Association reminded the agency of the critical role C-band plays in distributing TV and radio content to stations

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.