The Disease of More: Getting to the Right Number, Not the Highest Number, for C-Band

The conventional wisdom in the communications arena is that the United States is engaged in a race to be the first nation to deploy the next generation of wireless technology: 5G. But while many insist on the importance of winning the “Race to 5G,” we somehow can’t quite get out of the starting blocks.

Central to the policy debates over the Race to 5G is a swath of 500 megahertz (MHz) of spectrum affectionately called the “C-band.” Today, over 100 million households in the United States rely on this spectrum band most have never heard of. Satellite companies use C-band spectrum to deliver television and radio programming to broadcasters and others across the country. This C-band spectrum serves as the backbone of television and radio content distribution to American viewers and listeners.

The Federal Communications Commission (FCC) is currently considering how best to reallocate a portion of the C-band for new wireless services, while ensuring that the remaining amount can continue to support this critical content distribution system. To date, the Commission has given every indication that it appreciates the importance of both these goals; changes are coming to the C-band, but the FCC certainly doesn’t want to lay the groundwork for disastrous and unpredictable consequences to television and radio service.

Accordingly, up to this point, the FCC has been working as quickly and responsibly as it can to resolve the critical questions regarding what to do with the C-band: how much of the band to reallocate for wireless services, how to accomplish the reallocation, how to ensure continued robust content distribution and how to oversee a complex reallocation process. That process has led to a consensus that it is possible to reallocate a portion of C-band spectrum while protecting television viewers and radio listeners from disruption. Further, a consortium of satellite companies has demonstrated that they can make 200 MHz of spectrum available in the very near future while continuing to accommodate programming distribution in the remaining 300 MHz. While certain details still must be worked out, including the mechanism for the sale of spectrum to wireless companies and the interference rules to ensure a peaceful coexistence between wireless and satellite operations, a 200/300 split has emerged as a bird in the hand that would allow the FCC to move forward quickly without running the risk of programming disruptions.

Unfortunately, because of pressure from competing interests, the FCC has been reluctant to take the win. The devastating consequence is that the C-Band Alliance, a consortium of satellite operators that currently use the C-band, is feeling undue pressure to come up with even more than 200 MHz to reallocate for wireless services. This pressure will lead to bad results for consumers across the country. As they themselves have insisted to the FCC and their customers, there is simply no reasonable way for satellite operators to provide the same level of service to their existing customers if they must immediately surrender more than 200 MHz.

The facts haven’t changed. Only the level of pressure on the satellite operators has.

If we’re really in a race, shouldn’t we start running? There’s a win staring us all in the face – reallocating 200 MHz of C-band spectrum as quickly as possible while protecting critical content distribution infrastructure in the remaining 300 MHz. A relentless insistence on getting to a higher number for the sake of getting to a higher number carries real risk of breaking the content distribution system that viewers and listeners depend on today.

Moving on the 200 MHz we know can be done today without harming the existing content distribution system does not mean that additional spectrum cannot be reallocated in the future. This does not have to be the end of the process. The Commission can revisit the C-band as technology evolves and alternative distribution mechanisms become more viable. But forcing a messy, disruptive and delayed result for multiple industries for the sake of a higher number of megahertz right now seems to benefit no one.

We urge the Commission not to make “more” the only goal of this proceeding. The reliable and ubiquitous delivery the C-band affords cannot be duplicated by fiber or spectrum in alternative bands. That seamless reliability and ubiquity is critical to preserving the value of the content ecosystem hundreds of millions of Americans enjoy today. If playoff games, prime time programming or breaking news coverage is interrupted because of decisions the Commission makes in this proceeding, viewers and listeners will not care how much more spectrum the FCC has cleared for next generation wireless services – they will only care how much less reliable their programming has become.