TR Daily SpaceX Petition Seeks NGSO Spectrum Sharing Certainty
Friday, May 1, 2020

SpaceX Petition Seeks NGSO Spectrum Sharing Certainty

Space Exploration Holdings LLC (SpaceX) has filed a petition for rulemaking asking the FCC to revise section 25.261 of its regulations “to increase certainty in spectrum sharing obligations among non-geostationary orbit (‘NGSO’) satellite systems operating in the Fixed-Satellite Service (‘FSS’) and clarify the operation of a new processing round.”

In the petition, which was filed yesterday, SpaceX said the actions it seeks “will provide clarity to existing and future licensees, encourage more efficient use of limited spectrum resources, and—critically—encourage competition in the NGSO market. Further, revising this rule to apply to all operators equally will quell continued efforts by some to interpret the rule either in ways designed to harm U.S. operators specifically or all existing and future competitors more generally.”

SpaceX said that “to encourage both more competition and more investment among NGSO FSS operators,” the FCC should adopt “two small but important updates” concerning spectrum sharing.

First, “[l]icensees in later processing rounds should protect licensees from earlier processing rounds against interference to a specified level. To facilitate operations, SpaceX supports Amazon’s request that first round licensees share beam pointing information. Critically, first round protections should be sunset over time (as should most protections for incumbents).”

Second, the petition said, “[d]uring in-line events between two operators in the same processing round, first choice of home spectrum should go to the operator with the more spectrally efficient system.”

SpaceX continued, “These updates to Section 25.261 will clarify the rights of licensees in a given processing round, both as against each other and as against applicants filing after the close of the round. These revisions will provide the ‘measure of certainty’ the Commission intended for participants in a processing round while also providing a clearer path for later entrants. These revisions will also increase incentives to design NGSO systems with advanced technology capable of sharing spectrum efficiently and flexibly. As a result, all interested parties will be able to proceed more confidently and expeditiously to deploy their NGSO FSS systems and provide much-needed service to American customers, especially those in rural and other underserved areas.”

“The Commission should act on these updates expeditiously, as spectrum sharing among NGSOs is growing more urgent with the Commission’s recent initiation of a new NGSO processing round,” SpaceX added. “Since the close of the first Ku/Ka-band NGSO processing rounds, Kuiper Systems LLC (‘Amazon’) has filed an application for an NGSO FSS constellation 3,236 satellites and WorldVu Satellites Limited (‘OneWeb’) proposed to nearly triple the number of active satellites in its NGSO constellation as originally proposed and authorized, increasing from 720 to 1,980. Telesat has indicated its desire to operate a much larger NGSO system than currently authorized, and recently submitted filings to the International Telecommunication Union (‘ITU’) for such a system. SpaceX has also submitted ITU filings for an NGSO system with a substantial number of additional satellites, and expects that if it applies to the Commission to authorize their operation it will receive equivalent treatment to the applications from these other NGSO FSS operators.

“While the Commission will address these applications individually in the new processing round, it has not yet established spectrum sharing rules for this new round,” the petition added. “With the current uncertainty as to how the Commission will apply its rules for NGSO FSS systems, no one can be sure how those applications will be treated, leaving some applicants like Amazon and a collection of non-U.S. operators arguing for special treatment. Adoption of the rules proposed herein will ensure a level playing field and true competition among NGSOs.” —Paul Kirby, [email protected]

MainStory: FCC FederalNews Satellites SpectrumAllocation

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