Satellite, Wireless Industries at Odds Over Earth Station Licensing Proposal
Fixed wireless and satellite interests are starting to square off over suggested FCC earth station licensing rules changes in the 3700-4200 MHz band being pushed by the Fixed Wireless Communications Coalition (FWCC), as expected (see 1612270034). In comments in RM-11778, satellite interests labeled the FWCC petition as a rehash and "deja vu all over again." Wireless interests not only backed FWCC's proposal but also suggested expanding the scope of the proceeding to other sharing matters.
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Splitting the difference, the Open Technology Institute at New America and Public Knowledge said they agreed there should be a rulemaking on the shared access rules governing fixed satellite service (FSS) and fixed service (FS) but disagreed with FWCC's proposed rule changes. The current full-band, full-arc coordination regime runs counter to policies against spectrum warehousing, especially in light of the nation's booming bandwidth needs, they said. OTI/PK also criticized the FWCC proposal of setting aside "growth capacity" spectrum for FSS operators as "contrary to evolving principles of dynamic and efficient spectrum assignments and sharing." Instead, they said, the FCC should solicit comments on other approaches while also modernizing Part 101 rules to grease the path to more band sharing and allowing FSS licensees to reserve spectrum only for actual use.
FWCC's suggested earth station licensing rules changes don't give any grounds for the FCC to revisit its 2002 termination order that ended a previous FWCC-initiated proceeding asking for similar rules changes, Intelsat wrote. SES, echoing Intelsat, commented that the FWCC proposal would limit earth station licensing in ways that would undermine satellite networks' abilities to adjust to meet customer requirements, correct interference, facilitate satellite coordination or maintain service continuity in the event of an outage.
FWCC complaints about an FSS/FS rules schism ignore basic differences between the industries' business and operational requirements, and the huge need of FSS networks for flexibility, the Satellite Industry Association wrote. SIA said data shows growth of FS channels in the C-band and lack of any FWCC examples of FS operators that couldn't reach coordination agreements with FSS earth station licensees, so "this is a case of a proposed solution search of a non-existent problem." The association defended full-band, full-arc earth station licensing as needed for satellite coordination, emergency response, restoration of service in cases of malfunctions and resolving interference, and for enabling FSS customers to switch providers easily.
Arguing broadband needs are a big limiting factor to all the various last-mile fixed wireless services under development by various companies, Google Fiber said the full-band, full-arc coordination used now by FSS in the 3700-4200 MHz band "is a seeming inefficiency that cannot be overlooked." It said the FWCC approach might not be optimal, but the end of full-band, full-arc coordination is in the public interest.
The Wireless Internet Service Providers Association (WISPA) -- also saying the 3700-4200 MHz band is well suited for last-mile fixed wireless broadband due to its propagation characteristics -- wants the FCC to start a rulemaking on the FWCC proposal and other means of better utilization of the band. The other means might include updates to such Part 101 rules as the antenna specifications and out-of-band emission limits, WISPA said.
The FWCC's proposed coordination regime would sizably increase the amount of spectrum available to FS operators, said Federated Wireless, backing the plan. The company said it particularly supports the idea for a better coordination process involving exchanging more accurate information on actual FSS operator spectrum use "rather than preemptively reserving broad swathes of spectrum" under the full-band, full-arc coordination status quo.
The full-band, full-arc coordination status quo is "an inefficient use of spectrum that constitutes a de facto policy of spectrum warehousing," Engineers for the Integrity of Broadcast Auxiliary Services Spectrum commented, backing FWCC. EIBASS said the default for FSS earth stations should be the authority to protect only the actual uplinks and downlinks and look angles that it uses. Since changing frequencies and parameters is much tougher for satellites than FS earth stations, the FWCC proposal for growth channels and growth look angles is a reasonable balancing of FSS and FS needs, it said. To protect FS use in shared bands if the FCC stops short of full-band, full-arc rules changes, the agency should eliminate analog transmissions, especially since satellite companies have only a few transponders left that can handle analog; enforce user fees and "construction completed" notification requirements; shorten the FSS license term from 15 years to five; veer away from issuing special temporary authority for new FSS stations instead of regular FSS licenses; and let FS stations use previously protected spectrum as secondary when licensed FS stations are primary on the currently licensed frequencies and look angles.