A unified satellite operator license regime covering base stations, user terminals and other transmission facilities as part of FCC streamlining of its Part 25 rules would still let upper microwave flexible use service (UMFUS) and other licensees have full notice and opportunity to comment on planned earth station operations. That per EchoStar officials to International Bureau Chief Tom Sullivan, according to a docket 18-314 ex parte post Monday. It said there's no proof that aligning with international out-of-band emission limits will create harm to adjacent band UMFUS operations but doing so would resolve the inconsistencies in how different operators have applied those limits. Axing the requirement of notification about minor modifications would give earth station licensees regulatory parity with terrestrial licensees, and those minor modifications don't increase interference risks.

Any big change to the earth station siting rules could disrupt the network deployment plans of satellite operators, Intelsat said in a docket 17-172 post Monday, endorsing the Satellite Industry Association petition to rescind International Bureau guidance on earth station siting for upper microwave flexible use services (see 2007240072). It said the siting guidance lacks foundation in the record. Amazon's Kuiper also backed the petition, saying it conflicts with various FCC rules, as well as its intent to allow collocating fixed satellite service earth station antennas. The existing siting rules "are the product of a careful balancing of interests regarding access to this spectrum," and there's no reason to modify them, nor does the bureau have the authority to change them, Boeing said.

Relying on RF engineers for assessments that could affect aircraft performance and operators is "neither realistic nor appropriate," and due deference must be given to aerospace engineers, aerospace industry representatives told FCC Commissioner Brendan Carr per a docket 11-109 ex parte posting Monday. The FCC in its Ligado approval should have consulted with aerospace engineers, said Aerospace Industries Association, Air Line Pilots Association International, Aviation Spectrum Resources, Collins Aerospace, Helicopter Association International, Lockheed Martin and U.S. Geospatial Executives Organization representatives. The aerospace interests also cited what they see as the many potential dangers to their operations from Ligado's proposed system. The FCC didn't comment.

UHF non-voice non-geostationary mobile satellite service operators Kineis, Hiber and Myriota brought their concerns about Swarm's petition and waiver ask to the FCC eighth floor, meeting with aides of the four regular commissioners, said an International Bureau ex parte posting Thursday. They repeated their assertion (see 2007310035) that dividing up 120 KHz of uplink spectrum among four users would leave little bandwidth per operator. Swarm held its own meetings with aides (see 2007270002).

Citing the hundreds of millions of dollars it and other Ka-band satellite operators have spent in recent years on satellites and earth station site acquisition and prep, Viasat said in a docket 17-172 posting Friday that changing the regulatory environment "violates [their] investment-backed expectations." It voiced support for the Satellite Industry Association petition that urges rescinding International Bureau guidance on earth station siting in relation to upper microwave flexible use services (see 2007240072).

Satellite design and manufacturing firm LeoStella joined the SmallSat Alliance, it said Friday.

SpaceX's application to move much of its mega constellation to a lower orbit (see 2004200003) "is no mere 'adjustment' [but] an entire system redesign" with little resemblance to the constellation as first proposed, Amazon said according to an FCC International Bureau ex parte posting Tuesday on a conversation with bureau personnel. The modification poses sizable risks to space safety, with the overlap of 1,240 SpaceX satellites with 748 of Amazon's Kuiper satellites ramping up the projected number of possible collisions tremendously, it said. Also worsened would be the non-geostationary orbit fixed satellite service harmful interference environment, it said. If the space safety issues can be tackled, the application should be considered in the 2020 processing round, it said. SpaceX didn't comment.

Orbcomm's petition to dismiss or deny Swarm's request to double to the size of its proposed VHF constellation (see 2008180001) is an attempt by the company "to protect its monopoly from technological innovation," Swarm emailed us Tuesday. "We don’t think the FCC will be very sympathetic to that attempt. Swarm remains focused on bringing affordable, low latency, global connectivity to every corner of the world for agriculture, logistics, maritime, energy, and many other verticals."

Iridium CEO Matt Desch continues lobbying the eighth floor on the FCC's Ligado approval (see 2007240066), discussing its objections in a call with Commissioner Mike O'Rielly, per a docket 12-340 ex parte posting Wednesday. Iridium seeks reconsideration. Ligado said in talks with aides to Commissioners Jessica Rosenworcel and Geoffrey Starks it discussed how opponents of its approval "misrepresent ... and badly misconstrue" the record and approval. That FCC OK sets power limits much stricter than what GPS manufacturers insisted on, and the conditions to protect certified aviation GPS receivers were proposed by the FAA, which shouldn't be overruled, it said.

Accusing Swarm of a regulatory "bait and switch," Orbcomm petitioned the FCC to dismiss or deny Swarm's request to double to 300 satellites the size of its proposed non-voice non-geostationary (NVNG) VHF constellation (see 2005050001). In an International Bureau filing Monday, Orbcomm said Swarm's amendment application is contrary to the company's previous assurances to the FCC it wouldn't operate in spectrum assigned to Orbcomm on a primary basis. Orbcomm said Swarm hasn't identified any material change in its proposed service offerings, but the amendment application seeks to double the constellation size, use more spectrum and get a waiver of NVNG mobile satellite service (MSS) rules. Myriota said it backs Swarm's contention that spectrum assigned to Orbcomm is supposed to be shared with other NVNG MSS systems. It said the commission should require Swarm, Myriota and Orbcomm to develop a sharing arrangement to allow the best use of the small NVNG VHF bands. SpaceX said it supports Swarm's plan to implement onboard propulsion for its satellites due to the better safety profile of the NVNG system. Swarm outside counsel didn't comment Tuesday.