Rather than deferring action on a C-band reimbursement claim that's being disputed by a C-band incumbent until the FCC resolves the dispute, the C-band clearinghouse should disburse the incumbent's approved claim pending the outcome of the appeal to the agency, SES representatives told FCC Wireless and International bureau and Office of General Counsel staffers, per a docket 18-122 filing Tuesday. That wouldn't lead to fraud because incumbents are only going to appeal if they believe they're entitled to more than the amount determined by the clearinghouse, SES said. It also said the FCC should require the clearinghouse to adopt a rule allowing the party that succeeds on the merits in a dispute to get reimbursement of its arbitration or mediation expenses while the party that loses should be precluded from seeking reimbursement of its expenses, in order to disincentivize frivolous arbitration and mediation.

Sept. 30 is the deadline for C-band fixed satellite service operators to submit amendments and updates to their final transition plans, per an FCC Wireless Bureau docket 18-122 public notice listed in Friday's Daily Digest, announcing the limited filing window. The bureau said it doesn't plan to open another transition plan amendment window before the Dec. 5 C-band Phase I transition deadline, so no more Phase I amendments or updates will be accepted after Sept. 30.

Amended rules for licensing digital broadcast service satellites in the 12.2-12.7 GHz and 17.3-17.8 GHz bands take effect Oct. 4, says Friday's Federal Register. The changes were adopted 5-0 in 2019 (see 1909260032).

Amazon's claim it lacks resources to evaluate both proposed configurations of SpaceX's second-generation constellation (see 2108260002) "strains credulity" given the company "routinely brings as many as six lobbyists and lawyers to its many meetings with the Commission about SpaceX" and is part of an obvious strategy to slow competition, SpaceX told the FCC International Bureau this week. Amazon's Kuiper didn't comment Thursday.

Intelsat suggested seeking a waiver of an apparent requirement that it consolidate existing C-band telemetry, tracking and command/gateway sites in the contiguous U.S. by Dec. 5, per a docket 18-122 post Tuesday. Recapping a call with FCC International Bureau Chief Tom Sullivan and Wireless Bureau personnel, Intelsat said such consolidation would take more than 18 months.

Adding a small-satellite mobile satellite service spectrum allocation in the 2020-2025 MHz band would help feed smallsat operators' growing spectrum needs, and that unpaired band -- underused for more than 20 years -- seems of little value to terrestrial services, said Planet Labs, SpaceQuest, Myriota, Care Weather Technologies, Fleet Space Technologies, Xplore, Spire Global and Kepler Communications. Allocations available now to smallsat operators "are in many cases limited and unsustainable," they said posted in RM-11869 Monday. They urged an NPRM to "transparently evaluate the technical proposals of all interested parties." The allocation sought by Spire and Kepler faced some opposition (for example, see 2101140061).

Lynk Global's proposed "orbit cell tower" satellite system would provide only intermittent coverage of up to 90 minutes per day for any part of the globe, unlike other “always-on” mobile satellite service systems, meaning opportunities for spectrum sharing through geographic or temporal separation, it told the FCC International Bureau in a filing Friday. It said its operations in cellular frequencies are limited by the need to coordinate with and obtain consent of mobile network operators, and those MNOs can manage spectrum access by satellite operators using the same techniques used to manage spectrum within the MNO’s terrestrial network.

With the FCC setting up processes for challenging C-band accelerated clearing certification (see 2108040060), satellite and wireless interests made suggestions in docket 21-320 Monday. Verizon, warning of delayed deployment of 5G, said concerns need to be raised now with the relocation coordinator instead of via certification challenges. It urged the Wireless Bureau to clarify that the 30-day period in the challenge and reply process for announcing cert deficiencies applies to initial and refiled certifications. T-Mobile said the bureau should clarify when overlay licensees can use the 3.7 GHz spectrum in the partial economic areas where they won the auction, since there's potential for approval of different certifications at different times by various satellite operators. It said if one satellite operator submits a validated cert by the relevant accelerated relocation deadline, auction winners should be allowed to access their licensed spectrum by that deadline. It argued against challenges to refiled certs being limited to the new information, since the amendment is to replace the original. Make clear that if a C-band satellite operator can address a challenge without amending that cert, it may do so, Eutelsat asked. It said the bureau should require each challenger to demonstrate how it qualifies as a “relevant stakeholder,” and staff should let satellite operators and challengers seek confidential treatment for eligible information that's in their agreement. Intelsat said there seems to be no requirement that challenges focus on potential deficiencies specific to the C-band order's requirements and not to matters outside of phase 1 C-band clearing implementation. It sought clarity on how the bureau will screen for the entities that are “relevant” and have standing to challenge satellite operator certs. Not making that clear could "open the door to abusive challenges based on competitive or commercial motivations," it said. The process the FCC proposes could stretch the time frame for determining the validity of a certification by weeks to years, SES said, urging instead sticking with 60 days for resolution. It said amended or refiled cert shouldn't trigger a new challenge cycle.

FCC orbital debris policies should incentivize satellite operators to improve their covariance realism -- assessments of a satellite's current location and projected trajectory, SpaceX representatives told FCC Commissioner Nathan Simington, said a docket 18-313 ex parte post Friday.

As part of its plan to emerge from its Chapter 11 bankruptcy reorganization (see 2108250003), Intelsat asked the FCC to transfer its agency license and authorizations to New Intelsat. In a set of International Bureau filings Thursday (for example, see here), it said it expects the U.S. Bankruptcy Court in Richmond to approve the reorganization plan in October. It said New Intelsat's ownership structure would have Pacific Investment Management Company (PIMCO) indirectly holding about 32.8% of the voting and equity interests, and no other shareholder would directly or indirectly hold 10% or more of the voting or equity interests. It said its new board would be made up of its CEO, two people selected by PIMCO, a person with industry experience selected by PIMCO but who can't be an employee of or otherwise tied to PIMCO, and three people selected by CarVal Investors, Davidson Kempner Capital Management and Appaloosa Management, respectively.