral resources. All the while over 100Mhz of spectrum has been introduced or reintroduced into the market, and quickly consumed by the carriers. It is easy to claim that there is no "spectrum crisis" as new inventories of spectrum have entered into the marketplace to satisfy the demand. Mr. Farrar would have been correct if the new inventories made available had gone unsold and lain fallow in the marketplace. So he will play revisionist history and claim he was right, even though substantial amounts of new inventory has entered the market to squelch near term requirements. The real question is, will there be new inventory of available spectrum to continue to meet the requirements by potential new entrants? If DISH is building a network, will DIRECTV follow? Low cost equipment and deployment allows operators with access to smaller amounts of Nationwide sepctrum to build competitive networks. If spectral efficiencies double every 2.5 years as claimed, then a operator that held 10Mhz in 1998, would now have the spectral efficiencies of nearly 60Mhz of 1998 spectrum. Lower cost/high efficiency infrastructure should increase demand for even small amounts of spectral resources by companies wishing to build their own networks. In the past, high cost of infrastructure was one of the "barriers to entry", along with the requirement of 10's of Mhz of spectrum. You can claim that the low cost of infrastructure is lowering the demand for spectrum by existing carriers, but you haven't seen the reality of this thesis on the demand side for new spectrum at auction or in the aftermarket. In this regard, Mr. Farrar continues to claim he is correct about the lack of a spectrum crisis, while the reality of auctions and the resale market continue to prove he is wrong. PCSTEL