Washington - Dish Network presented its case to the government that it should be able to repurpose its 2GHz satellite spectrum for terrestrial wireless broadband, but the satellite-TV provider asked the Federal Communications Commission (FCC) in a filing to relax its proposed rollout schedule.
The FCC wants Dish to offer service to 30 percent of the population in three years of approval and offer service to 70 percent of the population within seven years of approval. Dish is seeking approval for a four-year interim build-out with a four-year target of reaching 60 million people with service, or about 20 percent of the U.S. population based on the 2010 U.S. Census.
Dish's proposal would push back the FCC's interim service goal into late 2016 at the earliest.
Dish also wants the final seven-year build-out requirement to be scaled back to markets with a population of 200 million people, or about 65 percent of the 2010 U.S. population, from the FCC's proposed 70 percent of the population.
Dish requested service goals by numerical population rather than by percent of population because a percentage would use "a figure potentially subject to interpretation," the company noted.
Even with the extra year for an interim build-out, "a more stringent interim build-out requirement on new licensees has never been imposed by the commission and successfully met by new [mobile wireless] licensees," the company said.
In its filing, Dish said that in order for it to "succeed over the long term, Dish must expand beyond offering linear video-distribution services and provide consumers with bundles that include fixed as well as mobile video, voice and data." In making its case that it is capable of building a terrestrial network, the company said its "knowledge and expertise in the satellite industry will allow it to further maximize the potential of the MSS (mobile satellite service) assets it has acquired from DBSD and TerreStar. And the commission's proposal to modify Dish 2GHz licenses to allow terrestrial use under new [service] rules will help Dish efficiently and competitively enter the market to maximize the use of the S-band for mobile video, voice and broadband services for American consumers."
Dish made its comments as part of the commission's proposed rulemaking to repurpose the satellite spectrum for terrestrial wireless broadband. Initial comments on the proceeding were due May 17. Replies are due June 1. The commission will rule sometime after June 1.
In its comments, Dish noted that a final build-out requirement of 70 percent is more than what was required of PCS-band licensees, who had 10 years to cover two-thirds of the population. The three-year interim build-out proposed by the FCC "may require inefficient use of technology or infrastructure to satisfy a regulatory requirement as opposed to the more scalable and long-term investments needed to launch a robust, competitive offering," the company claimed.
Dish explained that it wants to launch with LTE-Advanced, a faster version of the LTE technologies being deployed by cellular carriers. Dish also pointed out that it is working with a world standardization body to modify the standard for FCC service rules and S-band satellite spectrum. That work won't be complete until December 2012, the company said, and it will take four years from that time to meet the interim build-out goal "due to the complexity of creating a new, differentiated product in a new and technically constrained band, and the requirement for sequential development of chipsets and commercial devices."
It will take four years to develop infrastructure and end-user devices, service and billing systems to support new mobile broadband services, develop support systems to meet regulatory requirements such as E-911, build network operations centers, deploy S-Band cell sites in trial markets, negotiate interconnection and backhaul agreements, obtain IP addresses and telephone numbers, and implement other measures, the company claimed. .
Dish also proposed less stringent penalties for not meeting the build-out goals, including monetary penalties in other actions instead of license forfeiture. Other proposed changes are technical in nature.