At their monthly meeting in July, the Federal Communications Commission (FCC) voiced their much-anticipated proposal about the future of C-band. As many industry experts predicted, the proposal is a complicated series of potential rulings that left broadcasters feeling more uncertain about the future of C-band. Why? Because in this pending proposal the FCC appears to lean heavily toward choosing to place the aggressive agenda of 5G above thousands upon thousands of current C-band fixed satellite earth stations.
The Notice for Proposed Rule Making (NPRM) issued at the July 12th meeting seemingly formalizes the Commission’s culpability in a plan to take away the ability of C-band to operate without frequency interference on the bandwidth radio, television and cable has populated for nearly four decades.
The NPRM – A Closer Look
The NPRM is exhaustive – 102 pages – and reads like a document heavily influenced by the broadband industry. The abdication of their responsibility to protect C-band begins right on Page One, with the unquestioning support by the FCC for 5G’s utilization of the entire mid-frequency. “We propose to add a mobile, except aeronautical mobile, allocation to the band and seek comment on transitioning all or part of the band to terrestrial wireless broadband services.”
Yet, Commissioners seem to waffle a bit on Page 9 of the NPRM, where they talk about the continued importance of collecting information regarding the use and location of C-band earth stations.
Labeling their current knowledge regarding the use of the band “inaccurate and/or incomplete”, the FCC continues to strongly urge C-band earth station operators to register, insinuating the information is essential to their final decision. “This user data will be vital to our consideration of how much spectrum could be made available, how incumbent operators could be protected, accommodated, or relocated, and the overall structure of the band going forward. Several of the potential transition methods outlined in the Notice may require additional earth station or satellite information.”
On Page 13, Paragraph 30 the FCC makes it clear that limiting new earth stations to “provide a stable spectral environment for more intensive terrestrial use” is an objective. The Commission proposes to “permanently limit eligibility” of earth station licenses by limiting what existing earth stations can do. They would be allowed to “modify these stations at the registered location but not add new stations in new locations.” Under the FCC’s plan, applications for new earth station registrations would not be allowed.
Could it be that the FCC’s 8th Floor simply does not have more than a rudimentary understanding about the dangerous impact 5G’s high-powered omni-directional signals are expected to have on C-band antennas? Very possibly. On Page 16, Paragraph 39 of the NPRM, the Commission takes a stab at how they propose to define the coordination policy. The attempt reveals the FCC’s lack of knowledge of how broadcasters utilize C-band to receive programming.
Paragraph 39 begins with an acknowledgement that, “A reexamination of the full-band, full-arc coordination policy is appropriate in light of our goal to maximize spectrum efficiency…” But when the Commission’s proposal launches into enumerating the circumstances in which broadcasters would be protected from interference, they make a number of dangerous assumptions. Examples?
- The assumption that broadcasters are always looking at the same satellite and transponder
- The negating of redundancy plans that involve backup plans and backup transponders
- The assumption that broadcasters are, and will be in the future, associated with the same network (This would, of course, severely limit broadcasters’ options for content.)
- Dismissive of any viable future for news and sports networks to operate a typical C-band transportable
Now Is The Time For Action
This is just a sampling of the confusing, often waffling, simplistic statements made by the FCC about a complex matter that will define how broadcasters operate and compete in the future. Given the direction taken by the NPRM’s content, this issue is important – too important to ignore, or leave to the broadcast attorneys to flesh out.
No matter how focused on 5G the FCC appears to be, broadcasters must advocate for themselves, their businesses, and the industry. There is a short window to act; you need to get involved. How?
REGISTER. If you have not registered your C-band downlink(s) with the FCC, do so today. I cannot reiterate how important this is to your network. Registering your earth station(s) not only tells the FCC that you are there, but that – by registering – you expect consideration. It also reiterates what satellite providers like SES and Intelsat have been saying to the FCC all along; there are many, many broadcasters (as in tens of thousands) in the United States who use C-band for their daily programming.
To encourage this crucial registration, SES is now offering to help. Between now and October 17, SES is operating a Phone Helpline at (609) 987-4300, answering questions regarding how best to fill out the FCC’s Form 312.
SES has also set aside funds to reimburse their customers who find the $435 per earth station site a hardship. This is especially helpful to companies who have multiple downlinks to register. Contact SES at the email address fccregistration@ses.com for more information.
COMMENT TO THE FCC. Get a copy of the NPRM at https://www.fcc.gov/document/fcc-expands-flexible-use-mid-band-spectrum. Read it carefully, and file comments regarding this proposal with the FCC.
TELL WASHINGTON C-BAND MATTERS. Send an email or give them a call, but tell your Senator and Congressmen that the encroachment of 5G into the mid-band frequency of 3.7 to 4.2 GHz is a direct threat to broadcasting in general and your business, specifically. Lawmakers ARE impacted by contact from home and will, in response, reach out to the FCC.