Satellite Interests Seeking Numerous Last-Minute NGSO Draft Order Changes; Rules May Get 5-0 OK

The agency's proposed milestone requirement that half an NGSO constellation must be launched within six years of licensing and the remaining half in the subsequent three years isn't possible for some licensees of big NGSO constellations, Boeing representatives told aides to Chairman Ajit Pai and of Commissioners Brendan Carr, Mignon Clyburn, Mike O'Rielly and Jessica Rosenworcel and International Bureau staff. Boeing said there needs to be an exception of NGSO mega constellations of 1,000 or more satellites, letting them launch a third within six years of licensing, another third within nine years and the final third within 12 years. It could support the agency's proposed coordination trigger for spectrum sharing but might also be able to back SpaceX's proposal for an alternative coordination trigger, so the appropriate coordination trigger for NGSO uplinks and downlinks ought to be part of the NGSO Further NPRM.

SpaceX told aides to commissioners (see here and here) of its request for a Further NPRM on the definition of uplink in-line events, which it said would help avoid the need for spectrum splitting. SpaceX's proposal to resolve in-line events using one standard of coordination trigger for downlinks and a different standard coupled with angular separation for uplinks doesn't resolve the underlying problem that operators can't share in real time the data needed to determine that system noise temperature, Telesat Canada said. It called uplink power limits advocated by SpaceX "unnecessary." SpaceX didn't comment.

EchoStar recapped discussions (see here, here, here, here, here and here) with the IB and eighth-floor aides about recommendations for changes to the draft order. The company said such changes should include a secondary fixed satellite service allocation in the 17.8-18.3 GHz band, a secondary NGSO FSS allocation in the 18.3-18.6 GHz and 19.7-20.2 GHz bands and a co-primary geostationary (GSO) FSS allocation and secondary NGSO FSS allocation in the 19.3-19.4 GHz and 19.6-19.7 GHz bands. EchoStar also urged the FCC revise and clarify the draft order on GSO/NGSO sharing in the 18.8-19.3 GHz and 28.6-29.1 GHz bands or at least seek comment on a mechanism for resolving coordination disputes. It said the draft FNPRM should be revised to look at NGSO FSS operations above 30 GHz, such as equivalent power flux density (EPFD) limits.

SES, recapping a meeting with bureau staffers, asked that the proposal to let NGSO applicants certify EPFD compliance include a requirement to make publicly available the input data that's the basis of a certification. The company urged the agency to retain the current table of satellite frequencies, and said the FCC should undertake an FNPRM on receiver earth station patterns.

The EPFD limits in the draft order don't adequately protect GSO operations, ViaSat said. It said what's needed are EPFD limits that manage aggregate cofrequency use by multiple NGSO systems, something neither the ITU nor the draft order does. Instead, the draft order pushes "ineffective and outdated" individual EPFD limits that don't protect GSO networks and are based on ITU limits set nearly 20 years ago, ViaSat said. The company said there's no basis for concluding those limits would be effective or that a lack of aggregate EPFD limits 'will be tolerable" in the coming Ka-band operating environment of perhaps thousands of NGSO satellites.

With its stratospheric-based communications infrastructure likely to be deployed within several years, at around the same time as many planned NGSO constellations, Elefante Group said the FCC should implement a regulatory framework that lets airborne systems operate compatibly with other users in the same bands. It urged the agency not to end the fixed services allocations in the 28.35-29.1 GHz and 29.25-29.5 GHz bands at least for airborne platforms operating at nominally fixed positions. It pushed for earth station power limits to help promote sharing in the bands between airborne platforms and NGSO systems, and for making NGSO system ephemeris data available.