Airline Industry Concerned About Carrier Use of Upper C Band
Airlines for America (A4A) and Aviation Spectrum Resources Inc. (ASRI) jointly urged caution if the FCC moves forward on an auction of upper C-band spectrum. But CTIA and wireless interests called for the agency to take the next steps toward an auction, building on the record-setting C-band auction, which ended in early 2021 (see 2102180041) and reshaped carriers’ midband portfolios. Replies were due last week in docket 25-59 on a notice of inquiry approved by commissioners 4-0 in February (see 2502270042).
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The airline interests raised concerns about protections for radio altimeters, which also use the spectrum to measure aircraft altitude. Those concerns first emerged when the NOI was announced (see 2502120046).
A4A and ASRI “agree with the vast majority of commenters across multiple industries that strongly support maintaining aviation safety in the 4.2-4.4 GHz band through a deliberate and data driven process for any potential future Commission action in the Upper C-band." They called on the FCC to bring affected parties together before moving forward on an auction. “By addressing coexistence issues early, the Commission would avoid repeating the disruptive and resource intensive remediations needed” after the previous C-band auction.
Other band incumbents also raised concerns. NCTA said the upper C band “remains core to programmers’ nationwide media and content distribution and neither fiber nor other satellite bands that have been proposed can fully replace it.” Commenters “from rural and remote regions of the nation -- from Alaska to Appalachia -- explain the particular importance of the Upper C-band for essential communications and media services,” NCTA said.
Companies that use the band for content distribution echoed NCTA’s concerns. The upper C band “remains essential to the reliable distribution of programming, and ... its reallocation would compromise access to programming that millions of American households depend upon,” said A+E Global Media, Fox, NBCUniversal Media, Paramount Global, Warner Bros. Discovery and other companies.
NAB said using the upper C band “for satellite program contribution and distribution is critical to the broadcast industry and that use has become more intense since the ‘Lower C-band’ auction less than five years ago.”
But CTIA urged the FCC to move quickly on an NPRM. “There is a clear need for additional licensed, full-power 5G mid-band spectrum, and Upper C-band spectrum is well-situated to help meet that near-term need.” There are also “promising options” for repurposing the upper C band “that can be further explored,” and “the market-driven processes used to successfully transition the initial C-band spectrum can be leveraged once again to enable a timely and efficient transition of Upper C-band spectrum,” it said.
The Wireless Infrastructure Association noted that carriers face a spectrum shortfall for 5G and 6G and will need more midband airwaves. “In addition to the physical characteristics that make these frequencies critical for advanced mobile service deployments, there is strong consensus in the record that the FCC should take advantage of shared history to reallocate the upper C-Band expeditiously.”
Verizon, the leading bidder in the initial C-band auction, said the record supports quick action. “There is a significant need for additional licensed mid-band spectrum to meet the growing demand on wireless networks, and the Upper C-band is a prime candidate to help address our nation’s current shortfall,” the carrier said. Collaboration between the communications and aviation industries “is leading to a coexistence framework that enables full power wireless use in the Upper C-band along with continued safe radio altimeter operations above 4.2 GHz.”
AT&T, which bought the second-most licenses in the initial auction, also advocated for an NPRM. “With its favorable coverage, capacity, and propagation characteristics, the Commission and commenters alike have recognized that [this] mid-band spectrum is ‘critical’ to any provider’s 5G buildout.”
T-Mobile pushed for further study. “The Commission should (1) collect technical and operational data regarding in-band earth stations and adjacent-band radio altimeters, (2) initiate a rulemaking under Part 87 to provide clear performance requirements for radio altimeters, and (3) update aircraft filing obligations” in the universal licensing system “to maintain and make publicly available critical radio altimeter information,” it said.