The National Association of Broadcasters tells the FCC that it cannot "reasonably" employ a variable band plan for the post-incentive auction 600 MHz band if it includes broadcasters and wireless carriers on co-channels and adjacent channels in neighboring markets.
Soon after the FCC released its plan, which intermixes broadcast and wireless operators, broadcasters and some major wireless carriers teamed up to oppose that plan, saying it would cause interference or reduce the amount of usable spectrum the FCC could recover. The FCC says the plan allows it flexibility to recover different amounts in different markets.
NAB countered with its own so-called "Down From 51" plan. The FCC sought comment on that plan, its original and others, including a "Down From 51 Reversed" plan, which would reverse the uplink and downlink.
In comments filed Friday on the band plans, NAB said that none of the other plans adequately address the interference issue, but that the lesser of the evils would be the "Down from 51 Reversed" plan because it is the variable plan that least "exacerbates" the inherent problems.
But even there, inadequate interference planning can undermine the auction, said NAB. "If the Wireless Bureau continues to be locked into market variability it must, as a precursor, rigorously evaluate the issues raised throughout the record concerning co- and adjacent-channel interference and its impact on the proposed band plans." Only then, says NAB, can the FCC know whether variability is even possible from a real-world engineering standpoint.
One of the authors of the NAB comments is Rick Kaplan, the former Wireless Bureau chief under former chairman Julius Genachowski, who helped produce the alternative band plan.
While NAB proposed the "Down from 51" plan in concert with wireless companies AT&T and Verizon, it submitted its latest comments solo.
That may be because there are substantive differences in their responses. For example, Mobile Futures, a group whose members include AT&T and Verizon, said in its filing that the "Down from 51 Reversed" plan should not be adopted, period.