Inserting unlicensed services in the 600 MHz band, without unduly expanding the size of the guard bands and duplex gap, “will impair the adjacent mobile spectrum blocks and effectively destroy the fungibility of the licensed mobile spectrum that the Commission is working so hard to repurpose through the upcoming voluntary incentive auction,” Qualcomm told the FCC Wednesday (http://bit.ly/1gm79kk). The company was responding to a filing by Google and Broadcom, which “only analyzed a single use case” of the adjacent channel out-of-band emissions of the unlicensed device into an LTE user device, Qualcomm said. Google and Broadcom “completely overlooked the impact of blocking,” Qualcomm said. “Inserting unlicensed services in the 600 MHz band would be unwise from both technical and economic perspectives, will create wide areas of interference and impair the value of the adjacent licensed spectrum, and should therefore be avoided.”

New questions are starting to percolate about the conventional wisdom that, given expanding demands for data bandwidth, the AWS 3 and TV incentive auctions will each be a huge success, raising billions of dollars for the U.S. Treasury. The two are the first major auctions since the 700 MHz auction, which was under way at this time six years ago.

Intel continues to favor allocating additional spectrum at 5 GHz for unlicensed use and maximizing the amount of spectrum for unlicensed in the TV band, said Peter Pitsch, executive director-communications policy, in a meeting with Jeffrey Neumann, aide to FCC Commissioner Ajit Pai. Intel favors a band plan for 600 MHz spectrum with seven pairs of wireless licenses offered for sale if possible, Pitsch said, said an ex parte filing from the company. “The licensees in the top markets, if they unanimously agree, should be able to make band plan changes after the auction closes,” he said. “The FCC should consider setting nationwide reservation prices for the guard band and duplex gap based on its assessment of the societal value of unlicensed use of these bands and put the guard band and duplex gap out for bid. If the total bids exceeded the respective reservation price, then the guard band or duplex gap would be licensed, otherwise, they would be unlicensed.” Other companies have been lobbying the FCC in recent days on Wi-Fi and unlicensed spectrum (CD Feb 6 p17).

The wireless industry asked the FCC to move forward on proposals to make wireless siting faster, especially in light of upcoming spectrum auctions that will require additional buildout. The FCC began a rulemaking in September (CD Sept 27 p10) on speeding wireless siting, especially for distributed antenna systems and small cells. Local government groups are raising concerns about the loss of local control on zoning decisions (CD Feb 4 p11). The FCC logged nearly 100 comments in the initial comment cycle. Industry officials said work on the NPRM presents FCC Chairman Tom Wheeler with a series of issues that will inevitably prove controversial.

A report and order establishing the framework of the incentive auction will be presented to the FCC this spring, announced the Incentive Auction Task Force in its update presentation at Thursday’s open commission meeting. The R&O will be followed by two public notices and comment periods to finalize every aspect of the auction, applications from prospective bidders will begin to be accepted in early 2015, and the auction itself will be held in mid-2015, said task force’s Chairman Gary Epstein. The NAB and CTIA praised the commission’s timeline, though some broadcast attorneys told us they're concerned about a lack of specificity and the commission’s plans for reaching out to broadcasters. “We are on course at speed to get this thing done,” said FCC Chairman Tom Wheeler.

The FCC Office of Engineering and Technology asked for supplemental comment on a methodology for predicting potential interference between broadcast TV and licensed wireless services in the incentive auction. In response to the NPRM and the 600 MHz band plan supplemental public notice, some commenters raised concerns about co-channel and adjacent-channel interference between TV and wireless services in nearby markets as a result of accommodating market variation, OET said Wednesday (http://bit.ly/1ffr6KP). “Some commenters proposed separation distances between the two services. The most common approach commenters propose is to use a pre-defined separation distance between TV and mobile service areas. Commenters proposed distances that varied significantly -- ranging from 100 kilometers to 500 kilometers -- and generally provided limited technical analysis in support of these proposals.” Comments are due Feb. 28. Thursday’s FCC meeting will hear an update on the incentive auction. (See separate report in this issue.)

The FCC’s spectrum auction update should go beyond dates and timelines and dig into the substantive issues on the auction, said NAB Executive Vice President-Strategic Planning Rick Kaplan in a blog post Wednesday (http://bit.ly/1aFEKrW). The time is “ripe” for FCC staff to reveal its approach to “hotly contested topics” on the auction, Kaplan said. NAB would like the commission to announce early which broadcasters will receive protection in the repacking, relocation and protection procedures for translators and low-power TV, and the eligibility constraints placed on forward auction bidders. The commission should also announce that all changes to repacking software OET-69 will be dropped, and form an expert group to evaluate the repacking software, he said. The FCC should also release more information about its work in resolving spectrum issues along the Canadian and Mexican borders, Kaplan said. Such a release would “not merely list the number of meetings with Canada and Mexico; but rather, will detail how the staff intends to proceed if it has no agreement in place with one or both countries,” he said. FCC Chairman Tom Wheeler told lawmakers he doesn’t expect to have such agreements, Kaplan said. “Assuming that it is even lawful to proceed with the auction without these agreements (and NAB believes it is not), how will a lack of meaningful coordination affect the auction and the amount of spectrum recovered across the country?” Kaplan asked. The update should also include updates from FCC staffers on their current thinking on the 600 MHz band plan and their plans for wireless microphones, and the FCC should release a public notice on co-channel interference, Kaplan said. Wheeler should also “publicly affirm” that the FCC won’t “take actions to harm broadcasters in unrelated proceedings to encourage participation in the auction,” Kaplan said. “If there was ever a time the Commission needed to develop trust with broadcasters, that time is now,” said the blog post.

The FCC should dedicate more spectrum in the 600 MHz and 5 GHz bands for unlicensed use, Wi-Fi Alliance officials said in a meeting with FCC Commissioner Mike O'Rielly. In the 600 MHz band, the FCC should make four 6 MHz channels available to take advantage of legacy 20 MHz-wide Wi-Fi standards, alliance representatives said, according to an ex parte filing (http://bit.ly/1b1JaY3). “The Wi-Fi Alliance noted that there has been little use of the spectrum dedicated for white spaces operation because of the uncertainty regarding the future use of the 600 MHz band."

The FCC should take the idea of making changes to the software that will be used in the post-incentive auction repacking “off the table,” said NAB in an ex parte filing (http://bit.ly/1n8ns9Q). “Changing stations’ coverage areas during the auction process is antithetical to the stated purposes of the” Spectrum Act, said NAB. To coordinate the repacking, the FCC should create “an expert group of outside stakeholders” to test the software when it’s finished. “This proactive engagement will allow the FCC to have the confidence that its software is ready for prime time and will tap into the resources of various industries that are committed to seeing a successful auction,” said NAB. The repacking solution also needs to take the borders with Canada and Mexico into consideration, NAB said. Without new agreements with those countries, it will be “nearly impossible” for the FCC to reclaim enough spectrum “within 250 miles of the Canadian border and 150 miles of the Mexican border” because of interference issues, NAB said. It also urged the commission to appoint an “independent, third-party administrator” to oversee the process of reimbursing broadcasters for costs from the repacking. The TV Broadcaster Relocation Fund should be treated as a budget for the repacking, NAB said. “It is nonsensical to suggest that Congress only sought to cover some unstated portion of non-participating broadcaster costs as opposed to making them whole,” said NAB. The FCC should also process channel substitution applications submitted before the freeze on such applications, protect stations’ translators in the auction, and make its “latest thinking” on the incentive auction band plan available for public comment, NAB said. The FCC should also create a solution that provides adequate spectrum for wireless microphone operation, NAB said. The association is exploring the possibility of giving wireless microphones access to the duplex gap, and examining “the viability of LTE/wireless microphone coexistence in the upper 600 MHz band,” the ex parte said.

The FCC’s WRC Advisory Committee (WAC) agreed to disagree Monday on a proposal on whether the U.S. should recommend that the 460-890 MHz band is suitable for both mobile broadband and broadcasting, in any position paper to be submitted to the next World Radiocommunication Conference. NAB has insisted a U.S. position is premature, especially since the FCC has yet to approve a band plan for the 600 MHz band tied to the incentive TV auction (CD July 9 p1).