Earth Station Draft NPRM Seen as Not Generating Big Controversy
A draft rulemaking notice on earth stations in motion (ESIM) set to be voted on at next week's FCC commissioners' meeting shouldn't face any particular pushback or raise notable controversy and likely will garner at most suggested tweaks from industry operators, a satellite industry insider told us. With growth of satellite applications like in-flight connectivity and maritime services, the proposed rule changes NPRM are aimed at a cleanup of the Part 25 rules governing satellite communications, the insider said.
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One of those suggested tweaks is coming from Iridium. Letting ESIMs operate in the 29.25-29.30 GHz band -- which is shared on a co-primary basis between geostationary orbit fixed satellite service earth stations and Iridium's mobile satellite service feeder link earth stations -- raises the risk of interfering with Iridium's feeder links, the company told the International Bureau. In an ex parte filing posted Tuesday in docket 17-95, Iridium said the interference risk arises from the difficulty of knowing in advance the number or ESIMs or their locations. It said the FCC should either remove that sub-band from the ESIM proposal or take no position on the merits of its inclusion, but just solicit comments whether ESIMs feasibly could operate in the sub-band without interfering with Iridium's feeder links. The filing recapped a meeting between Iridium Vice President-Public Policy Maureen McLaughlin and bureau staff including Satellite Division Chief Jose Albuquerque. The draft NPRM notes that Iridium uses the 29.1-29.3 GHz band and that ESIM operations there would have to coordinate with Iridium in advance.
One of the aims in the draft NPRM is consolidating the agency’s Part 25 rules for technical and operational regulations for C-band earth stations on-board vessels and Ku-band ESVs, vehicle-mounted earth stations and earth stations aboard aircraft into one ESIM technical and operational rule section. The other aim, the agency said, is to allow ESIM operation in the conventional Ka-band -- specifically in the 18.3-18.8 GHz, 19.7-20.2 GHz, 28.35-28.6 GHz and 29.25-30 GHz bands -- under similar rules that already exist in the conventional C-band, conventional Ku-band and parts of the extended Ku-band.
The NPRM doesn’t contain specific technical or operational requirements for ESIMs in the conventional Ka-band, saying instead they would be authorized subject to existing requirements such as complying with equivalent isotropically radiated power density limits.
The new ESIM rules should "eliminate redundancies, reduce the burden on our applicants, and allow FCC staff to process applications more quickly," Chairman Ajit Pai said in a blog post last month announcing the May 18 items.
Gogo said it was still reviewing the draft NPRM provisions but it views it "more as the FCC trying to simplify requirements and won’t impact us." The Satellite Industry Association said after its members discussed the NPRM on Tuesday that it's trying to formulate a consensus position.