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Today, on behalf of the Public Interest Spectrum Coalition, Public Knowledge filed comments with the FCC about the plans to build wireless chipsets for the 700 MHz band, the band that is going to be important to the deployment of 4G service. While that might sound as boring and technical as boring and technical can be, it actually has some very important and straightforward real world ramifications.
Basically, we are urging the Commission to make sure that all of the 700 MHz devices can work across all of the 700 MHz. That way, when you switch from Verizon to AT&T to a regional wireless company, you can take your wireless device with you. Just as important, if you are already with Verizon or AT&T or a regional carrier, you won’t have to wait for the device you love to be reengineered for the specific piece of the 700 MHz band you happen to be on.
Two years ago, the FCC auctioned off a new part of the spectrum – the 700 MHz band. At the insistence of public interest groups, including Public Knowledge, the FCC imposed special openness rules on part of that band – the “C” block. These rules – known as “no locking and no blocking” – did just what it sounds like they did. The winner of the C block had to make sure that it was open to all devices that would not harm the network, and that customers could take their devices to other carriers if they wanted to.
This all seemed fairly straightforward. However, the fight has now moved to a place even more obscure than the FCC: 3GPP, a wireless industry standards setting body. AT&T and Verizon are insisting that 3GPP adopt wireless radio chipset standards that break up and rope off the 700 MHz band into smaller, non-interoperable pieces. As a result, instead of a single wireless radio chip that could be used by any device on any part of the 700 MHz band, the device would need a specific chip to a specific part of the band. If a manufacturer wanted to make a device available to everyone in the 700 MHz band, that manufacture would have to make a number of different versions, each with a slightly different wireless radio.
We told the FCC that this is a bad idea for three basic reasons. First, it hurt consumers because it guaranteed that no wireless chipset would ever reach true economies of scale to drive down costs. Moreover, consumers would have a hard time switching between carriers. If they were lucky, they would have to repurchase all of their devices to work with the new chipset. If they were unlucky the manufacturer of the device would not have a version with the necessary chipset, so the consumer would be unable to use the device of their choosing.
Second, it undermines the FCC’s goals. One of the major reasons that the FCC set up the special C block rules was to try and spur innovation and encourage other parts of the spectrum to embrace openness. If it is impossible to take a C block device to another carrier (because its wireless radio only works in the C block), it makes it much less likely that it will easily spread to different carriers. Manufacturers are less likely to invest in new devices if they can only serve a narrow market (the C block alone), compared to a 700 MHz wide market.
Third, breaking up the 700 MHz undermines public safety. In the National Broadband Plan, the FCC detailed how important it was for the public safety community to be able to access the entire 700 MHz band in an emergency. This will assure that they have adequate communications bandwidth when it counts. However, if device manufactures are only making block-specific devices, public safety will not be able to purchase low-cost, off the shelf devices. Instead, the public safety community will have to develop and purchase specially designed, limited run “all 700 MHz” devices. In addition to severely limiting the devices available to them, it will increase the costs of the devices that are available significantly.
As I said, 700 MHz wireless chipset designs can appear to be a bit obscure. However, details matter. Without band-interoperable devices, the promise of the 700 MHz will be diminished and customers will lose.