The Church of Jesus Christ of Latter-day Saints isn’t taking a position on how the Federal Communications Commission (FCC) restructures the C-Band—be it through a public auction, private sale or some other approach—but it is concerned about protecting its investment in the band and how earth station owners are treated.
The FCC has received comments so far this month from the likes of Verizon, AT&T, Google and the Competitive Carriers Association (CCA), as well as content companies like NPR, about proposals to clear part of the band for 5G services. The FCC issued a Notice of Proposed Rulemaking (NPRM) last year soliciting proposals for repurposing the C-Band.
The church’s July 9 filing (PDF) notes that the Mormon church owns and operates one of the largest networks of 3.7-4.2 GHz band receive-only earth stations in the U.S. and while it supports the repurposing of spectrum for 5G, it wants to make sure that current C-Band users have the flexibility to adopt technical solutions that work for them. It also wants to make sure that all direct and indirect costs of the C-Band transition are covered for registered earth station operators like itself.
The church explained that satellite programming is essential to its religious mission because it allows senior leaders to communicate with local members in ways that otherwise would be impossible. The church began using satellites as early as 1962, and since 1982 has invested an estimated $70 million to develop a satellite network that functions primarily in the C-Band.
While some earth station operators don’t see a viable alternative to the C-Band, the church said it could be open to transitioning to the Ku-band, installing a fixed terrestrial solution like fiber or implementing some combination of options, assuming the transition costs are covered.
The church is also motivated by concerns about the long-term prospects for use of the C-Band for video distribution. If operators like the church are required to install filters to stay within the C-Band now, there’s a concern that it will be required to transition to yet another solution in the foreseeable future.
“Thirst for 5G and other future communication technologies will be insatiable,” the organization said. “If a permanent solution to this issue requires the Church to limit its use of the C-band, the Church is open to discussing that solution. But, fair is fair. If the Church is required to reconfigure its distribution network to ensure the availability of spectrum for other services, it should be reimbursed for the cost of that transition.”
The filing also said the church is concerned that the C-Band Alliance’s (CBA) Customer Commitment Letter offers only to install filters, and doesn’t address administrative or coordination costs. The church is in discussions with its satellite provider Intelsat, and remains hopeful those discussions will lead to a positive resolution. But, it wants the FCC to make sure all reasonable transition costs of operators are fully reimbursed and that operators have the flexibility to decide for themselves how they will transition.
Intelsat is a member of the CBA, along with Eutelsat, SES and Telesat. In response to a FierceWirelessTech inquiry, Intelsat provided the following statement: “The NPRM asked stakeholders to balance the needs of current C-band users with the need to clear spectrum for 5G. The CBA’s customer commitment package was designed to ensure that the CBA members’ existing customers would contractually have the same quality of C-band service post-clearing as before, and that all their costs associated with the CBA’s proposal to clear 200 MHz (inclusive of a 20 MHz guard band) be reimbursed. We proactively placed on the record this list of commitments to current users, and subsequently converted it to an on the record contractual commitment.”
Specifically regarding the Church of the Latter-day Saints, Intelsat said in a statement, “We have identified and communicated the transition plan for its network, which if implemented would continue to work exactly as it does today. We have provided similar transition plans for every current C-band user. We unfortunately are unable to provide assurances for other potential outcomes under this proceeding for which we have no control.”