C-Band Earth Station Registration Done, Late Disclosure Sought by Stakeholders

The agency received 15,001 3.7-4.2 GHz earth station registrations during the window that closed Oct. 31, according to IBFS. An FCC spokesman said there's an intake process for earth station registration applications that includes payment processing and verification of basic components of the application such as location data. Once those requirements are satisfied, the registration application is placed on 30-day public notice, he said. After that PN period, the application may be granted, he said.

For registered earth stations "that's the end of it" for now, emailed broadcast and telco lawyer Scott Flick of Pillsbury Winthrop. He said the FCC may later ask registrants who filed during the registration window but didn't perform a frequency coordination to do one: "But that seems unlikely until the FCC establishes its long-term rules for using and sharing the band."

Society of Broadcast Engineers General Counsel Chris Imlay said once a registration application is filed for receive-only dishes, there's no discretion and the agency will enter its location in its database. He said unlike many other FCC licensing and registration databases, such as the land mobile database, the C-band earth station database "is top of the line, it's complete, it's accurate, and it's up to date" thanks to the registration window extensions. He said broadcasters who didn't register during the window still should do so now since the commission presumably hasn't made up its mind on what sort of 5G systems will be allowed into the 3.7-4.2 GHz band.

The question becomes how the FCC will implement 5G in a way that protects those 15,000 receive-only dishes, as the commission has pledged to do, Imlay said. "I don't think they had any idea there would be that many registrations." He said broadcasters and dish operators will have to rely heavily on the FCC claim it will protect those incumbent operations mainly because "there's no good alternative" since Ku-band isn't as reliable as C-band.

That spectrum is vital for end users like radio stations, since the typical C-band transponder equivalent has about the same wattage as a refrigerator light bulb and can't overcome signals from cell towers near satellite receivers, Microspace Communications said in docket 17-183 Wednesday. It warned midband sharing between satellite services and terrestrial "will create a 'noisy neighborhood' in which the earth stations will never work reliably."

The up-to-date C-band registration database enables a compatible 5G overlay in the band -- seemingly the route least disruptive to incumbent fixed satellite service receive-only facilities -- through a prior coordination notification process, electronics multinational Robert Bosch said. It said the idea that Communications Act Section 309(j) requires an auction process to allocate the C-band is an overbroad construction of the law, and nothing necessitates competitive bidding. BASF and Foxconn, like Bosch, said part of the band should be allocated for private networks to meet growing industrial needs (see here and here).

Intelsat urges C-band users to register, despite having missed the deadline, since every U.S. C-band downlink will require protection such as a filter, whether those earth station operators are in the database or not, a company spokesperson emailed. The company is a member of the C-Band Alliance, which commits to a filtering process for all C-band downlinks in the continental U.S., "and we can’t provide a filter installation if we do not know of a particular site," she said.