WASHINGTON — If the U.S. Federal Communications Commission wants a more accurate database of C-band satellite dishes, it should make the process of registering those dishes less expensive and time-consuming, fleet operator SES said Dec. 6.

In a letter recounting a Dec. 4, meeting between Luxembourg-based SES and representatives of the FCC, SES argued that its C-band customers have little incentive to register their dishes, since registration is a voluntary process that can cost over $1,000 per site.

The FCC is pushing for an updated registry of C-band users to better understand how the spectrum is used. That information would feed into an assessment of a large swath of “mid-band spectrum” that includes 3.7 to 4.2 GHz — the chunk of C-band available for satellite operators in the United States.

SES and competitor Intelsat account for more than 90 percent of the C-band spectrum rights over the United States, but lack accurate information on how many dishes their customers have deployed. Both companies say the FCC database’s 4,700 registered dishes vastly under-represents the true number of dishes in use.

Intelsat said Oct. 13 that one of its smaller customers has around 3,000 unlicensed dishes, meaning others have even more outside the FCC’s books. SES, in its letter, said “the American Cable Association has estimated that 90% of its members’ receive earth stations are unregistered, and if this rate is typical of C-band users, there could be more than 30,000 receive-only earth stations in total.”

Along with cost, SES said the only benefit C-band customers — who are typically television broadcasters — gain from registration is protection from subsequent C-band microwave links — a terrestrial telecommunications infrastructure with “extremely limited” use of C-band.

SES said it is trying both to ease the FCC process and encourage its customers to register their dishes.

“For example, SES has suggested that the Commission could undertake a two-step procedure, collecting basic location information first through a simplified online data entry process with no fee and subsequently conducting a more complete antenna registration, but with significant modifications to encourage participation,” SES wrote. “Specifically, SES has argued that the Commission should waive or significantly reduce the registration filing fee and eliminate the coordination requirement for receive-only earth stations.”

C-band customers have a greater motivation to register their dishes now that the FCC is actively considering using the band for fifth-generation (5G) cellphone networks. Mobile network operators have long sought after C-band spectrum to expand their networks, having already gained the lower portion of C-band from 3.4 to 3.6 GHz across most of the world. In the U.S., 3.4 to 3.7 GHz is prioritized for other users, giving domestic mobile operators reason to eye the remaining 500 MHz, and satellite operators a more vehement reason to defend a more limited resource.

SES and other satellite operators say C-band is relied upon heavily for its robustness — something Ku and Ka-band satellites cannot match. Emergency services also often use C-band thanks to the frequency’s ability to penetrate through rain storms.

Satellite operators say they cannot use the same C-band spectrum concurrently with mobile users because the cellular signals are stronger than satellite, drowning out satellite links with insurmountable interference. Intelsat and Intel, in response to the FCC’s mid-band notice of inquiry, submitted a proposal whereby satellite operators would voluntarily clear out portions of C-band in limited geographic areas for mobile 5G networks. Mobile network operators would have to financially compensate satellite operators for relocating customers who were using the needed C-band spectrum, along with other satellite operator expenses.

SES, the ally Intelsat needs most for the proposal, said it is “examining proposals in the record, including the framework suggested by Intelsat and Intel for a market-based solution, as well as brainstorming about other ideas that could preserve satellite access to C-band spectrum for highly reliable programming distribution services while accommodating expanded terrestrial use.”

On Nov. 15, SES said it was open to exploring Intelsat’s plan, but not opening the entire 500 MHz of C-band to mobile users.

“Due to its network design and planning, SES’s center-of-the arc cable neighborhood spacecraft are fully loaded, and SES does not have sufficient alternative C-band capacity elsewhere in its fleet with the 50-state coverage necessary for video distribution customers,” SES said in its Dec. 6 letter.

Fleet operators Eutelsat and Telesat, both of whom have C-band customers in the U.S., are still evaluating the Intelsat-Intel proposal.