Boeing's V-Band Constellations Plans Facing Terrestrial Wireless Pushback

Thursday was the deadline for oppositions to Boeing's V-band constellation (see 1611010060). The application triggered a processing round with a March 1 deadline for applications and petitions for similar non-geostationary orbit (NGSO) satellite operations in the same frequency bands.

Multiple opponents urged the FCC to hold off on or reject Boeing's application since the spectrum frontiers proceeding is looking at different potential V-band applications. Boeing's list of waiver requests in its application asks the FCC to consider or prejudge spectrum frontiers issues, and doesn't justify the 10 GHz of spectrum the company seeks, "a defect that is particularly troubling given the large amounts of spectrum already allocated for FSS use," CTIA said.

Boeing on Friday said the spectrum-sharing proposals in its application "are consistent with actions the FCC has taken in its Spectrum Frontiers proceeding. Also, the Commission incorporated several of Boeing's proposals on V-band spectrum sharing in its Spectrum Frontiers Further Notice, and Boeing has been actively participating in the Further Notice proceeding to demonstrate that robust spectrum sharing can be achieved between broadband satellite systems and UMFUS [upper microwave flexible use] systems in large portions of the V-band." The company's deadline for response is Dec. 12.

Granting Boeing's application "might create an early preference" for fixed satellite service 5G service at the same time mobile networks "desperately require additional, unique spectrum to satisfy capacity demands," CCA said. It said Boeing's request for waiving power flux density (PFD) limits in the 37.5-42 GHz band is premature since the issue hasn't been resolved in spectrum frontiers. And it said since the FCC has designated 47.2-50.2 GHz for fixed and mobile use, and is exploring sharing the band between FSS and terrestrial operations, a Boeing approval "would effectively allow Boeing to reap the benefits of this important spectrum without addressing important concerns regarding sharing and priority" that came up in the spectrum frontiers Further NPRM, CCA said.

Even without spectrum frontiers, reallocating the spectrum to satellite services should be part of a rulemaking, not a specific licensing application, 5G Americas and T-Mobile said in separate oppositions (see here and here). Boeing's proposed use of 37.5-42.5 GHz for downlinks is inconsistent with the spectrum frontiers order designating 37.5-40 GHz for terrestrial operations on a primary basis and limiting satellite use of the band, 5G Americas said. Straight Path Communications in its opposition also pointed to the spectrum frontiers report and order superseding satellite operations in the 39 GHz band and the FNPRM making premature any decisions regarding use of spectrum bands identified there as candidates for 5G use.

Boeing's analysis isn't based on any existing fixed service system or 5G system characteristics or deployment scenarios, making it impossible to ascertain how the PFD levels at which it wants to operate might interfere with 5G, backhaul and fixed broadband access, FiberTower Spectrum Holdings said. Until better data is in, it said, the FCC should defer action on Boeing waiver requests on PFD limits and FSS user terminal operations in 37.5-40 GHz until spectrum frontiers resolves the issue, or deny a waiver of those PFD limits or of a prohibition on deployment FSS user terminals in the band.

ViaSat, with its own plans for an NGSO constellation in the Ka- and V-bands (see 1611160010), raised some red flags with Boeing's plans, asking the agency to defer consideration of the application until after the processing round. It said in its filing Boeing's request for a waiver of band-splitting rules -- based on the assumption it and other operators will employ co-frequency spectrum sharing -- isn't backed by proof that would work given the size of Boeing's planned constellation. ViaSat also said its own technical analysis indicated a high likelihood of regular in-line interference events between Boeing's mega constellation and its 24-satellite NGSO constellation.

Constellation approval should be conditioned on Boeing's having to accommodate other NGSO networks, ensuring the Boeing constellation won't preclude other NGSO or geostationary operators from expanding into the band, said SES and its O3b subsidiary in a filing. SES also recommended the FCC consider the Boeing application together with any proposals that come in as part of the V-band processing round.

SpaceX said it backed Boeing's requests for rule waivers "inasmuch as they provide the policy context for continued development of rational rules for NGSO satellite systems generally." It said without full access to the 50.4-51.4 GHz bands and 37.5-40 GHz bands, a NGSO operating in V-band "would face significant capacity constraints." SpaceX also said Boeing is justified in seeking PFD limit waiver since those limits are more stringent than international PFD limits for NGSO systems in that band. And SpaceX said the FCC rules requiring laying out the division of spectrum depending on the number of qualified NGSO FSS satellite applications in a processing round wouldn't be as efficient as a regime based on avoiding in-line interference events.

Satellite operator OneWeb -- which has said Boeing needs to coordinate its constellation with it since both are planning similar altitudes for their constellations (see 1609200013) -- said the FCC shouldn't require NGSO applicants with established ITU priority status, like OneWeb, to risk jeopardizing that priority, which could happen if OneWeb had to alter its ITU filings that specify the 1,200 km orbital altitude.