The Federal Communication Commission’s failure to conduct adequate investigations into the potential of co- and adjacent-channel interference could seriously hinder the agency’s efforts to free up spectrum for the wireless industry, the National Association of Broadcasters said in its reply comments released last week.
Under the FCC’s proposed plan for the 600MHz incentive auction, TV broadcasters will be offered the option to submit bids to sell their 600 MHz pieces of spectrum to the FCC. Following this reverse auction, the spectrum will be “repacked” so broadcasters who declined to give up their spectrum can stay on the air. The newly freed spectrum will then be auctioned off to wireless operators, who will be intermixed with broadcasters who elected to keep their spectrum.
However, broadcasters and major wireless carriers have long expressed concern over possible issues with the proposed variable-band plan.
In the latest comments released by NAB, the organization alleged that the commission has “failed altogether to acknowledge” serious engineering concerns that must be addressed before moving forward. The document draws on comments filed by several wireless companies and a smartphone manufacturer, as well as past proposals of a similar nature, as the basis for its allegation that the necessary work required to mitigate interference that will likely result from variable use of spectrum has not been completed.
“If the Commission does not study and address it [interference], then the law will not allow the Commission to employ it [variability],” NAB said, comparing variability to overload interference in the LightSquared proceeding.
“One outcome of a rigorous look at the effects of co- and adjacent channel interference might very well demonstrate that the costs of variability outweigh its perceived benefits,” the NAB acknowledged. “But, it is also possible that, along with industry and the public interest community, the Commission could develop a solution that allows it to pursue some measure of variability. The Commission cannot know the correct answer, however, unless it poses the relevant questions and conducts the necessary technical analysis.”
“The problem [with the variable plan] in the most basic terms is this: If Market A (e.g., New York) clears less spectrum than adjacent Market B (e.g., Philadelphia) and therefore Market A continues to have broadcast operations on channel X (e.g., channel 46) while Market B moves to wireless operations on that same channel, the wireless and broadcast operations on that shared channel will interfere with one another,” former FCC official and current NAB executive vice president for strategic planning Rick Kaplan writes as a guest blogger on The Future of TV.
“There is no doubt this is a serious issue. And even though the Wireless Bureau dismissed the problem without any analysis (in a nonsensical footnote in its Public Notice), following the bureau’s Public Notice, AT&T, Verizon Wireless, Qualcomm, Ericsson and others have joined in to second the notion that further work on the subject is required.”
A statement from the FCC regarding NAB’s comments is not available at this time.
