Milestones, V-band Plans See Jousting in Satellite Rules Update Debate

Operators should be able to designate their own milestone thresholds for the number of satellites that reasonably constitutes the initial constellation that needs to be launched within six years, Boeing said in a docket 16-408 filing posted Tuesday. SES and O3b pushed for requiring 33 percent of a proposed constellation to be launched and operational at the six-year mark, and 75 percent by nine years. OneWeb said the current NGSO milestone criteria of an entire constellation up within six years will "deter speculative applications and spectrum warehousing," while allowing only a portion of a constellation "would be procedurally unmanageable." SpaceX backed a lesser penalty than license revocation for not meeting a terminal milestone date, such as capping the size of an NGSO constellation at the level reached by that date.

Making multiple criticisms of the NPRM, ViaSat said SpaceX, Boeing and O3b -- all with pending Ka- and V-band constellation applications -- are trying to use the Part 2 and 25 rules changes proceeding "to provide cover" for those applications that don't meet FCC requirements. It said the FCC should dismiss all pending NGSO applications and start new Ka- and V-band processing rounds after the Part 2 and 25 rules proceeding is complete. They didn't comment.

NGSO FSS operators that apply to deploy V- or Q-band constellations after the completion of the Boeing processing round (see 1703020036) should get equal status with applications that already were filed in that processing round, LeoSat said. It said the requirement to protect operators authorized in an earlier processing round, as the FCC has done for Ka- and Ku-band NGSO operators, isn't appropriate for the V- and Q-bands since the technology there is still nascent.

Satellite operators sought additional spectrum for NGSO. OneWeb said it would back a co-primary GSO allocation in the 18.8-19.3 GHz and 28.6-29.1 GHz bands if NGSOs receive some protection. SES/O3b backed adding fixed satellites spectrum in the 17.8-20.2 GHz and 29.3-29.5 GHz bands, and said the FCC should allow NGSO and GSO FSS access to the 17.8-18.3 GHz band on a co-primary basis with fixed service. They pushed for FSS access to the 19.4-19.6 GHz band and the 29.1-29.25 GHz bands and NGSO FSS access to the 29.25-29.3 GHz band, cautioning against allowing GSO FSS operations on a co-primary basis with NGSO FSS operations in the 18.8-19.3 GHz or 28.6-29.1 GHz bands. Boeing urged allowing earth station operations in the 17.8-18.3 GHz band on a secondary basis, NGSO FSS system operations on a secondary basis to GSO FSS in the 18.3-18.6 and 19.7-20.2 GHz bands, and GSO FSS operations in the 18.8-19.3 GHz band on a secondary basis to NGSO FSS. EchoStar and Hughes Network Systems said NGSO and GSO FSS operations are due for co-primary status in the 18.8-19.3 GHz and 28.6-29.1 GHz bands, with it being already standard practice internationally. They said GSO and NGSO operations should be allowed in the 19.3-19.4 GHz, 19.6-19.7 GHz and 29.3-29.5 GHz bands as long as the NGSO systems operate on an unprotected, non-interference basis with the GSOs.

Warning of an "upset ... balance" between fixed and mobile satellite services, Iridium's filing was critical of any expansion of FSS operations in the 29.25-29.3 GHz band it uses for feeder links, saying that would be beyond the scope of the proceeding.

Operators also opposed the FCC adopting the ITU default rule that bans NGSO FSS systems from causing unacceptable interference with GSOs. Inmarsat said running an international satellite system while complying "with disparate, location-specific regulations is burdensome ... and provides no clear benefit." SES/O3b said there's wide support for default procedures rather than band splitting to avoid in-line interference among NGSO FSS systems, but the FCC should avoid using ITU date priority to avoid in-line interference.

There also was disagreement over changing the in-line event trigger. LeoSat backed a narrower angle of 2-3 percent, but ViaSat said any narrowing would necessitate some substitute mechanism for mitigating interference possibilities, which could then unduly hamper network operators. SpaceX said it had backed keeping the existing 10 degree trigger angle, but it agreed with some other operators that a narrower angle could work for higher frequency bands.

Until more NGSO fixed satellite service (FSS) systems are operational and more is known about their actual operating characteristics, the FCC should delay major changes to rules protecting GSO FSS networks from NGSO FSS systems, Boeing said. SpaceX said everyone backs the idea of axing the rule precluding grant of an NGSO license where a GSO license has been given and vice versa in spectrum with no GSO/NGSO sharing criteria. The agency shouldn't replace that with a default presumption NGSO systems have to protect GSO systems in all such bands, the firm said.