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).

With the FCC apparently set to embrace Partial Economic Area (PEA) licensing in the incentive TV auction (CD Jan 16 p1), the big debate has shifted to whether the FCC should allow package bidding. Small carriers warned of the dangers of package bidding, while AT&T said it is necessary, especially if the FCC embraces license sizes smaller than Economic Area (EA) licenses for the auction. Package bidding allows a carrier to make a single bid for a particular package of licenses, rather than bid for each on an individual basis.

Change is on the way for the FCC Incentive Auction Task Force. The agency is poised to add longtime cable and wireless attorney Howard Symons to the team, as vice chairman to current task force Chairman Gary Epstein, industry and agency officials told us. Meanwhile, the FCC appears poised to give small carriers a win on at least one big issue -- the geographic size of the licenses that will be offered in the auction.

Top U.S. wireless carriers Verizon Wireless and AT&T told the FCC it should move forward with its original proposal to license the 600 MHz band and AWS-3 spectrum based on Economic Areas, rather than adopt the Competitive Carriers Association’s alternate proposal to license the spectrum based on Partial Economic Areas (PEAs). The PEAs, as proposed by CCA, would essentially be a subdivision of EAs and would be based on EA and Cellular Market Areas (CMA). The FCC had sought public input on the CCA proposal, which also has support from other rural carriers, and comments were posted online Thursday and Friday.

The FCC should reject an NTCA/Rural Wireless Association proposal to divide the forward auction of 600 MHz spectrum into two phases (CD Jan 9 p2), said AT&T in comments filed Thursday. Dividing the forward auction into one phase for purchasing large lots of urban spectrum and a second phase for smaller chunks of rural spectrum “adds complexity to what has already been widely acknowledged as one of the most complicated proceedings in Commission history,” AT&T said. The telco also argued that the two-phase auction would still expose buyers to aggregation risks, making it difficult for companies to provide coverage over large uninterrupted areas. Though the NTCA/RWA proposal framed the two-phase auction as still allowing carriers like AT&T to purchase large pieces of spectrum, the pieces aren’t big enough, AT&T said. The proposal would still lead to “operational difficulties inherent with such small license areas,” AT&T said.

The FCC forward auction of 600 MHz wireless spectrum should be split into two sequential phases, one covering high-demand urban areas and a second for smaller rural markets, suggested a NTCA- and Rural Wireless Association-sponsored report by NERA Economic Consulting (http://bit.ly/1afZ6Ws) filed Wednesday. The proposed plan would auction off urban, high-spectrum use markets under the economic areas licensing structure initially proposed by the FCC and favored by large carriers, while selling off rural spectrum in the smaller, geographically-based lots favored by NTCA and local carriers, called partial economic areas (PEAs), said NTCA Director-Legal Affairs Jill Canfield in an interview. The proposal might be a way to bring more participants to the auction by encouraging smaller carriers, and could be attractive to larger carriers by allowing them to avoid spectrum caps, said Telecommunications Industry Association Director-Regulatory & Government Affairs Mark Uncapher.