C-band Panel Presentation of Louis Peraertz, Capitol Forum, October 8, 2019
Many of the headlines around C-band focus on two public interest goals: Allocating more spectrum for 5G commercial mobile wireless services and preserving sufficient spectrum to allow satellite earth stations to support video programming distribution.
WISPA believes that the C-band proceeding presents the opportunity to advance a third important public interest goal: Bridging digital divides in rural areas.
As recently as the last FCC open meeting, FCC Chairman Ajit Pai noted that bridging digital divides in rural areas is his top policy priority. WISPA believes that the right way to advance that goal, in the C-band proceeding, is by allowing point-to-multipoint fixed wireless services to share spectrum in the band that is not cleared for mobile broadband and has been left for C-band earth stations. With the exception of ACA and Charter, there is no other party that has presented a detailed proposal that would help the FCC achieve Chairman Pai’s top priority.
Part of the challenge in selling this proposal is the fact that people are unfamiliar with wireless internet service providers, or WISPS. There are more than 2,000 WISPs nationwide. 557 of those are members of WISPA. And 70% serve 2,000 or fewer subscribers. A majority of these WISPS have 10 or fewer employees, meaning they are truly small companies. Altogether, WISPs serve more than 6 million individuals and businesses using fixed point-to-multipoint wireless services.
WISPs are on the front lines of the fight to bridge America’s digital divides. In fact, Chairman Pai referred to WISPs as the “foot soldiers of the digital revolution” in rural and low-income communities throughout America.
Because they lack the access to capital that larger companies enjoy, the vast majority of these small companies are using unlicensed spectrum to serve their customers. They would like to serve more customers. But because the unlicensed spectrum bands are congested, they need more spectrum to do that.
That is why in 2017, WISPA, as part of the Broadband Access Coalition, filed a petition for rulemaking asking the FCC to amend Part 101 of its rules to allow fixed wireless services to share spectrum with C-band earth stations. More specifically, of the 500 megahertz that is available in the C-band, we urge that the FCC make available 300 megahertz of that underutilized spectrum for fixed wireless on a shared basis with satellite earth stations. The remaining 200 megahertz would be cleared for “flexible use” via auction for 5G and other services.
We believe this sharing proposal can be implemented rapidly and simply because:
- This type of sharing already exists. Earth stations have coexisted with point-to-point services for decades, and today there are more than 8,000 instances in which point-to-point services are sharing C-band spectrum with earth stations.
- It is easy to protect earth stations from harmful interference by using well-established coordination procedures, then transitioning to an automated frequency coordination system developed by a multi-stakeholder group.
- No sophisticated spectrum management techniques, like SAS for the Citizens Broadband Radio Service, are required.
- No new allocations are needed.
- There are no Federal government allocations in the band.
It is clear that bridging digital divides is a vital goal that the FCC wants to achieve in the C-band proceeding. The section that introduces why this C-band proceeding is so important is entitled “5G Leadership and Closing the Digital Divide.” In the first paragraph, the FCC states that “fixed wireless services provide an additional opportunity to connect rural communities and to offer competitive wireless alternatives in urban areas.” The NPRM also favorably describes how allowing point-to-multipoint services could enable gigabit speed broadband in rural areas.
WISPA, with its partners Google and Microsoft, filed a technical study prepared by Virginia Tech professor Jeff Reed that demonstrated that the FCC can reduce the typical protection zones for FSS earth stations from 150 Km to 10 Km zones, and if it did that, it would enable co-channel sharing without interference that could provide service to more than 80 million Americans.
More than 250 entities have filed in support of our proposal. Frontier and Windstream, both of whom offer pay TV video services to hundreds-of-thousands customers, also filed in support, as did several significant coalitions: The Rural Wireless Association; the Center for Rural Strategies; the Schools, Health, Libraries Broadband Coalition; and the American Library Association. We have also filed letters from more than 36 fixed wireless service providers who say that they need access to the C-band spectrum in order to bring broadband service to more customers.
The opposition to our proposal falls into two categories. First, there are large commercial wireless companies who want the FCC to auction not only the 200 megahertz or possibly more spectrum that is cleared for 5G, but also the upper portion of the band that would be left for FSS earth stations. They assert that the FCC should not allow sharing because if small WISPs want the spectrum, they should compete at auction just like them.
Our response to that argument is that large commercial wireless providers care little about bringing more fixed broadband service to rural America and other underserved areas. Auctioning off all of the C-band, when combined with the well-established performance benchmarks that the FCC traditionally imposes (40% of the population in six years; 75% of the population in 12 years) means that rural and low-income communities will not be served for several years, if ever. These types of areas do not have the population or economic demographics to support buildout until urban areas are first served. Furthermore, given the large wireless companies’ need to maximize profit margins, they will likely just use the spectrum to offer commercial mobile broadband services. What people in rural and sparsely populated areas really need is fixed broadband service. Just ask any high school or elementary student how difficult it is to do homework on a smart phone.
Second, some broadcasters have claimed that transitioning FSS earth stations out of the C-band is complicated enough and the FCC should not further complicate that process by introducing new entities and services in the band.
We have two responses to that argument. First, of all the technical issues involved in this proceeding, the least complicated is our sharing proposal, because it has been happening for decades. There are thousands of instances in which fixed point-to-point services are successfully sharing with FSS earth stations both in the C-band and in the adjacent band (3.65 to 3.70 GHz). Second, although WISPA, Google and Microsoft presented a detailed technical study demonstrating that sharing is possible, broadcasters have failed to present any technical evidence to show that allowing point-to-multipoint services in C-band will complicate the band.
So, to wrap up, we understand that clearing spectrum for mobile broadband is getting a lot of attention because of what it means for 5G operators, and what it might mean for the shareholders of C-band satellite operators. Still, WISPA’s proposal is compatible with clearing part of the band. It’s the right policy, it’s easy to execute, it’s supported by a sound technical study, and it’s also supported by folks who work on rural access issues every day.
WISPA’s approximately 800 members are composed of fixed Wireless Internet Service Providers (WISPs) and the industry that supports fixed wireless broadband, including equipment suppliers, support services, and other components needed to run a successful business. Our members, and WISPs, in general, provide broadband access to over 4 million residential and business customers, often in exclusively rural areas.