Waiting on ITU Could 'Significantly' Delay Deployment: Amazon

The ITU lacks any process for assessing the joint effect of multiple ITU filings or deadline for doing such an assessment, and that timing uncertainty is why the FCC should let Amazon operate its Kuiper constellation before getting an equivalent power flux density finding from the ITU that explicitly considers the joint effect of Amazon's multiple Kuiper filings, the company told the Space Bureau Tuesday. Requiring that finding before Kuiper commences operations "would delay -- perhaps significantly -- Amazon’s deployment timeline," it said. If there are any concerns about splitting big constellations among multiple ITU filings, the modification request addresses them by letting Kuiper start operating on a noninterference basis while ultimately requiring a finding that shows the entire system complies with ITU limits, it said. In a petition to deny the modification application and partial rules waiver, Hughes said it "would plainly undermine the rule’s purpose to ensure interference protection of primary [geostationary orbit] services prior to any commencement of secondary [non-geostationary orbit] operations." With Kuiper yet to launch any satellites and not to launch production satellites until the first half of 2024, a waiver request is without basis, it said.