The FCC should revise its band plan for the incentive...

its reply comments on auction rules. “Numerous commenters highlighted the interference challenges created by the Commission’s proposed band plan, and noted that many of these problems could be prevented by focusing on reallocating spectrum above Channel 37,” CTIA said (http://bit.ly/WHtRPg). “Specifically, such a band plan -- unlike that proffered by the Commission -- would prevent interference caused by television broadcasters operating in the duplex gap between uplink and downlink frequencies.” A band plan that focused on just spectrum above Channel 37 also would simplify device design, CTIA noted. “As Qualcomm observed, the Commission’s proposed band plan ‘cannot be supported with a single antenna system’ and that ‘[a]dding an additional antenna into smartphones and tablets to support this band increases device size, complexity, and cost, and thus introduces potentially insurmountable design challenges given consumer demand for wireless devices with smartphone-sized form factors.'” The record also shows “overwhelming support” to the commission that the spectrum be sold in 5 MHz “building blocks.” The band plan should also provide a duplex gap of at least 10 MHz and “technically reasonable” guard bands, which allow for unlicensed uses “to the extent unlicensed use does not cause interference to primary licensed services.”