Yesterday the Federal Communications Commission gave notice of DISH Network Corporation’s (DISH) ex-parte meeting with some FCC staff members. DISH wanted to reiterate its position on the implementation of AWS-4 rules; arguing that it was urgent that the FCC provide the industry with some regulatory certainty given the billions of dollars DISH has invested in obtaining spectrum.
Specifically, DISH invested in obtaining 40MHz of spectrum in the S-band. The company is concerned that if the FCC allows a 5MHz upward shift in the 2000 to 2020 MHz range, DISH would face technical and regulatory obstacles that would negatively impact its ability to deploy facilities in the S-band.
According to DISH, “Specifically, a 5 MHz shift would disserve the public interest for at least the following reasons:
It would introduce substantial delay and risk into the standard-setting process, which in
turn would further delay – if not possibly scuttle – DISH’s planned deployment.2
It would significantly undermine the usefulness of DISH’s 2 GHz satellites by limiting
the spectrum available for mobile satellite service (“MSS”).
It would reduce the internationally harmonized spectrum to only 5 MHz in the uplink
band, limiting opportunities for global MSS roaming and global economies of scale.
It would expose AWS-4 base stations to potential interference from federal and Broadcast
Auxiliary Station (“BAS”) operations above 2025 MHz. “
You can read DISH’s ex-parte letter here.