More Plans for C Band Revealed; Further Fault Lines Displayed

The criticisms of the Broadband Access Coalition's plan for sharing 300 MHz of C-band for P2MP operations ignore that fixed services have shared the band with satellite earth stations for decades, BAC said. Simple coordination can guarantee interference protection, it said. Satellite interests opposed to sharing want to preserve their ability to monetize all 500 MHz of the band someday, with P2MP "stand[ing] in the way of this future multi-billion dollar windfall," it said.

Concerns of satellite content providers about P2MP sharing "are a red herring" and "large swaths of rural America" should be open for sharing, Microsoft said. There's broad support for P2MP shared use in the band since the C-band "is grossly underutilized [and] ripe for more intensive use by mobile, P2MP and other wireless systems," the Dynamic Spectrum Alliance (DSA) said.

Verizon said letting a new P2MP service in or allowing opportunistic use would conflict with flexible use policies. Those wanting to deploy P2MP service can compete for licenses like everyone else, Verizon said, adding P2MP co-frequency sharing would complicate efforts to allow flexible use services while maintaining existing C-band services in a repacked portion. P2MP operations "are fundamentally at odds" with band-clearing proposals and incompatible with existing fixed satellite services, CTIA said.

Introducing terrestrial 5G to the band on a co-frequency shared basis "would be a recipe for disaster" and require buffers of tens of kilometers around FSS receivers, the Satellite Industry Association said. The need to protect tens of thousands of earth stations makes meaningful P2MP deployments "fundamentally infeasible," SIA said.

Verizon called CBA's "the most reasonable approach" to repurposing the band while protecting incumbents. Boeing backed it. But Comcast/NBCUniversal said handing a C-band transition "and resulting windfall" to a group of private entities "is questionable." It said adopting the CBA approach would put the FCC at risk of legal challenges. That CBA would have discretion to sell means there might be merit in other approaches like a market-based auction, it said.

The CBA plan would have "foreign owned satellite companies [making] far reaching decisions about who will get access to this important spectrum, how much of it should be allocated for 5G and whether there are any requirements to build out to rural areas," Charter Communications blogged Wednesday. "The race to 5G will not be won if access to C-band spectrum is allocated using an untested, backroom process designed to further the private financial interests of foreign companies." DSA said the CBA plan puts foreign FSS incumbents' interests in monetizing their spectrum ahead of public interest, and sought auction. Google said repurposing the frequencies through auction is far more certain, especially since using a private transition facilitator carries big challenges such as making sure C-band licensees receive equitable treatment.

T-Mobile, with a plan for auctioning the band (see 1812070041), said CBA would violate the Administrative Procedures Act by delegating authority outside parties, and it's flawed by not having a minimum amount of spectrum that would be available.

AT&T's compromise would have the CBA craft and run an FCC-approved auction, with that plan going out for notice and comment and then being voted on by commissioners. "CBA's expertise qualifies them to take the initial pen [but] all interested parties should have the opportunity to provide input," AT&T said.

ABS Global, Hispasat and Embratel Star One, all authorized to provide U.S. C-band service, proposed an alternative. Earth station operators would be compensated for direct and indirect relocation costs as well as a separate incentive payment for each antenna affected by the spectrum reallocation. They said another 10 to 20 percent of the proceeds after that earth station compensation would go to Treasury. Funds left over after that would be divided among the eight satellite operators with C-band earth stations authorized to service the U.S. market.

There were clashes over the fate of the full-band full-arc coordination policy. Comcast said those backing its elimination don't rebut that the policy is "indispensable" to C-band video distribution. BAC said preserving a full-band, full-arc policy for the 3.7-4.2 GHz band wouldn't be consistent with maximizing the band's use and said there's not been satellite industry evidence showing the need for each FSS earth station having constant access to the entire band across the full spectrum arc. DSA said arguments about preserving full-band full-arc coordination don't offer much evidence about usage of frequencies and transponders by fixed satellite services. SIA said content distributors rely on full-band full-arc earth station licensing to immediately restore service in an outage.

The American Cable Association urged no more than 50 MHz be refarmed for 5G. It said it had concerns about the CBA plan, and if the FCC goes that route there should be a contingent of users in negotiations. An accompanying engineering study ACA commissioned said 50 MHz of spectrum being repurposed would necessitate the launch of two to three satellites to maintain existing downlink capacity, 100 MHz would require five to six and 200 MHz 15 to 16.

Many sought enforceable protection for incumbent video distribution operations. No plan did that, CBS, Disney, Fox, Univision and Viacom said. The ABC, CBS, Fox and NBC network affiliates associations sought specific protections. They want rules putting the cost burden of allocating a portion of the band to 5G uses on new users. NCTA said advocates of a reallocation process haven't shown incumbent users will retain enough bandwidth to sustain and expand their services or ability to fully protect incumbent earth stations from harmful interference. The group said the FCC needs to oversee any transition so there are guarantees earth station operators are compensated for direct and ongoing costs.