Wireless Carriers Urge FCC Caution in Reallocating 2 GHz Spectrum

Additional spectrum is “urgently needed to fuel the continued growth” of wireless broadband, CEA said. The group cites statements about the spectrum crunch by Chairman Julius Genachowski. “There is no debate that a spectrum crunch exists,” CEA said. “Study after study supports this conclusion.” CEA cited the explosive growth in smartphones and tablets, but also machine-to-machine (M2M) communications, projected by Cisco to grow 40-fold between 2010 and 2015, CEA said. “As mobile data networks become ubiquitous, bandwidth-intensive M2M connections will become more prevalent,” the filing argued. “Traditional appliances and devices, such as home appliances, vehicles, energy meters, and vending machines -- which traditionally have not been connected directly to mobile broadband networks -- are now connecting directly to these networks."

The 2 GHz band “is already an important band for mobile broadband,” Verizon Wireless said (http://xrl.us/bkzp4i). But the carrier said the FCC shouldn’t make any more decisions about 2 GHz spectrum until it resolves the future of the 1755-1850 MHz band, a prime carrier target for broadband use. The 1755-1780 MHz band in particular “offers a valuable opportunity to establish a long-term spectrum plan that is harmonized with global spectrum allocations,” Verizon said. “There is broad industry support for reallocation of the 1755-1780 MHz band and the pairing of that spectrum with the currently unassigned 2155-2180 MHz band.” The FCC should make that assignment before making other calls on how other spectrum in the 2 GHz range will be reassigned, the carrier said.

T-Mobile made similar arguments about the need for the FCC to first resolve the future of the 1755-1780 MHz band (http://xrl.us/bkzp8a). “The Commission should work with NTIA to make the 1755-1850 MHz band available for commercial broadband paired with the AWS-2 upper J Block spectrum (2175-2180 MHz) and the AWS-3 spectrum (2155-2175 MHz),” the carrier said. T-Mobile said two of the three proposals floated by the FCC for the 2 GHz range would “extract spectrum from the AWS-2 and AWS-3 bands.” In addition, T-Mobile said, “if the entire 1755-1850 MHz band is made available for commercial broadband, the FCC may wish to evaluate whether some of that spectrum may be effectively paired and used with the 2 GHz MSS band.” Sprint Nextel also suggested caution (http://xrl.us/bkzp72), saying whatever the FCC does it must protect incumbent PCS licensees from interference and not relent in requiring 2 GHz Mobile Satellite Service entrants to pay their fair share of Broadcast Auxiliary Service relocation costs incurred by Sprint under the 800 MHz rebanding.

Sprint argued that H Block uplink operations at 1915-1920 MHz “would pose a serious interference threat to G Block transmissions and other PCS operations.” Sprint said, “at a minimum, new 1917-1920 MHz users would need to be subject to restrictive transmitter power and [out of band emissions] limits to protect the millions of existing PCS devices operating in the 1930-1990 MHz band from harmful intermodulation interference."

AT&T said the FCC should move carefully in reallocating the 2 GHz spectrum (http://xrl.us/bkzp7q). “Rather than moving forward with the band plan concepts proposed in the 2 GHz Public Notice, the Commission should focus on collaborating with NTIA to pursue the reallocation of key federal spectrum resources, and on developing voluntary mechanisms for repurposing of commercial spectrum that will extract appropriate value for the public interest and will enable the creation of a comprehensive mobile broadband band plan,” AT&T said. Allocations should be “large enough to support several contiguous spectrum blocks,” AT&T said. “Equally important to identifying a sufficient quantity of additional spectrum is ensuring that the bands repurposed are spectrally located in such a manner as to be most useful for mobile broadband uses upon being repurposed. The spectrum bands identified should have sufficient uplink and downlink separation to allow full-power mobile broadband use of the entire band with conventional and commercially available filtering technologies."

The Telecommunications Industry Association also advised the FCC to proceed with care (http://xrl.us/bkzp9s): “TIA believes that the Commission should ensure that market certainty and license values for existing allocations are not threatened or disadvantaged in any way by new mobile and fixed broadband allocations, and that a holistic approach that includes consideration of existing and future pairing possibilities be considered."

The S-band licensees, DBSD and TerreStar, didn’t provide much insight into the future use for their spectrum in their filings. Both recently received bankruptcy court approvals for sales to Dish Network, though they still need FCC approval (CD July 11 p3). Dish didn’t file in the proceeding. FCC action to harmonize 2 GHz spectrum specifications “would significantly improve scale economies and availability of S Band infrastructure and devices and enable” faster broadband delivery, said DBSD (http://xrl.us/bkzpzs). Existing MSS operations must be protected from new terrestrial use in the 2 GHz band, it said. For instance, harmonized operations with adjacent band uplink and downlink with compatible power levels and emissions can help reduce interference with MSS operations in the band, it said. “Coordination with existing S Band licensees may be warranted in some circumstances, but with sufficient guidance from the Commission in advance on the expectations and rights of licensees in the band, coordination through industry practice can likely be achieved,” the company said.

Ancillary terrestrial component operations should also be protected said DBSD. If the FCC licenses spectrum in the 2155-2180 MHz range as downlink or flexible-use spectrum and the lower portions of the 2 GHz range as uplink spectrum, the licensees could make more efficient use of their spectrum, said DBSD. If the FCC decides to license the lower spectrum as flexible-use, as was done in the 700 MHz auction, new licensees would have to work with international standards bodies to coordinate with surrounding bands, DBSD said. The spectrum around S-band should be evaluated to ensure co-existence and guidelines may be necessary to facilitate agreements with operators in nearby bands that result in “optimum broadband capacity,” it said.

TerreStar said it’s supportive of an emphasis on voluntary approaches on increasing terrestrial broadband in the 2 GHz band in its comments (http://xrl.us/bkzp3f). “Ultimately, it is private sector investment that can optimize use of the band, but only if the marketplace is permitted to make rational choices with regard to service deployment,” said TerreStar. The FCC should make sure to consider the interference issues that could be created by an adjacent base station downlink band and a mobile terminal uplink band, which the FCC previously proposed, TerreStar said.