Industry Calls on FCC to Embrace ‘Consensus’ 600 MHz Band Plan

FCC officials told us the public notice was intended to explore other options, with an emphasis on developing a plan that would maximize the commission’s flexibility in making changes necessitated by an incentive auction of broadcast TV spectrum.

"I didn’t quite understand the hue and cry at the release of the public notice,” said a former FCC official Monday. “I'm not sure that there is full consensus on the so-called consensus plan. I believe that the criticism of the staff is misplaced. They're doing their job and right now is the perfect time to drill down because there are not going to be major decisions made before the new chair [Tom Wheeler] arrives.” But an agency official said Monday that, if anything, support for the industry-favored down from 51 plan has gotten stronger in recent weeks since the release of the notice.

"CTIA cannot find a single party in the record that supported the idea of placing mobile downlinks in spectrum adjacent to mobile uplinks as suggested in the ‘Down from 51 Reversed’ proposal due to the significant interference issues associated with dissimilar wireless operations in adjacent spectrum as well as the inefficiencies (extra guard band requirements) associated with this plan,” CTIA said (http://bit.ly/13NXfDA). The proposal would require an additional guard band between lower 700 MHz A Block uplink spectrum and the downlink spectrum at the top of the 600 MHz band, the group noted. “Given the grave spectrum crunch facing the wireless ecosystem and the urgent need for additional licensed spectrum, CTIA cannot support a band plan that would unnecessarily limit the amount of licensed spectrum made available,” it said.

The FCC’s down from 51 reversed plan “has significant disadvantages,” CEA said. “First, a DF51R approach would reduce the amount of auctioned spectrum and adversely impact auction proceeds,” the group said (http://bit.ly/11tFCFX). “Second, moving the uplink to lower frequencies has the potential to cause increased interference into other bands that will be used in consumer devices to provide services simultaneously, including bands used for Wi-Fi, Global Navigation Satellite Systems, Personal Communications Services, Wireless Communications Services and Broadband Radio Service/Educational Broadband Service. In fact, there are multiple harmonic jamming victim bands for uplinks in each 5 MHz block except the top five 5 MHz blocks in the 600 MHz band.”

Qualcomm said it favors a down from 51 plan and FDD rather than TDD for technical reasons. Both the down from 51 reversed and TDD plans “increase the number of bands that will be jammed when they are simultaneously operating within the device; this includes critically important global positioning bands, the 2.4 GHz unlicensed Wi-Fi band, and licensed mobile bands such as PCS, WCS, and the BRS/EBS bands,” Qualcomm said (http://bit.ly/11KPDhK). The alternate plans also “place uplink operations closer to broadcast TV receivers and directly adjacent to Wireless Medical Telemetry Services and radio astronomy stations in Channel 37 and thus increase the potential for harmful interference to these services when compared to the straight DF51 plan,” the company said. The plans proposed in the PN would also require additional guard band spectrum and “would be less amenable to accommodating market variation than the straight DF51 plan,” Qualcomm said. “The two plans would vary the uplink spectrum in regions of the country that recover less spectrum from TV broadcasters, but Qualcomm has calculated that full power TV broadcast stations could cause interference to mobile base station receivers (i.e., uplink operations) located more than 310 miles (or 500 km) away."

The down from 51 plan offers some advantages, Motorola Mobility said. “First, it avoids placing television broadcast stations in the spectrum between the uplink and downlink bands, which would result in a smaller duplex gap,” the company said (http://bit.ly/11jWnXD). “Antenna handset design is simplified by reduced antenna bandwidth. Second, the absence of television broadcast stations in the duplex gap helps eliminate a source of intermodulation products that would otherwise fall into the downlink receive band and interfere with wireless broadband devices.” Alcatel Lucent also cited the technical advantages of the industry-favored plan (http://bit.ly/19dYM7Y).

The alternates plans in the notice “have drawbacks that are not shared by the industry consensus proposal, including creating harmful interference both with other services and within end user devices, imposing unnecessary inefficiencies on wireless devices, wasting spectrum that could otherwise be dedicated to mobile broadband services, and reducing the Commission’s ability to repurpose additional broadcast spectrum that may become available in the future,” Verizon and Verizon Wireless said in their comments (http://bit.ly/1bOiXZE). “And although Verizon agrees with the Commission that accommodating variation in the amount of broadcast spectrum that clears in different markets is an important policy goal, the Notice’s proposals do not better advance that goal."

AT&T offered similar criticisms of the down from 51 reversed plan. The plan “would present several technical challenges that the Down from 51 band plan would not, such as antenna inefficiencies and harmonic and intermodulation interference,” AT&T said. “Those technical challenges would impair the utility and fungibility of the cleared spectrum, reduce the spectrum’s auction value, and thereby threaten the auction’s success.” The FCC should remain focused on the industry-backed band plan, the carrier said. “Given these fundamental flaws, the Commission should not allow itself to become distracted by the proposed alternative band plans so deeply different from the industry consensus. The Commission should devote its resources, instead, to the many complex issues that remain unresolved, including but far from limited to examining co-channel interference and refining the Down from 51 band plan."

T-Mobile continued its advocacy of its own version of a band plan. “T-Mobile continues to believe that its 35x35 MHz Down from 51 Band Plan represents the best balance between maximizing the amount of spectrum available for auction and minimizing the potential for harmful interference,” the carrier said (http://bit.ly/11GXoVg). “While there are technical and practical challenges associated with the Down from 51 Band Plan, in T-Mobile’s view those challenges are entirely manageable; at the same time, the benefits from such a plan are substantial."

Under the proposed band plans, stations hundreds of kilometers apart but sharing the same channel will interfere with each other, said NAB’s reply (http://bit.ly/12LPFfS). Executive Vice President Rick Kaplan said the Wireless Bureau is “refusing to ask questions” about the issue of co-channel interference, which he said could threaten the whole auction and currently has no solution. Kaplan said in an interview Monday that the issue is complex enough that it could lead to a delay in the auction proceeding. “The concern is if the auction goes too fast things like co-channel interference won’t be studied,” he said. “The longer we take to answer questions like this, the less likely it is we'll have a have a 3rd quarter band plan.”

NAB has raised the issue of co-channel interference before but he hasn’t seen any indication the bureau is working on the problem, Kaplan said. However, he pointed to comments filed by AT&T and Verizon acknowledging the problem as evidence that this may change. “Maybe the bureau will be more responsive to the wireless industry,” said Kaplan. He said FCC members are aware of the problem, and NAB wants the commission to either issue a public notice on the question of co-channel interference, or hold a workshop on the issue.

Sinclair said variable band plans like those suggested in the PN would lead to spectrum being reclaimed in less-populated areas where there’s no spectrum crunch, displacing translators, low-power TV stations and repeater stations for little gain (http://bit.ly/17TEHpx). Sinclair and other broadcasters blamed an FCC emphasis on freeing up the most spectrum for the potential problems of the auction. “This notion of maximum spectrum recovery can create some absurdities,” said a broadcast attorney representing clients involved in the auction proceeding. “It makes no economic sense to reclaim spectrum in rural areas where you don’t need it,” said another broadcast lawyer, Pillsbury Winthrop’s John Hane, who represents Sinclair. Wireless spectrum gained in rural areas will be wasted, since it’s unlikely carriers would build or sell mobile handsets that only work outside cities, he said. Hane said the variable band plan would leave no room for future technological transitions, because there would be no place to temporarily put stations during future repackings. “The Public Notice proposes clearing what can be cleared in the largest markets and then clearing additional spectrum in smaller markets and rural areas, apparently just because it can be done,” said Sinclair.

The National Translator Association attacked the band plan on procedural grounds, saying not enough information on it has been released to comply with the Administrative Procedure Act (http://bit.ly/11GYYpY). “You can’t tell from the rulemaking documents what their proposed rules will be,” said Borsari & Paxson attorney George Borsari, who represents NTA. “None of the models quantifies the desired exact amount of target spectrum to be recovered,” the NTA commented. “Accordingly, the attempt to match an amount of spectrum with actual need for broadband spectrum is not even being attempted."

The TDD proposal got at least some support. “Given the sheer complexity of the broadcast incentive auction and the reality of today’s downlink-heavy data traffic patterns, a TDD band plan offers the most flexible, efficient and forward-looking means for allocation of the 600 MHz spectrum for mobile broadband use,” C-Spire Wireless said.