Incumbents: NGSO/GSO Spectrum-Sharing Changes Must Protect Us

The Utilities Technology Council pressed for protecting terrestrial fixed services microwave systems used by utility companies, including those in the 11 GHz band. EchoStar said it's "willing to accept the sacrifice of certain prophylactic limits so long as GSO operators are fully protected," such as via a cap on the increase in unavailability caused by NGSO operators into GSO services.

Defending the equivalent power flux density (EPFD) framework, Viasat said it provided "much-needed certainty" while still letting NGSO and GSO operators innovate. NGSO technical "analyses" -- which Viasat put in quotes -- about how the spectrum-sharing regime's EPFD rules constrain their operations "are deeply flawed -- including because they use bespoke and biased methodologies that ignore the full scope of current and future GSO operations and misapply international standards and recommendations in order to generate predetermined results."

Claims that new NGSO systems with modified sharing requirements won't degrade legacy Ku-band GSO satellite services "may be too rosy," NAB said. It advised that changes to the NGSO/GSO sharing regime should ensure that there isn't a loss of service among GSO systems, especially as the FCC will reallocate at least 100 MHz of C-band spectrum, making broadcasters rely even more on the Ku band.

Others urging protection of incumbent services from interference risks included Nokia and CTIA. The latter also argued against changes to EPFD limits in the C band, which 5G is increasingly accessing, and against any actions that could affect the C-band transition.

Multiple satellite operators argued for at least keeping the EPFD methodology over some replacement.

Backing the existing sharing regime, Eutelsat, Hispasat and Ovzon said that if there are changes to the framework, an alternative approach to EPFD limits, like average degraded throughput and absolute increase in unavailability, wouldn't adequately protect GSO systems from interference. The satellite operators said any changes to the sharing regime should be done within the EPFD framework. DirecTV likewise said alternative NGSO/GSO sharing criteria, such as those based on an absolute increase in unavailability, don't protect GSO networks enough.

There's general satellite operator agreement that going away from the EPFD framework "would cause immediate and significant interference, economic, and anti-competitive harms to GSO operators, their customers, the broader communications ecosystem, and ultimately downstream users," SES said.

While backing a change to EPFD limits, Telesat advocated for keeping the EPFD methodology for protecting GSO systems, as it "has sufficient tenure that the international community has experience in its application and therefore a level of comfort, which will facilitate reasoned engagement at the ITU."

The Fixed Wireless Communications Coalition said that while there's broad consensus in the record for considering changes to the EPFD limits, there has been little talk of specifics and how such changes would affect adjacent or co-channel licensees. Advocates of changes should submit "detailed modeling and simulations sufficient to account for interference risks to terrestrial services."

Backers

GSO critics are offering "tired, rehashed arguments to stymie the Commission’s efforts to promote more efficient sharing," said SpaceX. Testing that the company conducted in Romania and Colombia shows "that the current EPFD limits are extremely overprotective of GSO systems."

The Computer & Communications Industry Association said the docket "makes a compelling case that the existing EPFD limits are hampering innovation and the full potential of NGSO satellite systems."

"A reasonable protection regime," instead of the existing EPFD limits, "could more than halve deployment costs for NGSOs while increasing their peak capacity by as much as 700% [and] no material consequence to GSO operations," Amazon's Kuiper said. It called claims of interference and service interruptions a "false specter."

Market demand for NGSO services is far greater than when the sharing requirements were set, meaning that from an economic standpoint, the standard "is clearly too strict today," the Phoenix Center said in an economic analysis. "Today, with NGSO services growing in market relevance whilst GSO services are stagnant if not shrinking, regulation should favor cost reductions for NGSO services."

Avoid decisions "based on the suspect premise" that GSO satellite systems are obsolete or will be phased out, Gogo said. As the FCC looks at the satellite spectrum-sharing framework, it must avoid putting more burdens on earth station operators, especially those with blanket licenses for earth stations in motion that don't control the associated satellite system.