NGSOs Challenge Rival Plans and Holes in Data

No non-geostationary orbit (NGSO) satellite system should have to shoulder the whole burden in coordinating spectrum sharing arrangements, and the FCC should push for equitable sharing expectations, SpaceX said in International Bureau comments filed Friday. That was the deadline for replies to oppositions to the slew of NGSO license applications and U.S. market access petitions filed in November (see 1705300042). SpaceX said NGSO operators should share data about the steering angles of each beam within a footprint, which would let operators identify which apparent in-line events are false. ViaSat said any NGSO application's approval should be conditioned on the outcome of the pending Part 2 and Part 25 rules update and on protecting geostationary orbit systems from harmful interference; Telesat Canada also backed conditions tied to Part 2 and Part 25 updates outcomes. OneWeb said any ViaSat approval should be conditioned on it only transmitting between medium earth orbit satellites and geostationary orbit (GSO) when the MEO is in the cone of coverage projected from that GSO satellite with respect to the earth. OneWeb also said the FCC should condition ViaSat's use of Ka-band for satellite-to-satellite links on ViaSat not interfering with or claiming protection from other NGSO fixed satellite service systems operating in the stated transmission direction. And Inmarsat said any use of the Ka-band for NGSO-to-GSO links needs study and rulemaking before the FCC approves ViaSat's application. Colorado-based Elefante Group, which is developing a stratospheric-based communications and IoT-enabling system, said Audacy must provide more information for better evaluating its compatibility with other services in the 22.55-23.55 GHz and 24.45-24.75 GHz bands. SES and O3b said the FCC should defer processing any Ku- or Ka-band NGSO applications lacking data needed to verify their equivalent power flux density (EPFD) compliance claims, with those including Telesat, Audacy, Boeing and SpaceX. It additionally said ViaSat's proposal is also lacking sufficient data needed for proper evaluation. OneWeb also said Boeing hadn't submitted sufficient EPFD data and its proposed phased milestone schedule would let the company keep its authorization indefinitely and prevent use of the underlying spectrum and orbital resources by others ready to launch. Iridium said that while Boeing acknowledges the need to coordinate with Iridium in the 19.3-19.7 GHz and 29.1-29.5 GHz bands, Boeing may underestimate the ground infrastructure the Iridium system might need and overestimates the effectiveness of some sharing strategies. The GPS Innovation Alliance said Theia's opposition to its petition to deny doesn't contain any meaningful technical analysis to address GPSIA's core assertion -- that Theia's earth exploration satellite service in the 1215-1300 MHz band would interfere with radionavigation satellite service operations.