A proposal by a group of satellite operators for freeing up spectrum in the C-Band for 5G terrestrial wireless services hasn’t exactly been embraced by industry, but a plan put forth by the ACA Connects, Competitive Carriers Association (CCA) and Charter Communications is getting push-back from the C-Band Alliance (CBA) and the National Association of Broadcasters (NAB).
Comments came due Wednesday in response to a public notice the Federal Communications Commission issued on several items related to the clearing of the C-Band to make way for 5G. The 3.7-4.2 GHz band currently is used by broadcasters and cable companies to deliver programming to consumers via agreements with satellite companies.
The C-Band Alliance asserts that the ACA Connects/CCA proposal fails to articulate a satellite-to-fiber transition plan or a fiber network management plan, and misunderstands the satellite/transponder environment. Not only is the ACA’s estimate of 18 months to clear 370 MHz of spectrum impossible to achieve, but it’s unlawful, according to the CBA.
NAB characterizes the ACA proposal as one that is ill-conceived and out of touch with reality, and it urges the commission to reject the proposal and any version that calls for a mandatory migration of content distribution to fiber.
“If the FCC adopts the ACA proposal, the FCC could effectively be forcing all television and radio programming distribution to migrate in the near term to an untested, enormously complex fiber distribution system that would also provide fiber providers with increased price-setting power,” the NAB told the commission (PDF). “The Commission should reject this approach.”
Implicit in the ACA proposal is the assumption that fiber can serve as a perfect substitute for C-band distribution for programmers, according to NAB. "It cannot,” the association added. “One need only perform a brief internet search for ‘fiber cut outages’ to come up with numerous examples of significant fiber service disruptions or outages due to construction, vandalism or other causes. These fiber outages are not resolved within seconds or minutes – they are resolved within hours or days – a wholly unacceptable time frame to restore programming distribution.”
ACA, CCA and Charter have argued that their plan protects and future-proofs the delivery of pay TV programming by transitioning to fiber, that it would use auction proceeds to pay for that fiber use and deployment, and would increase broadband deployment by building fiber—including in rural areas. They say their plan would also make more spectrum—at least 370 megahertz—available for 5G and do so in an expedited time frame.
The commission also sought comment on issues related to a study that Google, Microsoft and the Wireless Internet Service Providers Association (WISPA) filed. The study by Reed Engineering analyzed fixed satellite service (FSS) and fixed wireless point-to-multipoint co-channel existence in the 3.7-4.2 GHz band, and suggested that exclusion zones of about 10 kilometers are sufficient to protect most FSS earth stations from harmful interference caused by properly-engineered co-channel point-to-multipoint broadband systems.
Google, WISPA and others argue that making spectrum available for P2MP operations will go a long way toward bridging the digital divide and making fixed wireless broadband available in rural areas.
The CBA said the study, however, fails to account for aggregate interference to incumbent earth stations, and that the 10-kilometer exclusion zones would fail to adequately protect earth stations from harmful interference caused by P2MP operations. It told the commission to reject proposals to deploy standalone P2MP in the C-Band.
The Reed Study garnered support (PDF) from Frontier Communications and Windstream Services, which want the commission to continue exploring ways to speed rural broadband expansion, and enable fixed wireless use cases in rural areas. Frontier and Windstream also said they strongly support a public process for clearing spectrum as opposed to the private, “closed-door sale” that the satellite operators have proposed. They reiterated that FSS and fixed wireless are less likely to interfere with one another than mobile services.
Interestingly, Lockheed Martin, a manufacturer of satellite systems operating or planning to operate around the world in a variety of spectrum ranges, including the C-Band, provided comments on the proceeding last year and re-interjected itself into the conversation in comments (PDF) filed this week.
Lockheed Martin operates a fixed-satellite service earth station in Carpentersville, New Jersey, that provides telemetry, tracking and commanding. The company also is a developer and manufacturer of a range of systems, payloads and platforms that operate or are planned for operation at various altitudes and in various frequency bands.
Lockheed Martin said it’s unclear that any of the proposals or counterproposals—by the CBA, ACA or AT&T, which also submitted a plan—address the specific concern that it raised in its initial comments.
Lockheed Martin told the commission it must ensure the protection of C-Band telemetry operations, launch and early orbit operations, satellite services critical to aviation and adjacent-band satellite operations. “Any segmentation approach under consideration for the lower portion of the 3.7-4.2 GHz band—whether it is 100 MHz, 200 MHz or even 370 MHz taken away from FSS and handed over to 5G proponents—must have an important caveat that ensures protection of these operations,” the company said.
Another round of comments in the C-Band proceeding is due August 14.