The FCC’s GN Docket No. 18-122, involving the expansion of flexible use of the 3.7 GHz-4.2 GHz band, has captured the attention of many radio broadcasters.
Among the groups chiming in on the matter, which focuses on the rollout of 5G wireless technology, is NPR. A NPR presentation filed with the Commission is a chart that shows how, in its view, various C-Band reallocation proposals, including the 5G Plus Plan, would meet the needs of public radio stations that rely on the C-Band to deliver programming.
ACA Connects has something to say about NPR’s chart.
In a letter sent to the FCC on Oct. 10, ACA Connects VP/Regulatory Affairs Brian Hurley states that the chart presented to the Commission by NPR “does not present a complete picture of the 5G Plus Plan’s protections for public radio or how these protections compare with those of alternative plans.”
In fact, Hurley adds “the 5G Plus Plan is comparable or superior to the CBA plan across all of the criteria identified by NPR.”
Among other things, Hurley says, “even as it re-farms 370 megahertz of C-Band spectrum for 5G, the 5G Plus Plan reserves more than sufficient capacity for continued satellite use in the band.”
It does so, he notes, by funding the transition of MVPD traffic to fiber and confining continued satellite use to non-MVPD traffic. “The 5G Plus Plan would also ensure greater protection for all stakeholders, including C-Band users and the satellite operators themselves, making them better than whole,” Hurley asserts.
As an initial matter, NPR’s analysis of the C-Band Alliance (CBA) plan is premised on that plan clearing 200 megahertz of the band for 5G. As Hurley notes, recent reports indicate that the CBA may come forth with a revised plan that reallocates a larger swathe of the band, perhaps as much as 300 megahertz.
“Until the CBA reaches a final conclusion on the amount of spectrum it proposes to be reallocated, and submits into the record its plan for doing so, it is premature to conclude that the CBA’s plan affords sufficient protections for public radio stations or any other class of existing C-Band users,” Hurley says.
ACA Connects also disputes NPR’s contention that the 5G Plus Plan would produce a “smaller more congested band.”
According to Hurley, “Congestion depends not only the amount of spectrum allocated for a particular use but also on the amount of traffic that needs to be delivered through use of that spectrum. Because the 5G Plus Plan contemplates that MVPD operations would vacate the C-Band, other incumbent users could be repacked into a smaller portion of the band without necessarily producing any increase in congestion.”
He concludes, “Protecting existing users of the C-Band is a key tenet of the 5G Plus Plan and a core priority of ACA Connects in any transition of the band … the 5G Plus Plan includes protections for existing users of the band, including public radio stations, that match or exceed those of the alternative plans that NPR analyzes in its presentation.”
To review the letter, in full, please click here.
