Many FCC proposals to relax rules for unlicensed uses in the TV band “lack sound engineering support,” NAB told an aide to Commissioner Ajit Pai Wednesday, according to an ex parte filing posted online in docket 12-268 Friday. Proposals to allow fixed devices to use channels adjacent to TV channels don't account for the different interference characteristics of portable and fixed devices, NAB said. The FCC's proposal on a search for additional spectrum in which to place wireless microphones doesn't address “the urgent need for some reserved spectrum for licensed wireless microphones in all markets,” NAB said.
Without the proper reserve spectrum trigger, AT&T and Verizon could easily “foreclose” the ability of competitive carriers to buy licenses in the TV incentive auction, T-Mobile warned in a letter to the FCC. “AT&T and Verizon will benefit financially if they can delay the spectrum-reserve trigger,” T-Mobile said. “Bidding on all blocks, including the reserve blocks, will continue to increase after the spectrum-reserve trigger is met so long as demand exceeds supply.” If the reserve “successfully encourages AT&T and Verizon to bid only fair market value as opposed to the foreclosure value they would gain from excluding competitors from acquiring the low- band spectrum necessary for competition, no differential between reserve and non-reserve prices should exist at all.” Verizon made a filing of its own Thursday, slamming T-Mobile's pursuit of a revised trigger. The trigger T-Mobile wants would "jeopardize the auction, by shielding bidders for set-aside spectrum from fully competitive bidding before the auction raises enough money to cover all expenses," Verizon said. "It would tilt the auction rules further in their favor. And by triggering the set aside when prices reach $2.00 in the largest 40 markets, an arbitrary figure that is not grounded in market data, the proposal would allow T-Mobile and others to win spectrum at even lower prices." Both filings were in docket 14-252.
NCTA took issue with Qualcomm’s recent critique of many LTE-unlicensed comments filed at the FCC as being “misleading or outright incorrect statements” (see 1507280013). “In Qualcomm’s through-the-looking-glass world, PowerPoint presentations and unilateral pronouncements amount to collaboration, and sharing mechanisms that can be unilaterally scaled back or turned off constitute a fair and equitable approach,” NCTA said. NCTA said it's willing to work with Qualcomm and other LTE-U advocates on solutions that will allow the technology to make full use of unlicensed spectrum. “But this process will require Qualcomm and others to recognize the shortsightedness of their ongoing efforts to downplay the serious concerns of consumers and the unlicensed community, and to recognize that the so-called ‘sharing solutions’ suggested to date are incomplete and insufficient,” NCTA said. The comments were in docket 15-105.
The FCC needs to ensure that three channels are available for unlicensed use in every U.S. market and the agency should designate additional channels, including Channel 37, for unlicensed use, Google executives said in a series of meetings at the FCC. Alan Norman, Google principal-access strategy team and General Counsel Austin Schlick were among those who met with the FCC officials, Google said in a filing in docket 15-146. The officials also said new data shows a 40 mW white spaces device can safely operate in the duplex gap between carrier operations without causing interference to LTE in adjacent spectrum. "Common use cases add significant shadowing losses to unlicensed device signal propagation, as compared [with] idealized free space conditions,” Google said. Also, out-of-band emissions from an unlicensed white spaces device “do not affect LTE operations,” the company said. Google also discussed the possible benefits of establishing a 1 MHz separation between unlicensed channels in the duplex gap.
“Contrary to the claims of several commenters” Qualcomm “has worked, and is continuing to work” with the whole wireless industry to ensure that LTE-unlicensed can peacefully coexist with Wi-Fi, Qualcomm said in a filing at the FCC. The comments, in docket 15-105, respond to other filings there. In April, when the FCC finalized rules for the 3.5 GHz shared spectrum band, it agreed to seek comment on LTE-U and license assisted access (LAA) services (see 1504170055). The comment cycle closed in June (see 1506290060). Qualcomm also disputed claims that LTE-U’s and LAA’s coexistence features are vague and undefined. “To put these claims in perspective, Wi-Fi has no coexistence specification,” Qualcomm said. “The Wi-Fi Alliance merely has an interoperability specification and is currently studying whether to adopt a Wi-Fi coexistence specification. By contrast, LTE-U was built from the ground up to coexist well with Wi-Fi and to ensure that there will be no adverse impact on Wi-Fi.” The record also shows LTE-U and LAA “do share spectrum fairly,” Qualcomm said. “The record shows that Qualcomm, in the case of LTE-U, has conducted comprehensive testing in the laboratory and in the field, demonstrating that LTE-U has no adverse impact on Wi-Fi, and in many cases actually improves throughput for nearby Wi-Fi users.”
Representatives of the Wireless Medical Telemetry Service Coalition made their case Thursday for delaying a decision on Channel 37, used by medical devices, and for not addressing future use of the channel at the commission’s Aug. 6 meeting. The coalition representatives in meetings with FCC officials discussed a letter the group filed at the FCC last week (see 1507230053), seeking a three-month delay in a decision on Channel 37, said a filing in docket 12-268, posted Monday. “The Coalition also generally discussed the framework of discussions underway with representatives of the unlicensed device community … which would form the basis for an industry-wide resolution of those technical rules for the Commission’s consideration,” the coalition said.
NAB wants a 21-day extension of the deadline for comments on the FCC’s proposal to preserve one TV channel for use by TV white space devices and wireless microphones, the association said in a motion posted online Monday. Comments in the proceeding are currently due Aug. 3, replies Aug. 31. Under the NAB proposal, those deadlines would move to Aug. 24 and Sept. 23. The extension is merited by the FCC’s delay in releasing a procedures public notice (see 1507150058), NAB said. “Because the vote on the Procedures Public Notice was delayed by three weeks, NAB respectfully submits that a three-week delay in the comment deadline in this proceeding would be appropriate,” the motion said. The FCC “will have a better, more informed record” if comments are filed after the procedures PN, NAB said.
CTIA filed a petition for reconsideration asking the FCC to revise rules for the 3.5 GHz shared spectrum band. “A handful of policies adopted in the 3.5 GHz Order … threaten to undermine the investment and innovation necessary for the new 3.5 GHz Band to succeed,” CTIA said. The wireless association asked the FCC to increase the license terms for priority access licenses (PALs) to at least five years “and adopt an expectation of license renewal so that the risk of stranded investment does not deter interest in the band.” The FCC approved three-year license terms as part of the rules for the band. CTIA also asked the agency to revise a decision to auction one less PAL than the total number of PALs applied for in a given Census tract “so as to avoid systematically phasing out PALs with each subsequent auction.” The commission also should increase out-of-band emission limits “that otherwise will force licensees operating 20 MHz LTE channels to engage in power backoff” and increase power limits “to allow for meaningful indoor and outdoor coverage,” CTIA said. The commission approved its order creating the new Citizens Broadband Radio Service in the 3550-3700 MHz band at its April meeting (see 1504170055). Parts of the rules took effect Thursday.
Protecting licensed users of 600 MHz spectrum from unlicensed devices and wireless mics is key to a successful TV incentive auction, CTIA said in a filing Thursday in FCC docket 14-165. Tests show that the FCC’s proposed technical rules “would result in harmful interference to licensed services in violation of the Spectrum Act,” CTIA said. “It is essential that the Commission provide a means for addressing harmful interference from unlicensed white space devices and wireless microphone operations in the event they cause harmful interference to licensed wireless services in the 600 MHz band,” the wireless association said. “In other proceedings where the Commission has used a predictive model to prevent interference, the Commission also has adopted rules requiring the termination of interfering operations.”
It's “in the national interest” for “policymakers to execute a new spectrum plan to maintain the United States’ global wireless leadership position,” CTIA officials said in a meeting with FCC Commissioner Mike O’Rielly. CTIA wants the agency to “take up this mantle and identify and repurpose over 350 MHz for licensed mobile broadband services by 2019,” CTIA said in the filing Wednesday in docket 15-125. The TV incentive auction is critical to meeting growing spectrum needs, the association said. Final auction procedures and rules “can have a significant impact on wireless industry participation and the ultimate success of the auction,” the group told O’Rielly. “It is essential that the Commission adopt an auction framework -- including auction procedures, rules to protect licensed services, rules to govern licensees’ access to newly-purchased spectrum, and protections for remaining broadcasters -- that minimizes complexity and provides potential forward auction participants with the certainty needed to make the substantial capital investments that will be required for the auction to succeed.”