Early C-Band Comments Offer Preview of Fight to Come
Tests demonstrate the 3.7-4.2 GHz band can be safely shared, the Broadband Access Coalition (BAC) commented in docket 13-1. The FCC is preparing a report to Congress on the spectrum, also known as the C-band, as required by the Mobile Now Act. This offer a preview of arguments to come, with Chairman Ajit Pai promising to tee-up a C-band NPRM for commissioners' July meeting (see 1805230031).
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The Wireless ISP Association, a founding member of the BAC, is pleased Pai plans an NPRM this summer, President Claude Aiken said in an interview Thursday. “We tried to come up with a proposal which we think will work for everybody, which would involve clearing 100 MHz of the 500 MHz and making that clean spectrum available for mobile,” Aiken said. “The other 400 MHz you’d make available for point-to-multipoint sharing with appropriate protections for the satellite earth stations that remain in the band.”
Commissioner Mike O’Rielly has made clear he’s no fan of the proposal (see 1805240058). “We’re focused on trying to show [O’Rielly] why this actually does make sense for everybody,” Aiken said. Numerous filings have made the point it will be difficult to clear the band completely for mobile use, Aiken said. “That enforces our point that it will be really difficult to clear large pieces” of the band “to make it completely clean for mobile.” WISPs need additional spectrum for rural broadband and WISPA is focused on the 3.5 and 3.7 GHz bands, he said.
Aiken expects a bigger fight over 3.7 than was waged over the 3.5 GHz citizens broadband radio service band. “You have commercial interests that are already in the [3.7 GHz] band, which is the big difference,” he said. “We expect our proposal to be teed-up in the NPRM and we hope it’s teed-up prominently.”
“From the outset of this proceeding, the Coalition has repeatedly demonstrated the feasibility" of allowing commercial licensed point-to-multipoint (P2MP) fixed wireless broadband services to share use of the 3.7-4.2 GHz band with fixed satellite and fixed service incumbents, BAC commented. The coalition proposed a plan for the band last year (see 1708080050).
The Fixed Wireless Communications Coalition said the FCC must protect the 914 fixed microwave links in the band. The FWCC doesn’t oppose repurposing the band or opening it “so long as the fixed links are either fully protected or relocated to other bands,” the coalition said. “The number of 4 GHz links has been declining in recent years, so as time goes on there are likely to be fewer that need protection or relocation.” Most links there operate at reliability levels of 99.999 percent or 99.9999 percent, the group said. “These numbers allow for total annual outages of only five minutes or thirty seconds, respectively,” the coalition said. “Even very brief interference to one receiver can disable an entire network of links for several minutes, using up years’ worth of outage allowance.”
“Virtually every” U.S. TV and radio relies on C-band satellite operations for content distribution, NAB said. “The availability of reasonable, practical alternative means of content delivery, such as fiber, are significantly overstated,” NAB said. “The Commission should insist on rigorous technical analysis of specific and detailed proposals.”
GCI Communication said the band is key to its ability to serve hard-to-reach areas. “GCI relies on the 3.7 GHz Band in order to provide downlink FSS operations, and has a very long history of utilizing the C-Band to provide broadband and video communications services throughout Alaska,” the carrier said. "Many of GCI’s C-Band sites serve customers residing in the most rural and remote areas of the country that rely exclusively on satellite technology for the provision of basic telephone service, medical service, and distance-learning.”
The Aerospace Industries Association raised concerns about interference to wireless avionics intra-communications (WAIC) systems and aircraft radio altimeters in the adjacent 4.2-4.4 GHz band. “Any services permitted by the Commission to operate in the 3.7-4.2 GHz band must be sufficiently restricted to ensure radio altimeters and WAIC systems are adequately protected from harmful interference,” the group commented. “Impacts on the safe operation of radio altimeters has a cascading effect on the entire aviation ecosystem.”
The Air Line Pilots Association raised similar safety concerns. “Because there is no other source of height-above-terrain information, radar systems onboard aircraft are not capable of validating the data that they present,” the group said. “Interference may not be detectable, and would likely cause hazardously misleading information to be presented to the flight crews. Misleading information would easily increase the likelihood of approach and landing accidents and incidents.”