Over many months, the C-Band Alliance has worked with broadcasters to satisfy their concerns that giving up 40 percent of the eponymous spectrum used to distribute content to television and radio stations need not degrade the ubiquity and reliability of content contribution and distribution. During that time, the siren song of “more, more, more” echoed in the distance, luring policymakers off-course and potentially toward shipwreck on submerged rocks. We must not ignore the danger of veering off course. We urge policymakers to adhere to a carefully developed navigation plan for reallocation of 200 MHz now.

Reallocating 200 MHz now is a sound concept based on hard facts that have been independently considered and validated over the past year. Clearing 200 MHz of C-band spectrum is possible only because the necessary equipment changes are limited to filters, receiver tuning and dish positioning (with few exceptions). Calculating the costs and timing for those changes is straightforward because at that level, every satellite network is identical: only an antenna and a receiver are involved.

Clearing anything beyond 200 MHz will be based on supposition and guesswork because the necessary changes move back from the receiver into the guts of the distribution and network systems, and there the various systems become divergent. Some suggest that more spectrum can be reallocated if higher-efficiency compression is used. That may be true, but it certainly won’t be fast. When you start changing compression systems, a lot of testing is needed because some systems are more sensitive to the artifacts of compression than others. That testing would be needed on nearly every single network because their characteristics and requirements are not the same. Further, most video and audio distribution systems already use compression elsewhere in their networks and when an additional compression system is added at the uplink there can be unpredictable interaction between them.

Finally, broadcast formats are not static. For example, U.S. television broadcasters are well into preparing to upgrade from HD video to 4K (and possibly higher) resolution with augmentations, including high-dynamic range, wide color gamut and object-oriented audio. These consumer-driven improvements come at a cost: increased bandwidth. While higher-efficiency compression schemes can partially offset the requirements for increased bandwidth, clearing 200 MHz initially helps future-proof that predictable, but as-yet unknown, need. By imposing a requirement to make the present HD satellite systems more efficient and culling the available bandwidth for satellite contribution and distribution there will be no room for future improvements or growth. By pressuring satellite companies and content providers to accept less C-band spectrum now, the Federal Communications Commission could easily be setting the stage for unintended consequences with significant ramifications for competition and the content ecosystem as a whole.

There may eventually be a safe path forward that avoids the rocks and yields more than 200 MHz of 5G treasure in the C-band. But those seas are as-yet uncharted and be warned: there be dragons.

mm

Bob Weller

Vice President, Spectrum Policy
NAB

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