Today, AT&T will file reply comments with the FCC in a proceeding launched to explore interoperability challenges in the lower 700 MHz spectrum bands.  Amid the noise of the opening round of comments, fundamental facts have emerged that underscore that the proposed elimination of Band 17 would be profoundly poor public policy.

First, the proposed interoperability mandate sought by some commentators would be pointless.  The A Block licensees’ central claim is that they cannot obtain Band 12 devices without a mandate.  This claim has now been soundly rebutted.  Although the first A Block LTE service was only recently launched, A Block licensees already have access to Band 12 handset, tablet, and hotspot variants of devices first produced for other LTE bands, most significantly, Verizon’s Band 13 LTE devices that fall back to CDMA technologies.

Ignoring that fact, A Block licensees speculate that, absent a regulatory mandate, device manufacturers might not offer them the latest, greatest LTE devices, or might not do so at a reasonable price.  That concern too has now been debunked.  U.S. Cellular, the only provider currently operating in Band 12, just announced that it is offering a Band 12 variant of Samsung’s newest flagship LTE smartphone – widely considered this summer’s “blockbuster Android smartphone” – at the same time and at the same retail price as AT&T and Verizon.  Indeed, Samsung is debuting its Galaxy S III smartphone with five different U.S. providers – each of which uses different spectrum bands.  This simply confirms what AT&T has long argued – that LTE deployment in the United States will be a fragmented multi-band exercise that will require multi-band solutions.  Both chipset and device manufacturers understand that and are responding.

Second, the comments confirm that an AT&T Band 12 device would be virtually worthless to any A block licensee requiring CDMA fall back.  As one A Block licensee candidly noted, a Band 12 mandate “makes no difference to people like us.  …  If AT&T is forced to go from 17 to 12, they will still have GSM fallback, so that wouldn’t open up the availability of handsets to anybody.” 

With their “device ecosystem” arguments dismantled, the A block licensees fall back to roaming as a justification for a Band 12 mandate.  But here too, the rationale falls far short.  The opening comments confirmed that multiband chipsets that are already the industry norm will provide A Block carriers with robust opportunities to roam on a variety of LTE (and other) networks in addition to other Band 12 networks.  U.S. Cellular already uses quad-band LTE chipsets (and, indeed, was the first to offer that capability).  And LTE roaming options are about to expand further with chipsets that allow a device to transmit and receive signals on up to three different bands below 1 GHz and 7 bands in total.  And not only is a Band 12 mandate unnecessary to promote roaming, it would be flatly inconsistent with the Commission’s finding just last year in its Data Roaming Order that it is manifestly not in the public interest to require any provider to alter its network for the sole purpose of enabling roaming.

Even absent these failings, no one has disputed that a Band 12 mandate would do nothing to eliminate the CH 51 exclusion zones where A Block licensees are prohibited by the Commission’s own rules from deploying wireless broadband networks.

In the end, a Band 12 mandate would provide no quantifiable public interest benefit.  Yet it would exact an enormous price.  As our opening comments demonstrated, the proposed mandate would not only generally undermine incentives to invest in next generation LTE networks in reliance on critical 3GPP standards, but it would specifically subject AT&T and its customers to interference that would degrade AT&T’s LTE service quality and force AT&T to incur enormous and otherwise unnecessary costs in an effort to limit the harm from such interference.  The record evidence now overwhelmingly confirms that the interference-related harm is real and substantial.  Rigorous testing and engineering analyses demonstrate that at typical real-world power levels, Channel 51 transmissions would cause substantially degraded service – creating broad LTE “no call” zones –if AT&T were required to use Band 12 devices.  And there has never been any serious debate that high power E Block transmissions would cause debilitating interference to its neighbors. 

No regulatory solution will address these challenges absent full elimination of the root cause:  interfering transmissions from Channel 51 and the E Block.  On this point, there appears to be growing consensus.  Virtually every commentator agreed that the public interest would be served by prompt Commission action to prevent high-powered Channel 51 and E Block transmissions that are incompatible with efficient and effective use of the Lower 700 MHz bands.  And the comments contained a number of constructive suggestions for how the Commission could proceed to achieve this result.  AT&T continues to stand ready to work with the Commission, the A Block licensees and all interested stakeholders to develop win-win solutions that will promote broadband investment, spectral efficiency, interoperability and, most importantly, the interests of U.S. broadband wireless customers.

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