NAB to FCC: Take 100 MHz of Upper C-Band, but No More

The Federal Communications Commission’s carousel of repurposing satellite spectrum keeps spinning and broadcasters are hanging on tight.

The FCC clearly has a hunger for spectrum to further expand terrestrial 5G and other wireless services in the United States. Chairman Brendan Carr has repeatedly made that abundantly clear. He wants to “restore U.S. leadership in wireless.”

But just how much spectrum should the FCC repurpose for its use? The National Association of Broadcasters is cautioning the FCC to consider it carefully.

The commission is required by statute to auction at least 100 MHz of upper C-band (3.98 GHz–4.08 GHz) spectrum no later than July 2027. However, the FCC is proposing to auction up to 180 MHz (from 3.98 GHz–4.16 GHz) through competitive bidding; and wireless providers want even more.

Regardless of the outcome, broadcasters will be impacted, NAB said. The upper C-band is essential to the broadcast industry for satellite program contribution and distribution, according to the NAB, and its use has only intensified since the lower C-band auction less than five years ago.

NAB said in comments filed on Jan. 20 that the commission should limit the auction to 100 MHz to ensure that broadcast customers are fully protected and bear no harm throughout the transition.

Any greater amount of auctioning, the association warned, would cause “material disruption to broadcasters.

Furthermore, NAB argued that to the extent that broadcasters are forced to transition because more than 100 MHz of the upper C-band is auctioned, they should not be forced to bear the costs of the transition.

The costs, as was the case in past transitions, should be borne by auction winners, NAB said.

The comments are NAB’s initial submission in the open proceeding on the Upper C-band; comments had been due to the commission by Jan. 5, and reply comments by Feb. 3. Several groups, however, including NAB, had asked the commission for more time.

A more complex coordination

A previous auction in 2020 for the lower C-band, which generated $81 billion in net licensing fees for the FCC, required massive coordination between broadcasters and satellite companies to move services to 4.0–4.2 GHz., but NAB said another move for broadcasters would be even more complicated and require more time.

Even with a “planned transition, incumbents undoubtedly will bear some material inconvenience. On the other hand, a hasty transition would materially degrade and interrupt broadcast services,” NAB said.

(Read NAB’s complete filing on the Upper C-band with the FCC.)

NAB said that SES, the major provider of C-band satellite services to broadcasters in the U.S., has stated that most incumbent users can be “repacked” quickly into a reduced C-band if reallocation is limited to about 100 MHz.

Still, the broadcaster advocacy group said “there inevitably will be some disruption to incumbent users as a result of aggressive repacking. But repacking all or most users within C-band will be far less disruptive than forcing those users into other satellite spectrum or alternative platforms.”

During the previous transition, NAB told the FCC many earth stations required only filtering, repointing and modest “inside” equipment upgrades, which could be completed within the lump sum reimbursement amount of $17,000 for a receive-only earth station with dual feeds.

Going into the first repack, the FCC said there were approximately 20,000 registered earth stations used by broadcasters to receive satellite transmissions.

However, NAB pointed to reported delays from many C-band users of over two years to get reimbursed for costs consistent with the cost catalog. The group is asking the commission to streamline reimbursement processes or provide significant “up front” monies so that incumbents are not out-of-pocket millions of dollars for several years.

This time around a total move of broadcast satellite services out of the C-band to the Ku-band, for example, would be considerably more expensive, NAB said.

In contrast, the group says a C-band earth station that must move to Ku-band would often require construction of an entirely new earth station — including a second antenna, cabling and supporting equipment — to allow for dual-illumination during the transition period. It estimated the relocation cost would be more than $400,000.

Wish list

The broadcast industry learned valuable lessons from the previous lower C-band transition, according to NAB, which led to a wish list of sorts from the group if another move happens. Those include:

• Preference for a single transition: The transition of incumbents out of the lower C-band was completed in two phases. A single transition is preferred by NAB.
• Transition plans must be public: The commission should make clear that such plans will be publicly available for review and comment.
• Interference protection must be enforceable: NAB said there must be an enforcement mechanism to ensure recommendations and procedures are implemented.
• Prioritizing uplink frequencies for the remaining C-band: NAB shared concerns raised by the North American Spectrum Alliance that the reduced C-band downlink spectrum has created significant challenges coordinating uplink frequency use with terrestrial microwave users.

Aeronautics industry has altimeter interference issues

Beyond the multi-billion-dollar costs associated with relocating incumbents out of C-band, NAB said auctioning more than 100 MHz would also substantially increase both the costs of radio altimeter replacement and the risk of interference to those systems.

The operating band of radio altimeters sits at 4.2–4.4 GHz. The aeronautics industry has previously warned the FCC it has concerns about interference between the adjacent spectrum bands.

“Limiting the auction to 100 MHz, which would confine terrestrial operations to below 4080 MHz, would minimize the potential for interference to existing radio altimeter systems and could allow some aircraft to avoid equipment replacement,” NAB said.

NPR

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