ITU Power Limits for V-Band Rules Preferable, Say Satellite Companies
FCC action in developing rules for efficient use of V-band spectrum will help allay the shortage of feeder link spectrum for broadband use but it should move forward with a “light hand,” the Satellite Industry Association said in comments on the FCC’s proposed rulemaking for the band. The FCC is working toward making rules meant to increase the sharing of 37.5-42.5 GHz spectrum by terrestrial and satellite services. The agency should “embrace a flexible regulatory approach that does not impinge unnecessarily on satellite operators” that are designing systems to work with international and FCC spectrum frameworks, said SIA.
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The adoption of the fixed satellite service allocation and deletion of the broadcasting satellite service should be taken up at the same time, the association said. Unlike the Ku-band, the V-band can’t support the kind of ubiquitous coverage of BSS and the same “satellite service objectives” in the band can be attained through FSS, said SIA. The FCC shouldn’t further constrain satellite operations by increasing protections of the adjacent-band radio astronomy service (RAS), said SIA. Current limits adopted by the ITU already “overprotect” the band, said SIA.
The FCC should use the ITU’s approach to rain fade compensation rather than using the FCC power flux-density (PFD) limits that are based on a “flawed premise and exaggerated statistics,” said the association. There is no reason for the FCC to “fear abuse by satellite systems of the use of power control, and thus no reason for Draconian regulations that would complicate applications, be difficult to enforce, and limit the legitimate utility of the band for satellite operations,” it said.
In its comments, ViaSat said the FCC could add value to the V-band spectrum if it added a footnote to the Table of Allocations that showed that V-band mobile satellite terminals are FSS applications and are entitled to primary status. That would “expand the potential uses” of V-band and “offer significant public interest benefits, without harming other users of the band,” said ViaSat. The FCC can ensure through licensing procedures that mobile terminals aren’t more likely to interfere or be interfered with than fixed terminals, it said.
The FCC should clarify that coordination between FSS earth station licensees and fixed service wireless operators be required only if the FSS licensee “wishes to receive interference protection,” said ViaSat. ViaSat said the International Table of Frequency Allocations PFD limits to protect RAS would be sufficient. The FCC should give FSS operators the ability to demonstrate to the commission that they can raise PFD levels without causing harmful interference with wireless fixed service stations, thus providing design flexibility for FSS operators, said ViaSat.
The FCC should work with NTIA to “head off potential future coordination difficulties that may arise from the current discrepancy between Federal and non-Federal satellite allocations in the V-band,” said Northrop Grumman. In the past, such overlap “hindered commercial development” by increasing application review periods and by “putting excessive burdens” on simple tasks, it said. Since there are no satellite incumbents, the V-band presents an opportunity to establish more “streamlined coordination processes that encourage sharing on equal footing,” said Northrop.