Time is Running Out to Register Your C-band Earth Station with the FCC

NAB urges C-band satellite users to register their earth stations with the FCC in anticipation of a proposal to offer wireless broadband services in the 3.7–4.2 GHz spectrum (or some portion of that spectrum).  The FCC has announced that it plans to issue a proposed rule-making notice at its July 12 meeting.

 

In April, the FCC established a docket on “Expanding Flexible Use of the 3.7 to 4.2 GHz Band.”  Concurrently, the Commission also announced a 90-day filing window for existing C-band users (i.e., earth stations in operation as of April 19, 2018) that are not yet registered with the FCC to register their facilities. To encourage registration, the FCC is waiving the frequency coordination requirement but is not waiving the $435 filing fee during this 90-day window. NAB is working with the Commission to have the fee reduced or eliminated.  The deadline for registration is July 18, 2018. After that date, you may not be eligible for reimbursement of costs relating to establishing alternative/replacement service if wireless is deployed in your area.  Additional details are in this Public Notice.

 

Most broadcast program distribution, both radio and television, is done over C-band and interference from wireless broadband services could prevent stations from providing news and entertainment to listeners and viewers. Last summer, the FCC noted that there are just 4,700 registered C-band earth stations, suggesting that it believes the spectrum is presently under-utilized.

NAB believes that a majority of receive-only C-band earth stations are not registered, not included in the FCC’s 4,700 figure, and will not be protected from interference from new wireless broadband uses. If your earth station is one of those not registered, it could be wiped out by interference from new wireless services operating in the C-band spectrum. NAB urges all broadcasters with receive-only C-band earth stations to ensure that they are registered with the FCC. Further, we urge that such registration include the entire domestic satellite arc and all transponder frequencies, even if your present operation is confined to a single transponder on a single satellite. This will ensure that your operations are protected if you need to move to a different satellite or transponder.

To register during the 90-day window, you need to complete FCC Form 312 and pay a $425 filing fee.  Multiple earth stations at a single site can be registered on a single Form 312 for a single fee.

 

Given that the FCC has waived the coordination requirement (and its associated $1,000-plus cost), it is hard to see any reason to conduct a frequency coordination study at this time. Such a study would consider and protect against point-to-point microwave services, for which the FCC has also frozen new applications.  Since the FCC is considering allowing mobile operations in the band, NAB believes that the coordination analysis would be useless. Given the moving parts in this proceeding, any coordination analysis performed now could end up being moot.

Should you have questions concerning this matter, please contact Robert Weller in NAB’s Legal and Regulatory Affairs department.

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