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10. This assumes that PCS companies must deploy approximately three cell sites for every cellular cell site in order to achieve comparable coverage and that a hypothetical single nationwide cellular company would have deployed 7,500 cell sites to provide coverage.

11. Paul Kagan Associates. 1994. Wireless Telecom Investor, October 20, p. 9.

12. This assumes that cellular companies will roughly double the number of cell sites they had deployed as of midyear 1994 in order to improve coverage and capacity, and that Nextel will build out its 4,000 sites. The equivalent of four 30-MHz PCS systems would require a theoretical total of 90,000 cell sites (4 × 22,500 = 90,000). In fact, the number of antennas may be higher regardless of the number of service providers, simply to ensure adequate coverage and service quality.

13. See, for example, "Blairstown Township Zoning Board of Adjustment Resolution Memorializing the Denial of a Certain Use or 'Special Reasons' Variance Sought Pursuant to N.J.S.A. 40:55D–70(d)(1) to the Application of Pennsylvania Cellular Telephone Corporation Seeking Approval for the Erection of a Cellular Telephone Tower on Block 2003, Lot 14.01, on the Blairstown Township Tax Map Application ZB-2-94," pp. 23–24 (dated October 25, 1994; revised November 3, 1994).

14. See, for example, "Village of Wilmette Resolution 93-R-34." See also zoning ordinances of Jefferson County, Colorado, and the City of Stamford, Connecticut, which provide that more stringent state or county standards may supplant the 1992 ANSI standard. See Jefferson County Reg. Section 2, P(1)(a), and City of Stamford Ordinance No. 527 Supplemental.

15. See Ryser, Rob. 1994. "Tarrytown Extends Ban on Installation of New Cellular Antennas," Gannett Suburban Newspapers, December 6, p. 3A: "We have been surprised by the board's action from the beginning. The expert that Tarrytown hired to study (antenna transmissions) came back and found our cellular installation safe."

16. See Cody, Michael. 1995. "Bay Bridge Is Potential Antenna Site," The Capital, March 30, p. A1.

17. Letter dated October 27, 1994, from Thomas E. Wheeler, President and Chief Executive Officer, CTIA, to Reed Hundt, Chairman, FCC, p. 2.

18. See "CTIA Petition for Rulemaking," RM-8577, filed December 22, 1994.

19. See "Reply Comments of CTIA," RM-8577, filed March 6, 1995, p. 7 (referring to "Petition for Further Notice of Proposed Rulemaking in ET Docket No. 93-62, filed by EEA on December 22, 1994).

20. Letter dated March 22, 1995, from Thomas E. Wheeler, President and Chief Executive Officer, CTIA, to President William J. Clinton, p. 1.

21. Ibid.

22. Speech of House Speaker Newt Gingrich at Wireless '95, New Orleans, February 1, 1995.



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