AT&T: 700 MHz interoperability proposal unnecessary, unprecedented
AT&T (NYSE:T) struck back at 700 MHz A-Block licensees that are pushing the FCC to mandate that AT&T use Band 12, rather than Band 17, to provide LTE services using 700 MHz spectrum.
Making such a regulatory change would be "an unprecedented intervention in the marketplace," said Joan Marsh, vice president of federal regulatory for AT&T, in an Aug. 16 notice to the FCC detailing her Aug. 13 ex parte meeting with Courtney Reinhard, legal advisor to FCC Commissioner Ajit Pai.
Such a move, argued Marsh, "would undermine the integrity and predictability of the wireless industry's standards-setting process, retard broadband investment and deployment, threaten the reliability of existing LTE services, expose millions of consumers to additional interference risk and yield none of the 'interoperability' benefits upon which the proposed regulatory mandate is falsely premised."
Band Class 12 includes the Lower A Block 700 MHz spectrum held by small licensees, while AT&T holds Lower B and C Block 700 MHz spectrum in Band Class 17. AT&T has said it created Band Class 17 to guard against interference from Channel 51 broadcast transmissions adjacent to the Band Class 12 Lower A Block spectrum.
The FCC's ongoing 700 MHz interoperability rulemaking pits A Block licensees--including Vulcan Wireless, King Street Wireless (U.S. Cellular's bidding partner), C Spire Wireless and MetroPCS (NYSE:PCS)--against larger carriers, primarily AT&T.
Vulcan Wireless, owned by Microsoft (NASDAQ:MSFT) co-founder Paul Allen, recently presented a framework to the FCC via which the commission could force interoperability across all paired spectrum blocks in the Lower 700 MHz band, with Band Class 12 becoming the de facto standard if they could not agree to another solution. Vulcan argues an interoperability mandate would ensure device availability for smaller 700 MHz licensees, as well as nationwide roaming opportunities.
Among other things, Vulcan alleges the current Band Class arrangement proves that AT&T held considerable influence with standards-setting body 3GPP, which ratified Band Class 17 and Band Class 13--the latter includes Verizon Wireless' (NYSE:VZ) Upper C Block holdings--in September 2008 but did not ratify Band Class 12 until December 2010.
A Block licensees have argued that unless regulators force AT&T to switch from Band 17 to Band 12, device manufacturers will lack sufficient scale to create affordable Band 12 devices. "Marketplace developments in 2012 have already refuted these assertions," said Marsh, noting U.S. Cellular currently offers multiple Band 12 devices to its customers, "including two smartphones, a tablet, a Wi-Fi hotspot and a data card." Further, said Marsh, U.S. Cellular has announced that it will be adding up to four more 4G LTE devices this year.
While A Block licensees have argued that a Band 12 mandate is necessary to ensure their customers have nationwide roaming opportunities, AT&T claims "with broad availability of multi-band LTE chipsets, every operator has many LTE roaming options." U.S. Cellular already uses quad-band LTE chipsets, said Marsh.
According to AT&T, the proposed Band 12 mandate would subject AT&T's customers to interference from Channel 51 and the E Block. "Moreover, second-guessing 3GPP standards years after the fact would create substantial uncertainty as to whether future 3GPP standards can be relied upon, thus undermining incentives to invest in next generation networks, equipment, devices, and applications," said Marsh.
On a final note, Marsh asked the commission to phase out high-powered Channel 51 and E Block broadcasts "that are incompatible with efficient use of Lower 700 MHz spectrum."
Though Channel 51 licensees can participate in a planned incentive auction, in which they would be paid to give up their TV licenses to buyers that would use their frequencies for wireless broadband services, AT&T wants to the commission to move more quickly to encourage Channel 51 licensees to voluntarily relocate or cease their broadcasts during the period leading up to the incentive auction.
The operator also wants the FCC to ensure that the currently fallow E Block spectrum cannot be used for services that would cause significant harm in other Lower 700 MHz blocks.
- see this AT&T filing
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