T-Mobile Derides Verizon-Sprint-Nextel H Block Proposal

Verizon Wireless, Sprint and Nextel had urged transmit power limits for terrestrial mobile devices designed to prevent overload and intermodulation interference. They said the potential for interference was greater in the 1917-1920 MHz portion of the H Block than in the 1915-1917 MHz portion and asked the FCC to set a 6 dBm EIRP limit at 1917-1920 MHz and a 30 dBm EIRP at 1915-1917 MHz. They also said for operations in the 1850- 1920 MHz band, out-of-band emissions (OOBE) falling within the 1930-2000 MHz band couldn’t exceed -76 dBm/MHz.

“VSN’s OOBE proposal would increase costs and reduce functionality for GSM A-F handsets due to requirement to tighten OOBE specs beyond current GSM standards,” T-Mobile said in an ex parte Mon. It said VSN had not shown that extending the requirement to the PCS A-F Blocks was necessary to prevent harmful interference. T-Mobile also said while VSN’s EIRP proposal would make the H Block usable for CDMA 3G operations, it wouldn’t let that spectrum be utilized for UMTS operations or other broader bandwidth radio access technologies.

T-Mobile urged the FCC to ensure that “appropriate safeguards are in place” to protect incumbent PCS operations from harmful interference from H Block out-of- band emissions (OOBE) and in-band overload. It said a power limit of 200 mW EIRP measured on an average basis and a requirement that H Block handsets conform to an OOBE limit of -76 dBm/MHz should make that H Block “usable” for PCS-like services while protecting incumbent PCS operations. T-Mobile said industry data given the FCC weren’t conclusive, especially with regards to GSM handsets. “Given the tens of millions of PCS handsets at issue, more testing is advisable.” T-Mobile said the FCC should study trends in handset interference mitigation techniques likely to be in place at the time H Block operations would launch. The Commission should also study the impacts of MSS/ATC operations adjacent to H Block operation, it said, noting “the burden of addressing any such impacts should not be imposed unilaterally on H Block licensees.”

T-Mobile defended a joint proposal by T-Mobile and the Rural Telecom Group (RTG) to revise the plan for advanced wireless services (AWS) in the 1710-1755 and 2110-2155 MHz bands (CD March 15 p8). The proposal calls for reconfiguring the existing 30 MHz E Block AWS licenses block to create a 6th AWS license block.

T-Mobile said the FCC should revise the existing band plan for “compelling” reasons: (1) With industry consolidation and “dramatic” increases in large wireless carriers’ spectrum holdings of large wireless underway, it’s important that other national, regional and rural carriers gain access to “affordable” and “appropriately sized” spectrum blocks to enhance capacity and coverage and deploy new products. (2) Creating a 6th license block would ensure that national, regional and local licensees wouldn’t be forced to buy more spectrum than they need. (3) Bidders needing blocks larger than 20 MHz could aggregate 2 or more smaller blocks at auction. (4) With 20 MHz available in the smallest RSA/MSA market areas, local, mostly rural carriers would be able to afford adequate spectrum for voice and advanced data services in “markets of manageable size well suited to their existing service footprints.”

T-Mobile stressed it was “vital” that the FCC auction 90 MHz of spectrum at 1.7/2.1 GHz no later than June 2006. “This is the largest amount of spectrum coming available in the near term and is critical to the growth and competitiveness of wireless operators of all sizes,” it said.