Most Existing Earth Stations Violate Spectrum Frontiers Rules, EchoStar Says
Most of its earth stations already licensed to use the 28 GHz band wouldn't be in compliance with the siting restrictions put in place by the spectrum frontiers order, EchoStar said in a filing posted Tuesday in docket 14-177. It also submitted suggested power flux density (PFD) limits for 39 GHz band operations that it said are tailored for the regional atmospheric condition differences around the country. EchoStar said under the FCC rule Section 25.136, applicants for a 28 GHz fixed satellite service (FSS) earth station license face limits in the form of a protection zone that can't contain any major event venue, arterial street, interstate, urban mass transit route, passenger railroad or cruise ship port. The company said to demonstrate how onerous those conditions are to FSS operators, it analyzed its gateway earth stations authorized to operate with its EchoStar XIX satellite and found that only four of 17 grandfathered earth stations comply with the siting rules. It also said that in six of the seven cases where its sites have contours that cover no population at all, some other factor like a nearby road or event venue could preclude future earth stations there, so the agency should revise its siting rules. EchoStar also urged the FCC to establish the conditions whereby satellite operators can use ITU PFD limits set on the 39 GHz band to overcome rain fade, since currently the commission allows such power limits to deal with rain fade but also requires PFD limits that are 12 dB below the ITU during clear sky conditions. The satellite company said it would prefer uniform PFD limits, but if the FCC wants to tailor its downlink PFD limits to different geographies' atmospheric conditions, it could set tiers with higher PFD limits in more humid parts of the nation and lower tiers in more arid regions.