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Budding NGSO Constellations Launch Back at Petitions and Conditions

Companies with non-geostationary orbit (NGSO) constellation plan​s are pushing back at last month's petitions to deny and suggested conditions in the OneWeb processing round (see 1706270014). Friday was the deadline for oppositions to petitions, with replies due July 14.

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With the FCC having granted OneWeb's market application (see 1706220039), it should avoid "a difficult, lengthy and likely subjective process" of assessing satellite system designs of other NGSO applicants, as well as seeking changes to those systems in the name of spectrum sharing, Boeing said. Instead, the FCC should grant licenses promptly to qualified applicants, conditioned on compliance with in-line avoidance and other NGSO spectrum sharing rules, it said. Boeing argued again in support of its proposed phased milestones, letting the company add additional satellites to its constellation as needed, saying that would maximize efficient use of orbital and spectrum resources.

Red flags raised about coordinating with SpaceX's mega constellation don't acknowledge it has been designed to have sharing capabilities better than smaller constellations with larger and less flexible beams, SpaceX said. It said it will work with the FCC, NASA and others to keep reviewing and refining its system design for collision and orbital debris risk mitigation. The company said its requested waiver of system implementation requirements would still see it deploying 1,600 satellites within six years -- "more than enough investment" to demonstrate the waiver isn't about spectrum warehousing, it said.

"SpaceX must accept the consequences" of its design choices given that its planned 4,425-satellite constellation makes in-line events with O3b and other NGSO constellations inevitable, O3b said. It also disputed Telesat objections.

Pointing to its "narrowly tailored and minimally intrusive" feeder links, Audacy said the agency should avoid "unnecessary and unduly burdensome" conditions on its K-band use -- especially rules under consideration as the FCC looks at updating its Part 2 and Part 25 rules. It said its inter-satellite beams would infrequently go in the direction of the Earth, so there won't be meaningful degradation of co-frequency spectrum users' signals. Audacy said to facilitate coordination it will amend its application to eliminate the 27.5-30 GHz and 23.18-23.38 GHz bands.

Hughes, Inmarsat, SES-O3b and OneWeb objections to ViaSat's plan​s for Ka-band inter-satellite links should be rejected since such NGSO-GSO links are consistent with the FCC definition of fixed satellite service and will operate in a technical manner similar to other FSS links, ViaSat said. Boeing said it supported ViaSat’s proposal to operate inter-satellite links in portions of the Ka-band. Boeing said it's sympathetic to Inmarsat and Hughes assertions about apparent lack of data submitted by ViaSat, but that isn't grounds for denying the ViaSat market access application.

The GPS Innovation Alliance "sensationally overstates" how Theia’s proposed L-band radar operations in the 1215-1300 MHz band could interfere with global navigation satellite systems, Theia said. It said L-band coordination of its 52 satellites would be straightforward and far simpler than coordination of the thousands of satellites associated with the OneWeb processing round.