Skip to main content

TV Band Plan Proposals Diverge

WASHINGTON — No single solution is emerging for how the TV spectrum should be configured following next year’s incentive auction. So says Ruth Milkman, chief of the Federal Communications Commission’s Wireless Bureau.

“At last count, there were over a dozen proposed band plans in our record,” she said in a blog post on Friday. “While some differ substantially, many seem at a high level to be quite similar—and without close review may even give the misleading impression that a ‘consensus’ has in fact been reached. But we all know that the devil is in the details, and in reality the proposed plans are dissimilar in notable respects.”

The commission’s original band-plan proposal layered TV stations between wireless uplink and downlink bands. The National Association of Broadcasters along with several wireless providers counter-proposed a plan under which spectrum would be reassigned contiguously from the top of the TV band on down. Specifically, it would comprise a wireless uplink band starting at Ch. 51 (698 MHz), then a duplex gap and downlink band, situated possibly on both sides of Ch. 37, now occupied by radio astronomy.

This “Down from 51” plan, as well as a reverse model of same, was put out for comment by FCC Public Notice in May. The first round of feedback was due June 14. Replies are due June 28.

In the reverse Down from 51 plan, downlink would start after a duplex gap at Ch. 51 (abutting the established uplink band in the adjacent 700 MHz spectrum at Chs. 51-69), then uplink would begin below that after a duplex gap, straddling Ch. 37 if more than 84 MHz is cleared. A second Down from 51 reverse plan establishes a fixed downlink band at the top and varying amounts of spectrum dedicated to uplinking in individual markets, i.e., market variation. The uplink band would again straddle Ch. 37 if more than 84 MHz of spectrum is cleared.

Few parties support reverse Down from 51 because it would require the extra duplex gap and therefore be a “waste of spectrum,” said one broadcast executive familiar with the proceeding. The commission is also proposing to allow TV stations to operate in the duplex gaps, but the same executive said that “putting us between their operations creates enormous interference… to us and a lot to them.”

Milkman said that there was general support for Down from 51, but in various forms.

“A number of commenters support band plans that are in the ‘Down from 51’ family,” she said. “But some plans would limit paired licensed spectrum to 50 MHz, while others call for a larger number of paired bands.” Here, Milkman refers to proposals from AT&T; then T-Mobile and Verizon Wireless.

Where T-Mobil and Verizon do diverge is on market variation, i.e., freeing a different amount of spectrum in various geographic areas. The FCC favors market variation as a means to bring as much spectrum as possible to auction, and thereby maximize revenues for the Treasury. (Money already spent by Congress to extend unemployment benefits.)

“Were we to implement a plan that does not accommodate market variation, we could be forced to limit the spectrum available in all markets to the relatively small amount available in the most constrained market,” Milkman said.

Broadcasters and Verizon prefer consistent, nationwide spectrum blocks as a means to prevent co-channel interference.

“What we’ve said is, a TV channel still on Ch. 48 in New York is going to interfere with wireless on Ch. 48 in Philly,” said an NAB executive. “We’ve made clear you have to have a national plan. Wireless carriers didn’t anticipate this plan, but fear not getting enough in some markets. They’ve realized we’ve raised a good engineering point.”

January 24, 2013
, “NAB, 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.