The Competitive Carriers Association and leading members T-Mobile and Sprint jointly met with FCC Commissioner Mignon Clyburn to make their case for a larger spectrum reserve than the 30 MHz proposed by the commission. Dish Network was also at the meeting. The competitive carriers also stressed the importance of getting the reserve trigger right in the auction rules, said a filing posted Monday in docket 12-269. “The spectrum reserve is the only remaining competitive safeguard still under consideration to prevent AT&T and Verizon from using the 600 MHz auction to further consolidate their already considerable low-band spectrum holdings,” the competitors said.
The Wireless ISP Association defended its proposal to establish a professional installer program for TV white spaces devices and the 3.5 GHz shared spectrum band. The FCC should keep in place rules that allow professional installation in both bands, WISPA said. “The effectiveness of a professional installation certification program will benefit all spectrum users,” the group said. “To that end, WISPA invites stakeholders to work with WISPA to help develop an effective program that can apply in all spectrum bands.” The letter was posted in docket 14-165. NAB has questioned the viability of professional installer programs, especially in the 3.5 GHz band. “Simply put, experience has confirmed that professional installation is unreliable and inadequate,” said an NAB letter in the same docket. “Further, professional installation is not appropriate for consumer devices that are likely to be deployed in the 3.5 GHz band, and mere tweaks to the rules regarding the definition of 'professional installation' are unlikely to address the fundamental problems.”
The Obama administration is almost halfway to meeting its target of providing 500 MHz of additional spectrum for broadband in 10 years, NTIA Associate Administrator Paige Atkins said Wednesday in a blog post. The target was set in 2010. “I’m happy to report that we are making steady progress toward meeting the President’s 500 megahertz goal,” Atkins wrote. “In the last five years, NTIA and the FCC have repurposed 245 megahertz of spectrum that will enable the deployment of licensed and unlicensed broadband technologies.” Atkins included among the administration’s accomplishments the spectrum sold in the AWS-3 auction and the 3.5 GHz shared spectrum band. “While we’re on track to achieve the President’s goal, we recognize there is still much work to do,” she said. “The next opportunity to generate additional spectrum for wireless broadband will come early next year with the FCC’s planned launch of the first-ever spectrum incentive auction.” Finding spectrum for broadband is “a process that only increases in difficulty,” she said. “However, we are confident that our recent collaborative efforts have laid a foundation for us to build upon and charted a course for producing additional success stories.” NTIA “is a bit aggressive in its accounting,” CTIA Executive Vice President Brad Gillen said in an emailed response. “For example, it’s premature to count the 3.5 GHz spectrum given the substantial questions that still remain about the framework for its use,” Gillen said. He also questioned whether the 10 MHz of Wireless Communications Service guard band can be counted for broadband use. “None of that takes away from the Administration’s significant efforts to get as far as we have in five years,” he said. “It is undeniable that NTIA has been instrumental in making valuable finite spectrum available for commercial wireless service providers."
AT&T offered insights into its LTE buildout strategy in a letter filed at the FCC. AT&T said it decided to “unredact” information in a previous filing on various proposed spectrum transactions, including its buy of lower 700 MHz band licenses in California from Club 42 (see 1506030033). AT&T “typically” launches LTE in a 5 x 5 MHz configuration where only a single 12 MHz block of lower 700 MHz B or C block spectrum is available, “and will launch LTE in a 10 x 10 MHz configuration in areas where both the Lower 700 MHz B and C Blocks are available,” AT&T said. Where lower 700 MHz spectrum is available and has been deployed for LTE, “AT&T will deploy AWS-1 spectrum to provide additional LTE capacity,” it said. “AT&T also has deployed LTE on cellular and PCS spectrum in a few places. Where Lower 700 MHz spectrum is not available, AT&T’s initial LTE deployments will use AWS-1 spectrum and/or other spectrum bands. This spectrum deployment strategy may vary in individual areas based on the spectrum holdings and other local variables.” AT&T made the filing Tuesday in a number of dockets, including 14-145.
Broadcom, Google and Microsoft representatives raised concerns about an FCC staff proposal to put some TV stations in the duplex gap following the TV incentive auction (see 1507070055), in a meeting with aides to the various FCC commissioners. “We discussed the importance of access to low-frequency unlicensed spectrum and emphasized that a decision by the Commission to place broadcasters in the duplex gap in certain markets detracts from the goal of identifying three TV white space channels per market for consumers,” said a filing by the three in docket 12-268.
The Competitive Carriers Association, joined by Dish Network, Sprint and T-Mobile, met with FCC Commissioners Jessica Rosenworcel and Mike O’Rielly to explain why the FCC should mandate a 40 MHz spectrum reserve, or 50 percent of what is auctioned, as it takes up incentive auction rules. The reserve spectrum is set aside for carriers without significant low-band holdings in a particular market. FCC Chairman Tom Wheeler has proposed instead that the rules keep the 30 MHz reserve approved by the FCC last year (see 1506250057). “The spectrum reserve is the only competitive safeguard still under consideration to prevent AT&T and Verizon from using the 600 MHz auction to further consolidate their already considerable low-band spectrum holdings,” said a filing by the competitive carriers in docket 12-268. “In addition, AT&T or Verizon are reserve eligible in most of the country, including 74 percent of the nation’s geography and 40 percent of the [POPs].” CCA supports any proposal that would address concerns about the current trigger for determining when the reserve kicks in, CCA said. The currently proposed trigger “opens opportunities for gaming if the Commission pursues high clearing targets -- with attendant high clearing costs -- at the outset of the auction, but later falls back to a lower clearing target with lower clearing costs during a subsequent round,” CCA said.
The TV incentive auction will require “entirely new bidding software, as well as the release of new file formats, sample data, and other information to potential bidders” and the FCC needs to provide as much information as possible to potential bidders, Verizon officials said in a meeting with FCC officials. The information should be made available as early as possible and in as much detail as possible, Verizon said: “We also noted the benefits to potential bidders and the Commission of holding multiple bidding seminars and providing detailed information early on, well before applications are due.” Verizon on Tuesday filed a notice on the meeting in docket 12-268.
Cablevision representatives weighed in on touchy questions over restrictions on LTE-unlicensed and licensed assisted access (LAA) in a meeting with aides to FCC Chairman Tom Wheeler. In comments filed on the issue there was “widespread recognition of the danger of LTE-U and LAA [devices] to existing consumer devices and the ineffectiveness of proposed sharing mechanisms,” Cablevision said (see 1506290060). The FCC should test assertions by Qualcomm and Cisco that LTE-U can coexist with Wi-Fi “to gather the technical information on the record necessary for proper consideration and testing of these approaches,” Cablevision said.
CTIA and member companies asked the FCC to “engage” with potential bidders in the TV incentive auction in an “iterative, collaborative” process aimed at helping them understand the data the FCC will provide during the auction. The industry representatives met with FCC officials Wednesday to discuss their concerns, said an ex parte filing Monday in docket 12-268. The FCC “should adopt frameworks that speed deployment and promote bidder confidence,” CTIA said. “For example, 600 MHz licensees should be permitted to conduct pre-deployment testing of licensed spectrum without any encumbrances from secondary users of the spectrum as soon as possible and should not be required to provide ongoing notifications to secondary operations once a licensee has initiated transmissions.” CTIA also asked the FCC to clarify the scope of a requirement on what would trigger additional inter-service interference analyses and “fully disclose any potential impairment associated with this process,” the filing said. “For example, 600 MHz licensees should not be required to conduct extensive analyses of interference effects if proposed mobile network modifications would not increase the interference potential to a broadcast station.”
There's broad industry agreement that the FCC should minimize the intentional placement of U.S. TV stations in the 600 MHz band as part of the TV incentive auction repacking, an AT&T official said in various meetings at the FCC. “As the record confirms, repacking U.S.-based television stations into the 600 MHz band will significantly degrade the quality of the adjacent licenses for mobile wireless use, both within the same market and in geographically adjacent markets,” AT&T said in a filing in docket 14-252. Doing so would reduce the value of licenses sold to carriers in the forward part of the auction, AT&T said. The impairments also would “force the Commission to offer non-generic licenses under circumstances in which bidders cannot know during the forward auction which licenses they will ultimately receive, and that uncertainty will cause bidders to further reduce their bids,” the carrier said. The filing was signed by Joan Marsh, AT&T vice president-federal regulatory.