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FCC-Proposed NGSO In-Line Events Rule Seeing Some Satellite Dispute

The FCC proposal to replace avoidance angle rules with a trigger based on system noise temperature in the draft non-geostationary orbit (NGSO) satellites rules order on next week's commissioners' meeting agenda (see 1709110030) is coming under fire from some operators.…

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SpaceX in docket 16-408 filings posted Monday (see here and here) recapped meetings with an aide to Chairman Ajit Pai and with International Bureau staff at which the company said the agency's proposed definition of in-line events "could be workable," though with uplinks it could result in "unintended but detrimental consequences" due to the wide variety of NGSO system architectures being proposed. It said any "one size fits all" approach to in-line events will raise the likelihood of having to resort to band splitting for uplinks. SpaceX said the FCC should add a topic to the Further NPRM, specifically defining in-line uplink event parameters, which would minimize those events and promote spectral efficiency. Also raising red flags about the fixed separation angle issue is Telesat Canada, which in a filing in the docket posted Monday recapped discussions with aides to Pai and to Commissioners Brendan Carr, Mignon Clyburn, Mike O'Rielly and Jessica Rosenworcel (see here, here, here, here and here). It said the agency's proposed separation standard is as unworkable as its current fixed avoidance angle rules. It also said operators can't exchange information on many of the data items needed to make a trigger based on system noise temperature calculations in advance or in real time. Telesat Canada said "the only workable solution" is through ITU coordination. Intelsat said it's concerned geostationary orbit satellites wouldn't be adequately protected from harmful interference due to some NGSO operators seemingly not meeting equivalent power flux density (EPFD) limits required by the ITU. The company said the FCC needs to independently check the data of NGSO constellation applications it's reviewing and ask for corrections to ensure EPFD requirements, or, at least require the NGSO applicants to provide a set of input information for EPFD showing that third parties could verify. In a filing posted Tuesday, Space Norway said it particularly backed the draft order's proposed elimination of the global and domestic coverage requirements.