Is it PCS H or AWS H? FCC H Block Auction Rulemaking

Last week the FCC released its Notice of Proposed Rulemaking for the Service Rules for the Advanced Wireless Services H Block.  So despite the fact that the H channel in discussion here are virtually adjacent to the PCS block of spectrum, they are referred to as AWS H.  I'll continue to call them PCS H because that have no relationship with the spectrum commonly referred to as AWS (1.7 and 2.1GHz).  My primary question as I reviewed this rulemaking, was how the auction would be structured so there would be interest for this spectrum block, beside Sprint.

Clearly, this spectrum block is more valuable to Sprint, since it can be combined with its nationwide PCS G block to enable Sprint to migrate to a 10x10 LTE channel from its current 5x5 LTE channel.  Doubling their channel size will get this LTE deployment on par with Verizon, AT&T, and T-Mobile's initial deployments.

Interestingly, the FCC doesn't comment to the use of the channel for LTE, they consider a deployment with CDMA more likely.  This is probably the only way to think that there will be bidders beside Sprint.  A T-Mobile or AT&T could purchase this spectrum for additional WCDMA capacity since a WCDMA channel would fit perfectly in this block, but I believe that a deployment of WCDMA in this block would be delayed by the 3GPP standards board in the same way that Sprint's LTE deployment would be waiting for standards body support for a new band plan.

Two other interesting notes from this rulemaking.  The FCC is proposing to issue the spectrum with Economic Area (EA) Geographical Licensing.  Above is a FCC map depicting the recognized Economic Area boundaries.  Evidently EA licensing was chosen to encourage build outs in rural areas.  Given that the build out requirements are easily met by building only the large cities first, I don't agree with this logic.  More likely, the EA licensing allows the FCC to receive a higher price for rural areas since their POPS roll up within a more valuable metropolitan area.

The licensees will receive 10-year licenses with the requirement that 40% of the POPS are covered within 4 years and that 70% are covered before the license is renewed after year 10.  Neither of these requirements will drive investment into rural areas.

This spectrum will be challenging to utilized near the borders: San Diego, Detroit, Buffalo, and McAllen/Brownsville since Canada and Mexico are running 3-4 years behind the US in spectrum policy.  The use of this spectrum in border markets has to be done without interference with the Canadian and Mexican systems currently using this spectrum.

Lastly, this spectrum comes with a requirement to share the microwave relocation costs that Sprint and UTAM incurred to make the PCS G block usable.

Sprint Small Cells (Not Small Cells)

Sprint Small Cells - Light Reading

Above is a link to a Light Reading interview with Sprint VP of Network Development and Engineering Iyad Tarazi. The hot topic in wireless is small cells.  Clearly the carriers are blurring the definitions of small cells to demonstrate that they have a large installed base or are significantly down the road for new network installations.  From Iyad's interview, Sprint has over 500,000 femto cells providing primarily indoor coverage enhancements to customer residences.  These are using the customer's broadband service for connectivity and do not support handover of voice or data calls.  (Calls drop as you leave home and need to be re-originated on the carrier network.  Iyad describes the small cell developments for their LTE coverage.  It is not stated, but it is likely that this development is only for their PCS G frequency block, not Clearwires forthcoming LTE.  In addition, I would challenge whether they meet the definition for small cells.  Sprint is continuing down the path of a non-network integrated coverage device.  Whether installed in a small business or a residence, the products Iyad described are not integrated with Sprint's macro network, do not provide interference protection to that network, and will not hand over voice or data calls over without dropping the connections.  This is really no improvement to providing WiFi coverage and is deceptive to include in the small cell discussion where a prerequisite should be to provide seamless integration with the macro network.  What Sprint has solved for their version of the "small cell" is the impact of providing cost effective backhaul connectivity to the small cell.  In all of the cases that Sprint has developed a "small cell" product, they are utilizing the customers backhaul facility for connectivity.  To get true integration with their carrier/macro network, Sprint will need to provide and pay for backhaul to their facilities for small cells.

PCS H and 3.5GHz FCC Rulemaking

The FCC released their rulemakings today for the PCS H Auction and the Small Cell 3.5GHz spectrum.  In keeping with with my company's mission statement "Explaining the Wireless Industry from a Carrier Mindset", I will be evaluating and commenting on both of those FCC documents by the end of the week.

Why Couldn't Clearwire Sell Their Spectrum?

Another area of interest from the Sprint / Clearwire conference call yesterday were Erik Prusch's comments related to Clearwire's attempts to sell spectrum in 2010.  Erik indicated that the offers they received were below value.

I will be conducting a webinar for GLG Research on January 4, 2013 where I will be discussing the history and challenges of Educational Broadcast Service (EBS) and Broadband Radio Service (BRS) spectrum.  I believe that the undervalue offers were due to issues with the spectrum channelization, geographic boundaries, unlicensed channels, and FCC mandated obligations for leased spectrum.

Sprint Purchase of Clearwire

Inevitable.  If you have followed the Sprint/Clearwire saga since they were joined with Google, Time Warner, Brighthouse, Comcast, and Intel; it was obvious that Clearwire had a hard road ahead.  In yesterday's announcement Erik Prusch indicated the depth of the internal concern; Clearwire had retained an advisor to provide options for restructuring.

Once the carrier consolidation of 2012 occurred, the only path forward I saw for Clearwire was funding minimal operations into the 2014 time frame, with a hope that the other 3 national players would finally need the wholesale access to Clearwire's spectrum. With each of the national players, except Sprint, lining up their LTE capacity growth spectrum, the need for wholesale access to Clearwire's WiMax or planned TDD-LTE network was unnecessary.  Clearly Sprint needed Clearwire for its LTE growth spectrum and at $0.21/MHzPOP I believe we will look back 5 years from now and view this was steal.  Not only has Sprint put in concrete their LTE capacity growth, but they have cornered the market available spectrum for years to come.  When you consider that Clearwire controlled 160MHz of spectrum which could be expanded to nearly 200MHz in most metro areas with additional spectrum leasing and spectrum purchases, Sprint has the only meaninful swatch of "new" spectrum that will come to market in the next 5 years.

I don't see the Broadband Incentive auction, the Dish spectrum, or the recent 3.5GHz spectrum as meaningful for efficient macro network coverage.  Those subjects are covered in other blogs.

The purchase of Clearwire does not guarantee smooth sailing for Sprint.  Sprint still has very significant short term issues.  Their LTE network is 5X5 which is the smallest of any of the national carriers.  In addition, their customers with WiMax devices will continue to transition over to this network as they upgrade their devices.  Clearwire's TDD-LTE hotspot network is only at the construction start stage, with likely very limited coverage throughout 2013. Clearwire has talked historically about devices arriving for this network 2Q or 3Q 2013.  Thus, there won't be any material movement of traffic from Sprint 3G or LTE network until early 2014.  From what I experience on my Sprint Samsung S3, the 3G network is already challenged and LTE is not available in my market (Seattle).  It will get worse before it gets better.

AT&T Carrier Aggregation - Band 5 and Band 17

Posted during the 3GPP RAN Meeting on Dec 4-7, 2012 in Barcelona, Spain.

Customer Requirements for LTE Advanced Carrier Aggregation for Band 5 and Band 17.  This appears to be supporting AT&T's need to aggregate carriers between their 700MHz (Band 17) and the Cellular band (Band 5).  No mention of including the redefined WCS band.  Could this be a sign that AT&T's growth plan for LTE will be to grow into the cellular spectrum first, and then to the WCS spectrum?

Limitations to Clearwire's TDD-LTE Wholesale Model

When Clearwire first offered wholesale access to its spectrum, it was using the WiMax technology.  It had built this technology in the 2.5GHz band and it was covering up to 80 markets by the end of 2010.  At this time Clearwire provided meaningful WiMax coverage in each of their markets for Sprint, Comcast, Time Warner, and Best Buy to provide their customers 4G Only WiMax devices.  Essentially, Clearwire's WiMax network had broad enough coverage that these operators could selectively offer their customers service in the markets that Clearwire offered WiMax service.

As Clearwire has embarked on the TDD-LTE strategy, their wholesale model has gotten a bit more complex.  First, they continue to sign up relatively small partners for their WiMax wholesale offering:  Simplexity, Freedom Pop, Best Buy, CBeyond, Mitel, NetZero, Locus, and Kajeet.  They have Sprint already signed for Wholesale Access to the forthcoming TDD-LTE network and added Leap to the WiMax partner list early in 2012.

Leap demonstrates the change of direction for wholesale agreements for the TDD-LTE network.  For their TDD-LTE roaming strategy, a roaming partner would need a "thin" LTE network providing coverage in their markets.  They would then roam over to the Clearwire TDD-LTE "hot spots" only for capacity.  Sprint's 5x5MHz FDD-LTE deployment would qualify as a "thin" LTE deployment.  This implicit requirement for a "thin" coverage network, eliminates non-carriers from the TDD-LTE wholesale process since it would be difficult to sell "spots" of coverage across Los Angeles if you didn't have service already over the area.

In addition, the quantity of sites in the Clearwire LTE plan started at 8,000 of their 16,000 sites, was reduced to 5,000 sites and recently has arrived at 2,000 sites.  This has increased the challenge of finding wholesale partners with this very limited coverage.

Clearwire and Dish: Spectrum Hosting

The idea of Clearwire hosting Dish's AWS2 spectrum seems to be bouncing around the news pages today.  Clearly (no pun intended), Clearwire operates a 4G network that is very similar to Sprint Network Vision concept.  With the necessary zoning and permitting, Clearwire could add this spectrum band with a new set of antennas and tower top base stations.  So, this would get Dish to market after they pass the standard's body requirements for defining the new band, but what does it provide Clearwire.  Different than Sprint, they don't need the spectrum, they need capital to increase the TDD-LTE build out.  I believe that Clearwire would much rather Dish sign up for their wholesale mobile broadband service with an infusion of capital.  My next blog will look at one of the other drawbacks for potential wholesale partners like Dish with Clearwire's TDD-LTE plan.  Check back later in the week.

Dish and Sprint: Spectrum Hosting

On the surface, a deal to host Dish's spectrum on Sprint's Network Vision platform would make alot of sense.  The chart below highlights that part of Dish's (DI) spectrum is adjacent to the AWS-2 spectrum that recently has been referred to as the PCS H spectrum.  Sprint is interested in acquiring this spectrum to increase their LTE channel size from 5x5 FDD-LTE to 10x10 FDD-LTE. Unfortunately, the Dish spectrum is configured where the uplink (from the handset to the cell site) would be adjacent to Sprint's LTE downlink (cell site to handset).  This will be problematic for Dish. Cell sites transmit at much higher power than handset signals are received.  Expensive filters on the separate Dish antennas may not be enough to allow the Dish antennas to be installed in the same plane (level) as the Sprint antennas.

You can look at this as being similar to the Lightsquared deal, except Lightsquared was planned into the deployment through the zoning and permitting process.  With the standards body processes that are in front of Dish, it would still be years before equipment is installed and a network operating on Sprint's towers.    A Dish MVNO to operate on Sprint's 3G Voice and LTE network would allow Dish to get a wireless product to market quickly.

T-Mobile (Deutsche Telekom Capital Markets Day 2012)

There were several interesting details that came out of the Deutsche Telekom Capital Markets Day 2012.  The primary announcement concerned T-Mobile USA being blessed with the ability to sell the iPhone.  T-Mobile's new CEO, John Legere indicated that it will have a dramatically different experience than the other iPhone on the market.  In addition T-Mobile will sell it unsubsidized, although they will offer financing plans.  This should continue to drive T-Mobile's Cost Per Gross Add (CPGA) down, although they didn't disclose if this only affects their iPhone retail business or potentially all of their retail.  This is a dramatic step which eliminate the primary issue that I have had with the subsidy pricing model.  I have a problem with paying the same monthly rate for my smartphone if I am out of contract as the guy that who just got a new device.  With T-Mobile's plan the true cost of upgrading will be carried by the customer, with the expectation of lower monthly rates.

Above is a restatement of the testing data from PC Magazine which T-Mobile released.  It is interesting to note how far their speeds have fallen from their early announcements in late 2010 concerning the HSPA+ network.  It is also worth noting that they compared AT&T's LTE network.  You can again see the loading effect on the network.  AT&T's Chicago network was launched September 2011 so it has been loading for over a year reflecting the slower speeds.  AT&T's complete New York and San Francisco networks are much newer, launching September 2012, thus carrying less traffic.  I am curious why T-Mobile did not chose to compare themselves to AT&T's 4G (HSPA+) network.

From a LTE network build perspective, this was the first time I have heard clearly that T-Mobile is deploying tower top electronics.  It is interesting that they state that they are the first carrier in North America to broadly deploy radio-integrated antennas.  Clearwire was the first carrier to deploy tower top base stations, followed by Sprint with their Network Vision project.  T-Mobile is playing up the fact that their radios are some how integrated into the antenna.  Not really an earth shattering announcement.  From a technology perspective, deploying the tower top base stations will fill in coverage holes and improve data speeds so it is a good move.  In addition, these base stations will be Release 10 capable, meaning a software update will move these radio from the LTE features to the  LTE Advance features.

The Numbers:

• Current 4G Network covers 225 million POPs
• Release 10 Equipment being deployed to 37,000 cell sites
• T-Mobile and MetroPCS:  Migration not Integration
• With MetroPCS Spectrum Position across Top 25 service areas is improved by 21%
• Planning to shutdown 10,000 macro sites from MetroPCS
• Retain and integrate 1,000 MetroPCS sites
• Operating MetroPCS Markets
• San Francisco 
• Detroit
• Boston
• New York
• Dallas
• Atlanta
• Florida (except panhandle)
• MetroPCS brand will increase coverage from 105MPOPs to more than 280MPOPs.

What is wrong with Spectrum Pricing?

Clearly the wireless industry has locked in spectrum pricing with the MHz-POP pricing model, but is this the right way to look at it as we move into a 4G World where data throughput and capacity are key?  For those that aren't familiar, the typical value of spectrum is determined by the $/MHzPOP which is the dollars spent for the spectrum divided by the total amount of spectrum times population that spectrum covers.  This model falls short now as carriers are interested in acquiring larger contiguous blocks of spectrum enabling higher users speeds and more capacity.

To use a real estate analogue, a large plot of land is much for flexible for multiple uses, than two plots, even if they are in the same neighborhood.  In real estate, the developer that is able to consolidate several tracks of land into a larger development is rewarded as he sells the larger development.

In the wireless industry, we continue to price based upon the $/MHz POP basis, even as carriers such as T-Mobile and Clearwire have combined adjacent channels to create larger bands of spectrum to utilize in larger LTE channels.  T-Mobile has worked this year with Verizon, SpectrumCo, and MetroPCS which will allow it to assimilate a 2X20MHz LTE channel on a national basis.  Clearwire has leased and purchased operators in the BRS and EBS spectrum bands providing it with an average of 160MHz of spectrum in the top markets.  Since Clearwire's spectrum has many geographical boundaries, it is difficult to say how many 20MHz channels they could support across each of their markets, but they have been successful consolidating small bands of spectrum into larger more flexible spectrum bands.

How does a larger band of spectrum affect the wireless carriers?  In the US, carriers have deployed FDD-LTE in 1.25MHz channels, 5MHz channels, and 10MHz channels.  As you increase the channel size throughput performance improves because a lower percentage of the data packets are dedicated to overhead activities   Qualcomm has provided achievable LTE Peak Data Rates for different channel bandwidths based upon whether the antennas are 2x2 or 4x4 MIMO.

Link to Qualcomm Document

As you can see in the 4x4 MIMO downlink case, the throughput is 12Mbps greater in the 20MHz channel than the composite of 4-5MHz channels.

So if a  20MHz channel is 4% more efficient than 4 - 5MHz channels should the MHz POPs pricing adjust accordingly?

By the way.. I am going to look for more source data on the capacity improvements for wider channels, a 4% improvement would seem to be relatively negligible.  I recall hearing 30% improvements in capacity when a channel size is doubled, but I haven't been able to re-source that data for this blog.   More to come.

Webcast: Spectrum Update - Broadcast and Whitespace Auctions

Below is a link to an Investor's Presentation provided by AllNet Labs on the upcoming Broadcast Incentive Auctions and Whitespace Spectrum.

Audio and Slide Presentation

Download Presentation

Presentation Outline

Agenda

• ›       Current FCC Status
• ›       Preliminary Plan
• ›       Primary Participants
• ›       Devices
• ›       Preliminary Spectrum Availability

Whitespace and Broadcast Spectrum Clarification

It appears that there is confusion between Whitespace spectrum and the Broadcast Spectrum Auction.  As I reviewed the Broadcast Incentive Auction Notice of Proposed Rulemaking, I decided to sort these two issues out.

The Whitespace spectrum proceeding allows new devices to use the UHF and VHF bands if they have the on-board intelligence to determine what Broadcast TV channels operate in a market area and tune to unused (non-interfering) channels.  These devices must be able to determine their location and communicate with a host that will indicate the 'open' channels for their location.    For the UHF frequency band, the whitespace spectrum is defined to cover 470MHz to 698MHz.

The spectrum that the FCC is attempting to clear for the Broadband Incentive Auction is from 572MHz to 698MHz, which would reduce the spectrum band available for Whitespace operation to the VHF band, and 470MHz to 572MHz.

In addition, once the broadcast spectrum is repacked, the whitespace database administrators will need to update their broadcast records, for the broadcast operations that have shifted into the lower UHF band or the VHF band.

To state it another way, Whitespace Spectrum is multi-use spectrum while the Broadcast Incentive Spectrum  is targeted for wireless carrier exclusive use.

Has anyone begun to hear of companies using the Whitespace technology commercially?

Webcast: WiFi Offloading for Carriers - Challenges and Practical Experience

Below is a link to an Investor's Presentation provided by AllNet Labs focusing on the concepts of WiFi offloading

Audio and Slide Presentation

Download Presentation

Presentation Outline

Agenda

• › Reasons Carriers Need to Offload their Networks
• › Where do the Networks need to be offloaded
• › Customer Experience
• › Applications Experience
• › Next Generation Hotspots and Handsets
• › Business Concerns
• › Solutions and Business Opportunities

CDMA Sunset

Yesterday, Verizon announced 2021 as the retirement date for their CDMA networks.  This would include the 2G voice and the 3G EVDO networks.  To accomplish this Verizon will need to develop Rich Communication Services (RCS) for their LTE network and change out customer handsets.  9 years should allow this to be a smooth transition.  Verizon has clarified that this is more of a planning horizon.  Rich Communication Services is the route carriers are taking to retain their voice customers.  RCS is essentially Carrier Voice over IP (VoIP).  It will likely be the only VoIP service that will be capable of delivering E911 location information as is required today.  Obviously when every phone (device) only has a data connection, many VoIP solutions will be competing for the mobile customer.

In looking at Verizon's web site, I can purchase a Samsung Galaxy Tab 2 for $349.99 and have 4GB of data monthly for $30.00/mo, no contract.  I agree that this 7" tablet is a little big for a phone, but it does fit in my back pocket.  For $30/mo, I can have both voice and data using Skype, OOMA, or ClevorConnect for a small monthly fee.  For an iPhone with a 4GB data plan, I would be paying $110/mo for access.  Once the LTE network matures, covering homes, highways, and interstates between cities, an $80/mo savings will be pretty attractive.

Verizon's "shut down" statement also causes me to wonder why Sprint will be spending 3 years and multiple billions of dollars, modernizing their CDMA network.  I understand the enhancements to coverage that Network Vision provides and the unfortunate lack of other spectrum partners (Lightsquared) to use their new base stations, but I certainly hope that Sprint ran the numbers on developing a Nextel Push-to-Talk (PTT) solution on a WCDMA platform, before launching down the current path.  At this point, it appears that Sprint will be the primary US carrier pushing for continued support and development on the CDMA platform.

How are carriers going to prevent being only data providers without the current high dollar voice services?

An Offer from Sprint for MetroPCS?

It is interesting that a Sprint offer would be forthcoming for MetroPCS considering that Sprint walked away from a purchase earlier this year.  As the report below indicates, Sprint's spectrum holding are in the PCS spectrum band including their national PCS G channel while MetroPCS's spectrum holding is primarily in the AWS spectrum band.  Although Sprint and MetroPCS operate compatible CDMA networks and handsets the MetroPCS network would be virtually redundant with the Sprint network except for perhaps 5% of the towers that could be utilized to improve coverage or overload capacity.  Adding MetroPCS' spectrum to Sprint's spectrum holding is a case of 1+1=2 since no new efficiency is found.  Conversely, looking at the merger with T-Mobile, there is an opportunity to create a 1+1=3.  This is possible as I expect T-Mobile and Verizon to rationalize their spectrum holdings in the AWS band allowing each carrier to maximize their channel size across a market in this band.  Once MetroPCS' customer are shifted to T-Mobile's HSPA+ network, the MetroPCS spectrum can be added to the T-Mobile initial 10x10MHz FDD-LTE offering to create a 20x20MHz FDD-LTE channel.  This positions T-Mobile as one of the front runners on LTE channel size in the US.  Only Dish and Clearwire currently have the spectrum holdings to launch a 20MHz wide LTE channel and Dish's opportunity still sits with the FCC and its need to protect the AWS2 spectrum that is also being referred to as PCS H spectrum.  It is likely that Dish will not net the entire 20MHz that they anticipated.

T-Mobile and MetroPCS - Dreams of AWS

What does the merger agreement between T-Mobile and MetroPCS mean on a market by market basis?  You can fully understand the plan unless you figure in the Verizon's spectrum holdings in the AWS band.  Above is a screenshot of the AllNet Labs Spectrum Landscape that depicts the uplink AWS spectrum positions in New York and Los Angeles.  As a reminder, uplink is the traffic that goes from the mobile device to the cell site. In the New York market Verizon owns 2 - 10MHz blocks of spectrum and T-Mobile owns 2-10MHz blocks of spectrum and 1-5MHz block of spectrum, assuming the merger receives approval.  Since the game for Verizon and T-Mobile now is 4G-LTE, both carriers would prefer to have the largest blocks of contiguous spectrum in this band as possible.  This will allow the maximum speeds out of their spectrum positions.  Since Verizon's New York spectrum is currently unused, I would expect Verizon and T-Mobile to exchange the F block channels with the A block channels.  In this scenario, Verizon would own a 1x20MHz channel and T-Mobile would own a 1x25MHz channel.  This is inline with T-Mobile's statement that the MetroPCS merger would provide it with a 1x20MHz LTE channel in most markets after the MetroPCS spectrum is recovered in roughly two years.

Los Angeles is a bit more complicated unless the AT&T spectrum transfers to T-Mobile have not been updated with the FCC.  With October data from the FCC, AT&T still holds very minor positions in the AWS band in several of the Top 20 markets.  Assuming this is an accurate picture of the Los Angeles spectrum, T-Mobile and Verizon could exchange B and F bands, which would provide no benefit to Verizon but would increase T-Mobile's maximum channel size to 1x15MHz.

Why getting the largest channel size within a spectrum band important?  The LTE Advance feature of Carrier Aggregation will allow you to combine channels in different spectrum bands to 'form' a larger data pipe, but carrier aggregation cannot combine two or more different channels within the same frequency band.  When we speak of frequency bands, we are referring to the distinct 700MHz, Cellular, Personal Communication Service (PCS), Advance Wireless Service (AWS), Wireless Communication Service (WCS), Broadband Radio Service (BRS), and Educational Broadcast Service (EBS) bands.

Any potential T-Mobile/Verizon trades are simplified by Verizon's unused spectrum.  Do you think we will begin to see trades involving spectrum that is in use?

Webcast: Accessing the Spectrum Landscape

Below is a link to an Investor's Presentation provided by AllNet Labs utilizing the AllNet Labs Spectrum Landscape report to analyze three recent wireless announcements:  Verizon's 700MHz A block spectrum holdings; Verizon's SpectrumCo purchase and agreement to share the related AWS spectrum; and the AT&T proposal for the WCS band.

Audio and Slide Presentation

AT&T's Wireless Communication Services (WCS) Proposal and Acquistion

AT&T (A) has made an aggressive move into the Wireless Communication Services (WCS) band, with a two prong attack.  First, AT&T has announced they have come to terms to acquire the following companies' WCS spectrum holdings:  Nextwave (NW), Comcast (CC), Horizon (HO), and San Diego Gas & Electric (SD).  Reflected above is the consolidated result for the New York and Los Angeles Cellular Market Areas (CMA).  In both markets, AT&T will control all of the WCS spectrum below and above the Satellite Digital Audio Radio Service (DARS) spectrum block. This spectrum acquisition makes AT&T the primary (not exclusive) owner of WCS spectrum, enabling AT&T to propose to the FCC a band configuration that would enable FDD-LTE services to be launched in the lower 10MHz of the WCS band, paired with the upper 10MHz of the WCS band.  The lower 10MHz would be for base station operation and the upper 10MHz would be for mobile device operation.  The WCS C and D blocks (5MHz each) would be held as guardbands to protect the Satellite DARS transmissions.  

While this represents a significant effort on AT&T's part there are several issues that need to be resolved.

1. AT&T does not control all of the necessary spectrum for all of the country, let alone the Top 100 markets.  For example, Boston, St. Louis, and Dallas all have other spectrum owners that are not a part of this agreement with the FCC.  Obviously, AT&T can purchase this spectrum if it can come to terms with the sellers.  Also the FCC, could make it a market level decision, enabling AT&T to reconfigure the WCS if it controls all the spectrum in a particular market.
2. Currently on the LTE band plan, the WCS spectrum band is harmonized internationally as a TDD-LTE spectrum band.  AT&T will need to propose a new supported configuration to the 3GPP standards body for approval.  This would be similar to the proposal Clearwire made to the 3GPP several years ago to receive Band 41 approval.  Band 41 enabled the entire US Broadband Radio Service (BRS)/Education Broadcast Service (EBS) spectrum to be used for TD-LTE operations.  Prior to this, only the middle 60MHz (Band 38) was designated for TD-LTE operations and the upper and lower sections of the BRS/EBS spectrum were designated for FD-LTE operation.

What type of a time frame do would you put on receiving 3GPP standards support?

Current Handset - Band and Technology Report

AllNet Labs is pleased to announce the availability of the AllNet Labs Current Handset - Band and Technology Report.  In this report, we have consolidated technology, operating system, and spectrum band support for each of the National and Regional Wireless Carriers.  This report assists the reader in understanding the network compatibility and international roaming capability for the current Smartphone devices.  In addition, the reader can see technology trends developing, such as USCellular beginning to adopt LTE in Band 12 and Sprint enabling LTE in Band 13 (to match Verizon) and Band 25.  Band 25 is the expanded PCS spectrum band which includes the G block frequencies Sprint received from the FCC during the Public Safety interference negotiations.  It is also worth noting that Sprint is not including WiMax in its only LTE handset, thus their customers will lack 4G coverage with that device in markets where they have used WiMax, until LTE is deployed during 2012 and 2013.

What does this matrix highlight for you?