
WASHINGTON   No single  solution is emerging for how the TV spectrum should be configured following  next year's incentive auction. So says Ruth Milkman, chief of the Federal  Communications Commission's Wireless Bureau. 
 At last count, there were over a dozen proposed band plans  in our record,  she said in a blog post on Friday.   While some differ substantially, many seem at a high level to be quite  similar and without close review may even give the misleading impression that a   consensus' has in fact been reached. But we all know that the devil is in the  details, and in reality the proposed plans are dissimilar in notable respects. 
The commission's original band-plan proposal layered TV stations between  wireless uplink and downlink bands. The National Association of Broadcasters  along with several wireless providers counter-proposed a plan under which  spectrum would be reassigned contiguously from the top of the TV band on down. Specifically,  it would comprise a wireless uplink band starting at Ch. 51 (698 MHz), then a  duplex gap and downlink band, situated possibly on both sides of Ch. 37, now  occupied by radio astronomy.
This  Down from 51  plan, as well as a reverse model of same, was put out for  comment by FCC Public Notice in May. The first round of feedback was due June  14. Replies are due June 28.
In the reverse Down from 51 plan, downlink would start after a duplex gap at  Ch. 51 (abutting the established uplink band in the adjacent 700 MHz spectrum  at Chs. 51-69), then uplink would begin below that after a duplex gap,  straddling Ch. 37 if more than 84 MHz is cleared. A second Down from 51 reverse  plan establishes a fixed downlink band at the top and varying amounts of  spectrum dedicated to uplinking in individual markets, i.e., market variation.  The uplink band would again straddle Ch. 37 if more than 84 MHz of spectrum is  cleared.
Few parties support reverse Down from 51 because it would require the extra  duplex gap and therefore be a  waste of spectrum,  said one broadcast executive  familiar with the proceeding. The commission is also proposing to allow TV  stations to operate in the duplex gaps, but the same executive said that  putting  us between their operations creates enormous interference  to us and a lot to  them. 
Milkman said that there was general support for Down from 51, but in various  forms.
 A number of commenters support band plans that are in the  Down from 51' family,   she said.  But some plans would limit paired licensed spectrum to 50 MHz, while  others call for a larger number of paired bands.  Here, Milkman refers to  proposals from AT&T; then T-Mobile and Verizon Wireless.
Where T-Mobil and Verizon do diverge is on market variation, i.e., freeing a different  amount of spectrum in various geographic areas. The FCC favors market variation  as a means to bring as much spectrum as possible to auction, and thereby  maximize revenues for the Treasury. (Money already spent by Congress to extend  unemployment benefits.) 
 Were we to implement a plan that does not accommodate market  variation, we could be forced to limit the spectrum available in all markets to  the relatively small amount available in the most constrained market,  Milkman  said.
Broadcasters and Verizon prefer consistent, nationwide spectrum blocks as a  means to prevent co-channel interference. 
 What we've said is, a TV channel still on Ch. 48 in New York is going to  interfere with wireless on Ch. 48 in Philly,  said an NAB executive.  We've  made clear you have to have a national plan. Wireless carriers didn't  anticipate this plan, but fear not getting enough in some markets. They've  realized we've raised a good engineering point. 
See 
January 24, 2013,  NAB,  Wireless Providers, Agree on Contiguous Repack 
Broadcast and wireless lobbies agree on one thing regarding how the TV band is  repacked after the 2014 spectrum incentive auction: They don't want to mix it  up.
								
							 
								
							
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