FCC Seeks Additional Comment in the 3.7-4.2 GHz Band

Updated: Jul 31, 2019

On July 19, 2019, the WTB, IB, OET and OEA (the “Bureaus”) released a Public Notice seeking additional comment in the C-Band proceeding on new auction-based approaches and repurposing methodologies (GN Docket No. 18-122). Specifically, the Commission seeks additional focused comment on recent filings by: (1) ACA Connects – America’s Communications Association (ACA Connects), the Competitive Carriers Association (CCA), Charter Communications, Inc. (Charter) (collectively, ACA Connects Coalition); (2) AT&T; and (3) the Wireless Internet Providers Association (WISPA), Google, and Microsoft. Comments are due August 7, 2019, and reply comments are due August 14, 2019.

The ACA Connects Coalition proposal consists of three key elements that would make 370 megahertz of C-band spectrum available for flexible wireless use on a nationwide basis: (1) a Commission-driven auction that would award new terrestrial licenses and assign obligations for transition costs; (2) a plan to transition certain Fixed Satellite Service earth station operators to fiber; and (3) a plan for satellite operators to repack remaining earth station users to the upper portion of the band.

The AT&T proposal recommends dividing the 3.7-4.2 GHz band into three segments: (1) a largely unrestricted mobile terrestrial 5G segment in the bottom of the band (“Unrestricted Licenses”); (2) “Adjacent Licenses” in the middle of the band that would have to coordinate with or mitigate impact on Fixed Satellite Service; and (3) remaining Fixed Satellite Service spectrum in the top of the band.

WISPA, Google, and Microsoft filed a study conducted by Reed Engineering, which analyzed Fixed Satellite Service and fixed wireless point-to-multipoint co-channel coexistence in the 3.7-4.2 GHz band. Among other conclusions, the Reed Study suggests that exclusion zones of about 10 kilometers are sufficient to protect most Fixed Satellite Service earth stations from harmful interference caused by properly-engineered co-channel point-to-multipoint broadband systems. The propagation model used in the study relied on Fixed Satellite Service earth station characteristics that require them to point upwards towards the geostationary satellite arc. Thus, the earth stations are specifically designed to mitigate their response to signals arriving from the horizon, such as terrestrial point-to-multipoint links. Additionally, the study relied on the directional nature of fixed service antennas and clutter to assume reduced emissions at earth stations. The Bureaus seeks comment on the technical issues this study raised.

The Bureaus ask specific questions about each proposal or study, and seek general comment on next steps.

Please Contact Us if you have any questions.

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