With only a week to go before the FCC votes on the final incentive auction procedures framework (the beginning of the lobbying quiet period), CTIA: The Wireless Association wrote the FCC chairman and commissioners with an eight-item wish list of "targeted" reforms it calls "essential."
1. Insure no interference from wireless microphones and unlicensed devices being allowed to use the guard bands and duplex gap—buffer spectrum between broadcast and wireless operators and between wireless uplink and downlink spectrum.
2. Require unlicensed and wireless devices to cease transmissions immediately—CTIA calls it a "stop buzzer"—if they interfere with licensed wireless service.
3. Clear as much spectrum in near nationwide bands as possible while minimizing the number of TV stations that have to be placed in or near the wireless bands to allow for the variable band plan that clears the maximum amount of spectrum. That means reducing the allowable threshold percentage of interference below the FCC's initial 20% impairment limit.
4. Don't allow "secondary" users to operate contemporaneously in auctioned bands wireless companies are paying billions for. Those secondary users would be broadcasters. "The Commission should define the term 'commencement of operations' in a manner that enables licensees to conduct pre-deployment testing without encumbrances from secondary users and should not burden licensees with obligations to provide multiple, ongoing notifications to secondary users in order to access their own spectrum." Broadcasters have been arguing against the 39-month hard deadline for TV stations to make way for wireless operations after the auction.
5. The FCC should not do "repetitive" inter-service (between broadcasters and wireless operators) interference analysis.
6. The FCC should provide wireless bidders in the forward auction with complete information, in advance of the auction and in an easily accessible format, on potential inter-service interference and license impairments in the spectrum they will be bidding those billions for.
7. The FCC should increase the time between reverse and forward auctions from two days to 10 business days.
8. Hold multiple mock auctions before the real one.
