FCC Seeks Comment on C-Band Auction

The Federal Communications Commission's Wireless Telecommunications Bureau, International Bureau, Office of Engineering and Technology, and Office of Economics and Analytics invite interested parties to supplement the record to address issues raised by commenters in response to the FCC's July 2018 Notice of Proposed Rulemaking in GN Docket No. 18-122. The FCC sought comment on several approaches, including auction-based approaches, for making some or all of the 3.7-4.2 GHz band (C-Band) available for terrestrial, flexible use. The FCC also sought comment on other issues essential to the introduction of new terrestrial wireless services in the band, including incumbent protection criteria, technical and licensing rules, and appropriate methodologies for transitioning or protecting existing Fixed Satellite Service and Fixed Service operators in the band. Now the FCC seeks additional comment on proposals from: (1) ACA Connects – America’s Communications Association (ACA Connects), the Competitive Carriers Association (CCA), Charter Communications, Inc. (Charter) (collectively, ACA Connects Coalition); (2) AT&T; and (3) the Wireless Internet Service Providers Association (WISPA), Google, and Microsoft.

1. The ACA Connects Coalition, which collectively represents both incumbent C-band earth station users and wireless providers that seek to use this spectrum to provide 5G services, recently submitted a joint proposal for repurposing a large portion of the C-band for 5G use. Their proposal consists of three key elements that would make 370 megahertz of C-band spectrum available for flexible wireless use on a nationwide basis: (i) a FCC-driven auction that would award new terrestrial licenses and assign obligations for transition costs; (ii) a plan to transition certain Fixed Satellite Service earth station operators to fiber; and (iii) a plan for satellite operators to repack remaining earth station users to the upper portion of the band.
2. AT&T asserts that the C-Band Alliance’s proposed technical criteria would constrain 5G deployment, and it proposes an alternate band plan to address its concerns. AT&T recommends dividing the 3.7-4.2 GHz band into three segments: (i) a largely unrestricted mobile terrestrial 5G segment in the bottom of the band (“Unrestricted Licenses”); (ii) “Adjacent Licenses” in the middle of the band that would have to coordinate with or mitigate impact on Fixed Satellite Service; and (iii) remaining Fixed Satellite Service spectrum in the top of the band. Unrestricted Licenses could operate using full power and would not be obligated to coordinate with Fixed Satellite Service earth stations; Adjacent Licenses would operate using lower power or subject to other limitations, or would be obligated to coordinate with nearby Fixed Satellite Service earth stations.
3. WISPA, Google, and Microsoft filed a study conducted by Reed Engineering, which analyzed Fixed Satellite Service and fixed wireless point-to-multipoint co-channel coexistence in the 3.7-4.2 GHz band. Among other conclusions, the Reed Study suggests that exclusion zones of about 10 kilometers are sufficient to protect most Fixed Satellite Service earth stations from harmful interference caused by properly-engineered co-channel point-to-multipoint broadband systems. The propagation model used in the study relied on Fixed Satellite Service earth station characteristics that require them to point upwards towards the geostationary satellite arc. Thus, the earth stations are specifically designed to mitigate their response to signals arriving from the horizon, such as terrestrial point-to-multipoint links. Additionally, the study relied on the directional nature of fixed service antennas and clutter to assume reduced emissions at earth stations.