Posted by: Joan Marsh on September 2, 2010 at 2:53 pm
Yesterday, Chairman Genachowski removed from circulation the AWS-3 draft item, ending a long and largely frustrating debate about disposition of the AWS-3 spectrum at 2155-2180 MHz. A mountain of paper was amassed over the question of whether the spectrum should be auctioned subject to a unique set of restrictions that would have limited the use of the spectrum to a single specialized business plan proffered by M2Z. The FCC concluded, rightfully, that M2Z’s plan “was not the best policy outcome.” We agree, and fully support the Chairman’s decision and his continuing leadership on effective spectrum policy for the 21st century.
AT&T has long opposed the M2Z proposal at the heart of the debate, which was built on a complicated set of restrictions that would require 25% of the licensee’s “network capacity” be used to offer “free, family-friendly broadband service.” A myriad of questions arose around how the free service would be provisioned and supported, whether the quality of the free service would be acceptable and how the licensee would demonstrate compliance with the network capacity requirements. The top downlink speed of the free service would have been 768K, and many worried that such a service would chase other providers of affordable, low-speed broadband services from the market, relegating an entire class of users to a technological backwater.
To make matters worse, in support of its business plan, M2Z proposed service and technical rules that would allow this unpaired band to be used for the delivery of two-way broadband services using time division duplexing or “TDD” technologies. This proposal – which would allow the licensee to combine uplink and downlink operations in a single band – created the very real potential for harmful interference in adjacent AWS-1 bands. M2Z specifically opposed restrictions on out-of-band emissions and power limits that would have guarded against this interference, arguing that those restrictions would degrade the service. M2Z also opposed the use of appropriate guard bands – which have long been used quite effectively to address interference problems – calling instead for “cooperation and coordination requirements” to address the issue.
This approach to licensing could not have been more wrong-headed. The management of a wireless network is complicated enough without having to coordinate every dynamic adjustment with a competitor operating on an adjacent band. And licensing spectrum in a manner that is likely to cause interference is simply unacceptable. We’ve been down that road, and Sprint is still trying to untangle the mess that was created in the 800 MHz band when Nextel was permitted to launch service in a manner that interfered with adjacent public safety operations. The AWS-3 and adjacent AWS-1 spectrum is simply too valuable to NOT acknowledge the realities of interference concerns and avoid them.
In rejecting M2Z’s proposal, the Commission made clear their goal to pair the AWS-3 spectrum before sending it to auction. That too is the right decision. Paired spectrum drives the greatest spectral efficiencies and supports flexible use. It also creates the potential that the band could be internationally harmonized – which lowers equipment costs and facilitates international roaming. International harmonization is a goal that is becoming more and more important as more bands are becoming fragmented around the globe.
M2Z was quick to criticize the move, saying that the FCC’s decision to delay the use of this valuable spectrum reverses the FCC’s National Broadband Plan commitment to finalize the AWS-3 spectrum rulemaking in the fourth quarter of 2010. But the decision stays true to the core promise on spectrum in the plan.
Spectrum is the great enabler, and the National Broadband Plan envisions a more comprehensive approach to spectrum policy that increases efficiency, flexibility and utilization of this scarce and valuable national resource. It is true that finding an appropriate pair for the AWS-3 spectrum may take some time, but it will be time well spent. We applaud the Chairman for his vision and the Commission for staying true to its promise to unlock the full potential of available spectrum for the wireless broadband future.
