On February 28, 2020, the FCC adopted a Report and Order that established an accelerated timeframe for eligible satellite operators to clear services from the lower C-band spectrum (3700-4000 MHz) in the contiguous United States. While we have provided some details about the Report and Order in these responses, we recommend that you review the Report and Order.
1. What are the accelerated clearing deadlines?
- December 5, 2021: “Phase I deadline” – The lower 120 MHz of spectrum must be cleared and filters distributed to allow terrestrial service in 46 of the top 50 PEAs (Partial Economic Area, similar to a metropolitan area)
- December 5, 2023: “Phase II deadline” – Full CONUS clearing of the lower 300 MHz of spectrum for accelerated relocation payment
- December 5, 2025: “Relocation Deadline” – Satellite operator “sunset” (i.e., loss of primary protection and right to relocation costs)
2. Can I continue receiving C-band services in the 3.7-4.0 GHz band after the December 5, 2025 deadline or accelerated clearing deadlines within CONUS at my own risk of interference from 3.7 GHz Services?
No. Regulations prohibit the transmission of C-band satellite services in the 3700-4000 MHz band for purpose of receipt within CONUS after the afore-mentioned deadlines.
3. How can an earth station operator confirm that its earth station is an Incumbent Earth Station?
An earth station operator should consult with the FCC to confirm if its earth station is an Incumbent Earth Station. The FCC is expected to post a list of all Incumbent Earth Stations by late Summer 2020, with a period afterwards for comment. But, before that, an earth station operator can search in the FCC’s database (IBFS) or contact the FCC directly to determine if its earth station(s) are Incumbent Earth Stations.
4. How can an Incumbent Earth Station operator determine if its Incumbent Earth Station is going to be part of Phase I?
SES will indicate in its Transition Plan (to be submitted to the FCC on June 12th) which Incumbent Earth Stations accessing SES satellites will require Passband Filters in Phase I and Phase II.
5. What are the benefits of being an Incumbent Earth Station?
- Cost reimbursement: The FCC allows for reasonable and actual costs to be reimbursed through the Relocation Reimbursement Clearinghouse for all Incumbent Earth Stations.
- Protection from 3.7 GHz Service interference: The FCC has defined technical rules for 3.7 GHz Service licensees that include maximum power flux density (PFD) levels at Incumbent Earth Station locations. The combination of passband filters and maximum PFD levels reduce the risk of harmful interference from 3.7 GHz Service emissions into Incumbent Earth Stations. The requirements are set out in Sections 27.50, 27.53, and 27.55
- SES will include a listing of Incumbent Earth Stations accessing SES satellites in the SES Transition Plan, which may be adjusted based on an official list from the FCC.
6. What does it mean that an Incumbent Earth Station can take a lump sum as determined by the FCC?
The Order provides for Incumbent Earth Stations to elect a lump sum payment equal to the estimated reasonable transition costs of earth station migration and filtering, as determined by the Wireless Telecommunications Bureau, in lieu of actual relocation costs. If an Incumbent Earth Station operator elects the lump sum payment, it is responsible for coordinating with the relevant space station operator as necessary and performing all relocation actions on its own, including switching to alternative transmission mechanisms such as fiber, and it will not receive further reimbursement for any costs exceeding the lump sum payment. It must also inform the appropriate space station operator(s) and the Relocation Coordinator that earth station migration and filtering will not be necessary for the relevant earth station site and must coordinate with operators to avoid any disruption of video and radio programming.
7. What is the amount of the lump sum?
The lump sum amount has not yet been provided by the FCC. At this point it is unclear as to the amount and the timing of the FCC’s notification of it.
8. What happens if an Incumbent Earth Station elects a lump sum?
If an Incumbent Earth Station chooses a lump sum, it must choose the same option for all earth stations that it has registered. For example, if a major cable operator chooses a lump sum for its main earth station, it must also choose a lump sum for all its registered earth stations, regardless of size, location, etc.
In addition, the Responsible Satellite Operator(s) responsible for service to that site is no longer responsible for transitioning that Incumbent Earth Station site by the accelerated clearing deadlines. Any Incumbent Earth Station that is subject to the lump sum election can be deemed as transitioned by the Responsible Satellite Operator.
9. What happens if an Incumbent Earth Station does not elect a lump sum?
If an Incumbent Earth Station does not elect the lump sum option with the FCC, then one or more of the Space Station Operators must provide and install needed equipment at the earth station to ensure a smooth transition for that site to receive only in the 3820-4200 MHz band for those earth stations included in Phase I and in the 4000-4200 MHz band for all stations at the end of Phase II.
SES itself is responsible for providing and installing needed equipment at any Incumbent Earth Station that has an antenna pointed to one or more SES satellites and did NOT choose the lump sum payment. Until an Incumbent Earth Station has the ability to choose a lump sum reimbursement, the Incumbent Earth Station operator will be included in the SES Transition Plan.
10. What is SES’s transition/implementation process?
While the specific details of SES’s transition/implementation process are still being defined and will be submitted to the FCC on June 12, 2020, here is an overview of the general process:
- SES receives a list of the Incumbent Earth Stations either from a customer’s affiliate list or from the FCC’s IBFS database, which is currently being finalized by the FCC and will likely become official in Q3 2020.
- Every Incumbent Earth Station will initially be contacted by an outreach vendor (currently Superior Satellite Engineers and ATCi (a subsidiary of Evertz Microsystems, Ltd)) to confirm general earth station information.
- Incumbent Earth Stations who elect a lump sum payment will be removed from the list.
- The outreach will also determine equipment required for the transition (antenna equipment, filters, etc.) depending on the needs of the site in accordance with SES’s customer transitions. This will include a determination if the site requires a new antenna to access a satellite that the site does not currently access. It will also include a determination of the number of antennas at the site accessing SES satellites, which will define the number of Passband Filters that must be installed to minimize interference from 3.7 GHz Service emissions.
- All filters will be purchased by SES, held in a warehouse, and shipped out to the Incumbent Earth Station or to the SES-hired installer.
- The SES-hired installation teams will call the Incumbent Earth Station operator to schedule a time window to install equipment, based on SES’s transition plan. For example, all MVPDs will most likely be scheduled within the last 6 months of the Phase I and Phase II clearing timelines since most MVPDs will require access to several satellites and all transitions on those satellites will need to be completed before any filters are installed. On the other hand, some Incumbent Earth Stations such as those that only need access to one satellite may be able to accommodate the installation of filters at any time.
11. Will all Incumbent Earth Stations receive technology upgrades to assist them with receiving signals that have been compressed on the satellite?
No. Only earth stations that are affiliates of an SES customer receiving necessary technology upgrades (such as compression) for their uplink to the satellite will receive the corresponding earth station equipment upgrade (such as integrated satellite receiver/decoders). At this time, SES does not believe there will be many required technology upgrades so the number of Incumbent Earth Stations receiving the technology upgrade equipment will be limited. The impacted customers and affiliated earth stations will be contacted in the case that extra equipment will be required as part of the transition.
12. How are Earth Station on Vessels (ESVs) affected by the Order?
As set forth in Appendix A – § 2.106 Table of Frequency Allocations of the Order, the allowable reception in the 3700-4200 MHz is as follows:
- When in port and docked within CONUS, an ESV can operate in the 4000-4200 MHz band and have protected status via frequency coordination.
- When in port and not coordinated or when at sail, ESVs are authorized to operate in the 3700-4200 MHz band but without protected status. Note that if a passband filter is in use on the ESV, it will preclude the reception of services below the passband cutoff frequency.
Note that the use of a passband filter may reduce the effect of interference from 3.7 GHz Services on received satellite signals in the 4000-4200 MHz band.
13. Can I use any filter advertised as a “5G filter”?
These are not recommended for antennas pointed to SES satellites. SES plans to provide Passband Filters – built and tested to SES specifications and meeting FCC requirements as set forth in the Order – to all antennas at an Incumbent Earth Station location accessing SES satellites that have not opted for the lump sum payment. Frequencies used outside of the CONUS for 5G deployments in the C-band may be different than those used in CONUS; therefore, the filter specifications may not be adequate for CONUS.
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