CBA Response to FCC Public Notice Regarding Other Proposals – Fact Sheet
In a Public Notice issued July 19, 2019, the U.S. Federal Communications Commission (FCC) sought comment on several items related to clearing a portion of the C-band to facilitate the deployment of 5G in the continental U.S. (CONUS):
- The ACA Connects Coalition's ("ACACC") proposal to repurpose up to 370 MHz of C-band spectrum;
- A study regarding point-to-multipoint ("P2MP") deployment in the C-band;
- and AT&T's filing proposing changes to the C-Band Alliance's technical criteria.
The four satellite operators transmitting C-band satellite services in CONUS formed the C-Band Alliance (CBA) to propose a voluntary approach to clear incumbent services from part of the spectrum to enable the fast and efficient rollout of wireless 5G in the U.S. The CBA’s comments in response to the FCC public notice address issues related to the items above, and reaffirm that the CBA’sproposal is the safest, most effective, and most efficient way to make C-band spectrum available for 5G.
Response to the ACA Connects Coalition’s Proposal
The ACACC proposal lacks significant detail or is mistaken about almost every aspect of the process that would be required to replace satellite transmissions with fiber:
- It fails to articulate a satellite-to-fiber transition plan, or a fiber network management plan.
- The proposal would require programmers to operate two networks (one satellite, one fiber) for an extended period of time—likely longer than five years. With no one to coordinate this complex transition across all of the unique video networks, there is little assurance that spectrum would be cleared, meaning 5G services would remain on the starting blocks. ACACC proposal provides no accountability for these significant and complex tasks.
- Under the CBA proposal, the satellite operators serve as transition facilitator to ensure clearing is done in a coordinated manner, providing network reliability to existing users and schedule certainty for 5G operators waiting for spectrum.
- The technical and operational assumptions in their proposal reflect a gross misunderstanding of the satellite/transponder environment. Misunderstood elements include:
- Only certain transponders are useable to achieve the transition; transponders 1-10 would immediately be unavailable to support a transition.
- Only certain orbital locations are either in the right arc location or support media distribution objectives.
- Cable headends do not have the real estate to install up to 10 new 3.7M antennas that would be required under the ACACC approach. o ACACC inaccurately assumes transponders without active traffic are not in use, robbing media companies of contracted in-orbit restoration services and limiting news gathering services.
- The ACACC fails to understand the steps and timing necessary to safely transition media distribution networks to new frequencies; given there is no surplus of transponders, the launch of new satellites is required to begin any process.
- The ACACC fails to consider the actual number of cable headends, such as those in neighboring suburban areas, that must be fibered in order to clear an urban area and still protect satellite transmissions.
- Given the above facts, the ACACC estimate of 18 months to clear 370 MHz is impossible to achieve.
- Finally, it is unlawful. Neither of ACA Connects' proposed schemes—a "traditional auction" following reallocation of the C-band by administrative fiat, nor some form of an "incentive auction"—are lawful under the U.S. Constitution and the Communications Act.
For these reasons, the ACA Connects Coalition’s proposal is not a legitimate way forward in this proceeding.
Response to the P2MP Study
In general, there is significant evidence that co-primary wireless point-to-multipoint (“P2MP”) services in the Cband would disrupt critical satellite operations and effectively prevent satellite operators from clearing spectrum for terrestrial 5G services, thus undermining the objective of this entire proceeding.
More specifically, the study commissioned by WISPA, Google, and Microsoft fails to account for aggregate interference to incumbent earth stations. The 10-kilometer exclusion zones it proposes would fail to adequately protect earth stations from harmful interference caused by P2MP operations.
The FCC should reject proposals to deploy standalone P2MP in the C-band.
Response to AT&T’s Filing on Technical Criteria
AT&T’s proposal to allow “unrestricted licenses”—permitting terrestrial mobile operators to operate using full power without the obligation to ensure that earth stations do not receive harmful interference—is not feasible if earth stations are to continue to operate in the upper part of the C-band.
- The CBA believes that the use of 4G LTE deployment density as a proxy for 5G deployments results in an inaccurate assessment of the interference environment.
- The CBA provides technical analyses to prove why a 20 MHz guard band is required between new terrestrial flexible-use operations and repacked satellite services
As the CBA continues to collaborate with stakeholders in this proceeding, the CBA has outlined in its filing certain adjustments to its technical rules based upon AT&T’s analyses. The CBA’s changes will provide further flexibility to mobile operators while still avoiding interference and protecting FSS operations. These adjustments include:
- Greater flexibility in defining antenna elevation angles; • Reduction of earth station protection zones;
- Minimizing the spectrum impairment impact of TT&C (Telemetry, Tracking, and Commanding)/Gateway sites;
- Improved FSS antenna filters, allowing 5G base stations to operate nearer to FSS earth stations and antennas; and
- Greater flexibility in measuring and enforcing aggregate out-of-band emission (OOBE) levels.
The CBA proposes a fully accountable, “whole package” solution that addresses every aspect of a very complex transition process, providing a high degree of certainty with respect to schedule and amount of spectrum cleared. The CBA’s proposal provides the fastest, most efficient path to reallocate a portion of the C-band and enable the rollout of 5G in the continental U.S.—with all the accompanying economic benefits—while protecting the incumbent content distribution services upon which nearly 120 million U.S. households rely.