Elefante Group responded to critics of its proposal to get the FCC to start a rulemaking process that would consider rules for Stratospheric-Based Communications Services (SBCS) in certain spectrum bands—including bands that wireless carriers are eyeing for 5G.
Specifically, Elefante proposes that parts of the 22-23 GHz, 26 GHz, 70/80 GHz bands be considered for SBCS. Elefante wants to build airship-based radio stations, generically referred to as stratospheric platform stations (STRAPS), that would operate at fixed locations at about 65,000 feet above ground and support 1 Tbps in both directions for fixed user terminals and IoT solutions. It’s also talking about supporting 4G and 5G backhaul for cellular networks.
By way of background, Elefante Group filed a petition for rulemaking in May, and the FCC in June released a public notice asking for comments. The deadline for reply comments on Elefante’s proposal were due Aug. 15, 20 days later than a previous deadline of July 26, so that Elefante would have more time to address technical issues raised by commenters.
Elefante said in its most recent filing (PDF) that it agrees with CTIA and T-Mobile that the FCC should proceed in a “comprehensive fashion,” consolidating consideration of rules for SBCS in the 22-23 and 70/80 GHz bands, in addition to the 26 GHz band, with other issues in the Spectrum Frontiers proceeding. But it suggests that its SBCS can fill in wireless carriers’ 5G coverage more than the carriers acknowledge.
Elefante Group plans to begin commercial launches of its SBCS solutions in 2022, which it says will be timely in terms of supporting major rollouts of 5G by the nation’s largest mobile carriers.
“While the major mobile carriers are to be lauded for accelerating earlier plans to begin rollout of 5G fixed or mobile services in some cities starting this year and others in 2019, more full scale deployments are still likely several years away in the early 2020s,” the group said.
Even in the markets that are the first beneficiaries of the carriers’ 5G rollouts, there may remain areas of various sizes that will not receive next-generation capabilities.
“In all cases, the timing of 5G deployment in any given locality will depend, among other factors, upon additional fiber build out or other forms of network connectivity, connectivity which SBCS solutions can provide and accelerate when and where alternatives are not available due to difficulty of buildout, municipal regulation, cost, or other considerations,” the company said.
Founded in 2015, the Denver-based Elefante Group aspires to lead the world in low latency stratospheric-based communications, sensing and infrastructure. The group has been leveraging Lockheed Martin’s expertise with lighter-than-air (LTA) platforms, sensing and communications systems. Its systems are a continuation of the advances that Lockheed Martin first made through the HALE-D and Aerostat projects. It has said its airships will be capable of adjusting altitude to accommodate stratospheric winds and maintain stability for its payloads.
Elefante took issue with some of the assertions that T-Mobile made in its comments (PDF) earlier this summer, including that the high-altitude systems represent “an untested service that may serve a niche market less efficiently than existing proven services.”
On the contrary, Elefante said, the services that will be provided by Elefante Group and other SBCS operators will carry on the disruptive tradition of wireless communications. In fact, their services are central to next-generation network rollouts of 4G and 5G cellular backhaul, enterprise WAN (local loop replacement), fixed broadband access for residential and small- to medium-sized businesses and fixed broadband services to enterprises, according to Elefante.
T-Mobile had argued (PDF) that while there’s no guarantee that the Elefante service will actually be deployed into rural areas, 5G services, in contrast, have the potential to expand terrestrial services’ already significant reach. Moreover, terrestrial providers are subject to coverage obligations, including to serve rural areas, and they have further opportunities to target rural areas via the Mobility Fund. Plus, all the other services that Elefante is proposing, like the backhaul and fixed broadband, can be addressed through terrestrial wireless networks, according to T-Mobile.
CTIA also filed opposition comments (PDF) and said the 26 GHz band has been identified as a leading candidate for 5G services. Other spectrum bands identified by Elefante for SBCS also will need to be thoroughly evaluated by the FCC to make sure there’s no harmful interference to incumbent users, the association said.
Elefante said the 26 GHz band for STRAPS downlinks present a unique opportunity for SBCS in the U.S. That said, it’s inviting commercial mobile proponents and incumbent users to the table to discuss ways in which flexible mobile services might be able to share spectrum.
Loon argued (PDF) that contrary to Elefante’s suggestion, the system that Elefante envisions does not appear to be a “radical departure” from other aerial platform projects. Since 1997, ITU regulations have defined HAPS as a “station located on an object at an altitude of 20 to 50 km and at a specified, nominal, fixed point relative to the Earth,” it said. While Elefante has said its airships will operate about 19.8 km above their designated service areas, Loon argues that it’s unnecessary for the commission to create overlapping categories for aerial platforms.
Elefante acknowledged that the altitude range proposed by its petition would accommodate some systems that qualify as HAPS, but said SBCS would use different spectrum than that being considered for HAPS to achieve the proposed SBCS data throughput performance targets and spectrum efficiency.
“In any event, the overlap between HAPS and STRAPS categories is a red herring,” Elefante said. “The important thing is that the commission move swiftly to enable SBCS so as to foster continued innovation, investment, and deployment in stratospheric communications platforms.”