Amazon Processing Round Rules Petition Gets Pushback, Backing
Amazon got criticism and support from non-geostationary orbit (NGSO) operators for its rulemaking petition on satellite processing rounds and modifications that warrant updated spectrum sharing (see 2007100023). The company is trying to minimize the cost of its decision not to…
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participate in an initial processing round by disrupting the coordination priority currently going to first-round applicants, said SpaceX in an RM-11861 submission posted Tuesday. The FCC instead should codify that it will grant NGSO fixed satellite service modifications unless they cause significant interference and consider an application that would increase the number of NGSO FSS satellites under an authorization to be a major modification, SpaceX said. It also urged improved spectrum sharing rules that would include a spectrum efficiency metric. OneWeb said some of Amazon's proposals could unnecessarily constrain operators. It said the requested clarification that some modifications would be considered as part of a new NGSO FSS processing round, including changes in apogee and perigee and orbital inclination, are overly prescriptive. Telesat said Amazon's proposed categories of changes that would be subject to new processing round "are vague and unfounded." Interference standards can't be codified, but need to be looked at case by case, it said. O3b said it agreed the FCC should begin a proceeding to update the standards about when requested changes to an NGSO FSS authorization are considered substantial enough that the system should be considered newly filed for processing round purposes, though some Amazon-proposed rule changes are "unduly limiting." It said the focus should be on whether a modification would lead to more interference or more in-line events. And ViaSat said it's "sympathetic" to Amazon arguments about incongruity in FCC standards, but rather than focusing on how proposed modifications change the procedural standing between systems the FCC should look at its band-splitting rules and how proposed NGSO mega constellations could affect competition. It said there's a danger of smaller constellations having to give up sizable amounts of capacity and coverage to avoid in-line events with much larger NGSO constellations, though it would have no effect on capacity or coverage of those mega constellations. Amazon didn't comment.