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CBA Disagrees

T-Mobile Says C Band Could Be Cleared for $1 Billion

Every C-band receive location in the U.S. could be connected to fiber as a replacement for satellite delivery of content for about $1 billion, “demonstrating that it is cost effective to clear all 500 MHz of C- band spectrum” for 5G, T-Mobile filed in comments posted Monday in FCC docket 18-122. T-Mobile submitted a study by Roberson and Associates supporting that proposal. Officials from T-Mobile and the consultant also reported on meetings to present the study. The filing opposes the C-Band Alliance’s proposal.

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T-Mobile has proposed that the Commission conduct an incentive auction -- including satellite operators and earth station registrants -- as a means to apply market-based forces to find a more appropriate balance of spectrum for 5G use versus satellite use,” the carrier said. “Unlike the CBA proposal, which would conduct a private transaction with CBA members controlling supply and all other relevant conditions, an incentive auction would be a true open and transparent market-based mechanism.”

The company's study “fails to consider the significant costs to create this highly complex replacement network, other than the costs of trenching and laying fiber,” a CBA spokesperson emailed. “T-Mobile’s proposal completely ignores (1) required redundancy to meet availability standards, (2) incremental site hardware, (3) ongoing annual operational costs at both the programmer uplink and earth station sites, and (4) the necessity for video aggregation points, among other elements,” CBA said. “The actual capital cost to transition from satellite to fiber would be multiples of the T-Mobile estimate. Annual operating costs of video distribution, completely unaddressed in the T-Mobile filing, would be multiples higher than that of the efficient satellite distribution provided today.”

In meetings with Chairman Ajit Pai and with Wireless and International Bureau staff including IB Chief Tom Sullivan, Alaska Communications said the 3.7-4.2 GHz band in Alaska needs to be preserved solely for satellite downlink communications since satellite is often the only feasible way to communicate with remote villages. The carrier said the C band works better than other bands in the northerly latitudes and harsh weather conditions. Given Alaska's sparse population, existing spectrum allocations have enough capacity to support deployment of terrestrial mobile 5G there, it said. The company said CBA's proposal would exempt the state from any reallocation for terrestrial mobile use. Attendees included new CEO Anand Vadapalli.

SES and Intelsat, in meetings with a Commissioner Geoffrey Starks aide, said their proposed cap on aggregate nationwide unlicensed C-band device emissions is necessary given the extreme sensitivity of C-band receive antennas. They said a cap on aggregate interference makes a limit on deployment of unlicensed devices unnecessary. They said the automated frequency coordination (AFC) proposal can be used to implement the interference cap, and aggregate interference from unlicensed devices would need to be tracked nationally either with a centralized AFC or interconnection of multiple ones. The companies are CBA members.