Commenters Support Further Changes to 70/80 GHz Rules

The FCC should include ship-to-aerostat transmissions in rules for the 70/80/90 GHz bands, Aeronet said in reply comments to a January Further NPRM (see 2401290032). The FNPRM asks about including fixed satellite service (FSS) earth stations in the light-licensing regime for the 70/80 GHz bands and was expanded to also inquire about aerostats -- airborne transmitters operating within a small area, below 1,000 feet of elevation.

Aeronet said the FCC should add ship-to-aerostat transmissions to the shore-to-ship, ship-to-ship and ship-to-shore links already approved. “The maritime industry is underserved by current broadband offerings,” Aeronet said last week in docket 20-133: By using Aeronet’s technology and network architecture, “the industry can dramatically improve broadband access for passengers, crews and ship operators.” Aerostats are important for improved communications at sea, the company said.

SpaceX said the record shows plenty of support for allowing FSS connections to benefit from the light-handed regulatory regime approved for other band users. “Support for a unified light-licensing approach has been nearly unanimous,” the company said.

“The narrow, ‘pencil beam’ nature of 70/80 GHz transmissions and their sensitivity to weather and obstructions allow co-primary users in the band to readily share the spectrum, even in close physical proximity, without causing harmful interference to each other or foreclosing future deployment,” SpaceX commented. The change is “technically feasible” and would require only tweaks to the link registration process and the FCC’s Part 25 rules. SpaceX said that under current rules the earth-station licensing process for 70/80 GHz “can take over a year for a single site even if they have confirmed -- in a matter of minutes -- that no terrestrial operator will receive harmful interference.”

Comsearch, which has been a database manager in the 70/80/90 GHz bands since 2004, urged the FCC to maintain the current link registration system (LRS) regardless of how it is expanded. Comsearch said it welcomes new uses of the spectrum, but the FCC should recognize that the system works. Since LRS was launched in 2005, more than 43,000 links “have been registered by licensees under more than 900 different call signs with an average of over 1400 links registered annually,” the company said. To date, there has been only one report of harmful interference between commercial operators “that was ultimately resolved, and there have been absolutely no reports of harmful interference with federal operators in the bands in the nearly two decades of operation,” Comsearch advised.

The system should be expanded as much as possible, including for FSS links, said New America’s Open Technology Institute and Public Knowledge. “The rules governing open access to these millimeter wave bands represent an early and highly successful example of the enormous public interest benefits of spectrum sharing managed by third-party database coordination,” the public interest groups said. Expanding the system to accommodate FSS links will help close the digital divide, the groups said: The bands “will be used to increase the capacity of [non-geostationary orbit] FSS system gateway links, which will improve service quality for domestic and global customers alike.”