WTB Seeks to Supplement the Record on the 600 MHz Band Plan
Federal Communications Commission
News Media Information 202 / 418-0500445 12th St., S.W.
Washington, D.C. 20554
Released: May 17, 2013
WIRELESS TELECOMMUNICATIONS BUREAU SEEKS TO
SUPPLEMENT THE RECORD ON THE 600 MHz BAND PLAN
GN Docket No. 12-268
Comment Date:June 14, 2013
Reply Comment Date:June 28, 2013
In the Broadcast Television Incentive Auction NPRM, the Commission sought public comment on
creating a 600 MHz wireless band plan from the spectrum made available for flexible use through the broadcast
television incentive auction.1 The Commission identified five key policy goals that would provide the framework
for adopting a wireless band plan: utility, certainty, interchangeability, quantity and interoperability.2 The
majority of commenters support many features of the proposed band plan framework that aim to achieve these
goals,3 but express a broader range of views on how and where to configure the uplink and downlink blocks in the
band plan.4 To evaluate and quantify the technical tradeoffs associated with configuring the uplink and downlink
bands, on May 3, 2013, the Commission hosted a public workshop.5 At the workshop, stakeholders discussed a
variety of technical aspects to consider in creating a 600 MHz wireless band plan, including mobile antenna
issues, harmonics interference, intermodulation, and high power services in the duplex gap.6
As discussed in the workshop, many stakeholders support the “Down from 51” band plan proposal – or a
variation of it – in which the Commission would clear broadcast television channels starting at channel 51 and
expand downward: the uplink band would begin at channel 51 (698 MHz), followed by a duplex gap, and then the
1 Expanding the Economic and Innovation Opportunities of Spectrum Through Incentive Auctions, Notice of Proposed
Rulemaking, 27 FCC Rcd 12357 (2012) (NPRM). In response to the NPRM, over 400 interested parties filed comments. See GN
Docket No. 12-268.
2 NPRM, 27 FCC Rcd at 12401-02, para. 125.
3 These include auctioning “generic” blocks rather than specific frequency blocks; licensing in five megahertz “building
blocks;” offering blocks designated specifically for uplink and for downlink operations; establishing guard bands, where
necessary; and prioritizing paired blocks wherever possible. Federal Communications Commission Provides Additional
Details about Workshop to Discuss the 600 MHz Band Plan, Public Notice, DA 13-799, at 1 (Apr. 19, 2013) (600 MHz Band
Plan Workshop Public Notice). See also, GN Docket No. 12-268.
4 600 MHz Band Plan Workshop Public Notice at 1.
5 Id. at 1-2.
6 A video of the 600 MHz Band Plan workshop is available at: www.fcc.gov/events/learn-workshop-600-mhz-band-plan.
downlink band.7 The workshop made clear that support for a Down from 51 band plan framework is primarily
based on concerns over high power services in the duplex gap8 and antenna design issues.9
The Down from 51 proposals in the record generally limit the amount of market variation that can be
achieved, however. Specifically, most of these proposals are targeted at repurposing a specific amount of paired
spectrum nationwide, and provide limited options for how to offer less spectrum in constrained markets, or
additional spectrum in individual markets, and only under certain scenarios.10 In the NPRM, the Commission
expressed a strong interest in establishing a band plan framework that is flexible enough to accommodate market
variation, i.e., offering varying amounts of spectrum in different geographic locations, depending on the spectrum
available.11 Further, although the majority of commenters argue that the Commission should prioritize offering
paired spectrum blocks over unpaired blocks,12 some variations of the Down from 51 band plan limit the amount
of paired spectrum that can be offered.13 Under the policy framework set forth by the Commission, the Down
from 51 approaches in the record appear to favor certainty of the operating environment over the utility of
providing the maximum amount of spectrum through flexibility to offer a greater quantity of spectrum in
geographic areas where more spectrum is available.
In the NPRM, the Commission sought comment on a number of band plan proposals.14 Emphasizing its
goals of “balanc[ing] flexibility with certainty while maximizing the amount of spectrum we can make available
for wireless broadband services in each geographic area,” the Commission recognized that other band plans are
possible that may achieve the Commission’s goals.15 Consequently, the Commission sought comment on the
band plan approaches described in the NPRM, any variations on those approaches, and also invited commenters to
propose their own band plans.16 To advance the Commission’s goal of maintaining flexibility to offer different
7 See, e.g., Letter from AT&T Inc., National Association of Broadcasters, T-Mobile, Intel Corporation, Qualcomm, and
Verizon Wireless to Gary Epstein and Ruth Milkman, FCC (Jan. 24, 2013); Comments of T-Mobile USA, Inc. at 10-13;
Reply Comments of Ericsson at 13-29. See also, NPRM, 27 FCC Rcd at 12421, para. 178. Depending on the quantity of
spectrum that is repurposed, the downlink band could be situated on both sides of channel 37 (assuming existing channel 37
operations remain on that channel).
8 A number of commenters assert that putting high power services in the duplex gap will cause unnecessary and strong
intermodulation products, which will result in significant interference to mobile broadband units. See, e.g., Comments of
Alcatel-Lucent at 14-16; Comments of CTIA – The Wireless Association at 25, 28.
9 Some commenters raise concerns that a large duplex gap would increase the operating bandwidth the mobile antenna would
have to cover, and given current antenna design, it is difficult to cover such a large band with a single antenna in smaller
smartphones. See, e.g., Reply Comments of Intel Corporation at 2; Comments of T-Mobile USA, Inc. at 8-9. The Down from
51 band plan framework narrows the duplex gap by reducing the space between the uplink and downlink bands and thereby
reducing the total operating bandwidth for a given amount of repurposed spectrum.
10 See, e.g., Comments of AT&T Inc. at Exh. A p. 29; Comments of Qualcomm Incorporated at 16-20 (accommodating
variable uplink spectrum in constrained markets only if there is a sufficient number of low power TV stations to place in the
11 NPRM, 27 FCC Rcd at 12401, para. 123-124. The Commission proposed to accommodate market variation by offering a
consistent amount of downlink spectrum nationwide and allowing for variable uplink spectrum, and placing broadcast
television stations in the duplex gap in more constrained markets. See, NPRM, 27 FCC Rcd at 12406-09, paras. 136-143.
12 See, e.g., Comments of Competitive Carriers Association at 13; Comments of T-Mobile USA, Inc. at 5-6; Comments of
Verizon and Verizon Wireless at 6.
13 See, e.g., Comments of Qualcomm Incorporated at 4-20.
14 NPRM, 27 FCC Rcd at 12401-12423, paras. 123-184.
15 Id. at 12420, para. 177.
amounts of spectrum in different geographic markets,17 we seek further comment on how certain Down from 51
band plan approaches can best address the potential for market variation, particularly in markets where available
spectrum is constrained. Although the Commission continues to consider all band plan proposals in the record,
we seek additional comment on certain variations of the Down from 51 band plan, as described below, to develop
a more robust record on these concepts. We invite commenters to discuss the relative merits of all of the band
plan proposals and their variations in the record. Further, we also seek comment on which band plan other
countries would be most likely to adopt to allow for global harmonization of the 600 MHz spectrum.
“Down from 51 Reversed” Band Plan Variation
We seek comment on a variation of the Down from 51 band plan18 in which we reverse the configuration
of the uplink and downlink blocks (“Down from 51 Reversed”). Under a Down from 51 Reversed band plan, the
Commission would clear broadcast television channels starting at channel 51 and expand downward: the
downlink band would begin after a guard band at channel 51 (698 MHz),19 followed by a duplex gap, and then the
uplink band. As shown in the diagrams below, the uplink band could extend past channel 37, either nationwide or
in certain markets, depending on the amount of repurposed spectrum.
Down from 51 Reversed, less than 84 MHz cleared
Down from 51 Reversed, more than 84 MHz cleared
17 See, NPRM, 27 FCC Rcd at 12406-09, paras. 136-143. We recognize that some commenters have concerns about
accommodating market variation due to the potential for co-channel interference between wireless and broadcast TV
operations spaced as close as 200 km apart. See, e.g., Comments of National Association of Broadcasters at 39-45; Letter
from Gordon H. Smith, National Association of Broadcasters, to Julius Genachowski, Chairman, FCC (May 10, 2013), at p.
1-2. Nevertheless, even assuming that 200 km is the appropriate separation distance, we observe that the breadth of the
continental United States is more than an order of magnitude larger than those distances, which suggests that variable market
clearing might still allow for substantially more spectrum to be made available in the incentive auction.
18 See NPRM, 27 FCC Rcd at 12420, paras. 178-179.
19 Because the lower 700 MHz band is being used for mobile uplink operations while the upper 600 MHz band would be
used for downlink operations under this model, we must create a guard band between the two bands to protect against
interference. See, NPRM, 27 FCC Rcd at 12425, para. 189 n.273.
As discussed in the NPRM, the Commission proposed a structure to keep the downlink spectrum band
consistent nationwide while allowing variations in the amount of uplink spectrum available in any geographic
area to promote interoperability and accommodate market variation.20 As shown in the diagrams below, by
reversing the uplink and downlink bands, the Down from 51 Reversed band plan framework can maintain a
uniform downlink band nationwide and allow for market variation in the amount of uplink spectrum offered
without placing high power services in the duplex gap.
Market Variation in Down from 51 Reversed, less than 84 MHz cleared
Market Variation in Down from 51 Reversed, more than 84 MHz clearedWe seek comment on the Down from 51 Reversed band plan variation. Are there any special
considerations or rules that would be necessary in implementing this approach? We also seek comment on
technical issues associated with the Down from 51 Reversed band plan. Specifically, we request comment on
how this band plan approach would affect the ability of wireless broadband providers to utilize the 600 MHz band
effectively, particularly in terms of network and device design. Further, we seek comment on whether the Down
from 51 Reversed approach would provide greater flexibility with respect to market variation than other Down
from 51 band plan proposals.21 We ask commenters to discuss the tradeoffs associated with accommodating
market variation under the Down from 51 Reversed band plan and the other band plan proposals in the record.
Guard Bands. Like other band plan proposals, in a Down from 51 Reversed band plan, we must
implement guard bands to ensure all spectrum blocks are as technically and functionally interchangeable as
possible.22 Specifically, we would need to implement a guard band at the top of the 600 MHz wireless band
between the 600 MHz downlink band and the lower 700 MHz uplink band to protect these services from
20 NPRM, 27 FCC Rcd at 12401, para. 124.
21 Id. at 12406-09, paras. 136-143.
22 Id. at 12401-02, para. 125.
interfering with one another.23 Similarly, we would need to implement a guard band at the lower end of the 600
MHz wireless band between the 600 MHz uplink band and broadcast television stations. We seek comment on
the appropriate size of the guard bands under this proposal.
Channel 37. Under a Down from 51 Reversed band plan, it is possible that 600 MHz wireless operations
could be adjacent to radio astronomy (RA) and wireless medical telemetry services (WMTS) operations in
channel 37, conceivably on both sides, if the 600 MHz uplink band extends below channel 37. Would the Down
from 51 Reversed band plan require additional measures to protect existing channel 37 operations? If so, how
would these measures affect the ability of wireless providers to utilize the adjacent spectrum? We also seek
comment on a proposal to apply the spectral mask for TV white space devices to prevent interference and protect
existing channel 37 WMTS operations from interference if mobile uplink operations (rather than wireless
downlink operations) are on both sides of channel 37.24 Further, in the event that the Commission can repurpose
more than 84 megahertz of spectrum, yielding an uplink band that would extend below channel 37, wireless
uplink operations will be both above and below channel 37. If this occurs, the duplex spacing for paired blocks
with uplink blocks below channel 37 would be greater than for paired blocks with uplink blocks above channel 37
because wireless operations cannot operate on channel 37. We seek comment on the effects of this variable
duplex spacing, and how this affects network and/or device design. We seek comment on other issues relating to
existing channel 37 operations under the Down from 51 Reversed band plan approach.
Down from 51 with TV in the Duplex Gap in Constrained MarketsWe also seek comment on how the Commission should address constrained markets where less spectrum
is available if it adopts a version of the Down from 51 band plan that has been more generally discussed in the
record and the workshop, with the 600 MHz uplink band beginning at channel 51, adjacent to the 700 MHz band
uplink band. Specifically, should the Commission place television stations in the duplex gap in more constrained
markets?25 Although we recognize that some commenters have concerns about allowing high power services to
operate in the duplex gap,26 is this less problematic if it occurs only in certain markets? As compared to a Down
from 51 Reversed band plan, which alternative would allow the Commission to offer as many paired spectrum
blocks as possible? Which band plan approach is preferable if the Commission decides to accommodate market
Down from 51 TDD ApproachIn addition, we seek further comment on using a Down from 51 band plan framework with unpaired TDD
blocks (“Down from 51 TDD”). 27 Under a Down from 51 TDD band plan, the band would begin after a guard
band at channel 51 (698 MHz) and expand downward, followed by a guard band between wireless operations and
23 As discussed in the NPRM, we note that the Spectrum Act requires that the “guard bands shall be no larger than is
technically reasonable to prevent harmful interference between licensed services outside the guard bands.” NPRM, 27 FCC
Rcd at 12412, para. 152 citing Middle Class Tax Relief and Job Creation Act of 2012, Pub. L. No. 112-96, § 6407(b), 125
Stat. 156 (2012).
24See, e.g., Comments of Philips Healthcare at 4-6. See also, 47 CFR § 15.709(c)(4).
25 See, e.g., Letter from Trey Hanbury, Hogan Lovells, to Marlene Dortch, Secretary, FCC (Feb. 1, 2013), at Att. p. 14-17
(market variation with high power services between the uplink and downlink bands).
26 See, e.g., Comments of Alcatel-Lucent at 14-16; Comments of CTIA – The Wireless Association at 25, 28.
27 See NPRM, 27 FCC Rcd at 12423, paras. 183-184.
broadcast television operations at the lower edge of the 600 MHz wireless band.28 As in the other Down from 51
band plan proposals, the band could extend past channel 37, either nationwide or in certain markets, depending on
the amount of repurposed spectrum, which may also require the Commission to protect existing channel 37
Although the Down from 51 TDD band plan would require guard bands at both ends of the 600 MHz
wireless band, no duplex gap is necessary. Further, the Down from 51 TDD band plan would allow for market
variation without placing television stations in the duplex gap. Although a TDD band plan could not support
market variation through variable uplink, it could support market variation through an alternative approach that
aligns the amount of repurposed spectrum in constrained markets with the expected filter configurations, as
Market Variation in Down from 51 TDD, less than 84 MHz cleared
Market Variation in Down from 51 TDD, more than 84 MHz clearedStandard market plan
Filter 2 Filter 3 Filter 4 Filter 5
Constrained market option A
Constrained market option B
Constrained market option C
Constrained market option D
We seek additional comment on this Down from 51 TDD band plan. Specifically, we seek comment on
the tradeoffs associated with implementing the Down from 51 TDD band plan as compared to the other Down
from 51 band plan variations that also accommodate market variation. Which band plan provides the most
flexibility while maintaining the best certainty about the operating environment?
28 See Comments of Sprint Nextel Corporation at 22, Reply Comments of Ericsson at 27-29.
29 See, e.g., Comments of Philips Healthcare at 4-6.
30 See, e.g., Reply Comments of Ericsson at 29 (showing several filters being used to implement a TDD plan).
Interested parties may file comments and reply comments on or before the dates indicated on the first
page of this document. When filing comments, please reference
GN Docket No. 12-268.31
Comments may be filed using the Commission’s Electronic Comment Filing System (ECFS) or by filing
paper copies.32 Comments filed through the ECFS can be sent as an electronic file via the Internet to
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docket or rulemaking numbers appear in the caption of the proceeding, commenters must transmit one electronic
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applicable docket or rulemaking numbers. Parties may also submit an electronic comment by Internet e-mail. To
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Effective December 28, 2009, all hand-delivered or messenger-delivered paper filings for the
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Documents in GN Docket No. 12-268 will be available for public inspection and copying during business
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31 The NPRM in this proceeding included an Initial Regulatory Flexibility Analysis (IRFA) pursuant to 5 U.S.C. § 603,
exploring the potential impact of the Commission’s proposal on small entities. NPRM, 27 FCC Rcd at 12523-44. The matters
discussed in this notice do not modify in any way the IRFA we previously issued.
32 See Electronic Filing of Documents in Rulemaking Proceedings, GC Docket No. 97-113, Report and Order, 13 FCC Rcd
To request materials in accessible formats for people with disabilities (Braille, large print, electronic files,
audio format), send an e-mail to email@example.com or call the Consumer & Governmental Affairs Bureau at 202-
418-0530 (voice), 202-418-0432 (tty).
This matter shall be treated as a “permit-but-disclose” proceeding in accordance with the ex parte rules.33
Persons making oral ex parte presentations are reminded that memoranda summarizing the presentations must
contain summaries of the substance of the presentations and not merely a listing of the subjects discussed. More
than a one- or two-sentence description of the views and arguments presented generally is required.34 Other
requirements pertaining to oral and written presentations are set forth in section 1.1206(b) of the rules.35
For further information, contact Paul Malmud at 202-418-0006, or via e-mail at Paul.Malmud@fcc.gov.
33 NPRM, 27 FCC Rcd at 12494-95, paras. 416-417; see also, 47 C.F.R. § 1.1200 et seq.
34 See 47 C.F.R. § 1.1206(b)(2).
35 47 C.F.R. § 1.1206(b).
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