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.

Aviation interests continue to make the FCC eighth-floor rounds (see 2008060024) about their reconsideration petitions and NTIA's request for stay of the commission's Ligado approval, with a docket 12-340 posting Tuesday on a call with an aide to Commissioner Jessica Rosenworcel. The Aerospace Industries Association and Aviation Spectrum Resources participated.

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 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.