FCC Wireless Bureau chief Ruth Milkman says that market variation remains a key goal for the FCC's band plan if it is to get the most out of the incentive auctions, and may be the key to holding a successful incentive auction, period.
In a blog posting Friday (June 21), Milkman pointed out there had been some dozen variants on the band plan proposed -- how the FCC will fit both broadcasters and wireless companies in the 600 MHz band -- and that while some may look like a consensus position from 30,000 feet, it is "misleading" to characterize them as a consensus.
"[T]the devil is in the details," she wrote, and "in reality the proposed plans are dissimilar in notable respects." She said those include some calling for paired bands, some limiting them; some accommodating market variation by putting TV signals in the gap between uplink and downlink spectrum; some saying no market variation.
The FCC continues to believe that accommodating that variation is important, she said. "By implementing a band plan that supports variation between markets, we would not be forced to limit the auction to the amount of spectrum available in the least cleared markets.
"Consumers in all the other markets across the country would then be deprived of access to spectrum that could have been repurposed for mobile broadband."
The result, she suggests, could imperil the FirstNet mobile broadband emergency communications network, or even prevent the auction from concluding because not enough had been raised to pay broadcasters for their spectrum or relocate them.
Rick Kaplan, the former FCC Wireless Bureau chief and current National Association of Broadcasters executive who worked on the band plan "core principles" NAB submitted in conjunction with AT&T and Verizon, responded Friday to the FCC post.
"Somehow the blog post still misses the point when it comes to market variation. Of course the FCC wants the ability to have variation. But the relevant question - that for some bizarre reason the Bureau refuses to ask - is whether engineering even allows for meaningful variability. Where is the public notice that asks whether and how the inherent interference can be avoided? We haven't seen it and fear that the drive for variability has trumped the science and engineering essential to avoid some of the painful interference mistakes of the past."
That plan favored by NAB, AT&T and Verizon was a contiguous, "down from TV 51," spectrum allocation approach that avoided TV stations in the so-called duplex gap between downlink and uplink spectrum.