Voluntary Approach to 2 GHz Incentive Auctions a Necessity, Says TerreStar

CTIA said comments in the proceeding demonstrate broad support for dedicating 2 GHz spectrum to wireless broadband (http://xrl.us/bk25hj). “The 2 GHz spectrum identified in the Public Notice holds particular promise for mobile broadband, and CTIA applauds the measures taken both by the Commission and by NTIA to examine new spectrum bands for mobile broadband services,” CTIA said. Commenters “agree that the 2 GHz spectrum identified by the Commission possesses characteristics that make it ideal for mobile broadband services.” CTIA said there is general agreement on the need to harmonize U.S. actions with those elsewhere, as well as on the wisdom of holding incentive auctions to reallocate MSS spectrum: “CTIA has long been an advocate for incentive auctions and believes they represent a highly efficient and beneficial means of allocating new spectrum.” CTIA also cited many comments urging the FCC to focus its initial attention on the 1755-1780 GHz band, long a carrier focus for broadband. “CTIA and its members strongly favor pairing of the 1755 to 1780 MHz band with spectrum from the 2155 to 2180 MHz band and believe that the Commission should focus on this outcome,” the filing said.

Leap emphasized the what is saw as importance of a quick decision on the 1755-1780 MHz band in its reply comments (http://xrl.us/bk25kt). “Commenters point to significant efficiencies that could arise from pairing this spectrum with spectrum in the 2 GHz range, particularly the spectrum at 2155-2180 MHz, and the record indicates that such pairing could create more productive wireless broadband plans,” Leap said. “Leap supports the views of virtually all commenters that the Commission should work with NTIA to promote and facilitate this option as expeditiously as possible.” But Leap broke with some wireless industry commenters in arguing that work on the 2 GHz spectrum should continue and should not be delayed pending a decision on the 1755-1780 MHz band. “Certain commenters seem to want to place this entire inquiry ‘on ice’ until NTIA completes its review, but there is valuable analysis and investigation that can and should continue today to identify efficient uses of the 2 GHz spectrum that will advance the public interest,” Leap said.

T-Mobile countered Leap’s arguments on the 1755-1780 MHz band in its reply comments (http://xrl.us/bk25ms), citing initial comments from CTIA, AT&T, the Telecommunications Industry Association, and others. “Parties agreed with T-Mobile that rather than adopting any of the band plans contained in the Public Notice in this proceeding, the Commission should wait to determine if the 1755-1850 MHz band becomes available for wireless broadband so that it may be included in the Commission’s terrestrial broadband spectrum planning,” T-Mobile said. “Other commenters also broadly recommended that the Commission wait to consider a band plan for the 2 GHz MSS spectrum to determine if the entire 1755-1850 MHz band would be made available for wireless broadband use, recognizing that if the entire band becomes available, the Commission may wish to consider other potential band plans."

Sprint Nextel said the record is clear on the importance of creating “large, contiguous [spectrum] blocks” that will “bolster the use of 4G technologies and can promote spectral efficiency and increase throughput speed.” Large blocks also “help eliminate the costly filtering and other technical solutions that are needed to aggregate widely separated spectrum,” Sprint said (http://xrl.us/bk25j4). But to promote competition, some of the spectrum should be dedicated to smaller blocks as well, the carrier said. “Thus, the Commission should consider a range of spectrum block sizes for the 2 GHz band to spur competition among multiple service providers and promote innovation and consumer choice,” Sprint said. “For example, although providing robust 4G service in urban areas may require contiguous 10+10 MHz or 20+20 MHz blocks, new 4G technologies are scalable to different bandwidths, and the same or better data rates can be accomplished in rural and other less densely populated areas with only 5+5 MHz of spectrum."

Globalstar’s reply comments challenged the comments from the Engineers for the Integrity of Broadcast Auxiliary Services Spectrum. The EIBASS filing raised concerns over the treatment of grandfathered broadcast auxiliary service operations in 2483.5-2500 MHz. The EIBASS filing falls outside the scope of the FCC’s public notice in the proceeding and should be disregarded, said Globalstar. Protection of the BAS systems from interference doesn’t require the reconfiguration of the Big Low Earth Orbit MSS band or relocation of a BAS channel, Globalstar said. The FCC has previously weighed in on the issue and EIBASS doesn’t give any reason that the FCC should “revisit these sound decisions,” said Globalstar. EIBASS’ focus on interference from Open Range Communications, which operates terrestrial service in Globalstar’s ATC spectrum under a special temporary authority from the FCC, says nothing about Globalstar because Open Range is outside of Globalstar’s authority and regulatory responsibility, said Globalstar. “EIBASS once again fails to demonstrate that the existing regulatory framework in this band is insufficient” for the BAS systems, Globalstar said.