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‘What do they do?’

FCC Movement on WSI Proposal Premature, Says SIA

Wireless Strategies and the FCC Wireless Bureau need to answer several questions on the effect of distributed radiating elements on satellite communications before the agency moves forward on a rulemaking on the subject, the Satellite Industry Association said in a filing on WSI’s proposal on DREs. WSI proposed deploying DREs as a way to increase reuse of microwave frequencies in 2007. The proposal saw new light recently when it was referenced in the FCC’s National Broadband Plan. The bureau is preparing to issue a notice of proposed rulemaking to make changes to part 101 of the FCC’s rules which govern fixed microwave services and has sought some industry input before moving forward, the SIA said in a filing. The association has met with the International Bureau and the Office of the Engineering and Technology in recent months to voice its concerns on the issue.

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The proposal leaves a lot of information out, including what exactly the DREs would be used for, the SIA said in a list of questions. “What do they do?”, the SIA asked. The technical characteristics remain unclear and the FCC should require far more information before issuing an NPRM, it said. Only general descriptions have been filed by WSI, giving the SIA little assurance WSI or the FCC understands the affect of authorizing the services, said the association. Insufficiently defining the service would create too much flexibility for future uses of DREs, especially when it remains unclear the effect they will have on surrounding communications services, said SIA.

The main complaint from the SIA is that WSI “has failed to provide the FCC with anything near the specificity necessary to move forward with an NPRM,” it said. The SIA is worried the updated rules could cause interference to satellite services in shared frequency bands, such as public safety, government services and TV distribution. The fixed-satellite services companies share C-band and extended Ku-band and have invested billions to provide their service to the public, the SIA said. Even WSI’s recently added conditions to its proposal requiring prior coordination and secondary status for DREs meant to assuage the satellite industry’s worries leaves a lot of risk for interference, the association said. “The latest conditions proposed by WSI are ambiguous at best and opaque at worst,” it said. “It is not sufficient to simply leave these questions for further discussion in response to a” NPRM, it said.