OneWeb Critics Double Down on Spectrum, Orbit Worries
Opponents of OneWeb's planned non-geostationary orbit (NGSO) satellite constellation are continuing their criticisms before the FCC. Thursday was the deadline for reply comments to OneWeb's petition, and parties cited conflicting orbits and spectrum coordination. The petition already was opposed by parties such as SpaceX and Telesat Canada (see 1608160051) and the radio astronomy community (see 1608090037). Processing round applications in the proceeding are due Nov. 15 (see 1607180006).
Sign up for a free preview to unlock the rest of this article
Timely, relevant coverage of court proceedings and agency rulings involving tariffs, classification, valuation, origin and antidumping and countervailing duties. Each day, Trade Law Daily subscribers receive a daily headline email, in-depth PDF edition and access to all relevant documents via our trade law source document library and website.
Google earth imaging subsidiary Terra Bella used the OneWeb proceeding to urge the FCC to evaluate such proceedings against a backdrop of growing demand for Ka-band frequencies. Terra Bella said it isn't ready to apply for spectrum authorization but expects someday to seek approval for downlinks at 25.5-27.0 GHz and uplinks at 29.3-29.5 GHz. It said the FCC should consider the future use of those bands by NGSO earth exploration satellite service systems -- and specifically "to accommodate 25.5-27 GHz space-to-Earth EESS uses, where minimal active coordination is currently needed," and ID frequencies in 28.5-30 GHz to be available for EESS uplink purposes, such as 29.3-29.5 GHz.
OneWeb doesn't offer anything beyond its "own say-so" for why it needs access to the 12.2-12.7 GHz band and to operate across a swath of spectrum larger than that licensed to most satellite operators, the MVDDS 5G Coalition said. MVDDS admonished OneWeb for saying little about its mobile terminal plans despite having a business plan seemingly heavily focused on mobile terminals: "The company cannot postpone consideration of the system’s most potentially damaging components until some later date." MVDDS said its own technical analysis that was part of its petition to deny showed that there can't be NGSO and multichannel video distribution and data service sharing in the 12.2-12.7 GHz band, but OneWeb offered no technical analysis in response.
OneWeb has a lower ITU priority, Telesat Canada said, but an FCC condition requiring compliance with international coordination and carrying the possibility of the system with the later ITU filing being required to cease service in the U.S. market on launch of a non-U.S. licensed satellite with an earlier protection date would work. It said any OneWeb authorization even conditionally would be premature since the FCC has no rules for processing applications for large NGSO constellations and the OneWeb ongoing processing round is likely to see other NGSO applications.
OneWeb clearly "expects other systems to bear the burden of accommodating" its proposed operations, SpaceX submitted. Even if the FCC waives the band segmentation rule sought by OneWeb, there also is Section 25.261 of agency rules requiring band segmentation during in-line interference events in the absence of a coordination agreement, SpaceX said. If there are multiple large NGSO constellations, it said, such in-line events will be common and OneWeb "should not expect to enjoy access to all of the spectrum it has requested unless it can successfully share that spectrum with other NGSO systems."
More information is needed on protections of other Ku-band satellite network operations before the FCC grants OneWeb's petition, Ligado wrote. It shares SES and O3b concerns that OneWeb hasn't spelled out how its network would comply with equivalent power flux density limits. The petition lacks details on how OneWeb would address possible interference into geostationary gateway operations "such as those conducted and planned by Ligado," the company said. Ligado said the FCC should require processing round applicants to spell out how their networks would interact with licensed Ku-band geostationary systems and let interested parties comment after the processing round.
ViaSat repeated its argument for delaying consideration of OneWeb’s petition until the NGSO application processing round's close. ViaSat also said OneWeb -- looking at the lack of opposition to its request for waiver of the band-segmentation rule -- overstates the level of support. ViaSat said more information is needed to gauge whether a waiver is warranted.
NGSO satellites "are usually designed with some tolerance for altitude adjustments in the range of 20 to 25 kilometers," so coordinating orbits between OneWeb's and Boeing's proposed NGSO constellations should be feasible, Boeing said. It said the FCC should be required to disclose how accurately it will maintain its NGSO satellite orbital parameters, including apogee, perigee, inclination, orbital altitude and right ascension, and its transition plans. That information is publicly needed to assess its adherence with orbital debris rules, Boeing said, and to ease sharing among multiple NGSO fixed satellite service systems.
Its planned 720-satellite constellation "can coordinate efficiently and effectively with others," OneWeb commented last month. The company said it uses "very narrow Ka-band gateways from only a limited number of sites" for that coordination, and its Ku-band design "operates over a limited range with tight beams," letting other NGSO systems share. It pledged to coordinate in good faith with radio astronomy.