Satellite, Broadcast Industries Address ATIS, VSAT Authorizations in Satellite Licensing Proceeding

The Satellite Industry Association suggested revising some of the definitions. They included “expansion of the ‘permitted space station list’ to include Ka band stations, ‘routine processing’ (for bands other than conventional C band and conventional Ka band),” and the term “blanket license” to encompass both space and earth stations, SIA said (http://xrl.us/boaxz6). Part 25 reporting requirements should be consolidated and revised “to remove contradictions and overlaps,” it said. But SIA said it doesn’t support “expanding the reach of these requirements to licensees and operators not currently required to submit reports.” SIA sought revisions for several technical standards, including allowing some telemetry, tracking and command functions “to be conducted on a non-emergency basis away from the band edge,” and “provided that the signals cause no more interference and require no greater protection than communications or service traffic provided on those non-edge frequencies."

Boeing suggested the agency alter its process for its Critical Design Review. The expanded CDR evidentiary requirement doesn’t appear “to further the commission’s goal of ensuring that scarce spectrum does not lie fallow, while often requiring licensees to produce extremely sensitive technical documentation,” the company said (http://xrl.us/boax2i). It said the commission should narrow its evidentiary review of CDR milestone showings “to the original factors identified by the commission when this milestone was first created.” Satellite manufacturers are exceedingly diligent in ensuring the confidentiality of their CDR reports and “seek to minimize disclosure of this information to the greatest extent possible,” Boeing said. The FCC and the International Bureau “should require the disclosure of satellite CDR reports to the bureau staff only when absolutely necessary to ascertain a satellite licensee’s compliance with the commission’s rules,” it added.

EchoStar said it supports the comments of SIA and proposed revisions for geostationary orbit (GSO) fixed satellite services (FSS), the fleet management rule and ATIS requirements. The FCC “should make all GSO FSS services offered by foreign satellites eligible for the Permitted Space Station List to increase operational efficiencies,” EchoStar said (http://xrl.us/boax2v). The commission also should decline to apply its ATIS requirements to any digital video uplink transmissions other than the high-power, frequently repointed transmissions for satellite news gathering operations, “which represent the principal threat of harmful interference to satellite operators,” EchoStar said.

Revising Part 25 to ensure that all rules account for technological developments “would provide greater certainty and reduce the risks inherent in innovative business models,” LightSquared said (http://xrl.us/boax2z). Rationalizing and harmonizing Part 25 would provide more transparency “and allow the public to better understand both the substance of the commission’s rules and the manner in which they are applied to different parties,” it said.

Iridium supports amending the rules “to provide NGSO MSS [non-geostationary mobile satellite service] licensees with greater flexibility to implement system changes without seeking additional commission approval,” it said (http://xrl.us/boax2z). The company said the automatic grant of licenses process shouldn’t be available to earth station applicants “proposing to operate on a secondary or non-conforming use basis.” Iridium cautioned against increasing the number of authorized blanket-licensed, mobile and VSAT earth terminals. Authorizations that were issued on a secondary or non-conforming use basis for blanket-licensed, mobile and VSAT earth terminals “frequently are premised on an interference analysis that is tied to a maximum number of earth terminals,” it said.

Intelsat opposed the FCC’s suggestion of codifying a licensee’s obligation to pay ITU fees for each satellite filing and imposing a “red light” processing penalty for all Part 25 applications in the event of a past due payment. The record is devoid of any evidence “that unpaid ITU cost-recovery fees are of particular concern for the commission, or have caused any harm,” it said (http://xrl.us/boax27). Unpaid ITU cost-recovery notices may be in error or out-of-date, Intelsat said. The commission should limit the hold on application processing to the specific satellite associated with the alleged unpaid ITU cost-recovery obligation, it added.

The Global VSAT Forum asked the commission to avoid imposing a limit of two ATIS solutions for satellite uplink transmissions (http://xrl.us/boax3b). The rulemaking notice said the techniques proposed by the FCC are inserting the ATIS information into the network information table of an MPEG transport stream and transmitting digital broadband video uplink signals “with an accompanying low-data-rate spread-spectrum signal carrying the ATIS information” (http://xrl.us/boaxxu). The forum said it’s premature to set only two limits “while digitally modulated broadband video and methods for encoding ATIS information are still evolving."

NCTA urged the FCC to refrain from adopting changes to ATIS rules. Because of continuing problems with satellite interference, FCC action “may eventually be appropriate to mandate updated ATIS requirements,” it said (http://xrl.us/boax4e). However, there are multiple methods by which ATIS information can be included in digitally modulated uplinks, “and efforts are still under way by industry organizations around the world to arrive at a common solution,” it said: If the FCC acts prematurely, it may adopt requirements that conflict with industry standards, “resulting in unnecessary industry confusion, frustration and expense.” The commission should require the geographic location of the earth station to be included in the ATIS data, NPR said (http://xrl.us/boax4x). It said it supports the commission’s proposal to limit the number of techniques used to transmit ATIS information.