Add Categories to C-Band Relocation Reimbursements, FCC Asked
The FCC was close but not spot-on in its preliminary cost category schedule for C-band relocation expenses, said numerous interested parties in docket 18-122 filings posted Friday, suggesting additions and changes. There was some opposition to reimbursements for gold-plated upgrades and support for not finalizing the cost category schedule until after the FCC has filed, reviewed and approved satellite operator transition plans.
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It's likely costs in a particular category might exceed the catalog ranges, but that shouldn't automatically imply the requested reimbursements are unreasonable, AT&T said, advocating a review by the relocation clearinghouse. It said if a satellite technology upgrade is needed, the satellite customer should have a voice in what upgrades are applied and implemented instead of it being solely the satellite operator's call.
Cost reimbursement should be only for costs "truly 'necessary'" to relocate incumbent services to comparable facilities, Eutelsat said. It said incumbents shouldn't be able to "abuse" relocation funding "by cross-subsidizing a new fleet of hybrid, multiband satellites with vast coverage outside [the continental U.S.] in the guise of facilitating continuity of C-band services within CONUS." It said estimates of C-band satellites costing as much as $250 million are too high.
The pandemic increased the cost of procuring satellites, Intelsat said, saying the FCC's $104 million estimate for launch costs is about $36 million too low since a higher-cost launch provider might be needed because of transition time constraints or launch manifest availability. Intelsat said it might need to hire a program management consultant to do relocation coordinator and relocation payment clearinghouse reporting, for $6 million-$10 million. Buying higher quality, more reliable satellites goes a long way toward FCC goals of protecting C-band service incumbents while helping ensure no transition delays due to a satellite anomaly or failure, Boeing said.
Many sought to add to the cost catalog the costs for such things as tree removal, fencing, earth station operators’ labor and other operational costs directly attributable to continued video delivery to customers served by earth stations post transition. Altice said satellite operators will cover some earth station costs, but "the practical reality of continued and uninterrupted service delivery" necessitates the company doing some engineering tasks like site work for repointing new earth stations and installing new antennas.
Content companies said the FCC needs to acknowledge the transition will need "many thousands" of integrated receiver/decoders. A&E, Discovery, Fox, Disney, Univision and ViacomCBS said the catalog needs to count earth station switching costs like labor costs of installing passband filters. SES said costs to be added to the catalog include satellite ground control systems, and the agency needs to up its estimate for a category of antenna. NPR said such "soft costs" as engineering and regulatory fees, plus frequency coordination report expenses, should be reimbursable if tied to the transition.
The Church of Jesus Christ of Latter-Day Saints said the small receive-only 3.7-4.2 meter single-feed earth stations it uses often are at remote churches without full-time staff, meaning the catalog should also include the $500 to $1,500 per location in relocation expenses due to visiting these sites and paying a third-party property manager.
The catalog should include "reasonably foreseeable" future price increases outside the control of incumbents, such as higher vendor and labor costs due to economic realities during high demand, plus supply chain disruptions caused by the pandemic, NCTA said. It said the agency should make clear that lump sum election by an earth station operator doesn't prevent others in the distribution chain from receiving actual cost reimbursement.
The catalog needs to include an MVPD receive-only earth station category for lump sum election purposes because such preliminary categories don't reflect characteristics of typical such receive-only earth stations, ACA Connects said. It said the catalog also should include a $760,500 lump sum for the MVPD receive-only earth station category.
The catalog doesn't give specifics about lump sum payment amounts or create an MVPD-specific lump sum cost category, Cox Communications said. It said the catalog wrongly excludes MVPD earth stations from reimbursement for costs of changes in modulation and encoding and ignores that lump sums need to be calculated on a “per antenna” basis. Telesat asked for adjustments in some charges that might be more expensive than the FCC estimates, such as the maximum amount of the cost estimate for trenching and cabling.