17 GHz NGSO Downlink Allocation Sees Support, Raises Concerns
The FCC, having opened the 17 GHz band to geostationary orbit fixed satellite service, is facing some divides among satellite and wireless operators about doing the same for non-geostationary orbit FSS operations, per docket 22-273 comments this week. The commissioners adopted a 17 GHz GSO order in August on circulation that included an NPRM about an NGSO FSS downlink allocation in the 17.3-17.8 GHz band (see 2208040055).
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NGSO FSS downlinks in the band on a co-primary basis with incumbents would help tackle a "critical shortage" of downlink Ka spectrum, SpaceX said. The Ka-band downlink spectrum being shared by NGSOs "represents a bottleneck" on their broadband services, it said. Pointing to the 17 GHz band being allocated to NGSO FSS in ITU Region 1 on a co-primary basis with no equivalent power flux density limits, it said NGSOs can coexist with incumbents in the band on a co-primary basis without EPFD limits on them.
Interference concerns can be tackled by proven interference-avoidance measures being used successfully in other bands, said Kuiper. With the agency's 17 GHz order holding that blanket licensed earth stations and earth stations in motion should be allowed to receive in the band on an unprotected basis, NGSO FSS earth stations should get the same approval on the same terms, it said.
SES/O3b, Telesat and OneWeb said concerns about possible effects of NGSO operations on existing services in the 17.3-17.8 GHz band are "unfounded." The satellite operators said the FCC could incorporate protection mechanisms the Inter‑American Telecommunication Commission (CITEL) has put forward in advance of the 2023 World Radiocommunication Conference. WRC-23's Agenda Item 1.19 calls for a primary FSS downlink allocation in the 17.3-17.7 GHz band for Region 2. Mangata also backed the proposed allocation.
Other filers raised red flags.
The 17 GHz proposal is "premature," Viasat said. It said while NGSO FSS use of the band might be feasible, there haven't been any technical studies about whether NGSO FSS would be compatible with other users. It said advocates of NGSO FSS access haven't shown sharing with incumbent services is feasible, nor have they proposed technical criteria for sharing, it said. The FCC should defer consideration of an NGSO FSS allocation there pending the outcome of WRC-23, it said.
DirectTV and Hughes in joint comments said any 17.3-17.7 GHz NGSO FSS downlink allocation should be only on a secondary basis, while downlinks in the adjacent 17.7-17.8 GHz segment should be only on an unprotected basis. They urged safeguards to protect primary services such as broadcasting satellite service and geostationary orbit FSS downlinks and uplinks.
As licensees of fixed services in the 17.7-17.8 GHz segment, Verizon and AT&T said they have big worries about extending the sharing of that segment to NGSO constellations. They urged protecting incumbent fixed service operators by making NGSO use in the segment secondary to co-channel fixed service operations. The FCC doesn't have data yet to show NGSO FSS use of the segment won't interfere with incumbent terrestrial fixed service, and until coexistence studies are done, consideration of co-channel use by NGSO and fixed service operators is premature, they said.