Wireless industry and tech companies rallied behind CTIA’s push for revised FCC rules for the 3.5 GHz shared spectrum band. The Satellite Industry Association opposed many of the changes sought by CTIA and others, saying they pose an interference risk to fixed satellite service earth station use of the spectrum (see 1510200061). Wireless industry commenters said the changes are necessary to make use of the band viable.
Relaxed legal out-of-band emissions (OOBE) rules, higher power levels and unlimited antenna heights open the door to more fixed satellite service (FSS) earth station interference and should be rejected, the Satellite Industry Association said in filing posted Tuesday in opposition to a CTIA petition for reconsideration of FCC rules on the 3.5 GHz shared spectrum band. Instead, stricter citizens broadband radio service (CBRS) limits are needed to avoid "a significant increase" of more than 11 km in the protection distance needed between CBRS devices and FSS earth stations, SIA said in a filing in docket 12-354. While both CTIA and Nokia have pushed for greater emissions limits, "neither provides an adequate rationale," with CTIA itself arguing for more stringent OOBE limits "when its own members' operations could be the victims of unwanted emissions," SIA said. The satellite group also rejected the idea of changing the metric for OOBE limit compliance from average power measurements to a peak detector, because that would "undermine the prophylactic objectives of the OOBE limits." Similarly, a higher maximum effective isotropic radiated power (EIRP) and an eliminating of the antenna height limit for nonrural Category B citizens broadband radio service devices (CBSDs) will also "substantially increase the separation distances" needed to protect FSS from interference. Petitioners pushing for such higher EIRPs "fail to even acknowledge these trade offs," SIA said. But SIA said some areas of the FCC order should be reconsidered, such as the 60-second delay allowed for a CBSD to end transmission, lower its power or relocate to another channel, since even 60 seconds "could have significant adverse effects on FSS operations, including the potential to undermine safe satellite operations," SIA said. The FCC also should put in place a geolocation requirement to give reliable CBSD location information and "abandon the idea of relying on 'professional' installers to ensure the accuracy," the group said.
The Satellite Industry Association is urging Congress to reauthorize the Export-Import Bank. Without it, SIA President Tom Stroup said in a statement Tuesday, "U.S. commercial satellite manufacturers are increasingly uncompetitive in a global marketplace where foreign buyers account for roughly 75 percent of all commercial satellite sales." Numerous satellite companies have complained about loss of Ex-Im in recent weeks (see 1509210026). According to SIA, since the bank's virtual shutdown July 1, U.S. companies have seen at least three commercial satellite orders withdrawn and the U.S. has not been able to take part in some other competitions. "This is just the tip of the iceberg," Stroup said. "In the highly competitive commercial satellite manufacturing market, support from export credit agencies (ECAs) can be the difference between the winning proposal and a competitive one. And in some cases, ECA support is a required component of the proposal. The longer the Ex-Im Bank remains closed, the greater the damage will be to U.S. satellite manufacturers and the hundreds of local businesses that supply them."
The Satellite Industry Association is urging Congress to reauthorize the Export-Import Bank. Without it, "U.S. commercial satellite manufacturers are increasingly uncompetitive in a global marketplace where foreign buyers account for roughly 75 percent of all commercial satellite sales," said SIA President Tom Stroup in a statement (here). According to SIA, since its virtual shutdown July 1, U.S. companies have seen at least three commercial satellite orders withdrawn and not been able to take part in a number of other competitions. "This is just the tip of the iceberg," Stroup said. "In the highly competitive commercial satellite manufacturing market, support from export credit agencies (ECAs) can be the difference between the winning proposal and a competitive one. And in some cases, ECA support is a required component of the proposal. The longer the Ex-Im Bank remains closed, the greater the damage will be to U.S. satellite manufacturers and the hundreds of local businesses that supply them."
The FCC should take a new look at service designations in the 27.5-38.35 GHz band because technology and market changes have shown that satellite operators deserve co-primary status there, said the Satellite Industry Association in a filing posted Monday in docket 14-177. That co-primary designation "would provide satellite operators much-needed certainty that their investments in significant earth station facilities will be protected against the impacts of terrestrial operations in the band," SIA said. With the FCC looking at modifying the parameters for terrestrial use in that band and opening it up for 5G mobile services, the agency should also look at means of guaranteeing fixed satellite services (FSS) access to the spectrum, because they already use it for earth station uplinks without any interference to local multipoint distribution services, SIA said. The FCC also should revisit its "dated assumptions" on other FSS earth station terminals operating in the band to ascertain what -- if any -- techniques or technologies now exist that could let FSS earth station uplinks operate in the band without interfering with terrestrial networks, SIA said.
As the number of nongeostationary orbit satellites (NGSOs) in orbit or planned for launch rises, the role of geostationary orbit satellites (GSOs) is coming into question. "Over time, we'll see a shift" to NGSOs, Whitney Lohmeyer, OneWeb communications systems and regulatory engineer, said Friday as the FCBA's International Telecommunications Committee held a brown bag lunch panel talk about NGSO regulatory issues. Most services that a GSO satellite can provide, an NGSO can do as well but with lower latency, Lohmeyer said. However, said panelist Audrey Allison, Boeing director-frequency management, "we're not getting out of [the GSO] business. [NGSO] is an important supplement." But, she said, that GSO companies like EchoStar are investing in NGSOs "is pretty telling." GSO fits some niches, like video distribution, better than NGSO, said panelist Suzanne Malloy, O3b vice president-regulatory affairs. "The introduction of a new technology doesn't mean everything old is retired," Malloy said. A Boeing NGSO system is in the design stage now with the idea that holders of existing fixed satellite service spectrum allocations could be getting more use out of that spectrum through NGSOs, Allison said. OneWeb expects the first launches of its 648-satellite constellation to start in 2017 and has applications worldwide with numerous nations for the 50-150 gateways it needs, Lohmeyer said. It also is working on developing a terminal that operates both with GSOs and NGSOs, she said: "It'd be ideal, but it's challenging." And O3b has 12 NGSO satellites in orbit serving more than 40 customers in 20-plus countries, and is planning for eight more satellites, Malloy said. When asked about regulatory reforms the panelists would like to see, Malloy said the FCC's Part 25 rules tend to be both GSO-oriented and "very specific" on technical issues like antenna performance, which complicates changing the rules as NGSO regulations would have to be just as granular. Allison said Boeing's "particular pet peeve" is wanting to see better rules regarding milestone compliance -- an issue the Satellite Industry Association also brought up in an ex parte filing posted Tuesday in docket 12-267 (see 1509230022). SIA called on the FCC to simplify the critical design review (CDR) milestone, saying the routine submission requirement of CDR information both prolongs review and raises the danger of inadvertent disclosure of sensitive competitive information.
Small satellites pose their own regulatory issues and should be handled separately from the FCC's current look at changes to the Part 25 rules for earth and space station licensing, the Satellite Industry Association said in an ex parte filing posted Tuesday in docket 12-267. SIA said it is considering filing a petition for rulemaking specifically regarding small satellites. A parade of satellite industry representatives met with International Bureau staff to lay out industry proposals for Part 25 changes, the filing said. Present at the meeting were executives from or representatives of Boeing, DirecTV, EchoStar, Inmarsat, Intelsat, Iridium, Kymeta, OneWeb, O3b and SES, said SIA, which said the satellite industry "urged the Commission to move expeditiously" on an order. Among the industry-proposed changes are the recommendation the FCC should go further in its proposal that it file with the ITU an operator proposal for a geostationary satellite (GSO) for non-planned fixed satellite service (FSS) bands before a full space station application needs to be filed, SIA said. The FCC should allow ITU filings before license applications for non-geostationary (NGSO) operations in non-planned FSS bands as well as for GSO and NGSO operations in bands outside of FSS, SIA said. Current ITU filing practices put domestic applicants at a competitive disadvantage as they must disclose detailed space station plans before the FCC will file with the ITU, meaning operators have a disincentive to obtain U.S. licensing of new satellite systems, SIA said. The SIA group also told IB staff some technical rules "could be simplified, and in some cases relaxed" to help get products to market faster, though the changes would not materially increase the risk of interference.
If the FCC undertakes rulemaking regarding use of frequencies above 24 GHz for mobile services, including the 42-43.5 GHz band, it should look to answer a slew of policy and technical questions, such as what the 5G system characteristics are that can be used to look at the sharing environment, said the Satellite Industry Association in a filing posted Wednesday in docket 14-177. It lists more than two pages of suggested 5G, propagation, satellite, inter-service sharing, cumulative interference and licensing questions. They range from whether in certain bands 5G networks could be limited to indoor-only use to minimize interference to what are the prospects of developing user devices that can operate across the bands spanning 24-95 GHz and even above that might be used for 5G services. When looking at propagation models, SIA asked, should the FCC use the free space loss model to calculate interference, or are there other models that should be tested? It also said the FCC might want to inquire about technical parameters of the earth station types deployed or in the works in the frequency bands under consideration, and how sharing between satellite earth stations and 5G systems might work. And as it looks at cumulative interference, the FCC might need to ask about compatibility models or studies that look at cumulative 5G interference, SIA said.
If the FCC undertakes rulemaking regarding use of frequencies above 24 GHz for mobile services, including the 42-43.5 GHz band, it should look to answer a slew of policy and technical questions, such as what the 5G system characteristics are that can be used to look at the sharing environment, said the Satellite Industry Association in a filing posted Wednesday in docket 14-177. It lists more than two pages of suggested 5G, propagation, satellite, inter-service sharing, cumulative interference and licensing questions. They range from whether in certain bands 5G networks could be limited to indoor-only use to minimize interference to what are the prospects of developing user devices that can operate across the bands spanning 24-95 GHz and even above that might be used for 5G services. When looking at propagation models, SIA asked, should the FCC use the free space loss model to calculate interference, or are there other models that should be tested? It also said the FCC might want to inquire about technical parameters of the earth station types deployed or in the works in the frequency bands under consideration, and how sharing between satellite earth stations and 5G systems might work. And as it looks at cumulative interference, the FCC might need to ask about compatibility models or studies that look at cumulative 5G interference, SIA said.
If the FCC undertakes rulemaking regarding use of frequencies above 24 GHz for mobile services, including the 42-43.5 GHz band, it should look to answer a slew of policy and technical questions, such as what the 5G system characteristics are that can be used to look at the sharing environment, said the Satellite Industry Association in a filing posted Wednesday in docket 14-177. It lists more than two pages of suggested 5G, propagation, satellite, inter-service sharing, cumulative interference and licensing questions. They range from whether in certain bands 5G networks could be limited to indoor-only use to minimize interference to what are the prospects of developing user devices that can operate across the bands spanning 24-95 GHz and even above that might be used for 5G services. When looking at propagation models, SIA asked, should the FCC use the free space loss model to calculate interference, or are there other models that should be tested? It also said the FCC might want to inquire about technical parameters of the earth station types deployed or in the works in the frequency bands under consideration, and how sharing between satellite earth stations and 5G systems might work. And as it looks at cumulative interference, the FCC might need to ask about compatibility models or studies that look at cumulative 5G interference, SIA said.