<!Congress of tbe mtntteb $tates m.Iasbington, ill<£ 20510 780 October 21, 2019 The Honorable Ajit Pai Chairman Federal Communicati ons Commission 445 12111 Street SW Washington, DC 20554 Dear Chairman Pai: As you consider whether and how to reallocate the C-Band spectrum between 3.7-4.2 GHz for terrestrial '·5G" mobile wireless services, we urge yo u to preserve this spectrum for use in Alaska by maintaining the current al location of the entire band to the Fixed Satellite Service in our state. C-band satellite services prov ide the vital , irreplaceable backbone of communications in remote communities all across our state, including broadband , wireless and wireline voice services, telehealth, distance learning, and other innovative products that rely on the C-Band for backhaul. Alaska compri ses over one sixth of the land area of the entire nation. yet has a population onl y slightly greater than that of the District of Columbia. Outside of Anchorage, Fai rbanks, and Juneau, the state is dotted with scores of small , iso lated, rural and remote Bush communities that lack access to basic infrastructure that is common elsewhere in the nation. These Alaska communiti es are not connected to the state's core road system or power grid, and are frequently separated from one another by vast expanses of road less wilderness or open ocean. The greatest challenge in delivering services in Alaska is a lack of sut1icien t, affordable, terrestrial middle mile connecti vity. C-Band backhaul provides the critical foundation in our state for education, health care, economic opportunity, civic engagement, public safety, and cultural exchange. Yet, sparse populati on, forbiddi ng terrain, and harsh climate conspire to make it technical ly and economically infeasible to deploy scalable terrestrial fiber to serve most Alaska communities. Even where facili ties are built, the challenges of operating and maintaining them make satell ite backup fac ilities essenti al. Seismic acti vity, extreme weather events, ongoi ng freeze-thaw cycles, and other environmental challenges create ever-present ri sks to the network, wh ile transportati on and resource chal lenges may delay repairs for weeks or months. Alaskan operators rel y on the full 500 MHz of the C-Band for the provision of critical and important services. Part of this reli ance is due to the need for full-band , full-arc flexibi lity to efficiently shift frequencies and sate II i tes in the event of a transponder or satelli te failure, changing customer requirements or market competition. ln Alaska, there are no suitable alternatives to the C-Band in rural and remote Alaska at this time. Fiber, alternative satellite bands, and even microwave technology are unable to replicate the C-Band's coverage and capacity, partially due to Alaska's harsh weather, unique topography and land regulation. Simply put, Alaskan operators use the C-Band out of necessity, not convenience. Ex isting use of C-Band in Alaska is efficient, effective, and innovative. In fact, no reallocation of any C-Band spectrum to te1Tes trial mobile use in Alaska is necessary to ensure sufficient spectrum to support terrestrial mobile services in Alaska or upgrades of such systems, including to 5G, for the foreseeable future. The large cities of the lower 48 states are far larger and more densely populated than Anchorage, creating a very different balance of public interest considerations for the use of this spectrum. This difference is reflected in the record compiled by the Commission in ON Docket No. I 8-122, which strongly favors retaining C-band spectrum for services in Alaska. The solution to the C-Band puzzle in Alaska does not require moving incumbent services into a smaller portion of the band, or onto a different means of transmission. Rather, the critical services provided over the C-Band in Alaska, coupled w ith the unique Alaskan considerations when it comes to serving rural and remote customers, support ensuring the continuity of C-Band operations in Alaska. Such a solution should involve excluding the State of Alaska from any changes to the allocation of or services provided via the C-Band, including point-to-multipoint sharing, and incorporating the following protections for the current and future C-Band operations of incumbents: (1) commitments from satellite operators and MVPD programmers alike to maintain the status quo of Alaskan C-Band operations; (2) assurances of protections from interference; and (3) reimbursement to Alaska earth station operators for any impacts to their operations as a result of the reallocation of the C-Band services, regardless of whether that occurs exclusively in the Lower 48. We thank you for the International Bureau's recent grant of several appli cations to license C-band satellite earth stations to serve rural and remote communities in Alaska. In order to preserve the benefits that these and other future C-band earth stations bring to the communities they serve, we ask that you retain the entire current all ocation of this spectrum for Fixed Satellite Services in A laska. Sincerely, Dan Sullivan United States Senator Cc: Honorable Michael O'Rielly Honorable Brendan Carr Honorable Jessica Rosenworcel Honorable Geoffrey Starks