Overall Support For Part 25 Rule Changes Tinged With Disagreement On Industry Proposals
Replies in the FCC proceeding on streamlining Part 25 rules for earth and space station licensing showed overall support for the commission’s effort, with some disagreement on operational and technical aspects proposed in original comments (CD Jan 16 p8). Replies in docket 12-267 were due Wednesday on the rulemaking notice approved by the FCC Sept. 28, which proposed changing definitions of terms related to satellites and the equipment on the ground with which they communicate (CD Oct 1 p10). Among the goals is to “remove unnecessary reporting rules” and consolidate “remaining requirements for annual reporting, while improving reporting of emergency contacts,” the item said (http://bit.ly/VXlc5E).
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The Satellite Industry Association opposed the Engineers for the Integrity of Broadcast Auxiliary Services Spectrum (EIBASS) request for “keep away zones” to protect Broadcast Auxiliary Service networks in bands shared with fixed satellite service operations. EIBASS then “attacks the commission’s policy of permitting earth stations to be licensed on a ‘full-spectrum, full-arc’ basis in those bands,” SIA said (http://bit.ly/XFm2qY). In doing so, EIBASS interposes “an untimely and repetitive challenge to the coordination plan adopted by the commission in 2010 to facilitate efficient use of the 7 and 13 GHz spectrum,” SIA said. SIA urged the FCC not to revisit its decision on those issues. EIBASS also fails to provide any meaningful support for its proposal for increased protection of electronic news gathering receive-only sites, SIA said. SIA also recommended that any non-geostationary (NGSO) mobile satellite service (MSS) repositioning “not result in an increase in protection from interference from others."
SES and O3b cautioned that some proposals by EchoStar and Intelsat would undermine the FCC’s ability “to prevent harmful interference and should therefore be rejected,” they said in joint comments (http://bit.ly/WqMtzh). SES and O3b opposed EchoStar’s request to change the starting angles for the C- and Ku-band off-axis antenna gain masks. They objected to Intelsat’s request to eliminate a requirement to conduct telemetry, tracking and command at the band edges. SES and O3b also opposed Intelsat’s “proposed expansion of fleet management to include offset locations,” they said: Requiring the licensee to certify that “it will operate consistently with coordination agreements will not constrain the licensee’s flexibility in all cases.”
Iridium supported Intelsat’s suggestion of discontinuing use of FCC Form 312 Schedule S, which collects technical and operational information for new satellites. Use of this form “imposes an unnecessary, duplicative and time-consuming regulatory burden on applicants,” Iridium said (http://bit.ly/Yb2ff8). Iridium said it’s against EchoStar’s proposal to make 29.25-29.5 GHz band applications eligible for autogrant. Iridium also urged the FCC to oppose Cobham’s proposal to ease mobile earth station receiver standards. Relaxing receiver standards for Ka-band earth stations “could complicate coordination in the band between GSO [geostationary] FSS earth stations and NGSO MSS feeder link earth stations,” it said.
The FCC should implement SIA’s proposals, including a proposal to remove unnecessary filing requirements “when information can be gathered from other sources,” Intelsat said (http://bit.ly/YtNsgy). Intelsat urged the commission to broaden the fleet management rule “by authorizing relocation without prior agency approval to a nearby nominal orbit location, so long as operations would conform to existing coordination agreements.” Intelsat also said it supports a modest expansion of the Automatic Transmitter Identification System (ATIS) rule “to cover digital video transmissions from SNG [satellite news gathering] vehicles."
Inmarsat supported various suggestions from SIA, EchoStar, Orbcomm and other commenters. EchoStar’s proposal to expand the definition of the Permitted Space Station List “would provide a one-stop place for all foreign-licensed satellites to be identified,” Inmarsat said (http://bit.ly/12laDjR). It agreed with Orbcomm’s suggestion that milestones for replacement/replenishment satellites should be eliminated, it said: This requirement doesn’t make sense “as a method for precluding warehousing of spectrum for systems that are already operational.” Inmarsat asked the commission to take an approach from SIA and the Global VSAT Forum to eliminate the obligation of small earth station applicants “to provide detailed earth station information ... and the number of user terminals.”