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In its order setting forth a process for reallocating a portion of the C-band, the Federal Communications Commission (FCC) established that only registered earth stations would be eligible for protection from harmful interference caused by new wireless operators in the band. The FCC required earth station operators to register all C-band antennas individually - including those antennas at collocated sites. Some operators may not have registered all earth stations at a given site, and instead registered only a single earth station.

In an effort to provide some relief to broadcasters who may not have understood the requirement to register each individual earth station, NAB asked the FCC to provide a limited opportunity to register additional dishes located within 150 meters of a registered dish, with a cap of 25 additional antennas at each site. Such registrations would not make these additional dishes eligible for reimbursement of relocation expenses, but would make additional dishes eligible for protection against harmful interference.

On September 16, the FCC released a Public Notice announcing a brief window for operators with multiple additional antennas at a site with only one registered earth station to register those additional antennas. Broadcasters needing to register additional antennas at sites with only one registered dish must file a request for a waiver at the FCC no later than September 25. Specific instructions are included in the Public Notice. Briefly, broadcasters seeking a waiver should include specific information on the additional antennas needing protection, including the following:

  • Whether the antenna would have been eligible for incumbent protection when the filing window closed on November 7, 2018;
  • Whether the request involves a site or facility with one or more incumbent earth stations in the 3.7-4.2 GHz band (providing the specific Callsign, SiteID and AntID of the incumbent earth station(s));
  • How far away the additional antennas are from an incumbent earth station (providing the specific Callsign, SiteID, AntID and GPS coordinates of each antenna);
  • How many additional antennas per registrant at any given site; and
  • Whether grant of the waiver would require reimbursement of additional relocation expenses to the applicant.

We strongly urge applicants to include all of this information in their requests - in particular specific distance calculations based on the GPS coordinates of the currently registered earth station and the GPS coordinates of each new antenna. Inclusion of this information will significantly aid the FCC staff in processing the requests and will increase the chances of the waiver request being expeditiously granted.

Please contact the NAB Legal department at (866) 682-0276 with any questions.