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CBA v. P2MP

C-Band Interests on All Sides See Consensus Forming Around Their Plans

Different sides offered the FCC conflicting readings of initial comments on alternative plans for opening the C band for 5G. Those comments showed little move toward consensus (see 1908080041) on how the regulator should address the band, which has emerged as a top commission spectrum priority. The FCC sought input on a proposal by America’s Communications Association, the Competitive Carriers Association and Charter Communications and a study by Jeff Reed of Virginia Tech and Reed Engineering on sharing the band with fixed point-to-multipoint (P2MP) operations (see 1907020061). The regulator also asked about an AT&T letter raising technical and band plan issues. Replies posted through Thursday in docket 18-122.

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The C-Band Alliance sees the ACA-led plan as a nonstarter. “The Coalition’s lack of a serious plan to implement its proposal has, understandably, caused serious concern among content companies, broadcasters, and other parties which rely on Fixed Satellite Service,” CBA said of FSS. Sharing the band with P2MP “would disrupt critical satellite operations and effectively prevent satellite operators from optimally clearing spectrum for terrestrial 5G services,” CBA said: “Introducing P2MP is also unnecessary. Fixed wireless service providers have abundant access to other spectrum.”

ACA, CCA and Charter countered that their proposal has much support. The recommendation offers “more spectrum, more competition, a statutorily-guaranteed benefit to taxpayers, and more fiber for broadband and backhaul -- and it is well within the capabilities of industry and the legal authority of the Commission,” they said.

The record “shows strong support” for sharing with P2MP services, the Public Interest Spectrum Coalition commented: “Although most FSS incumbents oppose coordinated sharing, they provide no actual evidence or data to suggest that the findings of the Reed Study are baseless or unreliable.” Its initial comments were backed by Consumer Reports, New America’s Open Technology Institute, Public Knowledge, the Schools Health Libraries Broadband Coalition and several others.

Google found “strong support” for sharing with P2MP. “Submissions by P2MP providers demonstrate that they are ready, willing, and able to rapidly deploy high-speed broadband services to customers over shared C-band frequencies, and this additional spectrum is critical for that purpose,” Google commented: “Contrary to some commenters’ assertions, launching these new P2MP offerings would not complicate the C-band repacking process, limit or compromise operations by FSS earth stations in the repacked portion of the band, or prevent future clearing of additional C-band spectrum for flexible use.”

The Satellite Industry Association slammed the sharing plan. P2MP operations won't "protect the tens of thousands of ubiquitously deployed C-band receive earth stations,” SIA said: “Significant separation distances around earth stations are necessary to protect FSS operations, greatly limiting potential P2MP operations.” Databases to prevent interference are “unproven and cannot be relied on” here, the group said.

T-Mobile, which has its own plan for the band, said comments generally agree on some principles. “Commenters join T-Mobile in urging the Commission to make hundreds of megahertz of C-band spectrum available for terrestrial use,” the carrier said: “Commenters also broadly agree that C-band spectrum should be made available through a Commission-led process rather than a private transaction that directs all financial gains to a handful of satellite companies. While some parties question the viability of fiber as an alternative transmission mechanism to free up C-band spectrum, those concerns are overstated and are fully addressed.”

Verizon focused on restrictions. CBA has made progress in moving away from restrictive out-of-band emissions (OOBE), the carrier said: “With a reasonable receiver protection threshold that would limit 5G operations at registered earth station locations, the Commission need not adopt restrictive, across-the-board power level and OOBE limits that would force significant, unnecessary reductions in 5G transmissions.” Samsung Electronics America agreed.

Broadcasters, comfortable with the CBA plan, raised concerns. Initial comments "reflect broad opposition to [ACA's] ill-conceived, self-serving and anticompetitive proposal,” CCA, NAB and Charter said. “Diverse interests, including wireless carriers, satellite operators and content providers are all in alignment” against the sharing proposal, NAB said. Network affiliate associations said their concerns have grown.

Although some parties have proposed that safeguarding FSS operations may best be accomplished through implementation of appropriate receiver protection standards, AT&T continues to believe that transmitter regulation likely will be necessary and, as a consequence, that the effort of defining a class of relatively unrestricted licenses blocks is warranted,” the carrier said.