LEO Spectrum-Sharing NPRM Could Raise Contested Issues

sunsetting a non-geostationary orbit fixed satellite system's interference protections could get operator pushback. He said there's some gray area in the current FCC rules, so some clarity of what it means to be a first- or second-round licensee could help. ITU has no concept of a sunset, and ITU priority is forever, he said. The FCC draft NPRM in docket 21-456 wants input on sunsetting protections for an NGSO FSS system before the expiration of its 15-year license term and what protections should apply after sunsetting. Astroscale regulatory associate Laura Cummings emailed that there will be a divide among operators over rights sunsetting, because some that were licensed in earlier processing rounds invested first and heavily with the expectation of FCC protection, though later-round applicants would like easier entry into an already crowded spectrum market. She said an FCC decision to sunset first processing round protection rights could result in a legal challenge. She said another issue that could have diverging operator views is on sharing beam-pointing information, which some operators view as proprietary business information. She said operators with government clients also expect client opposition to that sharing. Between spot beams and the sheer number of beams, real-time coordination "would require incredible computing power and logistics" if mandated across thousands of satellites with multiple beams each, she said. She said most operators should agree there should be rules clarity on issues such as the sharing regime, since there has been a struggle to work out how first-round and subsequent licensees can share spectrum across processing rounds. The draft item got mixed feedback from operators. SES/O3b officials told International Bureau Chief Tom Sullivan last week they have concerns about the NPRM, and that other countries also dealing with NGSO sharing might be watching closely. Amazon Kuiper officials, in discussions with aides to Commissioners Brendan Carr, Geoffrey Starks and Nathan Simington and with Sullivan, said that licensees "need reasonable protection and certainty [but] the current rules risk hampering competition and placing the promise of satellite-delivered broadband in the hands of a small group of earlier-licensed incumbents" if there aren't limits on priority protections. SpaceX also told the aides the draft NPRM had its support.