Former House Commerce Chairman Henry Waxman, D-Calif., now a consultant to T-Mobile, offered a revised approach to the duplex gap and reserve spectrum trigger for the TV incentive auction, said a letter posted Friday by the FCC. The FCC put the incentive auction items on its sunshine notice Thursday for this Thursday’s meeting, cutting off further lobbying efforts at the agency. All of the filings were in docket 14-252.

CTIA officials stressed in a meeting with aides to Commissioners Ajit Pai and Mike O’Rielly the need for the FCC to give carriers the time and information they need to make informed bids in the TV incentive auction, to guarantee the success of the auction. “CTIA urged the Commission to provide sufficient inter-service interference data, including detailed information on the television stations causing potential interference well in advance of the forward auction,” CTIA said in an ex parte filing on the meeting in docket 12-268. For example, carriers need information on potential impairments “as early as possible, including preliminary data once participants in the reverse auction are known,” CTIA said. “CTIA asked that the FCC release the formats for the files it will provide bidders during the auction well before the applications are due. In addition, the Commission should ensure that its proposals do not sacrifice informed decision-making in favor of auction speed.” The CTIA officials also cited the importance of minimizing impairment of the blocks offered for sale in the auction: “While a certain degree of impairment to 600 MHz licenses is inevitable, the Commission’s originally-proposed 20 percent threshold would result in significant impairment.”

CTIA filed a letter at the FCC Thursday laying out its bottom-line advice on rules for the TV incentive auction. Headed into next week’s vote on those rules by the FCC (see 1506250057), CTIA urged a “stop buzzer” to halt harmful interference from white spaces devices and wireless mics using the 600 MHz spectrum, in the letter, and sought eight “reforms” to the rules. CTIA President Meredith Baker, a former commissioner, signed the letter.

FCC staffers are leaning on wireless carriers to endorse their proposal to put TV stations in the “duplex gap” between uplink and downlink frequencies bought by carriers, industry and FCC officials said. Broadcasters, consumer and public interest groups, and high-tech companies have lined up against the plan, which they characterize as a change from the auction rules approved by the FCC last year (see 1507070055). Pressure has been intense, but carriers for the most part have taken more of a middle-of-the-road stance, the officials said, saying the issue has emerged as the biggest hot-button issue going into a vote on the TV incentive auction rules next week (see 1506250057).

The Competitive Carriers Association, joined by Dish Network, Sprint and T-Mobile, met with FCC Commissioners Jessica Rosenworcel and Mike O’Rielly to explain why the FCC should mandate a 40 MHz spectrum reserve, or 50 percent of what is auctioned, as it takes up incentive auction rules. The reserve spectrum is set aside for carriers without significant low-band holdings in a particular market. FCC Chairman Tom Wheeler has proposed instead that the rules keep the 30 MHz reserve approved by the FCC last year (see 1506250057). “The spectrum reserve is the only competitive safeguard still under consideration to prevent AT&T and Verizon from using the 600 MHz auction to further consolidate their already considerable low-band spectrum holdings,” said a filing by the competitive carriers in docket 12-268. “In addition, AT&T or Verizon are reserve eligible in most of the country, including 74 percent of the nation’s geography and 40 percent of the [POPs].” CCA supports any proposal that would address concerns about the current trigger for determining when the reserve kicks in, CCA said. The currently proposed trigger “opens opportunities for gaming if the Commission pursues high clearing targets -- with attendant high clearing costs -- at the outset of the auction, but later falls back to a lower clearing target with lower clearing costs during a subsequent round,” CCA said.

T-Mobile representatives cautioned about an FCC proposal to put the brakes on joint bidding arrangements in the TV incentive auction (see 1506250057). FCC Wireless Bureau staff “explained their recommendations … to limit joint bidding arrangements among nationwide carriers as well as among nationwide and non-nationwide carriers in the upcoming 600 MHz auction,” said a filing posted Monday in docket 14-170. “T-Mobile cautioned against adoption of overly broad and ambiguous joint bidding restrictions that could have unintended negative consequences for a robust auction by limiting the ability of smaller bidders to raise capital against well-heeled dominant carriers.”

CTIA and member companies asked the FCC to “engage” with potential bidders in the TV incentive auction in an “iterative, collaborative” process aimed at helping them understand the data the FCC will provide during the auction. The industry representatives met with FCC officials Wednesday to discuss their concerns, said an ex parte filing Monday in docket 12-268. The FCC “should adopt frameworks that speed deployment and promote bidder confidence,” CTIA said. “For example, 600 MHz licensees should be permitted to conduct pre-deployment testing of licensed spectrum without any encumbrances from secondary users of the spectrum as soon as possible and should not be required to provide ongoing notifications to secondary operations once a licensee has initiated transmissions.” CTIA also asked the FCC to clarify the scope of a requirement on what would trigger additional inter-service interference analyses and “fully disclose any potential impairment associated with this process,” the filing said. “For example, 600 MHz licensees should not be required to conduct extensive analyses of interference effects if proposed mobile network modifications would not increase the interference potential to a broadcast station.”

There's broad industry agreement that the FCC should minimize the intentional placement of U.S. TV stations in the 600 MHz band as part of the TV incentive auction repacking, an AT&T official said in various meetings at the FCC. “As the record confirms, repacking U.S.-based television stations into the 600 MHz band will significantly degrade the quality of the adjacent licenses for mobile wireless use, both within the same market and in geographically adjacent markets,” AT&T said in a filing in docket 14-252. Doing so would reduce the value of licenses sold to carriers in the forward part of the auction, AT&T said. The impairments also would “force the Commission to offer non-generic licenses under circumstances in which bidders cannot know during the forward auction which licenses they will ultimately receive, and that uncertainty will cause bidders to further reduce their bids,” the carrier said. The filing was signed by Joan Marsh, AT&T vice president-federal regulatory.

Sprint CEO Marcelo Claure and T-Mobile CEO John Legere are duking it out on Twitter. Meanwhile, Verizon and AT&T both attacked T-Mobile Thursday in blog posts, both on the TV incentive auction. Claure tweeted Tuesday about Sprint’s new unlimited data plan (see 1507010011). “We heard you loud and clear and we are removing the 600 kbps on streaming video,” Claure said, under the hashtag “Allin.”

Test results by consultant V-Comm show major interference issues if white space devices and wireless mics are allowed to use the 600 MHz guard band or duplex gap after the TV incentive auction, said CTIA officials and representatives of member companies in a meeting with aides to FCC Chairman Tom Wheeler. According to an ex parte filing in docket 12-268, "CTIA explained the incentive auction represents a once-in-a-lifetime opportunity for the Commission to make available much-needed spectrum for mobile broadband use and noted the wireless industry’s willingness to invest in spectrum rights so long as those spectrum rights are afforded the interference protections mandated by Congress in the 2012 Spectrum Act.” The industry representatives also stressed the need for the FCC “to increase out-of-band emission and frequency separation as outlined in V-COMM’s report,” the filing said. Carriers need certainty and the current rules "threaten to undermine the success of the incentive auction," CTIA said.