Working toward an effective band plan

Today AT&T, the National Association of Broadcasters, and Verizon jointly posted the following blog.

The TV broadcast spectrum incentive auction proceeding raises some of the most difficult engineering challenges the FCC has ever faced.  One thing is clear:  a successful auction must start with an effective band plan.  A band plan must seek to mitigate interference challenges to the greatest extent possible while offering blocks of spectrum best suited for deployment by U.S. wireless carriers.  Otherwise, it will drive down the value of the spectrum and likely undermine the auction’s success.

With that in mind, broadcasters, wireless carriers and equipment manufacturers have spent an enormous amount of time, energy and expense reviewing and commenting on the optimal framework for the 600 MHz band.  Hundreds of pages of comments have been filed, two industry consensus letters have been submitted and the FCC just recently convened a day-long workshop to discuss this issue.  The result is growing consensus for adoption of a “down from 51” framework that seeks to maximize paired allocations and build guard bands only to meet engineering necessity.  This approach reflects the best collective engineering judgment of the companies most affected by the auction, including those that will spend billions of dollars to purchase 600 MHz licenses at auction and billions more to develop and deploy the spectrum in U.S. wireless networks.

Despite these significant advances, on Chairman Julius Genachowski’s last day, a Public Notice was released seeking comment on two alternative band plan frameworks, one reversing the uplink and downlink allocations and one featuring time division duplex (TDD).  The first has absolutely no support in the record and the second adopts a technological approach contrary to the one proposed by the majority of U.S. carriers.  A fair reading of the Public Notice suggests that the FCC feels the consensus approach constrains its ability to adjust the band plan to meet market-by-market variations.  We believe, however, that this notice will consume resources better spent on dealing with other critical and as-yet-unanswered questions in this proceeding, such as how co-channel interference concerns could undermine the variability of any band plan and how the FCC plans to conduct an effective re-packing.

Each of us of course will respond to the notice, but we don’t anticipate any fundamental shift in positions we’ve already taken in the record.  In the meantime, we are concerned about the apparent disconnect between the FCC and the various industries that will be critically affected by this auction.  Nothing about this auction will be easy, and, if we are to succeed, we must all work together to find solutions best designed to respond to broadcast industry concerns while meeting wireless industry requirements.