A joint statement released today by AT&T, the National Association of Broadcasters, and Verizon criticized the FCC for seeking comments on new proposals for reorganizing the spectrum currently used by television broadcasters, which the statement said would go against the “growing consensus” of the broadcast and wireless industries.
In a May 17 Public Notice, the FCC asked for comments regarding possible variations on the previously proposed “Down from 51” band plan. Under that plan, the FCC would clear TV spectrum from Channel 51 down after the anticipated auction of spectrum voluntarily relinquished by TV broadcasters. The original plan would place a new uplink band in the higher portion of the cleared spectrum (adjacent to the current 700 MHz uplink band), while a new downlink band would occupy the lower portion of the spectrum. One of the possible variants discussed in the May 17 Public Notice would reverse the position of the uplink and downlink bands. Another proposal would convert cleared TV spectrum into a single band for mobile broadband, relying on Time Division Duplexing (TDD) to separate upstream and downstream traffic rather than paired uplink and downlink spectrum. The Notice expressed the FCC’s concern that the original “Down from 51” plan would not allow enough flexibility if different amounts of TV spectrum are cleared in different markets.
However, today’s joint statement says that reversing the positions of the uplink and downlink bands “has absolutely no support in the record,” while the TDD approach would be “contrary to the one proposed by the majority of U.S. carriers.” The statement suggests that the FCC’s resources would be “better spent on dealing with other critical and as-yet-unanswered questions in this proceeding, such as how co-channel interference concerns could undermine the variability of any band plan and how the FCC plans to conduct an effective re-packing.”