A variable band plan would allow the commission to auction off a different amount
of spectrum in discrete geographic areas. It favors this approach because it would
bring more spectrum to, and therefore more revenue from, the auction. Both broadcasters
and wireless providers oppose a variable band plan because their signals would overlap on
the same channel in different markets and wreak havoc with one another.
The OET’s Jan. 29 Public Notice indicates the agency is sticking to it’s guns. The
26-page document seeks a second round of comments on TV-cellular interference, assuming
a variable band plan. Given that
the first round treated a variable band plan theoretically, the resulting comments
didn’t provide the type of details the commission sought.
General consensus in the first round was to establish a “separation distance” between
wireless and TV operations. The commission said proposed distances ranged from 100
to 500 kilometers with “limited technical analyses in support of these proposals.”
It also characterized the approach as “spectrally inefficient and overly conservative”
because it treats all interference scenarios identically and without regard for
variations in terrain, transmitter power, antenna height and so forth.
“Such an approach also fails to account for technologies and techniques that wireless
licensees might employ to mitigate potential interference, such as antenna characteristics
and resource block provisioning,” the Notice said.
Rather than a fixed separation distance, the commission is proposing using predictive
analysis based on the Longley-Rice model now used for estimating potential interference
between TV signals in OET Bulletin No. 69. (Longley-Rice signal propagation image at right.)
“The methodology described… may be used
to predict whether interference is expected to occur at a location and thereby establish
the necessary separation distances in a deterministic way,” the Notice said.
OET-69 has never been applied to wireless services nor in a mixed-use context,
but the OET said that it could work in three of four possible interference scenarios:
DTV transmitter to wireless uplink; DTV transmitter to wireless downlink; and vice
versa for both.
Use of the ATSC standard for TV stations and LTE for wireless providers is assumed.
Signal overlap virtually is guaranteed in a variable band plan because wireless
providers will be licensed in 5 MHz chunks while broadcasters transmit on 6 MHz
channels. The amount of overlap will vary. To account for it, the OET proposes to
define co-channel TV/wireless pairs as having 1 to 5 MHz of overlap, and adjacent-channel
pairs as being within 5 MHz of one another.
First-round comments focused on co-channel rather than adjacent-channel interference
because of the presumed use of guard bands. With a variable band plan, “guard bands
could be slightly different in each market, creating the potential for interference
between DTV and wireless services that otherwise would not exist,” the Notice said.
The OET therefore asks for feedback on “the impact of adjacent-channel interference
constraints in the context of market variation.”
The OET is soliciting comments on “whether this methodology can provide greater
accuracy than a generic separation distance in predicting potential harmful interference
between services.” It also asks if analog TV transmissions should be considered,
since some low-power U.S. TV stations and translators still use the format, as well
as broadcasters in Mexico and a handful in Canada.
The commission will hold a workshop and webinar on its predictive interference proposal
on Feb. 21. Comments are due on Dockets No
14-14 and 12-268 (the incentive auction Notice of Proposed Rulemaking) by Feb. 28,
December 2, 2013:
Challenges FCC’s ‘Reasonable Effort’
FCC is proposing the use of “proxy” channels in calculating the reach of TV stations
relocated after next June’s spectrum incentive auction.
August 22, 2013,
The software developed to determine TV channel assignments following next year’s
spectrum incentive auction can churn hundreds of millions of data sets requiring
hours of processing.
August 20, 2013,
Update No. 3 Does Cross-Border Analysis
Vers. 1.2.7 is said to be able to perform cross-border channel
analysis of TV signal interference between stations in the United States and those
in Canada and Mexico “on proxy channels.”
July 22, 2013:
Releases Channel Repack Analysis, Updated OET-69 Software
“One of the key advantages of the TVStudy
Vers. 1.2 software is its ability
to easily replicate multiple stations to generate various nationwide scenarios,”
the commission said.
June 21, 2013,
Band Proposals Diverge
No single solution is emerging for how the TV spectrum should be configured following
next year’s incentive auction. -
June 7, 2013: “$370 Million in TV Deals Done for Spectrum Auction
$370 million worth of TV stations have traded hands with the express purpose of
offering them up in the incentive auction.
June 25, 2013
Consensus Really Means and the Importance of Driving It
” ~ by Rick
Kaplan at NAB’s Policy Blog.
June 21, 2013
: “A Band Plan That Serves the Public Interest
by Ruth Milkman at the Official FCC Blog.
June 21, 2013
: “TV Band Plan Proposals Diverge
The commission’s original band-plan proposal layered TV stations between wireless
uplink and downlink bands.
April 26, 2013,
Releases Updated OET-69 TVStudy Software
“This update addresses an issue with calculation cell indexing that can result in
the population of some cells not being correctly considered, and which may cause
the program to crash in unusual instances.”
March 18, 2013
: “NAB’s Kaplan: Rushed Incentive Auction in 2014 Will ‘Fail’
If the commission insists on holding this auction—and does so—in 2014, the auction
will almost certainly fail,” Kaplan.
February 6, 2013:
Update Injects Legal Uncertainty
Insiders say wagons are circling over the new methodology for predicting TV
station coverage and interference.
February 5, 2013
, “FCC Reveals Crucial Piece of TV Channel Repacking Model
The FCC has quietly revealed what amounts to its methodology for repacking TV channels
in the post-incentive auction spectrum band. The agency released a new version OET-69
software that it intends to use for the repacking, and is seeking input on its efficacy.
January 24, 2013
Wireless Providers, Agree on Contiguous Repack
Broadcast and wireless lobbies agree on one thing regarding how the TV band is repacked
after the 2014 spectrum incentive auction: They don’t want to mix it up.
December 21, 2012
: “McAdams On: $pectrum, Guard Bands and Ch. 51
Congress is betting enough TV stations voluntarily either move in together or get
out of business such that it will raise upwards of $30 billion. This means that
Congress fully expects at least 20 TV channels in every market to be cleared.