Small Carriers and Tribes Among Groups Seeking Changes to Proposed Upper C-Band Rules
While aviation safety and protection for radio altimeters were possibly the hottest topics in comments on the future of the upper C band (see 2601210067), other major issues emerged as well in FCC filings this week (docket 25-50). Small carriers warned that the proposed auction rules benefit large providers, while tribes and public interest groups decried the lack of a tribal licensing window. Upper C-band incumbents also defended their use of the band.
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The Rural Wireless Association asked the FCC to reconsider the proposed bidding credit limits of only 15%, the exclusive use of relatively large partial economic areas as the geographic size of licenses, and population-based buildout requirements. As rural providers struggle “to compete with the ‘Big-3 Oligopoly,’ it is important for the Commission to establish Upper C-band auction rules that facilitate the connection of rural Americans in the hardest to serve areas of the country.”
The Competitive Carriers Association called for larger bidding credits for small providers, county-level licenses and pre-auction bright-line spectrum aggregation limits. Midband spectrum is essential for rural carriers, “but the costs associated with acquiring Upper C-Band licenses as proposed -- combined with clearing obligations, equipment expenses, and deployment requirements -- create significant barriers for rural carriers competing against nationwide providers with exponentially greater financial resources,” the group warned.
The Coalition of Rural Wireless Carriers said that without changes to the rules, its members will be largely shut out of the auction. “The gulf between the Big Three and small rural carriers for low- and mid-band spectrum is wider than ever,” and three recent auctions "produced vanishingly small results for small rural carriers." For example, Pine Cellular, a small carrier, has only 27.1 MHz of low and midband spectrum, while Smith Bagley has 55.4 MHz, Nex-Tech Wireless 58.4 MHz and Carolina West Wireless 84.2 MHz, the coalition said. In comparison, Verizon Wireless has 289.8 MHz of low and midband spectrum, and T-Mobile has 303.9 MHz, it noted.
Public interest and tribal groups jointly urged the FCC to launch a tribal window, noting the “concrete and durable public-interest benefits” of doing so. Tribes have used licensed spectrum from the 2.5 GHz window “to serve homes in areas neglected by commercial providers, improve educational outcomes, secure telehealth access and strengthen essential emergency services,” the groups said. The propagation characteristics of the band “make it well suited for large, sparsely populated, and topographically challenging Tribal areas.” The filing was signed by Public Knowledge, the Benton Institute for Broadband & Society, the First Nations Development Institute, the Open Technology Institute at New America and others.
Navajo Nation President Buu Nygren said tribal lands “continue to be the least connected lands in America.” In the Navajo Nation, 164,000 people are spread across 27,000 square miles with “sprawling deserts, canyons and mountains,” and fiber isn’t a viable option, Nygren said.
The FCC also heard from incumbents of the band. The Society of Broadcast Engineers said the agency should set aside “as much of the band as possible” for broadcast operations. There remain “many substantial and longtime incumbent uses of the Upper C-band; uses that both implicate critical ‘last-mile’ links in existing broadcast communication infrastructure and represent significant prior business investments,” the group argued. NAB raised similar concerns.
The North American Spectrum Alliance reminded the FCC that upper C-band spectrum is widely used to deliver TV and radio content. In the first C-band auction, “broadcasters sacrificed 60% of … spectrum that is critical to their operations, effectively increasing spectral efficiency of the C-band by 250%,” it said. It’s “unlikely that any further compression … can be tolerated without compromises to quality of service.”