In recent months, there has been a renewed push to drive a regulatory mandate to address the interoperability issues that challenge the lower 700 MHz band.  Perhaps acknowledging that a Band 12 mandate ignores the interference concerns present in the band, the small carriers are now arguing that B and C block licensees should be required to support both Band 17 and Band 12 in all the devices they offer.  Setting aside the fact that this would require carriers like AT&T that own only B and C block licenses to support a band class that they don’t need and won’t use, a Dual Band mandate would fall far short of solving the interoperability challenge and raises a host of new problems.

At the outset, such a requirement would needlessly add material extra cost and complexity to devices.  A Dual Band mandate would require AT&T to equip every device we offer with both Band 12 and Band 17 components.  The result:  inferior performance, form factor limitations and more cost – which would adversely affect competitiveness and user experience – all to enable operations on a block of spectrum that we don’t own.

Moreover, AT&T is already pushing the envelope on how many bands we can accommodate in our devices. Devices today are tightly engineered to achieve the small form factor that consumers desire, and even the smallest change in components can have substantial impacts on form factor and performance.  And the majority of radio chipsets in use today support only three bands below 1 GHz.  AT&T already must support Band 17 (700 MHz B and C Blocks), Band 5 (800 MHz), and Band 29 (700 MHz D and E Blocks) just to cover its LTE requirements, not to mention the need for ports to support legacy technologies and international roaming.  In short, there are no ports to spare for unnecessary chipsets and, if we were forced to support Band 12, something else would likely have to go.  

Advocates of an interoperability mandate have suggested that handset manufacturers might design handsets that use an additional switch to support Band 12 and Band 17 on a single port, but they fail to acknowledge that the introduction of those additional components would further degrade device performance and further constrain device form factors.

AT&T made a substantial investment to acquire Lower 700 MHz D and E Block licenses, and should have the flexibility to design devices that make productive use of that spectrum.  A Dual Band mandate today would threaten our ability to support those blocks in our devices in favor of a chip set that we do not need and that would offer no benefit to our customers.  As a result, AT&T customers could lose critical downlink capacity that the D and E blocks are being engineered to provide and AT&T’s substantial investment in the D and E blocks could be stranded.

Such a result is completely unacceptable, particularly because A block licensees are currently in a position to deploy Band 12 devices today.  As the A Block licensees readily concede, Qualcomm already offers the necessary chipsets, and thus in the vast majority of cases A Block licensees need only make a small investment to obtain Band 12 variants of devices already under development.  Indeed, U.S. Cellular – the only A Block licensee that has deployed a Band 12 network – currently offers fifteen Band 12 LTE devices to its customers, including ten smartphones, two Wi-Fi hotspots, two data cards, and one tablet, from five different manufacturers (soon to be six manufacturers).

Notably, U.S. Cellular offers Band 12 versions of the Samsung Galaxy S III and Galaxy Note II, as well as the Motorola Electrify M (a variant of Verizon’s DROID RAZR M).   All of these are variants of VZW’s Band 13 CDMA devices.

Finally, and significantly, no mandate will solve the problem with the CH 51 exclusion zones.  A block licensees in CH 51 markets simply cannot build and will not be able to pursue a build until CH 51 broadcasters are relocated.  Indeed, Leap, which owns the A block license for Chicago, recently requested a two year extension of the June 2013 build requirement because of the CH 51 exclusion zone prohibitions.  Any solution that does not address the CH 51 problems will be woefully inadequate and leave the A block significantly impaired and undeployed.

For all these reasons, a Dual Band approach resolves very little.  The only solution to the interoperability challenge is to fix the interference problems.  If CH 51 operators were relocated and the E block service rules harmonized with the rules for the rest of the lower 700 MHz band, business and deployment opportunities in the A block would lead to a resolution without the need for a regulatory mandate.

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