The NAB on Monday filed reply comments with the FCC regarding its NPRM concerning expanded operations in the C-band. While the NAB does not endorse any particular proposal for reallocation in the C-band, it wants the Commission to take three steps in this proceeding.
Here’s what they are.
The C-band is the colloquial term of the 3.7-4.2 GHz band, a swath of spectrum that the NAB notes radio and TV broadcasters use every day to deliver news, sports and other popular content for their broadcasts.
“Without ever knowing it, those viewers and listeners depend on C-band spectrum to receive many of their favorite programs,” the NAB writes. “Thus, any changes to the amount of spectrum currently being used for this purpose, including the rules governing C-band use, could have a profound impact on consumers.”
As such, the FCC is asked to ensure that C-band users “are successfully accommodated and protected in any reallocation by requiring a transparent, enforceable and fully-funded plan for protection or relocation.”
Using the “Race to 5G” as its backdrop, the NAB asserts that reasonable C-band alternatives “are not readily available.” Additionally, “Fiber is not a realistic option.”
Further, the NAB is also aware of “no other satellite spectrum band that can replace the C-band.”
In its second argument, the NAB requests that the FCC balance public interest considerations in making reallocation decisions “and not succumb to artificial pressures to allocate higher amounts of spectrum arbitrarily.”
Thirdly, the NAB says, the FCC should not allow shared use in the portion of the band that is not reallocated for mobile use.
“Because of the vital role the C-band plays in content distribution today, any consideration of expanded operations in the C-band should start with the protection and preservation of the capabilities the C-band offers users: a seamless and reliable content distribution system that can serve every corner of the nation,” the NAB says. “Accordingly, whether the
Commission ultimately chooses to reallocate some portion of the C-band through a private
arrangement, a government-administered auction or some other mechanism, the Commission should take three important steps to ensure that making additional spectrum available for mobile use does not upend the nation’s content distribution architecture … consistent with both the need to protect existing users and allow for future expansion, the Commission should not degrade satellite use of a reduced C-band by allowing shared operations in the band.”
