TR Daily Entities Reiterate Views on 3.7-4.2 GHz Band Use
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Friday, June 1, 2018

Entities Reiterate Views on 3.7-4.2 GHz Band Use

A variety of entities have weighed in on the feasibility of allowing commercial wireless operations in the 3.7-4.2 gigahertz C-band, with a number of incumbents and parties that rely on the spectrum saying it must be protected and terrestrial wireless entities saying that the Commission should open at least some of it for terrestrial use.

The comments were filed in response to a public notice released last month by the FCC’s Office of Engineering and Technology and International and Wireless Telecommunications bureaus seeking comments on a statutorily mandated report that is designed to assess the feasibility of permitting commercial wireless services to use or share the 3.7-4.2 GHz with federal or non-federal entities (TR Daily, May 1). There are no federal allocations in the spectrum.

The report was mandated by the MOBILE NOW Act, which was part of the RAY BAUM’S Act, which was included in a fiscal year 2018 omnibus appropriations bill that was signed by President Trump in March (TR Daily, March 23). The report is due by Sept. 23, 2019.

The FCC is already exploring future use of the 3.7-4.2 GHz band and other mid-band spectrum in a proceeding launched with a notice of inquiry last year (TR Daily, Aug. 3, 2017). FCC Chairman Ajit Pai announced last week that he will ask his fellow Commissioners to consider at their July 12 meeting “a proposal to make more intensive use of that 500 MHz of spectrum, including seeking additional input on making it available for commercial terrestrial use” (TR Daily, May 23).

In comments filed in response to last month’s public notice in GN docket 18-122, many entities reiterated comments they filed in response to the NOI (TR Daily, Oct. 3 and Nov. 17, 2017).

For example, the Satellite Industry Association renewed its complaints with proposals to repurpose the 3.7-4.2 GHz band for terrestrial use.

“For the foregoing reasons and those expressed in SIA’s comments and reply comments in response to the NOI, the Commission should advise Congress that FSS use of the 4 GHz band must be protected, as it supports a myriad of services that benefit every American, including distribution and contribution of video and audio programming, lifeline connectivity in remote areas, and operations necessary to public safety and national security,” SIA stressed. “The protections required to ensure continuity of these critical services preclude meaningful co-frequency use of the spectrum by new terrestrial services.”

In joint comments, Intel Corp., Intelsat License LLC, and SES Americom, Inc., touted their market-based proposal to provide terrestrial entities access to part of the C-band.

“In sum, because it gives the relevant parties the flexibility to negotiate a solution that best balances the competing interests, the market-based proposal of Intel, Intelsat, and SES will make spectrum in the 3.7-4.2 GHz band available for mobile broadband use in a voluntary, efficient, and expeditious manner, while protecting critical FSS operations,” they said. “The Parties urge the Commission to report to Congress that if the Joint Proposal is adopted, wireless operators would be able to quickly access new mid-band spectrum that would help accelerate the introduction of terrestrial 5G services, benefitting American consumers. Accordingly, the Parties’ Joint Proposal should serve as the cornerstone of the Commission’s report to Congress.”

In February, Eutelsat S.A. said it was joining the consortium favoring the market-based proposal (TR Daily, Feb. 20). But it did not join Intel, Intelsat, and SES Americom in their filing and submitted a separate filing expressing some reservations with the plan.

Eutelsat said it “is continuing to evaluate various aspects of this proposal, particularly the amount of C-band spectrum that would be identified for clearing in the 3.7-4.2 GHz band. Initial indications were that 100 MHz in the 3.7-3.8 GHz portion of the band might be made available for commercial wireless services in major cities. Eutelsat may be able to accept such a proposal as long as sufficient measures are available to compensate Eutelsat and its customers for their expenses and opportunity losses in clearing this spectrum. Terrestrial wireless interests, however, have repeatedly argued that more than 100 MHz of the 3.7-4.2 GHz band should be cleared for mobile use, which Eutelsat does not believe is achievable.

"The Intelsat’s proposal for partial band clearing has been endorsed by the two largest satellite operators (Intelsat and SES), which seek to manage the reconfiguration process. Eutelsat believes, however, that an adequate role for other C-band satellite operators, and for the major U.S. companies and government agencies that use C-band satellite services to support mission-critical communications, is needed to reach a consensus agreement on a partial band clearing approach,” the company added. “As Intelsat’s original proposal acknowledged, an ‘important’ consideration is ensuring that any C-band spectrum clearing ‘does not come at the expense of existing FSS users who rely on C-band downlink spectrum access.’ Most importantly, given the critical importance of many of the communications services that are supported by C-band satellite networks, the Commission should recommend in its report to Congress that any voluntary process that is adopted to permit commercial wireless services to operate in a portion of the 3.7-4.2 GHz band does not evolve into a coercive or compulsory process of band clearing.”

GCI Communication Corp. said that “FSS operators such as GCI have relied upon unencumbered access to the entire 500 MHz offered in the 3.7-4.2 GHz band for many years to provide critical services to customers in remote or rural areas. Modifying the current 3.7 GHz landscape by introducing commercial wireless services without additional protections would severely impact GCI’s FSS operations, and the customers that rely on them the most. Accordingly, in the event that a sharing solution is contemplated for the 3.7 GHz Band, the significant critical incumbent uses in these bands must be recognized and suitable protections for these services must be incorporated in any adopted sharing framework.”

The National Association of Broadcasters stressed the importance of the C-band for the distribution of TV and radio content, and it argued that “the availability of reasonable, practical alternative means of content delivery, such as fiber, are significantly overstated. In many cases, substitute modes of delivery are unavailable or less reliable. Even in those areas where fiber is available, it may not be economically viable.”

NAB added that “because of the importance of the C-band, and because of the limited alternatives, the Commission should insist on rigorous technical analysis of specific and detailed proposals before making decisions that will impact tens of millions of radio and television households. The Commission should not assume that technical solutions will appear that will allow incompatible services to share spectrum. NAB reiterates that, as a practical matter, this means the Commission should acknowledge that terrestrial users cannot share C-band frequencies based on geographic separation alone.”

In joint comments, CBS Corp., Discovery, Inc., The Walt Disney Company, Time Warner, Inc., 21st Century Fox, Inc., Univision Communications, Inc., and Viacom, Inc., said they “support thorough Commission evaluation of potential new spectrum uses in accordance with the MOBILE NOW Act. But any new uses in the C-band must take appropriate account of the crucial existing usage in that band, including its use by the Content Companies to reliably deliver video programming across the United States. Most importantly, the Commission should conclude in its report that co-channel or similar forms of sharing are not compatible with the protection of existing C-band uses.”

“C-band spectrum remains a core part of the delivery system for television content across the country and important for broadband access in remote areas,” NCTA said. “The record developed by the Commission to date suggests that many stakeholders would like to see the 3.7-4.2 GHz band made available for widespread terrestrial wireless broadband use. However, proponents of introducing new terrestrial wireless services have not provided sufficient detail for incumbent users to assess the potential impact of such proposals on important existing operations. It is not yet clear: (1) how much spectrum might remain available to accommodate today’s robust C-band ecosystem; (2) whether equivalent alternatives to C-band exist that could accommodate some of today’s C-band services; (3) whether new users can protect incumbents from harmful interference; (4) how much a transition would cost; or (5) how incumbent users would be made whole for costs incurred in accommodating any new wireless services. As the Commission prepares the report to Congress required by MOBILE NOW and moves forward in parallel with a rulemaking, NCTA urges the Commission to develop a comprehensive record, including technical and economic analysis of proposals for new terrestrial wireless entry, before recommending any one approach to enabling such uses.”

“C-Band spectrum has played an integral role in the evolution of the video industry over the last four decades, and remains critically important to the transmission, reception, and distribution of high-value, high-quality video to hundreds of millions of Americans,” Comcast Corp. and its NBCUniversal Media LLC subsidiary said in joint comments. “To fulfill Congress’s charge to address the feasibility of any potential changes to the existing C-band framework without negatively impacting existing C-Band users and consumers, Comcast urges the Commission to develop a full record that analyzes the critical interference, cost, reliability, redundancy, and other issues and questions highlighted herein, and carefully evaluate potential sharing approaches as informed by this record. Without a full record addressing these serious issues, the Commission will be unable to make an informed judgment about whether the claimed benefits of any spectrum sharing or other proposed approach outweigh the potentially significant costs to the video industry and, ultimately, consumers of video services.”

The Air Transport Association said, “In assessing the implications of changes to the 3.7-4.2 GHz band, IATA strongly recommends that the FCC consider both in-band and adjacent band systems that directly support aviation safety. Any interference from new terrestrial systems within the 3.7-4.2 GHz band to aviation systems should be fully assessed, preferably in close coordination with the Federal Aviation Administration (FAA), to ensure the safety of the general public before any decision is made by the Commission. The C-band satellite system operating in the 3.7-4.2 GHz band is being used for distribution of aviation data to remote areas and as redundant links to avoid single points of network failure. Networks using this capability include remote stations providing coverage for VHF Air Traffic Services networks and National Oceanic and Atmospheric Administration weather data used by aviation operators to make flight routing decisions.” It added, “The 4.2-4.4 GHz aeronautical radionavigation service (ARNS) allocation has been used globally by the airborne radio altimeter for more than 40 years to improve safety and avoid Controlled Flight Into Terrain accidents.”

“Airlines for America and its members believe that FCC must avoid allowing any encroachment upon the frequencies associated with radio altimetry,” according to a filing by the trade group. “The systems are required for safety of flight and retrofit of potentially tens of thousands of aircraft is impractical and astonishingly costly. Further, we encourage the FCC to be thoroughly mindful of the wide use of C-Band for SATCOM and many other purposes that have been raised by other commenters. Finally, we urge FCC to involve the FAA at a detailed level to assure full understanding of the Notice’s potential impacts to aviation safety.”

Delta Air Lines, Inc., echoed the position of the other aviation interests. “The aviation industry is a heavy user of both the 3.7-4.2, and 4.2-4.4 GHz bands, using the C-band satellite system for the distribution of aviation data, and the adjacent band (4.2-4.4 GHz) radio altimeter system for avoiding terrain,” it noted. “Therefore, any interference from new terrestrial systems within the 3.7-4.2 GHz band to aviation systems should be fully assessed technically and operationally for the safety of the general public before any decision is made by the Commission.”

The Aerospace Industries Association said it “recognizes the Commission’s goal of identifying additional spectrum suitable for flexible usage for high density mobile services. The Commission, however, must ensure that any additional use of the 3.7-4.2 GHz band adequately protects not only in-band satellite services, but aeronautical communication and safety systems operating in the adjacent 4.2-4.4 GHz band. Failure to do so impacts safety-of-life operations for all aircraft, and could potentially result in a catastrophic loss-of-aircraft situation due to wireless spectrum interference issues.”

Similar comments were filed by other entities, including the Air Line Pilots Association International, the Aircraft Owners and Pilots Association, the Helicopter Association International, the General Aviation Manufacturers Association, Aviation Spectrum Resources, Inc., United Parcel Service, Inc., and The Boeing Company.

“The potential for sharing 3.7 GHz to 4.2 GHz band with licensed or unlicensed commercial wireless users is of concern to America’s weather enterprise, including those businesses, trade groups, scientific organizations, academic institutions, and government agencies responsible for providing meteorological research and services, because the timeliness and reliability of weather information is of utmost importance,” said joint comments submitted by the American Meteorological Society, the American Geophysical Union, and the National Weather Association.

The Fixed Wireless Communications Coalition said it “does not oppose repurposing the band or opening it to new services, so long as the fixed links are either fully protected or relocated to other bands. The number of 4 GHz links has been declining in recent years, so as time goes on there are likely to be fewer that need protection or relocation. As part of an otherwise acceptable agreement to protect or relocate the existing links, the FWCC will not promote the installation of new links in the band. (A freeze currently in effect bars new applications for the time being.)”

Many advocates for mobile terrestrial services focused on sharing or repurposing the band.

“While the 3.7-4.2 GHz band supports important operations today, spectrum sharing in the same or nearby geographic areas is not a viable option between wireless broadband and satellite downlink operations,” CTIA said. “As one study submitted in response to the Notice of Inquiry demonstrates, large protection zones would be necessary for co-frequency satellite and terrestrial operations, making sharing in the same geographic area infeasible. To that end, CTIA applauds the Commission’s recent action to temporarily freeze any new or modified applications for satellite earth station receivers or fixed point-to-point microwave licenses in the 3.7-4.2 GHz band. The 90-day filing window allowing existing, operational receive-only earth stations to register will expand the number of earth stations that the Commission may consider in any repurposing, but it is not in the public interest to add new encumbrances in the band at this time. As noted below, however, there are myriad ways to enable repurposing while ensuring that existing users of the band can continue to receive their services, including repacking existing operations into a smaller portion of the band, relocating to other spectrum, moving to remote areas, and transitioning to another medium such as fiber.”

AT&T, Inc., said it “is optimistic that there may exist opportunities for sharing the lower C-Band between FSS and licensed mobile terrestrial operations. The FCC has recently undertaken further investigation into the actual use of the lower C-Band, a step that AT&T has recommended as a necessary prerequisite to an informed sharing discussion. Various proposals for a market-based transaction have been suggested, including an FCC-driven auction mechanism and a private solution under which FSS satellite operators, in conjunction with potential terrestrial mobile users, would develop a centralized clearing mechanism to consolidate satellite operations in the C-Band. Regardless of which way the FCC proceeds, AT&T has argued a necessary precondition is addressing the continued needs and protection rights of incumbents.”

T-Mobile US, Inc., said it “appreciates the Commission’s continued focus on making mid-band spectrum available for terrestrial services. Because Congressional interest in the 3.7-4.2 GHz band, as expressed through Section 605(b) of the MOBILE NOW Act, must be viewed in the context of other Commission proceedings in this area, T-Mobile urges the Commission to adopt an NPRM and then issue a Report and Order in this proceeding and use that activity as the basis of the MOBILE NOW Act Report. In its proceeding stemming from the NPRM, the Commission should make the 3.7-4.2 GHz band available for exclusive licensed commercial services to support the deployment of 5G mobile wireless broadband technologies. Incorporating a Commission report in an already-initiated proceeding would be the most administratively efficient course of action.”

“The 3.7-4.2 GHz band offers particular promise to provide vital spectrum to fuel 5G,” Verizon Communications, Inc., said. “As Verizon detailed in its comments and reply comments on the Commission’s Mid-Band Spectrum Notice of Inquiry, the 3.7-4.2 GHz band contains more bandwidth than the Cellular, PCS, AWS-1, AWS-3, 600 MHz, and 700 MHz bands combined and is likely to be globally harmonized for mobile broadband. The U.S. telecommunications industry is in a global race to lead the world in 5G. The United States, however, is facing a mid-band spectrum deficit that could ultimately slow 5G deployment, particularly beyond dense urban areas. While the Commission must consider how to accommodate incumbent operations in the band, the promise of the 3.7 GHz band for 5G far outweighs the challenges of adding a new terrestrial mobile allocation to the band. As a result, the Commission should move quickly to find that it is not only feasible, but critical, to allow licensed commercial wireless use of the 3.7-4.2 band.”

“While the FCC should look at all possible solutions for how best to introduce new flexible-use services into new bands, a sharing approach in the 3.7-4.2 GHz band will be of limited utility,” Ericsson said. “As discussed below, an Ericsson study confirms that significant separation distances for co-channel sharing between wireless broadband systems and earth stations will be needed (at least 30 kilometers under favorable conditions). While a further study indicates improved separation distance requirements for adjacent channel sharing, additional engineering solutions would be necessary to deploy in dense markets. Given the dispersed nature of existing operations in the band, database management tools do not adequately expand the opportunities for 3.7-4.2 GHz mobile broadband spectrum. Finally, interference concerns raised by the Broadband Access Coalition (‘BAC’) proposal remain.

“There is, instead, much greater promise in repurposing the 3.7-4.2 GHz band for mobile broadband use,” Ericsson added. “The record supports using some combination of band-clearing approaches, including relocating incumbents, using alternative transmission means such as fiber or Ku-band satellites and market-based approaches.”

“The key to assessing the impact of sharing on current users in the band is to understand the full extent of, and technical characteristics of, those current uses,” said Nokia. “The vast majority of current users operate in the Fixed Satellite Service (FSS). Unfortunately, at this time, there is a lack of correct, public data to conduct an accurate assessment. Nokia urges that the Commission require current earth station licensees to improve the accuracy of the Commission’s database, and that the assessment quantify only the impact on registered earth stations.”

“As previously noted by Federated Wireless, a broad cross-section of commenters agree that shared use, enabled by dynamic spectrum sharing technology, is the best and fastest path to enabling flexible use of the 3.7-4.2 GHz band,” Federated Wireless, Inc., said. “Federated Wireless believes the Commission should have as its primary goal expeditiously maximizing the efficient use of spectrum in order to allow the largest possible number of users to access this limited resource. Although there are alternative ways to address the shortage of usable spectrum (e.g., clear and auction, repackaging, co-location, sharing), of all the methods dynamic spectrum sharing holds the greatest promise of achieving this important goal quickly. Indeed, a Spectrum Access System (‘SAS’) for the Citizens Broadband Radio Service (‘CBRS’) band is about to undergo certification testing with commercial deployment of CBRS expected before the end of 2018. Such a system is already perfectly suited to manage dynamic spectrum sharing in the 3.7-4.2 GHz band.”

The Broadband Access Coalition said, “From the outset of this proceeding, the Coalition has repeatedly demonstrated the feasibility of allowing commercial licensed point-to-multipoint (‘P2MP’) fixed wireless broadband services to share use of the 3.7 – 4.2 GHz band with incumbent Fixed-Satellite Service (‘FSS’) and Fixed Service (‘FS’) users under Part 10 of the Commission’s Rules.”

“By requiring FSS registrants to update and supplement IBFS listings, the Commission has begun the process of ensuring availability of accurate and sufficient FSS data for decision-making,” said Google LLC. “The Commission next should amend its Part 101 Rules to permit expanded use of fixed links, including for P2MP services, on a non-interfering basis with FSS services. Upon resolution of coexistence challenges between mobile and FSS services, exclusively licensed flexible use should be allowed, and fixed links should be repacked into the remainder of the band and/or coordinated with mobile and other exclusive flexible uses on a shared-spectrum basis.”- Paul Kirby, [email protected]

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