ESIM Rules Harmonization NPRM Sees Points of Contention Over 29.25-30 GHz Use
While the FCC's move to lessen regulations on earth stations in motion is seeing general support from satellite and terrestrial mobile interests, disagreements remain over ESIM operations in certain parts of the 29.25-30 GHz band. Wednesday was the deadline for replies in docket 17-95. The rules harmonization and consolidation NPRM wasn't expected to see notable pushback (see 1705090018).
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The agency should reject Iridium's call to bar ESIM operations in the 29.25-29.3 GHz band, calling it "protectionist," Inmarsat said, adding that any exclusion zones around Iridium gateways would resemble those for fixed earth stations. ViaSat said ESIM transmissions at the band aren't any different from ViaSat's uses of the band segment that have been allowed for 15 years, and coordination with Iridium feeder links can be handled the same way fixed geostationary earth stations are. SES/O3b said Iridium red flags about defining an interference reception zone ignore that the FCC has experience protecting NASA tracking and relay data satellite system earth station sites from ESIM terminals already, so there's no reason the FCC can't similarly specify an area around existing Iridium feeder ink sites in which coordination with Iridium would have to come before an ESIM licensee can operate in the 29.25-29.3 GHz band.
Iridium, meanwhile, said arguments by Inmarsat and others that coordination with ESIM is possible lack any meaningful analysis to back them up. Without any coordination method on the record, the FCC can't rely on a coordination agreement to protect Iridium's feeder link operations in that band, the company said.
Global Mobile Suppliers Association's analysis of ESIM stations' effects on adjacent-band mobile services should be the basis for any solutions framework for ESIM operations in the 28.35-28.6 GHz band, it said. According to that analysis, land-based ESIM could pose some problems for mobile service terminals in close proximity and there's not an immediate non-burdensome coordination fix.
More information is needed for analyzing the potential interference effects from such operations into adjacent band terrestrial mobile broadband operations, CTIA said. While applauding FCC efforts to reduce regulatory burdens on ESIM operators, CTIA said any such relaxations can't exacerbate existing coexistence challenges between fixed satellite service providers and upper microwave flexible use service and local multipoint distribution service licensees. It said the FCC should define specific deployment and protection scenarios for ESIM operations, giving adjacent band licensees the data to let them model interference effects.
Like Inmarsat, Telesat Canada also challenged a National Academy of Sciences' Committee on Radio Frequencies suggestion about restricting ESIM operations in the 18.6-18.8 GHz band. The companies argued the band and the adjacent ones are for downlinks, while ESIMs won't be transmitting in that direction there.
The FCC should consider a Further NPRM to allow operation of ESIMs with non-geostationary orbit satellite constellations and to address ESIM operations in parts of the V-band, Boeing said. It said the agency should take further steps to aid licensing of ESIM networks, such as allowing applicants to certify earth station terminals will comply with shut-down requirements rather than having to demonstrate such compliance.
In backing SES/O3b calls for expanding bands available for ESIM operations to include the 10.7-10.95 GHz and 11.2-11.45 GHz bands, Gogo said earth stations on vessels and earth stations aboard aircraft terminals already are allowed to operate there.