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While the wireless industry is still far from agreement over how the Federal Communications Commission should auction off the blocks of airwaves that it will reclaim from TV broadcasters, many have expressed opposition to the FCC's latest proposed band plan.
In the plan known as the “Down from 51 Reversed” band plan, the FCC would clear broadcast TV channels starting at channel 51 and expand downward; the downlink would begin after a guard band at channel 51, followed by a duplex gap and then the uplink band. Parties representing a diverse cross-section of the wireless and broadcasting industries have weighed in on this and other technical and policy issues, and some, including AT&T Inc., have said the plan potentially “overvalues” the FCC's goal of offering different amounts of spectrum in different geographic markets. AT&T urged the FCC to focus instead on devoting resources to “refining” what has been termed by industry as the “straight” Down from 51 band plan.
“By requiring one more guard band--between the 600 MHz downlink blocks and the 700 MHz uplink blocks--than does the Down from 51 band plan, the Down from 51 Reversed band plan would unwisely, and perhaps unlawfully, reduce materially the amount of spectrum available for licensed use, thereby diminishing the revenue potential and increasing the likelihood of auction failure,” AT&T wrote in comments filed June 14 with the commission.
AT&T took pains to highlight a recently reached consensus agreement between itself, the National Association of Broadcasters, Verizon Wireless, T-Mobile USA Inc., Intel Corp., and Qualcomm Inc. As part of the agreement, the parties developed a list of principles the FCC should adopt, such as:
• relying upon 5 megahertz spectrum blocks as “building blocks” for a new spectrum band plan;
• incorporating a duplex gap, or spacing, between uplink and downlink of a minimum of 10 MHz, but no larger than technically necessary;
• avoiding broadcast television stations in the duplex gap;
• providing guard bands that are, consistent with the statute, “no larger than is technically reasonable” to prevent harmful interference between adjacent operations;
• providing a guard band between a high-power broadcaster and mobile downlink that is sufficient to protect the wireless service from interference, which will likely be larger than the 6 MHz proposed by the FCC; and
• facilitating “international harmonization,” prioritizing harmonization across North America and working expeditiously to coordinate with Canada and Mexico for new broadcast assignments.
“The commission should not allow itself to become distracted by the proposed alternative band plans so deeply different from the industry consensus,” AT&T said.
Broadcast television spectrum is attractive to the wireless industry for two reasons. First, the spectrum has technical characteristics well-suited for current and next-generation mobile broadband services. TV bands make up nearly 30 percent of the spectrum allocation between 225 MHz and 1 GHz, considered the most valuable “beachfront” property for mobile broadband due to the excellent propagation characteristics in that frequency range, according to the FCC. And second, the TV bands, in their current use, have lower market value than spectrum recently auctioned for mobile broadband use.
T-Mobile USA, meanwhile, advocated for its 35x35 MHz Down from 51 band plan, which it says represents the “best balance” between maximizing the amount of spectrum available for auction and minimizing the potential for harmful interference.
“Rather than indiscriminately introducing a guard band under all clearing scenarios, T-Mobile's plan avoids adding a guard band until it is absolutely needed,” the company explained in its June 14 filing. “This preserves a significant amount of valuable spectrum, offering over 16 percent more paired spectrum than the proposed Down from 51 Reversed Plan in markets where at least 84 MHz can be cleared. This 16-percent return can help compensate for any challenges associated with accommodating television channels above Channel 37 in lower-clearing markets.”
T-Mobile further suggested that if the commission remains concerned that insufficient spectrum will “clear” in a substantial number of markets, it can always adopt a backup band plan.
Along those lines, Verizon Communications Inc. and Verizon Wireless noted in comments that it would be impossible to calculate the spectral efficiency of the FCC's proposed plan because the agency's public notice provides no information about the sizes of guard bands or the number of licensed spectrum blocks that would be auctioned. However, the need for a guard band would likely reduce the total amount of spectrum that is repurposed and auctioned under most--if not all--clearing scenarios, Verizon said.
Verizon said its own proposal for an 84 MHz clearing scenario “efficiently uses” the spectrum between Channel 37 and the 700 MHz band to create a total of 70 MHz of paired spectrum (35 x 35), whereas the commission's plan could at most create 60 MHz of paired spectrum (30 x 30) under the same scenario.
Similarly, Qualcomm Inc. reiterated support for a straight Down from 51 FDD (frequency division duplex) band plan in which a 25 MHz-wide uplink portion of the band would be placed directly adjacent to the lower 700 MHz “A Block,” followed by a 10 to 12 MHz duplex gap and then a 25 MHz-wide downlink portion, with the remaining spectrum allocated for supplemental downlink.
Qualcomm said both the Down from 51 Reversed band plan and proposed TDD (time division duplex) band plans would require a guard band at the upper end of the 600 MHz band, which wastes spectrum that is much better suited for licensed uplink operations.
These proposals would also increase the number of bands that will be “jammed” when they are simultaneously operating within the device, and would place uplink operations closer to broadcast TV receivers and directly adjacent to Wireless Medical Telemetry Services and radio astronomy stations in Channel 37 and increase the potential for harmful interference with these services, Qualcomm said in its comments.
One large wireless carrier, Sprint Nextel Corp., is backing a TDD band plan, citing both competitive and technical concerns.
“In order to accommodate market variability, the commission and other FDD supporters propose to limit the amount of uplink spectrum that would be made available for auction and use in the market,” Sprint said in its comments. “Such an approach would unnecessarily sacrifice the utility--and thus desirability and availability of this spectrum--for operators that do not already have low-band spectrum, since those potential competitors need uplink spectrum with similar propagation characteristics to take advantage of the downlink spectrum. It would create a significant number of unpaired downlink spectrum blocks that would be of very limited use to anyone except AT&T and Verizon--the two operators that already hold licenses for ample paired low-band spectrum that could be paired with 'excess' unpaired 600 MHz spectrum. This approach would limit the opportunity for competitive access to the 600 MHz spectrum, and coincidentally provide additional downlink spectrum that is likely to only further skew the imbalanced competitive situation.”
The comments are available at http://apps.fcc.gov/ecfs/comment_search/input?z=54c3l. Punch in Proceeding Number 12-268.
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