The Dynamic Spectrum Alliance (DSA) recently met with FCC staff to stress the importance of improving the information in the FCC’s C-band database and said it supports most of what AT&T suggested in its midband comments about database auditing.
“Without accurate information, it will be impossible for the Commission to move forward with any of the proposed mechanisms in the Mid-Band NOI proceeding to make more efficient use of the 3.7-4.2 GHz band,” wrote DSA President Kalpak Gude, who visited the commission with Michael Calabrese, director of the Wireless Future Project at New America's Open Technology Institute, on Dec. 12, according to an ex parte filing (PDF).
They aren't the only ones saying the FCC's database needs to be cleaned up. Part of the problem is that C-band users have little incentive to register their dishes since the process is volunteer-based and expensive.
In an earlier filing, AT&T suggested that the commission consider a “refresh” of the C-band database and allow a period of time for operators that previously did not register to do so. AT&T also suggested that the FCC confirm that the active registrations in the database are current and correct, including requiring information from registrants that their earth stations remain operational and are identified by accurate coordinates, as well as notifying C-band registrants of their obligation to cancel earth station registrations that are no longer used.
Citing potential challenges and delays related to the Paperwork Reduction Act requirements, the DSA also urged the commission to consider starting the process on a voluntary basis while moving forward with the necessary approvals for a mandatory data collection.
C-band satellite service provider SES recently pointed out that registration is costly, requiring payment of a $435 fee per site and submission of a coordination report that often costs about $700. Therefore, many receive earth station operators have simply chosen not to register their facilities; the American Cable Association has estimated that 90% of its members’ receive earth stations are unregistered, and if that’s typical of C-band users, “there could be more than 30,000 receive-only earth stations in total,” SES said.
SES suggested that the FCC undertake a two-step procedure to streamline the registration framework. The commission could collect basic location information first through an online data-entry process with no fee and then conduct a more thorough antenna registration but with significant modifications to encourage participation.