WASHINGTON – 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. Both agree that spectrum should be reassigned to wireless providers contiguously from Ch. 51—now the top TV channel—down. The proposed band plan from the Federal Communications Commission has wireless uplink starting at Ch. 51 and extending downward, while the downlink band would start at Ch. 36 and extend downward.

“This creates a tremendous amount of interference between us and the wireless guys,” said Rick Kaplan, executive vice president of strategic planning for the National Association of Broadcasters.

Kaplan, along with executives from AT&T, Verizon Wireless, T-Mobile, Qualcomm and Intel have all signed off on a letter to Ruth Milkmen, head of the FCC Wireless Bureau, and Gary Epstein, Incentive Auction Task Force chair, urging them to adhere to 10 procedural conditions in the repack, including the contiguous reassignment. :

 

•Adopt a contiguous “down from Ch. 51” approach with uplink at the top;

•Maximize the amount of paired spectrum above Ch. 37 (rely on supplemental downlink configurations where spectrum is cleared but pairing options are not viable);

•Rely upon 5 MHz spectrum blocks as building blocks for the band plan;

•Incorporate a “duplex gap” or spacing between uplink (mobile transmit) and downlink (base transmit) of a minimum of 10 MHz, but no larger than technically necessary;

•Avoid broadcast television stations in the duplex gap;

•Preclude any operations in the duplex gap or guard bands that would result in harmful interference to adjacent licensed services;

•Provide guard bands that are, consistent with the statute, “no larger than is technically reasonable” to guard against harmful interference between adjacent operations;

•Provide a guard band between a high-power broadcaster and mobile downlink that is sufficient to protect the wireless service from interference, which will likely be larger than the 6 MHz proposed by the FCC;

•Permit existing operations in TV 37 to remain;

•Facilitate international harmonization, prioritizing harmonization across North America and move forward expeditiously to coordinate with Canada and Mexico for new broadcast assignments.Kaplan noted that moving stations within 250 miles of the Canadian border requires coordination with that border nation.

Also, notion that guard bands might need to be heftier than 6 MHz is counter to the hopes of Republican members of the House Communications and Telecom Subcommittee, who want as much spectrum as possible to be auctioned off in order to generate revenues. Democrats on the subcommittee want the guard bands preserve for unlicensed devices, as the FCC has proposed. Kaplan said the size of the guard band would be an issue for the wireless providers to determine.

The letter refers to the FCC incentive auction docket, No. 12-268, for which comments are due tomorrow, Friday, Jan. 25.

~ Deborah D. McAdams