Satellite Industry Pushes for Spectrum Frontiers Rules Rewrites

Reserving the 42-42.5 GHz band exclusively for terrestrial use falls short of the standard for reasoned decision-making, ViaSat filed Thursday. It said numerous satellite operators pushed for an FSS allocation in the band, and T-Mobile was the lone voice for terrestrial access to it. FCC reasoning was cursory, referring to FSS enhanced access to the 37.5-40 GHz band when FSS actually saw no such enhanced access, ViaSat said: "The Spectrum Frontiers Order significantly diminished satellite access to the 37.5-40 GHz band segment."

Its planned FSS V-band network needs 5 GHz of downlink spectrum, which includes full access to 40-42 GHz, shared access to the 37/39 GHz band and access to the 42 GHz band, Boeing said. It also said it could share the 42 GHz band with upper microwave flexible use services (UMFUS) as long as rules are in place defining both services' characteristics.

Satellite interests also targeted FCC rules for protecting earth station siting in the 28 GHz and 37/39 GHz band. Boeing said a cap of three earth station protection zones per county or partial economic area will force satellite operators to put earth stations in more populated areas because there aren't enough rural PEAs to meet satellite need. All 416 PEAs combined would allow 1,248 earth stations, "far less than the several thousands ... that will be needed to support NGSO [non-geostationary satellite orbit] satellite systems in the V-band," said Boeing.

SES and its O3b said instead of the 0.1 percent population coverage limit on county-based UMFUS license areas, there should be a pooling population data for UMFUS areas in a basic trading area, with the aim of encouraging new earth stations being sited in counties with low-population densities or in less-populated regions of higher-density counties. They urged the agency repeal the new prohibitions against locating earth stations near transient population areas like passenger railways and highways, clarify its definition of "gateway-type" services and create a database or other route for identifying existing UMFUS facilities. The FCC also should allow earth station operators to co-locate new antennas with grandfathered earth stations -- a route to expanding satellite capacity that would minimally affect UMFUS licensees, they said. They asked the agency to take another look at the technical evidence satellite operators submitted indicating the risk of satellite receiver interference from all the terrestrial devices to be operating in the 28 GHz band as the first step to addressing future interference.

The lack of definitions of some terms like "major event venue" can "be expected to lead to disputes when it is applied in the future," said EchoStar and Inmarsat jointly, also urging a change to the rules barring earth stations near transient population centers. Urging the agency to replace its 0.1 percent of the population metric, EchoStar/Inmarsat said there's no proof UMFUS operators "would suffer economically or lack incentive to deploy their networks if they were able to serve less than 99.9% of all people located in their license areas." They also backed leaving the three earth station per PEA cap.

At the very least, the FCC should make clear that protected fixed satellite service operations are co-primary with UMFUS, the Satellite Industry Association wrote. SIA said any docket the FCC opens on aggregate interference issues should be incorporated into spectrum frontiers, with its results being considered alongside the reconsideration phase of spectrum frontiers. The group proposed UMFUS station transmit power levels be capped at 40 dBm per station -- a level that wouldn't ensure FSS receiver protection but would cut the likelihood. Boeing also backed lower base station power limits on UMFUS than the 75 dBM proposal in the draft rule.