Posted by: Joan Marsh on January 25, 2013 at 10:28 am
The FCC’s Incentive Auction proceeding moves forward in earnest today with the filing of opening comments. The stakes are as high as the issues are complex. Freeing up more spectrum is critical to U.S. economic growth and technological leadership. And this auction presents the FCC with the best opportunity it will have for many years to advance that goal.
This is far from a typical auction. In auctions past, the Commission has sold specifically defined frequency blocks to raise money for the U.S. Treasury. In this auction, the Commission must persuade two different sets of auction bidders to participate in two separate auctions designed to create forward-auction revenues that exceed winning reverse-auction bids, plus administrative and repacking costs. If they fall short of these goals, only limited amounts of spectrum will be cleared or, in the worst-case scenario, the auction could fail altogether.
This fact has profound consequences for every decision the Commission must make in this proceeding, from establishing a band plan, to designing the forward and reverse auctions, to establishing the ground rules for participation.
As discussed in our comments, the Commission has already set the stage for success. The NPRM issued by the FCC put forth innovative approaches to managing the complexity inherent in this process, from the organization of the cleared spectrum to the mechanics of the forward and reverse auctions. But as the Commission has readily recognized, the NPRM’s proposals are only a starting point in the search for the best solutions.
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Posted by: Joan Marsh on January 7, 2013 at 3:26 pm
In the midst of a prolonged and deep national recession, the U.S. wireless industry has generated billions of dollars of investment capital, produced millions of jobs, and spawned a breathtaking array of innovative new consumer products and services. This wireless success story is due in no small measure to the Commission’s longstanding recognition that a light touch approach to wireless regulation best promotes competition, innovation and investment.
Not surprisingly, however, some wireless providers urge the Commission to abandon that approach in favor of blatantly skewed spectrum policies that are designed to tip the competitive scales in their own favor. For example, Sprint/Clearwire, which controls double the spectrum of any other carrier, contends that most of its own spectrum should continue to be excluded from the spectrum screen, while much of the spectrum held by Verizon and AT&T should be double-counted. T-Mobile, which chose to sit out the Commission’s 700 MHz auction entirely and to forego low band secondary market spectrum opportunities, now wants the Commission to adopt spectrum rules designed to guarantee its ability to catch up on the cheap. And the Rural Telecommunications Group (“RTG”) has asked for spectrum caps so draconian they would require AT&T and Verizon to undertake immediate divestitures – unless, of course, AT&T and Verizon “volunteer” to be yoked with RTG’s entire wish list of regulatory obligations that have no connection whatsoever to spectrum policy.
None of these proposals has the slightest merit. For example, while Sprint and Clearwire weakly argue that the bulk of Clearwire’s 2.5 GHz spectrum should continue to be excluded from the spectrum screen, these arguments are flatly inconsistent with these carriers’ claims regarding the value and utility of its spectrum in every venue but the FCC. And, even more importantly, they cannot be reconciled with the undeniable reality that the spectrum they want to exclude from the screen is today being used for mobile broadband services. Indeed, Sprint has made quite clear that it is buying the rest of Clearwire “to maximize the value of Clearwire’s 2.5 GHz spectrum and use it to increase Sprint’s network capacity.” These are inconvenient facts for Sprint and Clearwire which they blithely ignore in their comments.
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Posted by: AT&T Blog Team on October 4, 2012 at 3:01 pm
By Joe Marx, AT&T Assistant Vice President of Federal Regulatory
Yesterday, AT&T submitted a formal analysis of the V-COMM Test Report that came out in mid-July claiming minimal impact of Channel 51 and E-Block signals on Band 12 and Band 17 devices. As we previously discussed, there are real credibility issues with the testing conducted by V-COMM for the lower 700MHz A Block licensees.
The V-COMM Report concluded, contrary to multiple other tests and analyses, that although Band 12 devices are far more susceptible to interference from Channel 51 and E Block signals than are Band 17 devices, LTE signals are strong enough to overcome the interference. The problem is that the test assumed an LTE signal strength not likely to occur in most real world situations. After a more thorough review and additional testing by 7Layers (a well-regarded, independent testing firm), it is apparent that the conclusions in the V-COMM Report are wrong, and reflect a number of incorrect assumptions, parameters, and methodology.
There is often more than one approach to take when embarking on an interference test program. In the case of interference testing as with Channel 51 and E-Block, it is not enough to test a best or average case scenario which looks for interference where it is not likely to exist and then claims the results prove it doesn’t exist. That’s like looking for snow at the equator and concluding from its absence that snow doesn’t exist. But that is essentially the case with the V-COMM Report. It is much more useful to look at more challenging scenarios that show the presence of interference and prove those scenarios could occur in a real world. That is the approach taken by AT&T and the test labs on which we relied.
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