Satellite Industry Seeks Changes to Part 2 and Part 25 Rules Revisions Plan

ITU rules set up the regulatory status between geostationary orbit (GSO) fixed satellite service and broadcasting satellite service networks and are "the internationally accepted framework that applies between GSO and NGSO systems" until other rules are adopted in a specific band, Inmarsat said. It sought replacement of part of Section 25 rules with ITU's 22.2 default sharing rule.

Telesat Canada called the FCC's current 10-degree avoidance angle rule "inappropriate as a technical matter" since the angle needed to prevent harmful interference will depend on the design of each system and the relative locations of satellites and ground stations. It said a "share during in-line events" rule wouldn't work because of the volume of sensitive data operators would have to exchange in real time, because of the uncertainty operators would be left with on the availability of inference-free spectrum, and because the frequency and duration of those in-line events could essentially turn a "share" rule into band segmentation. Instead, NGSO fixed satellite services systems should coordinate using ITU rules, it suggested, saying FCC rules for NGSO and GSO FSS systems overall should be harmonized with the ITU.

Rather than limit FSS earth stations in the 17.8-18.3 GHz band to secondary basis, individually licensed earth stations should be allowed to operate on a co-primary basis in the band with fixed services, Intelsat said. The FCC should consider opening the 19.4-19.6 and 29.1-29.25 GHz bands to GSO FSS operations as long as they coordinate with Iridium, which operates feeder links in those bands. Intelsat also said it doesn't object to the NPRM's proposal of letting GSO FSS operations in the 18.8-19.3 GHz downlink band on a secondary basis -- which would run contrary to an ITU allocation -- as long as that doesn't undermine its own primary use of the band internationally.

Iridium said it doesn't oppose the proposal to let new FSS operations in the 19 GHz and 29 GHz sub bands, but it uses those sub-bands for gateways, and coordination there has become increasingly difficult with the growth of GSO FSS activity. Iridium said the NPRM proposal would put additional strain on Iridium feeder link operations and the FCC should "give appropriate weight to these pressures" to ensure those feeder links are protected.

Along with making the 19.4-19.6 GHz and 29.1-29.25 GHz band segments more widely available to GSO FSS operators, ViaSat said the FCC also should consider means of managing NGSO interference into GSO systems. The company warned that rules on avoidance of in-line interference could have unintended consequences. For example, limiting NGSO operations and relaxing the milestone requirement could constrain smaller NGSO system capacity and coverage.

Lockheed Martin backed many NPRM proposals and said it generally supports the 75 percent milestone, but applicants should have the flexibility to show they can provide meaningful service at some lower percentage of their constellation being operational, such as 50 percent. Kepler Communications said that when looking at milestones the FCC needs to differentiate between big operators launching all satellites concurrently and smaller operations entering the market over time. For nanosat constellations, it proposed a tiered approach of bonds.

Along with allocating additional spectrum to NGSO FSS in the 17.8-18.3 GHz, 18.3-18.6 GHz and 19.7-20.2 GHz bands, the FCC also should adopt co-primary status for NGSO FSS gateway earth stations for terrestrial services, OneWeb said. The company said there should be a codification of in-line interference avoidance, but FCC guidelines should mirror the ITU rule "rather than retaining the overly restrictive current rule." The company is combining with Intelsat (see 1702280057).