FCC rules for the TV incentive auction must prioritize the rights of companies that buy spectrum in the auction to build out those frequencies, CTIA said in reply comments on a public notice on defining the term “commence operations” in the context of the 600 MHz band transition rules. The FCC should “err on the side of protecting primary uses” of the spectrum, said the filing posted Monday in docket 12-268.. Carriers should be able to “engineer and test their networks free from interference by defining ‘commence operations’ as the moment of first transmission on the licensed spectrum,” said the association. “This will ensure that the band is cleared of secondary uses early enough in the testing process that essential network testing functions are not subject to interference.” After carriers buy licenses in the auction, they have lots to do to build out their networks and test services and equipment before service begins, CTIA said. The 600 MHz licensees face a tough spectrum environment, with white spaces devices, low-power TV and wireless mics also using the 600 MHz spectrum, the wireless association said. “These secondary operations have the potential to interfere with the testing and use of licensed spectrum if permitted to operate in close proximity to licensed wireless transmissions.”

The AWS-3 auction is over but “the heavy lifting” is just getting started as industry and the government work to clear the spectrum bought in the auction, said Paige Atkins, NTIA associate administrator for spectrum management, at the Commerce Spectrum Management Advisory Committee meeting (see 1505120040) Tuesday. Relocation could take up to 10 years, she said: “We expect significant sharing to occur in the interim and a lot of coordination and collaboration to occur during that time.” Atkins said the Competitive Carriers Association and CTIA will host an AWS-3 government and information exchange June 4, which will be open to winning bidders in the auction. “This is to begin the informal dialogue around expectations, processes and tools that will facilitate the transition,” she said, noting it will be similar to coordination after the 2008 AWS-1 auction. NTIA and the Institute of Telecommunications Sciences (ITS) are expanding their spectrum monitoring pilot in the 3.5 GHz band, spectrum set aside for shared use, Atkins said. They're working with federal agencies to host four additional sensors and potentially expand coverage beyond 3.5 GHz, she said. ITS, in collaboration with the National Institute of Standards and Technology, is also developing a measured spectrum occupancy database, she said. “That’s intended to make the sensor data available on a near real-time basis to support policy planning, engineering, and eventually, potentially, dynamic sharing.” Spectrum for international mobile telecom (IMT) is the top priority of the U.S. at the World Radiocommunications Conference later this year, Atkins said. “Go figure,” she said. “The challenge for mobile broadband services is the same internationally as nationally,” she said: “The most suitable bands are already being used by other services for things like broadcasting” and satellite links. The U.S. focus is on sharing, she said. The U.S. supports sharing in the 3.5 GHz band, the 600 MHz spectrum being offered in the TV incentive auction and the L band, at 1424-1518 MHz, which the U.S. supports but doesn't plan to implement here, she said. The second priority is spectrum for beyond-line-of sight command and control link for unmanned aircraft systems. A likely topic of the WRC in 2019 is a look at the use of bands above 6 GHz, she said.

The “economic value” of the 645.5 MHz of licensed spectrum in play in the U.S. is almost $500 billion, CTIA said in a report released Monday, written by the Brattle Group. Economists see the social benefits from licensed spectrum as running at least 10 to 20 times the spectrum's direct economic value, the report said.

How the FCC defines the term “commence operations” will have major implications for the success of the TV incentive auction, CTIA said in comments responding to a March 26 public notice. “It is essential that the Commission adopt a standard that is readily understood by all stakeholders and leaves no doubt as to the regulatory obligations of affected parties.” Among CTIA’s suggestions is that the FCC ensures wireless licensees have access to the spectrum they buy “free from interference, including to test their networks, by tying the definition of ‘commence operations’ to the initial transmission on the spectrum by licensee.” Wireless licensees should also have “primary control” over the notice process, CTIA said. The definition has implications for many other parts of the post-auction transition, the group said. “Before commencing operation wireless carriers must provide 120 days’ notice to Low Power Television [LPTV] and TV translator stations, and must coordinate with the National Science Foundation regarding operations at permanent fixed locations near certain radioastronomy service observatories,” CTIA said. “Critically, the date of a 600 MHz wireless licensee’s commencement of operations triggers the obligation of the secondary users of the 600 MHz band (namely LPTV, TV translator, broadcast auxiliary service, and TV white space device operations) to vacate the band.” The comments were posted Tuesday in docket 12-268.

Almost half way through 2015, with the TV incentive auction to start next year, Sprint still hasn't made any decisions about whether it will participate in the auction, CEO Marcelo Claure said on a call with analysts Tuesday. Sprint also said Tuesday it has reduced sharply post-paid churn -- the measure of customers leaving for another provider. Sprint sat out the FCC's last big auction of mid-band AWS-3 spectrum.

Competitive carriers formed a new coalition, SaveWirelessChoice, to fight against what they see as Verizon and AT&T domination of the wireless market. Initial members include Comptel, the Competitive Carriers Association, Computer & Communications Industry Association, C Spire, Dish Network, NTCA, the Rural Wireless Association, Sprint, T-Mobile and other companies and associations. “The members of SaveWirelessChoice are united by a single issue that holds massive consequences for U.S. consumers, businesses and the entire broadband economy -- and that is whether the future of wireless will be dominated by a duopoly or by competition,” said CCA President Steve Berry. The 600 MHz spectrum offered in the TV incentive auction is “the last prime spectrum real estate available,” the group said in a news release. “It is critical to ensure that smaller wireless providers have fair access to enough low-band spectrum to meaningfully compete against the country’s two largest carriers -- AT&T and Verizon -- who already own nearly three quarters of this valuable spectrum nationwide.” Public Knowledge joined the Save Wireless Choice Coalition, the group said in a news release Monday. “We can’t let AT&T and Verizon, the two largest carriers, completely dominate the wireless market by buying up all the spectrum licenses,” said Public Knowledge Senior Vice President Harold Feld. “This lack of competition drives prices up for consumers and encourages carriers to overlook updating their own networks.” Mobile Future fired back. “As consumer demand for mobile connectivity skyrockets, all wireless carriers need access to additional spectrum to support the millions of data hungry consumers devouring exponentially more bandwidth each year," the group said. "With Sprint leading the spectrum holdings pack and T-Mobile loudly touting more spectrum per subscriber than any other wireless provider, calls to 'help' Sprint and T-Mobile through spectrum set asides at taxpayer expense are misguided and gratuitous.”

U.S. Cellular representatives elaborated on the carrier’s proposal for a point system to help determine which licenses in the 600 MHz band a bidder will be assigned after the TV incentive auction. Northwestern University professor Robert Weller made the proposal in a note attached to a March ex parte filing by U.S. Cellular. “To allow bidders to express preferences without generating payments, the FCC could allocate a supply of, say, 1000 bidding ‘points’ to each bidder,” Weller suggested. “Let the bidders allocate these points across assignments, in order to indicate their preferences. Then either choose an assignment which maximizes some objective function which incorporates the point allocations, or resolve the assignment as if the points were bid amounts, but collect no payments (many colleges handle the allocation of seats in popular courses in this manner).” In the meeting last week, U.S. Cellular argued that the point system would be doable. The system “could be implemented without informing bidders of the spectrum block assignments that remain feasible for them after the auction system has optimized for the ... objectives proposed by the Commission in the Procedures PN,” the carrier said. “Our proposed ‘point system’ likely would not result in a large number of ties after bidders have expressed their preferences for particular spectrum blocks in a” particular market, said the filing posted Thursday in docket 12-268.

The FCC’s designated entity rules need to be revised before the TV incentive auction to ensure that small carriers at least have a shot at winning licenses, Panhandle Telephone Cooperative and Pine Belt Telephone Company said in a filing at the FCC. The small carriers told an aide to Commissioner Jessica Rosenworcel they are interested in buying 600 MHz licenses during the auction, but noted that the track record for small carriers was “dismal” in the recently completed AWS-3 auction. “Of the 70 qualified bidders in the auction, over half (38 or 54.3 percent) were rural telcos or rural telco affiliates, yet only 28.9 percent of the rural entities were successful in winning any licenses. Many rural bidders were completely shut out, and those that were successful won only 25 of 1,611 licenses (1.55 percent).” Despite some larger companies' use of “shell” companies as DEs to buy spectrum with bidding credits, fewer than half the successful rural telco bidders in the AWS-3 were able to qualify under DE rules as small businesses, the two carriers said. The filing was posted by the FCC Friday in docket 10-208.

The FCC should take more steps to ensure communities continue to be served by public broadcasting after the spectrum incentive auction and repacking process, said the Association of Public Television Stations (APTS) and Public Broadcasting Service (PBS) staff, collectively PTV, in an ex parte notice posted at the commission Wednesday in docket 14-252. PTV met with commission staff Wednesday to discuss noncommercial educational (NCE) broadcasters, the auction and repack, PTV said. PTV urged the commission to grant the petition for reconsideration filed Sept. 15 and to revise its incentive auction rules to ensure at least one NCE reserved channel remains in each community after the auction. The petition presents an auction design that allows broadcasters to volunteer to participate and reserves space for new entrants in case an unserved area develops in the process, PTV said. The commission also should adopt a selection priority for displacement applications of translators that NCE licensees operate, it said. PTV also encouraged the commission to provide a selection priority for NCE translators where mutually exclusive displacement applications are filed. The commission shouldn't assign TV stations in the repurposed 600 MHz band during the repacking process, PTV said. "Placing television stations in the 600 MHz band risks creating many of the same challenges faced with channel 51 for years following the digital transition, but magnified and significantly more complicated due to the combined impact of interrelated geography, frequency, and power level variables," PTV said. A contiguous TV broadcast band should be maintained because of challenges with a repacking plan that combines broadcast and wireless services in the band, PTV said.

Twenty-three non-national wireless carriers represented by the Competitive Carriers Association Wednesday asked the FCC to expand the amount of spectrum set aside for competitors to AT&T and Verizon in the TV incentive auction. The three-block reserve now in the rules for the auction is “too small to enable competitive carriers to secure sufficient spectrum in this important new frequency band,” their letter to the FCC said. “Increasing the size of the reserve helps fulfill Congressional goals and advances the public interest in promoting wireless broadband deployment.” The FCC should expand the maximum size of the reserve to four 10-MHz blocks, while limiting the amount of reserve spectrum that any one bidder can buy to 20 MHz, the small carriers said. CCA’s two biggest members, Sprint and T-Mobile, didn't sign the letter. “The very fact that twenty-three small, reserve-eligible carriers, all of whom are CCA members, have come together to stress the importance of the 600 MHz incentive auction should send a clear message to the Commission that these carriers must have a meaningful opportunity to bid on and win spectrum in the upcoming auction,” said Steve Berry, CCA president, in a news release. "Although some rural carriers buy spectrum and provide service to consumers, CCA's letter is unfortunately more of the same posturing -- rent seeking by certain companies who want to buy at a discount now, decline to build, and then later sell at a profit,” responded Mobile Future Chairman Jonathan Spalter. “There is simply no basis for the FCC to increase the size of the reserve."