PART I
The worst-case and highly-feared—yet widely anticipated—"doomsday scenario" for broadcasters (and many other satellite communications users) in the United States has taken another dramatic and strong step toward becoming reality.
The FCC voted unanimously in its July 12, 2018 meeting to proceed with an Order and NPRM aiming to gather information and explore opening the entire 500 MHz of C-band downlink frequencies (a.k.a. "Mid-band Spectrum") for use by mobile and terrestrial wireless broadband companies.
If that sentence was overwhelming in its scope and meaning, here's the simple version in layman's terms:
The FCC officially still thinks it's a good idea to reallocate and repurpose the satellite downlink frequencies that just about all radio and television broadcasters use to receive content. From a pragmatic view, that means simply that the FCC is not looking to protect and serve its existing licensees and frequency users who already serve the public interests; it instead is looking to appease big data and wireless companies' financial interests and generate revenue for the government in the process.
Now don't get me wrong—I've been a big fan of some of Chairman Pai's moves to roll back some of the obvious overreaches of the prior administration's FCC. It's been refreshing to see the FCC move back toward allowing the free market to work things out under the gentle "light touch" oversight by the official overseers of all things related to radio frequency and telecommunications. History has shown time and again (at least here in the United States) that when people and companies are free to innovate, new products and services abound. Thankfully, our forefathers had the foresight and forethought to encourage innovation by the establishment of the United States Patent Office, and that freedom has allowed U.S. technical companies to lead the United States to become the global leader in technical advancements and prowess (at least from my humble perspective).
HIGH-DOLLAR LOBBYING
But, alas, it seems that yet again, the governmental agencies can't help but bow to pressure of the high-dollar lobbying campaigns put on by big companies who stand to realize large capital and operational infusions by taking resources from one group and giving it to others. The behemoth chipmaker Intel's original proposal to reallocate parts of the C-band downlink spectrum obviously would benefit that manufacturer directly through increased product sales, and no discussion is needed to figure out why Verizon, Google, CTIA, and a variety of other companies want the spectrum ( See footnote #2 on page 4 of General Communication's Comments for a short list).
Yet one satellite operator seems to have taken a desperate measure to survive, almost like a parent being willing to sacrifice one child so another could have a chance to survive. In particular, Intelsat's willing participation in that Intel proposal seems "strangely" akin to Dr. Strange voluntarily turning over his Infinity Stone to Thanos in "Avengers: Infinity War." Any company involved in or utilizing satellite communications that would willingly suggest it's a good idea to give up their most valuable resource—RF spectrum—obviously must have done so out of a desperate and final play to survive... yet that's not the perspective or playbook shared by any terrestrial broadcasters with common sense and a heartfelt mission to serve the public.
HEADLONG AND HEADSTRONG
The NAB's comments were an excellent reflection of the entire broadcasting industry's views, concerns, and preferences regarding the (then-potential) possibility of the FCC giving away the C-band spectrum. Many other comments filed with the commission (and many more broadcasters' public forum comments not officially submitted to the commission) sided with the NAB, and for good reason.
Initially, the FCC seemed to be willing to listen to petitioners: To gather information about the number of existing C-band downlink sites, the FCC created a 90-day window wherein C-band downlink users could register their downlinks without the expensive frequency coordination study previously required. And then, in response to concerns that users needed more time to register all their downlinks, the Commission extended that window another 90 days, also reducing some of the complexity and cost of registering multiple sites.
In spite of those moves, however, the FCC marched headlong and headstrong along its much-trumpeted path toward 5G, voting on July 12 to formalize the NPRM to take away part—or all— of the C-band downlink frequencies that broadcasters (and many other government and commercial users) use on a daily basis and instead give it to the wireless and broadband industries. What is notable is that the FCC voted on the NPRM even before the original downlink registration deadline of July 18, 2018 had arrived and over three months before the extended registration deadline.
Showing disregard for the information it said it wanted, the commission's vote clearly reveals their agenda is much like the Communist paradigm of taking resources from those who have them and give those resources to those who don't (all ostensibly in the name of the "Common Good"). The obvious conflict of interest here is that the government stands to gain much financially from a possible auction of spectrum (like they did from the Incentive Auction in which some television broadcasters participated between 2016 and 2017).
In this, the commission has publicly bumped themselves back down a significant notch in their self-proclaimed move toward a light touch and market-driven approach. Even though their July 12 vote on the issue aligned precisely with their previously-stated intentions of closing the "digital divide" and therefore wasn't a surprise, the commission's ongoing move in this matter toward the "communal good" still reeks strongly of corporate lobbying and self-aggrandizement. It also sadly confirms that even good intentions of excellently-qualified individuals (like Chairman Pai and Commissioner O'Rielly) get buried in the swamp of politics-driven Washington, D.C.
Time continues to tell the story that the public—including broadcasters commercial and non-commercial alike—suffers as a result of Big Government's expansion and overreach under corporate influence and lobbying.
Simply put, this proposed action could realistically result in everything needing to be delivered over the Internet. I don't know about you, but I wouldn't want to be worried as a broadcaster that the backhaul delivery of the FIFA World Cup final or Super Bowl could be interrupted by an Internet outage—yet that's precisely the direction the FCC and many commenters seem to think is best for this country.
Broadcasters (and other SatCom users alike), beware! Now is the time to stay (or get!) actively involved in this NPRM. Its affirmation could mean dramatic—or fatal—impact on how live and prerecorded content gets delivered to hundreds of millions of listeners and viewers every day.
Lastly, by all means (even if it seems like an exercise in futility), at the very least go ahead and register your C-band downlinks. There are some extremely well-written and thorough instructions on Intelsat's site, SES's site, and the FCC even has some sample forms available for review. There are several consultants and/or private companies that can provide assistance with registering your sites, so don't let inexperience keep you from letting the FCC know about your C-band usage.
In Part II, we'll look at the impact of worldwide implementation of 5G and alternatives to C-band will have on the future of satellite communications.
Sherrod Munday currently serves as vice president of engineering for Sky Angel, a 2-channel TV network found on Dish Network. His experience includes full-time and consulting engineering in both TV and Radio, delivering live and preproduced content over the air, via satellite syndication, and directly to consumers across the Internet. You may reach him at smunday@ieee.org
