Several satellite industry entities have stressed the sector’s focus on delivering broadband communications and providing network resiliency and called for technologically neutral regulations, including concerning spectrum allocations.
The entities submitted comments in IB docket 18-251 in response to a public notice released by the FCC’s International Bureau last month soliciting comments on satellite communications services for a communications marketplace report that the agency is required to submit to Congress every two years under the RAY BAUM’S Act, which became law in March (TR Daily, Aug. 17).
The public notice invited parties to submit comments on (1) “[r]etail and wholesale communications services that are provided by satellite communications providers;” (2) “[i]dentification of satellite communications providers and description of the communications services;” (3) “[t]he types of buyers of satellite communications services;” (4) “[r]equirements for entry into the marketplace and significant barriers to such entry;” (5) “[r]ecent and prospective entry into and exit from the marketplace;” (6) “[o]rbital and spectrum resources, access to spectrum, spectrum usage, and spectrum aggregation;” (7) “[p]rice levels, as well as trends in service offerings, pricing, and consumer behavior;” (8) “[i]nvestment, subscribership, and financial indicators (such as revenues or profitability);” (9) “[n]etwork quality and speed of service;” (10) “[i]nnovation in the market;” and (11) “[t]he extent of competition as it relates to satellite communications, including the effects of intermodal competition with other fixed or mobile providers of communications services.”
The public notice continued, “We also request comment on whether laws, regulations, regulatory practices or demonstrated marketplace practices pose a barrier to competitive entry into the marketplace for the delivery of communications services provided by satellite communications providers, or to the competitive expansion of existing providers. We seek input concerning the extent to which any such laws, regulations or marketplace practices affect entry barriers for entrepreneurs and other small businesses in the marketplace for the delivery of such communications services.”
“Satellite services have a significant impact on the U.S. economy, contributing $52.1B to the U.S. economy, and $104.5B to the global economy, in 2017. Satellites provide a wide range of services across the entire United States, including satellite TV, radio, and broadband delivery directly to consumers, as well as distribution of video and audio content to broadcast stations, radio stations, and cable headends,” the Satellite Industry Association said in its filing. “Satellites also play a critical role in situations where terrestrial communication infrastructure networks are not available such as natural disasters and electrical outages. A significant area of growth for the satellite industry is broadband delivery to end users, including those on aircraft and ships. This growth is fueled by the satellite industry’s investment of tens of billions of dollars in high-throughput geostationary satellites and innovative non-geostationary satellite systems and associated ground infrastructure. Satellites have played [an] important role in providing Americans with valuable communications services and that role will only increase as communications platforms and the data shared over them increases.”
SIA also stressed the industry’s need for reliable spectrum.
“As the Federal Communications Commission seeks to identify additional bands for terrestrial 5G it must carefully consider how to both protect incumbent satellite operations and provide additional spectrum that is available to support their growth. Because of the global nature of satellites, it is equally important that spectrum for satellites be made available on a globally harmonized basis,” SIA said. “In order to ensure Americans across the country continue to have access to reliable and valuable video and audio content, the Commission must ensure that any decision to introduce expanded terrestrial service in the 3700-4200 MHz C-band spectrum include adequate access and protections for existing and future C-band satellite service users. Additionally, for the United States to ensure its continued global leadership in next generation satellite broadband and to meet our national security communication needs, it is critical that the FCC support the use of the spectrum in the bands above 24 GHz in a way that will support the next generation satellite systems that are being built.”
In joint comments, EchoStar Satellite Operating Corp. and its Hughes Network Systems LLC subsidiary said, “The Commission can further improve satellite communications competition by creating a technology-neutral regulatory environment for satellite service providers and revising its satellite licensing framework to encourage additional U.S. satellite filings at the International Telecommunication Union (‘ITU’) and the licensing of additional U.S. space stations.”
“With regard to access to spectrum resources, it is critical that the Commission adopt a technology neutral approach to ensure that competitive broadband providers have access to the spectrum they need to support current and future customers,” the companies added. “Over the previous decade or so, spectrum was still largely allocated to different uses on an exclusive or dedicated basis. While the Commission required spectrum sharing in certain bands, this was accomplished primarily through coordination in limited geographic areas, whereby these services had technical characteristics that enabled sharing to occur within limited operational constraints.”
“To ensure that consumers can have access to the technologies that best meet their needs, the Commission must follow the principle of enabling competition among platforms by ensuring that no single platform is favored,” the companies added. For example, EchoStar and Hughes said, “to the extent additional spectrum is cleared and made available for 5G, it should not be made available simply for one technology – whether satellite or terrestrial wireless. While the split between platforms does not have to be 50-50, it should take into account the consumer demand for access to different platforms, and the role that these platforms will play generally and in different geographic areas of the country.”
Iridium Communications, Inc., said that “the Commission must provide (1) a stable spectrum foundation for the satellite industry; (2) consistent protection from harmful interference; and (3) robust international engagement to preserve space spectrum allocations. Finally, we highlight two specific policy issues that must be addressed for Iridium to continue to expand its services – protection from harmful interference from adjacent band operations, and the potential threat from increasing orbital debris.”
NCTA noted that its members rely on the 3.7-4.2 gigahertz band and said that “the Commission should avoid regulatory actions in its 3.7-4.2 GHz rulemaking that would reduce competition or raise prices in the C-band services marketplace.”
“Comments on the Commission’s Mid-band Notice of Inquiry also noted that the Commission’s full-band, full-arc licensing policy provides important flexibility to consumers of wholesale C-band services, including NCTA’s members,” it added. —Paul Kirby, [email protected]
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