October 31, 2018

ACA To FCC: Missteps In C-Band Proceeding Would Harm Millions Of Pay-TV Consumers

Agency Must Balance Vital Interests Of Incumbents In Effort To Expand Use Of Airwaves

For Immediate Release
Contact: Ted Hearn
(202) 713-0826
[email protected]

 

PITTSBURGH, October 31, 2018 – The American Cable Association welcomes the Federal Communications Commission’s initiative for the potential expanded uses of the C-Band, but the national communications regulator should proceed carefully in light of what is at stake: Disrupting video content to millions of Americans, especially in rural areas, and harming thousands of small businesses in the process.

The C-Band is a spectrum allocation responsible for ensuring that satellite providers can beam 2,000 cable TV channels to thousands of cable TV headends located around the country – signals that are then redistributed to millions of pay-TV customers. Thus, the C-Band has been, and remains, nothing less than vitally important for ACA members, which should explain why they want the FCC to protect their spectrum incumbency in the effort to determine if the C-Band can be also utilized by 5G mobile communications service providers and others.

“Diminution of satellite operations across the C-Band would have a hugely disruptive impact on the video programming distribution industry, and ACA members in particular, that rely in many cases exclusively on the C-Band to deliver programming content to their customers, as many are concentrated in rural America where fiber delivery is not available,” ACA President and CEO Matthew M. Polka said.

The potential of major disruption is no exaggeration, ACA explained in comments filed Monday with the FCC in connection with proposals related to alternative uses of the C-Band. For the hundreds of operators using many thousands of earth stations, both registered and unregistered, a spectrum reallocation would, if compounded by a reduction in interference protection, result in dramatic shortages of backhaul capacity. It could completely vitiate the competitive choices that programmers have today for delivering their programming to the headends of multichannel video programming distributors (MVPDs). And that would be the best-case scenario.

Under the worst-case scenario, the MVPD and video programming industries would be uprooted and forced to migrate to new modes of delivery at a cost that would run into the billions, if not tens of billions, of dollars. Ejecting or diminishing video backhaul from the C-Band would also deal a serious blow to the cause of advanced television, at a time when the bandwidth requirements for the delivery of programming are on the cusp of a steep increase.

As a result, ACA took care to outline a number of recommendations that the FCC should embrace, including:

• Refraining from “sandwiching” satellite backhauls between two potential incompatible uses;
• Appointing an independent engineering expert to assess questions presented by out-of-band emissions from 5G and in-band sharing with Fixed Service, in recognition that the two main C-Band satellite licensees have a legitimate interest both in protecting satellite service and in “monetizing” the spectrum for 5G;
• Exploring the use of incentive auctions, if the FCC decides to reallocate the lower end of the spectrum; and
• Compensating not only satellite companies for any reallocation but also users of the C-Band, including for costs associated with higher backhaul prices as well as harm to rural distributors’ ability to compete.

About the American Cable Association: Based in Pittsburgh, the American Cable Association is a trade organization representing more than 700 smaller and medium-sized, independent companies that provide broadband, phone and video services to nearly 8 million customers primarily located in rural and smaller suburban markets across America. Through active participation in the regulatory and legislative process in Washington, D.C., ACA’s members work together to advance the interests of their customers and ensure the future competitiveness and viability of their business. For more information, visit: https://acaconnects.org/

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