Terrestrial, Satellite Interests Sometimes at Odds Over WRC-19 Recommendations
From issues ranging from longer time frames before non-geostationary orbit (NGSO) satellite constellations are considered in use, to identifying the entire 47.2-50.2 band for international mobile telecommunications (IMT), terrestrial and satellite interests are pushing numerous and sometimes jousting suggestions for the World Radiocommunication Conference Advisory Committee draft recommendations. Comments were posted this week in docket 16-185.
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The swath is “positioned to play a critical role in the deployment of 5G services using millimeter wave spectrum in the U.S.,” T-Mobile said. “The benefit of using this spectrum domestically for terrestrial broadband operations can most effectively be realized by harmonizing the allocation of the full band internationally.” It was less positive on possible allocation of spectrum for high altitude platform stations (HAPS) within existing fixed service allocations for upper microwave flexible use services (UMFUS). “The need and demand for stratospheric communications, like HAPS, is speculative,” the carrier said.
CTIA agreed on the high-band spectrum and HAPS. As the U.S. prepares for WRC-19, “the overarching goal should be to ensure that its international efforts support 5G deployment at home,” the association said. CTIA said the 37-43.5 GHz range has “the best opportunity for harmonization of spectrum for IMT use worldwide.” Keep focus on the 47.2-50.2 GHz range for IMT, CTIA said. “The U.S. is the only country so far that has made spectrum available for flexible terrestrial use in this frequency range,” the group said. “However, other countries are beginning to look at adjacent spectrum in order to take advantage of economies of scale.”
AT&T said the U.S. should support identification of the 47.2-50.2 GHz range on a global basis for IMT. "Harmonization of the 'radio tuning ranges' provides the benefits of economies of scale and global roaming, even if different countries use different segments of the range for IMT,” AT&T said.
Satellite Concerns
Some satellite operators also raised concerns about allowing an NGSO system to be considered brought into use on deployment of a single satellite into a single orbital plane for one day.
Omnispace said one-day continuous deployment isn't sufficient to show bringing to use and wouldn't deter "paper satellite networks," urging a continuous 30-90 days. EchoStar said the FCC should look for a sufficiently long deployment period that would show long-term stability of a satellite's orbit and utility of its communication payload. SpaceX said the NGSO brought-into-use time frame should be less than the 90 days geostationary satellites must follow, and slightly longer than 30 days would deter parties "from bringing their systems into 'use' by simply launching ... a low-cost satellite not designed for extended operation." OneWeb urged sending the bringing-into-use proposal to Inter-American Telecommunication Commission (CITEL) with the idea the time frame could be adjusted later, since otherwise it could delay U.S. contributions to CITEL.
Until evidence that fixed satellite system networks and systems can be protected from HAPS operations in the fixed service, there shouldn't be new HAPS frequency designations or changes to those designations in fixed service bands used by FSS, EchoStar said. It said it's possible before WRC-19 there could be consensus on protection provisions to allow new HAPS designations in the bands on a co-frequency/co-coverage basis.
Motorola Solutions protested a possible upgrade of meteorological-satellite service from secondary to primary status in the 460-470 MHz band. In the U.S., that band “is used intensely by public safety, critical infrastructure, industrial and commercial entities,” Motorola said.
HAPS advocate Facebook said the platforms could play a big role in an often under-connected world and the U.S. should urge that some spectrum be made available. HAPS “could provide more affordable, fast and flexible backhaul of broadband services, and ... become a key link to emergency communications in the wake of natural disasters,” Facebook said.
EchoStar, Inmarsat and Intelsat backed no change in the 48.2-50.2 GHz band and said WRC-19 should identify bands for IMT that line up with expectations for IMT deployment. SES/O3b backed no change to radio regulations for the band. Boeing said unfettered access to 48.2-50.2 is vital for uploads and can't be shared with IMT without "severe restrictions."
Letting multiple NGSO FSS systems in the V-band is problematic because there's no evidence of any effective mechanism for dealing with aggregate interference when more than three NGSO FSS systems come into operation, ViaSat said. SpaceX said the proposal to use filtering to protect earth exploration satellite systems adjacent to geostationary satellite systems in the V-band ignores other techniques for interference protection. SpaceX criticized the proposed 10 percent deployment milestone at two years for NGSOs, saying it could encourage hasty deployments.
Inmarsat, Thales and SES supported using 17.7-197.7 GHz upload and 27.5-29.5 GHz download bands for earth stations in motion. Even if the 19.3-19.7 and 29.1-29.5 GHz bands aren't included, ESIM backers will have substantial spectrum available, Iridium said, warning use of those bands for ESIM doesn't protect MSS feeder links.
There shouldn't be a finalized U.S. position on the 401-403 MHz band before more discussion in Informal Working Group-3, Spire Global said. Globalstar and Omnispace urged no change to rules for the 5150-5250 MHz band. Globalstar said the FCC's allowance of unlicensed national information infrastructure devices in the band is interfering with its mobile satellite service, which it has raised with the commission (see 1805220006).