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Mandatory Maneuverability?

Satellite Interests Push C-Band Protections, Licensing Regime Rules Changes

From mandatory reporting of a satellite failure to revising the FCC's satellite licensing regime, satellite interests and others brought an array of must-dos in docket 18-251 comments due Friday regarding the satellite communications industry (see 1808170024). There were calls for protecting incumbent users of the 3.7-4.2 GHz band.

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While the FCC looks for more bands for terrestrial 5G, it must be sure to provide satellite operators with spectrum they need for growth alongside protecting incumbent operations, with those needs particularly pronounced when considering the C-band, the Satellite Industry Association said. SIA called for making spectrum above 24 GHz available for satellite use.

Also urging protection for incumbent C-band users, NCTA -- pointing to its importance to programing networks in distributing content -- said the agency needs to consider in its 3.7-4.2 GHz band proceeding if reducing satellite industry capacity in that band will lead to reduced competition or higher prices. It said the FCC should explore if there will still be a viable market for delivering content by C-band if there's no longer nationwide coverage due to repacking in some markets. The group said the C-band proceeding should include a look at whether pulling back on the full-band, full-arc licensing policy would limit earth station operators in their choices of satellite service providers or undermine competition in other ways.

Satellite broadband "is poised to create a paradigm shift," especially due to the huge role it will play in 5G, SIA said. The association said the FCC is "in a pivotal position" via its broadband deployment report to make clear that satellite-delivered broadband service is available across the continental U.S. It said the FCC should include users living in regions covered by 25/3 Mbps satellite broadband service as being served.

A must-have for the satellite industry is "a stable spectrum foundation," with the U.S. needing to partner with satellite operators before ITU and other multilateral organizations, defending domestic allocations and interference protections, Iridium said. It said Ligado's planned ancillary terrestrial component (ATC) service in the L-band "is precisely the type of activity that must be avoided" to avoid harmful interference issues with incumbent satellite operators. Ligado emailed Monday that, "As Iridium notes, the ATC service in the L-band was authorized 15 years ago. It was only two years ago, however, that Iridium raised concerns -- just as Ligado’s IoT plans were taking shape. It’s never been more clear that Iridium's real concern is that we pose a business risk and it doesn't want the competition.”

To tackle the growing threat of orbital debris, Iridium said operators should be required to provide technical and design information with their applications that will assure the FCC and other operators those designs won't fail and become a debris source. The company said operators should be required to have the ability to perform collision avoidance maneuvers and to retain control of the satellite so as to do such maneuvers even after the satellite has reached the end of its life.

Any spectrum clearing for 5G has to be technology-neutral and not cleared for either satellite or wireless alone, though the split between platforms "does not have to be 50-50," EchoStar said. It urged the FCC to push at the 2019 World Radiocommunication Conference for some millimeter wave bands having both dedicated and shared bands. The company urged overhaul of the FCC satellite licensing regime to incentivize operators to again license their satellites in the U.S. It said the milestone requirement should be revised so it's met by operating or providing service using an existing in-orbit satellite for two years, rather than requiring a new satellite to be built to develop a new orbital location.