In 5G proceeding, SpaceX urges FCC to protect future satellite ventures

Space Exploration Technologies, otherwise known as SpaceX, the space transport company founded by billionaire Elon Musk, wants the FCC to consider not only existing but future innovative uses of Ka-band spectrum before committing to a proceeding that might create barriers to entry.

The company made the comments as part of the FCC's Notice of Inquiry (NOI) on technical and service rules for 5G in bands above 24 GHz. Reply comments on the proceeding were due last week. Several other satellite-related entities, as well as wireless industry vendors and service providers, filed comments as well.

SpaceX pointed out that it recently announced plans to build a network of 4,000 non-geostationary orbit (NGSO) communications satellites, which it will manufacture, launch and operate. It plans to hire a large number of skilled workers at a new satellite manufacturing center in the Seattle area.

While well established as a launch services company with NASA contracts, SpaceX will be a new entrant in the satellite communications space, seeking to provide low-cost, high-speed broadband Internet service worldwide, including to end-users in the United States. SpaceX said its network will be operating in higher frequency bands, including the Ka-band spectrum at issue in the current FCC proceeding.

The company notes that the record in the proceeding firmly establishes that satellite operators have launched or are developing satellite systems to operate in the Ka-band frequencies above 24 GHz. For its part, SpaceX says it will join the ranks of Ka-band spectrum satellite operators "in the near term" as it begins to test and deploy its network of satellites.

The Satellite Industry Association (SIA) has asked the commission to carefully consider the potential impact on incumbent satellite services in bands above 24 GHz from possible sharing with new 5G services, and SpaceX echoed those concerns.

SpaceX urges the commission to take into account new satellite entrants and not just incumbent satellite operators and their existing or planned operations. "SpaceX is committed to introducing a new NGSO network in the Ka-band, further enhancing competition and innovation for satellite services. Any adopted 5G policies should contemplate the continued march of innovation and new entrant business models so as to enhance competition and expand consumer choices in the Ka-band," the company said.

The company also noted that even in satellite uplink bands, there are potential challenges to sharing between intensive, high-power terrestrial operations and satellite services. Satellite earth station uplink operations have the potential to cause interference into terrestrial receive antennas, and aggregate interference from terrestrial operations could adversely affect satellite receive operations. Such effects are particularly important to consider in the context of NGSO operations, where steerable earth station transmit antennas would have a wider geographic impact and significantly lower satellite altitudes magnify the impact of aggregate interference from terrestrial transmissions, the company said.

Iridium Satellite, one of the existing satellite service providers, told the commission that it should make clear, as soon as possible, that critical public safety and national security uses must be protected from harmful interference; its particular concern is the 29.1-29.3 GHz band.

In a joint filing by EchoStar Satellite Operating Corp., Hughes Network Systems and Alta Wireless, the satellite firms point out that the record identifies one frequency band where the FCC can move forward: the 27.5-28.35 GHz, 29.1-29.25 GHz (28 GHz band), where local multipoint distribution services (LMDS) operates on a primary basis and fixed satellite service (FSS) operates on a secondary basis.

Moving forward with a rulemaking to provide LMDS operators with greater flexibility to provide mobile services and allow co-primary uses by FSS gateway stations would achieve several important FCC goals, including obtaining greater spectrum efficiency, promoting fixed and mobile broadband services and enabling the use of spectrum by innovative technologies, the satellite companies said.

Straight Path Communications, which holds an extensive portfolio of 39 GHz and 28 GHz wireless spectrum licenses, told the commission it can and should move expeditiously to open up the bands above 24 GHz, particularly the 39 GHz and LMDS bands, for flexible services.

"While satellite interests assert that the FCC should protect and preserve their use of the mmW frequencies in the V-band (37.0-42.5 GHz) and Ka-band… their arguments, particularly with respect to the V-band, are speculative and should  not block the potential 5G use of the mmW bands," the company said in its filing. "As the satellite operators themselves recognize, there is no commercial use of the V-band today, making a straightforward separation of satellite and mobile uses of the V-band a feasible and practical solution" to best serve the public interest. "Satellite operators' use of the Ka-band may be more complicated, but their needs may be accommodated in other bands that may not be appropriate for mobile 5G use."

Samsung Electronics America and Samsung Research America recommend the commission initiate two rulemakings in the near term, one for the 28 and 39 GHz bands and the other for the 64-71 GHz band, in order to analyze the best way to implement 5G networks in these bands.

For more:
- see this SpaceX filing
- see this Straight Path filing
- see the EchoStar filing

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