WASHINGTON—NAB has called on the FCC to recognize the important role C-band plays in content delivery for radio and television stations, MVPDs and OTT operators, to be judicious in the way it makes decisions about reallocating part of the band for wireless use and not to take steps that will degrade C-band satellite service by allowing shared use in the non-reallocated part of the band.

The association Oct. 29 filed comments with the FCC regarding the agency’s Notice of Proposed Rulemaking regarding expanding flexible use of the 3.7 to 4.2 GHz band.

“In the wireless industry’s ‘Race to 5G’ it is critical for the Commission to not sacrifice the nation’s position as the world leader in content,” NAB said in the filing. “If premium programming–including live sports, entertainment and news–cannot be reliably distributed, the fastest 5G network in the world will have far less value and the prize for winning will be a participation trophy instead of a substantial economic boost.”

Any agency plan to allow expanded operations in the C-band must guarantee existing operations are fully protected by “requiring a documented, enforceable and fully-funded plan for accommodating existing users,” NAB said.

The association reminded the agency of how important C-band satellite content distribution to existing media distributors. More than 1,000 TV stations affiliated with networks, thousands of MVPD headends and OTT providers rely on C-band satellite distribution to receive programming, NAB said. Additionally, 475 public radio earth stations that together account for public radio service to 42 million Americans every week rely on reliable C-band program distribution.

These C-band transmissions are a critical piece of “a near-flawlessly reliable distribution network” that does not suffer the service interruptions and outages “that plague fiber optic networks and higher-frequency satellite systems,” the filing said.

NAB told the agency that content delivery must be allowed to evolve and any decision it makes to reallocate the band must not preclude future uses of the band for satellite distribution of emerging types of programming, such as 4K and high dynamic range video.

Further, NAB reminded the FCC that any proposals to share C-band spectrum with wireless companies to date have been based on the assumption that 4,700 registered or licensed C-band earth stations exist. However, the agency’s current registration window has seen thousands more register. “As of October 26, there were approximately 16,500 C-band earth stations registered in the Commission’s IBFS system,” NAB said, adding that this represents “a dramatically different operating environment than previously assumed.”

In the comments, NAB also pointed out that rule changes allowing shared operations in non-reallocated parts of the band run the risk of creating harmful interference today and impeding future operations.

“The worst outcome the Commission could achieve in this proceeding would be to assume that existing users can easily be accommodated in a smaller band or relocated to alternative spectrum or fiber,” NAB said. The next worst possible outcome would be undermining such a plan by “forcing C-band operations into a smaller spectrum band that is further degraded by additional operations on a co-frequency basis based on unproven sharing technologies.”

The association urged the FCC to “require a specific accommodation plan for C-band operations” serving more than 100 million U.S. households “to ensure viewers and listeners continue to have access to the premium content they enjoy today,” the filing said.

Whatever mechanism the agency ultimately uses to reallocate a part of the band, it should take three steps to make sure new mobile services in the band don’t “upend the nation’s content distribution architecture,” NAB said.

They include:

• A “specific, documented, actionable and public plan” to accommodate existing C-band users;
• A provision that ensures the costs of implementing the plan fully fall upon “the beneficiaries” [i.e. the satellite operators or wireless operators] that acquire the rights to use the spectrum; and
• Steps to ensure capacity for future video marketplace evolution, such as sufficient spectrum to accommodate 4K video programming.

“Small missteps in this proceeding will have dramatic ramifications that threaten the stability and reliability of the infrastructure that distributes content American viewers and listeners enjoy, and in which programmers invest billions of dollars every year,” the comments said.

Broadcasters have until Oct. 17 to register their C-band satellite downlink sites with the FCC in order to prevent future interference and push back against plans that would completely rearrange the way the FCC allows C-band satellite channels to be received.

Satellite operator SES has announced that they may pay for broadcasters’ FCC application fee if C-band antenna owners register their existing C band antennas with the commission prior to the Oct. 17 deadline.

[Read: TV, Radio Broadcasters: Now’s The Time To Register Your C-Band Downlink Sites]

For more information contact SES for details and conditions at fccregistration@ses.com or DAWNco at 248-391-9200. Facebook members can learn more by visiting DAWNco’s Facebook page. 

PART I

The worst-case and highly-feared—yet widely anticipated—"doomsday scenario" for broadcasters (and many other satellite communications users) in the United States has taken another dramatic and strong step toward becoming reality.

The FCC voted unanimously in its July 12, 2018 meeting to proceed with an Order and NPRM aiming to gather information and explore opening the entire 500 MHz of C-band downlink frequencies (a.k.a. "Mid-band Spectrum") for use by mobile and terrestrial wireless broadband companies.

If that sentence was overwhelming in its scope and meaning, here's the simple version in layman's terms:

The FCC officially still thinks it's a good idea to reallocate and repurpose the satellite downlink frequencies that just about all radio and television broadcasters use to receive content. From a pragmatic view, that means simply that the FCC is not looking to protect and serve its existing licensees and frequency users who already serve the public interests; it instead is looking to appease big data and wireless companies' financial interests and generate revenue for the government in the process.

Now don't get me wrong—I've been a big fan of some of Chairman Pai's moves to roll back some of the obvious overreaches of the prior administration's FCC. It's been refreshing to see the FCC move back toward allowing the free market to work things out under the gentle "light touch" oversight by the official overseers of all things related to radio frequency and telecommunications. History has shown time and again (at least here in the United States) that when people and companies are free to innovate, new products and services abound. Thankfully, our forefathers had the foresight and forethought to encourage innovation by the establishment of the United States Patent Office, and that freedom has allowed U.S. technical companies to lead the United States to become the global leader in technical advancements and prowess (at least from my humble perspective).

HIGH-DOLLAR LOBBYING

But, alas, it seems that yet again, the governmental agencies can't help but bow to pressure of the high-dollar lobbying campaigns put on by big companies who stand to realize large capital and operational infusions by taking resources from one group and giving it to others. The behemoth chipmaker Intel's original proposal to reallocate parts of the C-band downlink spectrum obviously would benefit that manufacturer directly through increased product sales, and no discussion is needed to figure out why Verizon, Google, CTIA, and a variety of other companies want the spectrum ( See footnote #2 on page 4 of General Communication's Comments for a short list).

Yet one satellite operator seems to have taken a desperate measure to survive, almost like a parent being willing to sacrifice one child so another could have a chance to survive. In particular, Intelsat's willing participation in that Intel proposal seems "strangely" akin to Dr. Strange voluntarily turning over his Infinity Stone to Thanos in "Avengers: Infinity War." Any company involved in or utilizing satellite communications that would willingly suggest it's a good idea to give up their most valuable resource—RF spectrum—obviously must have done so out of a desperate and final play to survive... yet that's not the perspective or playbook shared by any terrestrial broadcasters with common sense and a heartfelt mission to serve the public.

HEADLONG AND HEADSTRONG

The NAB's comments were an excellent reflection of the entire broadcasting industry's views, concerns, and preferences regarding the (then-potential) possibility of the FCC giving away the C-band spectrum. Many other comments filed with the commission (and many more broadcasters' public forum comments not officially submitted to the commission) sided with the NAB, and for good reason.

Initially, the FCC seemed to be willing to listen to petitioners: To gather information about the number of existing C-band downlink sites, the FCC created a 90-day window wherein C-band downlink users could register their downlinks without the expensive frequency coordination study previously required. And then, in response to concerns that users needed more time to register all their downlinks, the Commission extended that window another 90 days, also reducing some of the complexity and cost of registering multiple sites.

In spite of those moves, however, the FCC marched headlong and headstrong along its much-trumpeted path toward 5G, voting on July 12 to formalize the NPRM to take away part—or all— of the C-band downlink frequencies that broadcasters (and many other government and commercial users) use on a daily basis and instead give it to the wireless and broadband industries. What is notable is that the FCC voted on the NPRM even before the original downlink registration deadline of July 18, 2018 had arrived and over three months before the extended registration deadline.

Showing disregard for the information it said it wanted, the commission's vote clearly reveals their agenda is much like the Communist paradigm of taking resources from those who have them and give those resources to those who don't (all ostensibly in the name of the "Common Good"). The obvious conflict of interest here is that the government stands to gain much financially from a possible auction of spectrum (like they did from the Incentive Auction in which some television broadcasters participated between 2016 and 2017).

In this, the commission has publicly bumped themselves back down a significant notch in their self-proclaimed move toward a light touch and market-driven approach. Even though their July 12 vote on the issue aligned precisely with their previously-stated intentions of closing the "digital divide" and therefore wasn't a surprise, the commission's ongoing move in this matter toward the "communal good" still reeks strongly of corporate lobbying and self-aggrandizement. It also sadly confirms that even good intentions of excellently-qualified individuals (like Chairman Pai and Commissioner O'Rielly) get buried in the swamp of politics-driven Washington, D.C.

Time continues to tell the story that the public—including broadcasters commercial and non-commercial alike—suffers as a result of Big Government's expansion and overreach under corporate influence and lobbying.

Simply put, this proposed action could realistically result in everything needing to be delivered over the Internet. I don't know about you, but I wouldn't want to be worried as a broadcaster that the backhaul delivery of the FIFA World Cup final or Super Bowl could be interrupted by an Internet outage—yet that's precisely the direction the FCC and many commenters seem to think is best for this country.

Broadcasters (and other SatCom users alike), beware! Now is the time to stay (or get!) actively involved in this NPRM. Its affirmation could mean dramatic—or fatal—impact on how live and prerecorded content gets delivered to hundreds of millions of listeners and viewers every day.

Lastly, by all means (even if it seems like an exercise in futility), at the very least go ahead and register your C-band downlinks. There are some extremely well-written and thorough instructions on Intelsat's site, SES's site, and the FCC even has some sample forms available for review. There are several consultants and/or private companies that can provide assistance with registering your sites, so don't let inexperience keep you from letting the FCC know about your C-band usage.

In Part II, we'll look at the impact of worldwide implementation of 5G and alternatives to C-band will have on the future of satellite communications. 

Sherrod Munday currently serves as vice president of engineering for Sky Angel, a 2-channel TV network found on Dish Network. His experience includes full-time and consulting engineering in both TV and Radio, delivering live and preproduced content over the air, via satellite syndication, and directly to consumers across the Internet. You may reach him at smunday@ieee.org