In the wireless industry’s “Race to 5G,” it is critical that the FCC not sacrifice the nation’s position as the world leader in content, the National Association of Broadcasters (NAB) told the commission as part of its 3.7-4.2 GHz proceeding.
“The American media and entertainment industry produces the most valuable programming in the world, and content is one of our most successful exports,” NAB said in an Oct. 29 filing. “Indeed, it is this world leadership that is driving much of the desire for a new generation of wireless technology. If premium programming—including live sports, entertainment and news—cannot be reliably distributed, the fastest 5G network in the world will have far less value and the prize for winning will be a participation trophy instead of a substantial economic boost.”
The broadcasting alliance is just one of the groups chiming in on how the commission should handle the 3.7-4.2 GHz spectrum, also referred to as a subset of the C-Band. The C-Band Alliance, which was formed in October 2018 by four leading global satellite operators—Intelsat, SES, Eutelsat and Telesat—have proposed clearing up to 200 megahertz of spectrum for terrestrial 5G wireless services, bypassing an auction and offering up the spectrum on the secondary market.
The proposal has gathered quite a bit of support as the commission has been soliciting comments on it and other ways to handle this band, which is increasingly drawing interest in the wireless community because it’s seen as precious mid-band spectrum—enjoying some of the coverage benefits of low-band spectrum and some capacity advantages of high-band spectrum.
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The band is currently allocated mostly for satellite operations, which are used to carry television and radio content. R Street researchers note in their filing (PDF) that the portion of the spectrum in question is attractive for a variety of uses and a number of reasons. At 500 MHz wide, it is one of the largest contiguous blocks of spectrum in the country, and contiguous frequencies allow for the operation of bandwidth-intensive services that are increasingly prevalent in wireless.
The NAB notes that the C-Band is used to deliver TV programming to more than 1,000 broadcast television stations affiliated with national networks, as well as thousands of MVPD head-ends and over-the-top service providers. Fiber is not a realistic option, they say, because it’s far from ubiquitous, particularly in rural America, and it may not be an economically viable alternative.
Separately, C-SPAN also weighed in (PDF), saying it relies on C-Band satellite providers to deliver its three programming networks to its nearly 5,000 or more affiliated cable systems around the country. “We considered whether fiber technology was an option for the C-SPAN Networks and we quickly rejected it primarily because fiber service is simply not available everywhere,” nor is it likely to be so soon, the organization said.
The commission in July adopted a Notice of Proposed Rulemaking (NPRM) that kicked off the comment period on the ideas associated with the band.
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National Public Radio (NPR) submitted comments (PDF) saying that it analyzed the proposals in the commission’s NPRM and by various commenters, and it remains concerned that re-allocating C-Band spectrum for use by mobile wireless services would be disruptive to public radio service. However, if the FCC chooses to proceed, the least disruptive route may be the one proposed by the C-Band Alliance.
The Public Radio Satellite System (PRSS) is completely dependent on extremely low-power satellite-to-earth station C-Band downlinks that are particularly susceptible to interference and the public radio system also depends on the commission’s longstanding “full-band, full-arc” policy for authorizing earth stations, NPR said.