Claims that there’s an “industry consensus” for a...

and Verizon have both recommended a “Down from 51” band plan, Dish said the two companies’ plans have several differences, and the DBS provider favors a third choice, a “Down from 51 without Supplemental Downlink (SDL)” plan. Dish’s plan has “a common paired downlink and uplink block” which it said will motivate smaller carriers to participate in the incentive auction and “maximize the total revenue.” The “Down from 51 without SDL” plan would also give carriers more certainty in the Third Generation Partnership Project (3GPP) global standings setting process, Dish said. Paired uplink and downlink “facilitates the adoption of a common 3GPP band, resulting in better standards harmonization and economies of scale for handsets and other equipment,” Dish said. In the 700 MHz band, the commission shouldn’t change the authorized power levels for the lower 700 MHz E block as it adopts 700 MHz interoperability rules, Dish said. “Any changes to the service rules for the E-block post-auction will upset Dish’s legitimate, investment-backed expectations for use of this spectrum, jeopardize Dish’s investment and business plans, and may be considered an unauthorized partial revocation of Dish’s license,” said the company. It’s “unlikely” Dish will “meaningfully participate” in the H-block auction “given the current regulatory requirements for H block and AWS-4,” Dish said. Dish also said a recent commission proposal to designate the lower J block for uplink would make future operations there “vulnerable to significant interference from adjacent Federal government and Broadcast Auxiliary Service users above 2025 MHz."