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Not Either/or Choice

Boeing, SIA Defend V-band Constellation Plans From Wireless Critiques

The satellite industry is shoving back on wireless industry arguments against Boeing's plans for 2,900-plus V-band satellite constellation. "Authorizing V-band service does not require the Commission to choose between terrestrial and satellite services," the company said in an International Bureau filing Monday, taking aim at various wireless interest arguments that Boeing's proposed satellite constellation would hamper V-band use for 5G (see 1612020002). Satellite Industry Association said wireless arguments that the spectrum frontiers proceeding should supersede Boeing's application are flawed since the agency isn't required to complete more work on the frontiers before the bureau takes substantive action on the Boeing request.

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5G Americas President Chris Pearson told us Tuesday that the group's opposition stands. He said the Boeing application is inconsistent with FCC rules and, if granted, would help to prejudge decisions the FCC subsequently will make regarding this spectrum.

Monday was the deadline for replies on Boeing's application, with final comments due Dec. 19 (see 1611010060). The application started a processing round with a March 1 deadline for petitions for similar non-geostationary orbit (NGSO) satellite operations in the same bands.

Boeing denied its NGSO application is an end-run around the frontiers millimeter wave planning, noting it's taking part in spectrum frontiers. Instead, the company said, it expects its V-band application "will be considered in parallel with and in light of" spectrum frontiers. It said it will accept granting of its application being conditioned on the outcome of the frontiers and on any anticipated rulemaking proceeding on spectrum sharing between non-geostationary orbit satellite systems.

The 37.5-42.5 GHz, 47.2-50.2 GHz and 50.4-52.4 GHz spectrum that Boeing said it plans to use has long been part of the existing fixed satellite service allocation "and is recognized as a critical growth band for FSS." The aerospace manufacturer said lower fixed satellite spectrum spectrum bands are close to saturated, making V-band the only FSS spectrum available with the capacity for nationwide high rate broadband coverage.

To make sharing happen between its constellation and upper microwave flexible use systems (UMFUS), Boeing said its earth stations in 37.5-40 GHz would operate passively, only receiving. It said its network would operate at power flux density levels high enough to "cause only negligible degradation" to UMFUS. For the 40-52 GHz band, UMFUS use will have to be on a secondary basis to broadband satellite services since that spectrum swath is "core growth spectrum for the satellite industry." Outdoor sharing with UMFUS likely can't happen in the 47 GHz band since that spectrum is needed for satellite uplinks, it said. The sharing is feasible in the 50 GHz band since gateways operating there will be in rural areas away from the likely UMFUS markets, Boeing said.

SIA said the FCC has a history of accepting for filing and evaluating applications before the completion of related rulemakings. That includes a 1995 satellite processing round that saw more than a dozen Ka-band satellite system applications during a related rulemaking about the shared use of those frequencies with terrestrial systems. SIA pointed out a similar 1999 Ku-band constellation processing round during a pending rulemaking also about shared terrestrial/satellite use. Given the demand for broadband services that could be filled by the Boeing V-band proposal, the company's application should be considered contemporaneously with spectrum frontiers, the group said.

The association said its opposition to the wireless procedural objections was backed by all its members except DirecTV, which abstained. Members ViaSat and SES/OneWeb previously raised separate concerns about the V-band plans.

In a statement, CTIA said fixed satellite service "already has extensive spectrum allocations (more than five times the spectrum available for licensed terrestrial mobile services). Boeing has failed to make a technical showing as to why the currently allotted spectrum is insufficient and has not made the case to justify the need for an additional 10 gigahertz of spectrum. A grant of Boeing’s requests by the International Bureau would undermine the full Commission’s efforts in the Spectrum Frontiers proceeding."