SpaceX GSO-NGSO Sharing Petition Gets Opposition
SpaceX's petition seeking a revision of U.S. spectrum-sharing methodology between geostationary orbit (GSO) and non-geostationary orbit (NGSO) fixed satellite service downlinks (see 2408120018) is facing pushback from some satellite operators. It also gained support from a fellow mega constellation operator. Fights over equivalent power flux density (EPFD) limits arose during ITU's 2023 World Radiocommunication Conference and were expected to continue before the FCC and ITU up into the forthcoming WRC-27 (see 2402200005).
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In an opposition posted Monday, Viasat said SpaceX previously certified it would meet the EPFD limits and has been able to deploy thousands of satellites based on an authorization revolving around that certification. Yet now SpaceX "seeks to escape the consequences of its previous certifications," Viasat said. The existing EPFD limits "remain critical and must be preserved to ensure continued competition and innovation." Considering SpaceX's petition would go against FCC policy that strongly favors harmonization between the domestic and international GSO-NGSO sharing regimes, it added.
Also opposing, EchoStar said the proposed rewrite of GSO-NGSO sharing rules "would in fact unleash a cascade of harmful consequences [and] undermine the very international cooperation that underpins the successful functioning of the global satellite ecosystem." The petition makes "speculative assertions" about NGSO systems' ability to coexist with GSO systems at higher power levels than what's currently permitted "while disregarding the proven effectiveness of the current EPFD limits in protecting GSO services."
Eutelsat Group said that with the ITU studying the GSO-NGSO sharing rules, the FCC should "continue working toward international consensus [on any update] rather than independently updating the EPFD limits applicable on its own territory." But if the FCC moves forward with an NPRM, then it should pay particular attention to protecting GSO systems, as they have long operated under the current EPFD limits. Any revised limits must be based on technical analyses showing GSO operations will be protected, it said.
Amazon's Kuiper said it agreed with SpaceX that sharing rules "overprotect" GSOs. That substantially constrains NGSO operators, cutting their power levels and ability to reuse spectrum "even where there is no plausible impact to GSO links," Kuiper said. It said the FCC needn't wait for the ITU to act.
SES/O3b said that while a review of EPFD limits governing GSO-NGSO sharing "is warranted," the FCC should wait on international studies before issuing a rulemaking of its own. It said SpaceX claims that GSO services wouldn't be harmed are "unsupported." Waiting until the ITU study process is finished would let the FCC "avoid unneeded duplication of effort and promote consistency."
SpaceX's petition doesn't consider the potential impact of the proposed changes to terrestrial wireless operations in the same or adjacent frequencies, CTIA said. Proposed rule changes must consider "the downstream impact" on terrestrial licensed wireless operations, including existing licensed bands and in spectrum that is being explored domestically and globally for future licensed wireless use, it said.