Comments and concerns continue to pour in about the potential impact on radio and TV stations from proposed reallocation of C-band spectrum to wireless carriers.
In an August 2019 filing, the National Association of Broadcasters urged the Federal Communications Commission to reject what it calls “ill-conceived and self-interested proposals” that would impact the delivery of content to millions of radio and TV viewers and listeners via C-band spectrum.
The NAB specifically pointed out what it called a “self-serving and anticompetitive proposal” submitted by ACA Connects Coalition. That organization submitted a proposal to the commission in July 2019 that proposes to clear at least 370 MHz of C-band spectrum in an expedited time frame for use by wireless services and transition broadcasters and earth station users from C-band delivery to terrestrial fiber video delivery.
The coalition, which represents both incumbent C-band earth station users and wireless providers, also proposed creation of an auction that would award new terrestrial licenses and assign obligations for transition costs, and proposed a plan that would repack remaining earth station users to the upper portion of the band.
In its current filing, NAB most specifically objects to portions of the ACA Connect proposal that say that fiber is the answer.
“The ACA proposal simply cannot achieve sufficient reliability in any immediately foreseeable timeframe because they cannot replicate the simplicity of C-band satellite’s one-to-many network topology,” the NAB said in its filing. The association pointed to C-band’s reliability, saying that “the “99.999 percent reliability [that] C-band distribution provides translates to just minutes per year of potential C-band delivery outages, which can be significantly exceeded by a single fiber failure.”
The NAB also expressed concern that the ACA Proposal is not for a single point-to-point fiber connection but rather for hundreds of individual fiber connections, thereby frustrating end-to-end service agreements. The loss of connected networks like fiber, including those that occurred in New York City in September 2001, illustrate the pressing need to maintain sufficient C-band spectrum for content delivery.
“The commission should not further indulge ACA’s nakedly self-interested proposal to use auction funds to pay ACA’s members to install fiber to displace their competition,” the NAB said. “Instead, the commission should speed the 5G transition at C-band by focusing its attention on reallocating 200 MHz of spectrum immediately while preserving flexibility to evaluate additional opportunities as they become warranted.”
The comments are being submitted as part of the commission’s proposal to make some of the of the 3.7–4.2 GHz band, known as C-band, available for terrestrial use. The commission specifically requested comments on those proposals suggested by ACA Connects as well as those submitted by Google, Microsoft and the Wireless Internet Service Providers Association (WISPA) and separately by AT&T.