Daily Ex Parte, Aug 28, 2025
Upper C-Band (25-59), Spectrum for Utilities & Other Critical Infrastructure Industries (CII)
Filers
Synamedia Ltd. — How its technologies can help the Commission meet its congressional mandate to auction at least 100 MHz of Upper C-band spectrum.
Utility Broadband Alliance — Advocates for greater access to broadband spectrum for utilities and other critical infrastructure industries (CII).
Synamedia Ltd.
Proceeding(s): 25-59
Date of Meeting: August 25, 2025
Date Disseminated: August 27, 2025
Participants: Representatives of Synamedia Ltd. and its majority owner, Permira Advisors LLC (collectively referred to as Synamedia), held two separate meetings with FCC officials.
Synamedia Ltd. was represented by Paul Segre, Edward Allfrey, and Kenelm Deen.
Permira Advisors LLC was represented by Nic Volpi.
Also attending on behalf of Synamedia were their advisor, Christophe De Hauwer of Moonshot Consult, and outside counsel from Milbank LLP: Patrick S. Campbell and Darren Fernandez.
They met with:
Commissioner Olivia Trusty and her legal advisor, William Holloway.
Jay Schwarz (Bureau Chief) and Kerry Murray (Deputy Chief and Chief of Staff) of the Space Bureau.
Summary of Discussion: Synamedia met with FCC officials to discuss the Notice of Inquiry regarding making spectrum in the Upper C-band (3.98 GHz – 4.2 GHz) available for more intensive use, referred to as the "Upper C-band Clearing" (GN Docket No. 25-59).
Synamedia expressed support for the proceeding and outlined how its technologies can help the Commission meet its congressional mandate to auction at least 100 MHz of the Upper C-band spectrum. They emphasized that clearing this band presents greater technological challenges than the previous Lower C-band clearing, as the Upper C-band is now much more heavily utilized.
To overcome these challenges, Synamedia argued that the Commission must use a broader range of solutions and, critically, ensure that satellite operators are "in the driver's seat" of the transition, similar to their role in the Lower C-band clearing. Synamedia positioned itself as a key technology partner, ready to deploy its advanced compression and IP terrestrial solutions to assist satellite operators and their customers in this process, ensuring incumbent services are protected from interference or degradation.
Key technological solutions proposed by Synamedia include:
Advanced Compression:
Synamedia can deploy state-of-the-art compression technology that reduces the bandwidth required for existing video channels without any loss of visual quality.
They estimate that migrating all services to this new compression technology, combined with existing satellite capacity, could free up 100 MHz of spectrum.
This compression efficiency would also benefit terrestrial IP distribution by reducing necessary transmission bandwidth.
IP Terrestrial Solutions:
Synamedia's technology can facilitate the migration of video services to a hybrid satellite/terrestrial distribution model.
Their solutions currently support video distribution over fiber, internet, and satellite networks.
To ensure service reliability, customers can use Synamedia's technology to combine multiple transmission paths (e.g., satellite and IP), creating greater resilience.
Synamedia asserted that, based on terrestrial connectivity, its solutions could enable the clearing of the entire Upper C-band in urban areas at a minimum.
Source: [NOTICE OF EXPARTE, Synamedia Ltd., https://www.fcc.gov/ecfs/document/10827013216844/1]
Utility Broadband Alliance
Proceeding(s): 24-99, RM-11977, 25-178
Date of Meeting: August 25, 2025
Date Disseminated: August 28, 2025
Participants:
From the Utility Broadband Alliance (UBBA) and its allies:
Bobbi Harris, Executive Director, Utility Broadband Alliance (UBBA)
Paul Anuszkiewicz, Secretary, UBBA
Holly Henderson, Southern Communications Services, Inc. d/b/a Southern Linc
David Rines, Lerman Senter PLLC
From the Federal Communications Commission (FCC):
Staff of the Wireless Telecommunications Bureau, including: Susannah Larson, Stacy Ferraro, Roger Noel, Stephanie Asous, Alice Koethe, Morgan Mendenhall, Kambiz Rahnavardy, Thomas Reed, Nina Shafran, and Joshua Smith.
Summary of Discussion:
Representatives from the Utility Broadband Alliance (UBBA), Southern Linc, and Lerman Senter PLLC met with staff from the FCC's Wireless Bureau to advocate for greater access to broadband spectrum for utilities and other critical infrastructure industries (CII).
The UBBA delegation began by clarifying that for utilities, "broadband" refers not to high-speed consumer internet, but to a foundational network technology essential for modernizing the electric grid. They argued that utilities require dedicated, private communications networks to manage increasing data volumes, ensure low latency for real-time grid control, provide comprehensive coverage across service areas, and maintain high levels of security and reliability. The delegation stressed that private networks allow utilities to implement robust cybersecurity measures, including the ability to "island" their systems from the public internet during a large-scale cyberattack.
To illustrate the need, UBBA provided several use cases that private broadband spectrum enables:
Enhanced Advanced Metering Infrastructure (AMI) and SCADA systems.
Wildfire prevention through "Falling Conductor Protection" solutions that de-energize broken power lines before they hit the ground.
Video surveillance of critical assets like substations and generation facilities.
Advanced load balancing applications to manage the anticipated surge in electricity demand.
The central argument of the presentation was that the amount of broadband spectrum currently available to utilities is insufficient to meet present and future operational needs. While acknowledging the success of the 3/3 MHz broadband segment in the 900 MHz band, UBBA asserted that more spectrum options are required to support expanding use cases and new technologies. They also emphasized the importance of aligning this spectrum with globally harmonized 3GPP standards to foster a larger equipment ecosystem, reduce costs, and promote innovation.
The delegation detailed significant challenges utilities face in acquiring spectrum:
Spectrum Auctions: These are generally not a viable option because the geographic license areas are often too large and do not align with utility service territories.
Secondary Market Transactions: While the necessary alternative, this path presents major hurdles.
Regulatory Uncertainty and Time: Utilities are regulated entities that must obtain state approval for capital expenditures. The lengthy process of building a "greenfield" network—from spectrum valuation and acquisition to network design, permitting, and construction—is often at odds with FCC rules.
FCC Rule Conflicts: The "permanent discontinuance" rule and license renewal coverage requirements often do not provide enough time to complete a new network buildout. The option to request waivers lacks the certainty required by state regulators to approve the significant investments needed.
Based on these challenges, UBBA urged the FCC to take action in two specific, open proceedings:
WT Docket No. 24-99 / RM-11977 (900 MHz Band): UBBA reiterated its strong support for expanding the broadband segment in the 900 MHz band to a 5/5 megahertz configuration, emphasizing that protections for incumbent and adjacent-band operations remain a key priority.
WT Docket No. 25-178 (T-Mobile/Grain Transaction): UBBA expressed support for the pending license assignment applications between T-Mobile USA, Inc. and Grain Management, LLC, as they could provide utilities with access to critical licensed spectrum. However, this support is contingent upon the FCC granting the parties' requests for waivers of the permanent discontinuance rule and associated coverage and renewal requirements, which UBBA considers essential for making the spectrum usable for utility network deployments.
Source: [NOTICE OF EXPARTE, Utility Broadband Alliance, https://www.fcc.gov/ecfs/document/1082786286653/1]