WASHINGTON—NAB has filed comments that urge the FCC to maintain “an unwavering focus” on protecting content distribution via C-band spectrum as it considers the transition plans submitted by satellite operators in accordance with the agency’s order expanding flexible use in the C-band.
“C-band spectrum will only be timely cleared for flexible use if the commission, satellite operators, programmers and earth station users can ensure that content distribution is protected both during and after the transition,” the NAB comments said.
NAB told the agency it should “be wary” of those looking to take advantage of the proceeding to reap financial benefits that “have little to do with the commission’s primary goal” of C-band reorganization. The association pointed to some MVPDs that have asked the FCC to include the cost of integrated receiver/decoders (IRDs) in the lump sum available to MVPDs that handle their own transition or transition to other technologies.
NAB cautioned the FCC that agreeing with the request is “inconsistent with standard practices in the industry” and introduces “unnecessary risks” into the process, such as an MVPD taking a lump sum with the idea of transitioning to fiber and failing to do so in a timely manner.
“The only reason this dispute has emerged is the efforts of some MVPDs to drive up lump sum payments because they see an opportunity to extract additional financial benefits from the C-band transition,” NAB said.
The association also told the agency that clarifications or adjustments of the plan are needed. NAB cautioned the FCC that cost estimates for the transition are based on “generalities about average costs and best estimates” of earth station users. “Individual earth station users may have particular needs or issues that are not accounted for in these estimates,” said NAB.
The FCC should inform those bidding for flexible use licenses of this spectrum who are responsible “for the entire allowed costs of the relocation—even to the extent that those costs exceed the estimated range of costs” that “circumstances and costs” of individual earth stations will vary, it said.
NAB also told the FCC that its C-band transition plan should allow for scheduling flexibility. Both the FCC and satellite operators should know that individual broadcasters may have “competing priorities and unexpected complications or delays.” The transition plan must provide for schedule changes and build in some flexibility “for individual earth station outreach and installation,” it said.
The comments are available online.
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