Mr. And Mrs. LinkUp Go to Washington – Part One

(Sharing With the FCC the “Real Life” Impact of 5G on C-band Frequencies)

Mark and I arrived in DC a little before 7am on a north-bound Amtrak train a bit bleary-eyed, but ready to begin our scheduled three days of meetings at the FCC and Capitol Hill. The real “nail-biting” meeting was scheduled to begin in early afternoon with representatives from the International Bureau (IB) of the FCC. The topic? You – our customers – and the proposed “sharing” of prime C-band frequencies with 5G. In a nutshell, the countless concerns we have surrounding the entire idea.

When we were asked to speak before the staff of the FCC at the urging of both space company giants Intelsat and SES Global, we eagerly agreed. We were excited at the opportunity to present to the Federal Communications Commission a “real life” perspective of the impact 5G broadband could have on the heavily used C-band frequencies between 3.7 to 4.2 GHz.

We were to be joined by representatives from the Society of Broadcast Engineers, SBE President Jim Leifer and SBE General Council Chris Imlay. As a group we met up in the lobby of a nearby hotel to focus our message. If we had the undivided attention of the FCC for a short period of time, we needed to ensure that a crisp, concise missive was relayed.

For us, the compelling reason to travel to DC and speak to the FCC is to tell our story and yours; giving the staff a glimpse of the challenges our customers will face if the proposed 5G “sharing” of C-band became a reality.

It didn’t take long for us to realize our list of concerns was too long to share in this initial meeting. It was determined that focusing on the FCC filing itself – the complexity of the form, the need for the ability to “batch file” multiple C-band downlinks, and the fee itself – was our best course of action.

Though our group was originally scheduled to speak with the FCC for 30 minutes, the meeting ran over a bit as the FCC generously allowed us nearly an hour. We put most of our metaphorical eggs into the “why does registering your C-band earth stations need to be so difficult?” basket. We expressed to the FCC how our clients were working to comply with their request for licensees to register their C-band antennas, but the complexity of the form and the time it took to fill it out were all-too-real stumbling blocks in the process.

I find it worth noting that the FCC responded best to hard numbers. As Mark spoke about how we calculated what we believe is a “true” estimate regarding the number of C-band downlink earth stations in the US (approximately 27,000) the FCC took note. The FCC also seemed most interested when we shared that – combined – our customers covered 144 markets, with a listenership of 14 million. Even more importantly, our clients rely upon C-band communications for as much as 98% of the programming distributed by their stations into local communities.

Take a look at the Notice of Ex Parte Presentation from this meeting on the FCC website  for a detailed description of what was said and submitted to the Commission by our group. Also included for public record is a copy of the report Mark produced regarding the impact the proposed 5G encroachment will have on the future of C-band broadcasting.

Did our meeting with the FCC make an impact? It certainly did; at least for us. Our impressions…

There were more than a few members of the IB sympathetic to some of the concerns we raised – specifically, concerns over the sheer number of C-band downlinks many in the industry were attempting to register and the un-budgeted expense of registering multiple downlinks.

The $435 filing fee will continue. No doubt. When asked why a fee was necessary, we were told that it was needed to compensate staffing for the additional burden of handling so many complex filings within a short time frame.

We are hopeful the FCC may provide some financial relief for multiple downlink registrations. The FCC has mastered the art of holding their cards close to the vest but, again, we had a sense that the staff understood the undue burden this hefty expense would have on so many broadcast licensees.

Of course, this meeting happened on Tuesday, May 25 – two days before Chairman Pai’s announcement that at the July FCC meeting he is intends to put up for a vote a proposal to “make more use” of the frequencies between 3.7 and 4.2 GHz. As discouraging as this appears, it is just a Notice of Proposed Rulemaking (NPRM). We must take advantage of the window of opportunity we have to file public comments.

Not that you must wait until July to have a voice in this matter. We continue to encourage you to address the FCC directly with your concerns about the encroachment of 5G into C-band satellite frequencies. Registering your C-band earth station with the FCC and filing a letter stating your concerns about 5G encroachment into C-band frequencies are two very tangible ways you can make a difference.

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