Satellite Operators Jousting Over Two-Degree Spacing Changes
Proposed elimination of the two-degree spacing policy is creating degrees of separation among some satellite companies. While operators want higher power satellite services than the policy allows, "such services should not come at a cost of increased uncertainty of the interference environment," EchoStar said in a filing in FCC docket 12-267 posted Tuesday. It responded to Intelsat, which has been the leading proponent of eliminating the two-degree spacing rules. "The mere existence of the policy creates a licensing imbalance that favors non-U.S. operators who do not face similar constraints from their licensing administrations," Intelsat said in a filing early this year. "Worse yet, the two-degree spacing policy can be leveraged to impair the United States’ priority spectrum rights" at the ITU.
Sign up for a free preview to unlock the rest of this article
Export Compliance Daily combines U.S. export control news, foreign border import regulation and policy developments into a single daily information service that reliably informs its trade professional readers about important current issues affecting their operations.
The 32-year-old orbital spacing rule sets a variety of technical requirements, including earth station antenna diameter and power restrictions, on fixed-satellite service satellites in geostationary orbit (GSO), ensuring they operate without signal interference on other FSS GSO satellites operating as close as two degrees away. The International Bureau in 2014 as part of proposed updates to the Part 25 rules on the licensing and operation of satellite communications services sought comment on an Intelsat recommendation to do away with the two-degree spacing rule and go with ITU filing priority as the basis for coordination requirements.
The existing two-degree policy "makes the most efficient use of the orbit/spectrum resource and creates certainty as to what level of service operators are able to provide at a particular orbital location," EchoStar said. The very robustness of the U.S. satellite communications market shows the policy's success, EchoStar said. The company said that abandoning or modifying it would mean licensees trying to start or deploy a satellite service "would have no certainty on whether they could coordinate their space station." Intelsat hasn't explained in its opposition what incentives satellite operators would have to reach an agreement "with a lower priority new entrant," EchoStar said. "Experience tells us that the operator with the priority is incentivized to maintain status quo, which means new entrants are kept out and consumers suffer."
Intelsat's assertion that two-degree spacing blocks high-powered services is incorrect, EchoStar said, pointing to its own blanket licensed operations on high-powered satellites operating in two-degree spacing. If operator coordination agreements are the only route for allowing orbital and spectrum access, EchoStar said, "it is likely that more" not less "abuse will occur, resulting in actual limits on high-power services." EchoStar also said it opposes the Intelsat/DirecTV idea: "U.S.-licensed operators who fail to operate in a manner consistent with two-degree requirements should not be rewarded at the cost of new entrants."
Pointing to the growing array of national satellite operators in the developing world and that most operators outside the U.S. work under ITU coordination procedures and not the FCC two-degree policy, EchoStar's argument "that reliance solely on the ITU's procedures will stifle new entry" has no basis, Intelsat said in a statement to us Thursday.
The idea of changing the two-degree spacing power limits has some support. Such a revision -- raising the effective isotropic radiated power downlink levels to 13 dBW/4kHz for the Ku band and 3 dBW/4kHz in the C band -- would mean "reasonable" operational guidelines for allowing new operations to start while coordinating talks go on, SES Americom said in a filing last month. SES also has pushed that two-degree spacing be expanded to other fixed-satellite service bands beyond conventional C and Ku.