Aggregate Interference Cap Really a Cap on Competition: Kuiper

An aggregate cap on all interference caused by later-licensed non-geostationary orbit fixed service satellite systems would be "unworkable and unnecessary [and] only hinder competition now to solve a problem that does not now -- and may never -- exist," Amazon's Kuiper said in a docket 21-456 filing Tuesday. The aggregate cap argument seems more about protecting earlier-licensed systems from newer ones than preservation of spectrum stability, it said. Amazon repeated its arguments for instead using a degraded throughput methodology (see 2203280029), saying that would protect incumbent systems since new entrants couldn't start operating until it completes coordination with earlier systems or demonstrates the entire system wouldn't increase the incumbent's unavailability or decrease its throughput.