UPDATE The C-Band Alliance (CBA) urged the FCC to fairly allocate incentive payments for satellite companies that clear the lower portion of the C-band by certain deadlines. The CBA is a consortium of global satellite operators that they say provides the majority of 3.7-4.2 GHz (C-Band) services in the U.S. The CBA has three members, Intelsat US LLC, SES Americom, Inc. and Telesat Canada.
The CBA told the agency its members have developed “a fair and non-discriminatory methodology” to divvy up the payments.
Specifically, the CBA proposes an allocation based on the effort required to clear spectrum, which it say “is very closely tied to use of C-band downlink over CONUS.”
As a proxy or methodology for determining use, the CBA previously suggested an allocation based on 2017 CONUS downlink revenue, which would lead to a share of 95.94 percent for the members of the CBA. More recently, the CBA proposed an allocation based on the number of earth station C-band feeds in CONUS.
The CBA collected detailed information on the large and statistically significant sample of 9,756 FCC-registered earth station sites representing more than 25,000 antennas. Based on this information, the CBA estimates that approximately 99 percent of earth station C-band feeds in CONUS point to a CBA-member satellite; approximately 1 percent point to a Eutelsat satellite; and between 0 percent and 0.1 percent point to an SSO satellite.
CBA called other allocation methodologies proposed in the record “grossly unfair.” It singled out former CBA member Eutelsat’s proposal that “suggests assigning equal value to all satellite capacity” that touches CONUS.
“Eutelsat’s methodology would result in extraordinary compensation for the satellite companies that have the least amount of work to do. [A]nd anemic compensation for the satellite companies that will be required to do the most work to accelerate the transition,” contended CBA. “Fundamentally, the premium methodology Eutelsat proposes rewards operators for behavior that does not support the overall mission of the proceeding, making C-Band spectrum available for 5G use, because 5G cannot be deployed until ALL operators have cleared the band.”
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