ISIX Issues Could Be Addressed With New Band Plan, NAB Says
Projected difficulties with interference between wireless and broadcast signals after the incentive auction and repacking are largely caused by FCC use of a variable rather than nationwide band plan, said NAB in comments in docket 14-14, responding to a public notice on interservice interference, called the ISIX PN. CEA, CTIA and engineering firm Cohen Dippell made suggestions on how the problems associated with interservice interference could be addressed. NAB’s suggestion that the FCC completely redo the band plan was the most sweeping. The FCC “could make its own job simpler, reduce the number of points of potential failure during the auction, present clearer, more attractive offers to bidders, and avoid an unnecessarily jumbled post-auction interference environment by pursuing a nationwide band plan,” said NAB.
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NAB pointed to the AWS-3 auction's success as evidence that the variable band plan made the incentive auction too complicated. AWS-3 has a nationwide band plan, and allows wireless companies to bid on licenses more simply, NAB said. The incentive auction will offer bidders two categories of licenses, based on the degree to which they're affected by interservice interference, the Incentive Auction Task Force has said. “There is still time for the Commission to say yes to a $45 billion blueprint for success,” said NAB, referring to the amount of money so far generated by bids in the AWS-3 auction.
Aside from the band plan, NAB agreed with many of the commission’s proposals for addressing interservice interference. Wireless carriers should hold copies of their interference analyses and make them available to the FCC to address complaints, NAB said. Those analyses should also be shared with affected broadcasters, NAB said. Mobile and portable devices operating on adjacent frequencies to broadcasters should be restricted to five kilometers outside the station’s broadcast contours, NAB said. The FCC also has to use its original OET-69 software to predict interservice interference, not TVStudy, NAB said. “The FCC is required to use OET-69 to protect both coverage area and population served in reassigning television stations -- including in reassigning those stations to portions of the 600 MHz band where they may be subject to interference from wireless operators.”
CTIA disagreed, endorsing TVStudy. “The framework adopted by the Commission in the ISIX Order -- including its use of TVStudy software to calculate interference -- will effectively model the complicated interference environment,” CTIA said. The FCC shouldn’t adopt a “zero percent threshold” for harmful interference from wireless licensees to broadcasters endorsed by NAB, CTIA said. Such a rule would be “impractical, unprecedented and has the potential to undermine the Auction’s ultimate success,” CTIA said. Only impaired licenses should be required to conduct ongoing interference analyses, and the FCC should treat low-power TV and translators as secondary for interference purposes, CTIA said.
The FCC has more to do to clarify how it will address interference problems, said CEA. “Intermodulation interference” between two LTE signals and interference affecting future DTV receivers that can receive LTE frequencies are problems that merit “further analysis” to see if the issues can be fixed, CEA said. “It remains unclear how a wireless licensee should determine potential inter-service interference with a broadcaster that has not yet repacked during the 39-month transition period.” These matters need to be clarified before a final order is issued, CEA said.
Since viewing video over wireless has become more popular, the FCC should provide resources for households experiencing inter-service interference, said Cohen Dippell. The FCC should “identify areas where market variation is implemented and create in advance, a mechanism that is fully publicized so that the general public will be cognizant which households may be subject to loss of off-the-air service,” said the engineering firm. It said the commission could create an “interference book” that “demonstrates how an off-the-air viewer may be faced with interference from a new wireless operation.”