The Federal Communications Commission received over 300 comments from the public regarding its proposals to allow broadcast television stations to voluntarily participate in an auction of their spectrum to mobile broadband providers and to involuntarily repack remaining television stations into a smaller television spectrum band.  Broadcast television station groups, individual stations, mobile broadband providers, wireless microphone operators, proponents of unlicensed spectrum uses, equipment manufacturers, radio astronomers, wireless medical device makers, and a variety of trade associations weighed in on the Commission’s proposals.  There was significant disagreement on a number of the FCC’s proposals — including the extent to which viewers’ existing television services should be preserved in the repacking, the timeframe to complete the repacking, and how to address wireless microphones and unlicensed uses in the spectrum band.  However, at least three key areas of general industry agreement emerged:

1. It is critical that the Commission get the incentive auction and repacking process right.  Commenters generally agreed that the Commission has one shot at getting the incentive auction and repacking process right, and that the stakes are high if this first-of-its-kind process fails.  While mobile broadband providers focused on ensuring that the incentive auction process maximizes participation by broadcasters and mobile broadband providers, many broadcasters focused on ensuring that viewers do not lose access to their television services as a result of the repacking.
2. Broadcasters should be made whole.  In general, commenters agreed that the intent of the Spectrum Act legislation is to make broadcasters whole.  Mobile broadband providers encouraged the Commission to adopt rules that maximize voluntary participation by broadcasters in the reverse auction, where the market will determine fair compensation for the spectrum that is reclaimed.  Broadcasters, in contrast, encouraged the Commission to adopt fair reimbursement procedures to ensure that stations remaining on air after the incentive auction are able to continue providing valuable television services to the public.
3. International coordination will be challenging and must be addressed.  Across the board, commenters agreed that coordination with the Canadian and Mexican governments will be necessary and challenging for stations along the border who are forced to transition to new channels.  Commenters encouraged the Commission to address this issue by developing a plan for addressing international coordination as soon as possible.

In addition, AT&T, Intel, the National Association of Broadcasters, Qualcomm, T-Mobile, and Verizon Wireless jointly submitted a letter urging the Commission to follow a number of principles when developing the 600 MHz band plan.  These principles include, for example, adopting a contiguous “down from TV 51” approach with uplink at the top, relying on 5 MHz spectrum blocks, and incorporating a “duplex gap” or spacing between the uplink and downlink spectrum of at least 10 MHz.

The Commission is accepting reply comments until March 12, 2013.  You can find more information about the proposed incentive auction and repacking here, here, and here.