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Faster 'Always Better'

NGSO Application Review Could Mean Approvals This Quarter

The FCC anticipates getting at least one non-geostationary orbit (NGSO) satellite constellation application approved this quarter, and the review for most applications being done potentially this year, an official told us. In some cases, the licensees aren't in a hurry, with constellation plans still being worked on, the official said, adding there hasn't been strong pressure from the industry to accelerate that process.

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"Faster is obviously always better" from a licensee perspective, said Jonathan Rosenblatt, Spire general counsel and a head of the Commercial Smallsat Spectrum Management Association. "We understand how much work it is" to go through the applications, which can cover novel technologies not quite fitting the existing framework of Part 25 rules covering satellites, he said. Echoed Satellite Industry Association President Tom Stroup, the NGSO applications are complex, as is the regulatory process of trying to fit them together and look at possible effects like interference.

Rosenblatt said he hopes the agency progresses on a small satellite rulemaking that will streamline rules for some categories of applications, cutting costs for prospective licensees.

The agency is working on an NPRM on smallsats that currently receive experimental authorizations under the agency's Part 5 rules, the official said. Part 25 rules are too cumbersome for launching a small number of satellites going up for a short duration, and the NPRM's aim is to streamline the application process for them, the expert said.

A smallsat NPRM will come out before an orbital debris NPRM also being worked on, the official said. Both could be out this year, we were told. The debris NPRM looks at mega constellations, including requirements for odds of a collision and how that should be addressed.

The NGSO applications are being processed in parallel, but each application doesn't have its own team of attorneys and engineers working on it, the official said. Instead, batches of three or four are done at a time, the person said. Some applications also can be delayed more by back-and-forth with the company as the agency seeks clarification on an issue, the official said.

Some of the applications have brought up novel issues, the official said, like proposed V-band use and questions about coordination with government systems. Satellite use of 47.2-50.2 GHz and at 50.4-51.4 GHz leaves a gap used by passive earth observation satellite systems, resulting in questions about potential effects of out-of-band emissions, the official said.

It's not clear all will get approved, but most likely will since the applications haven't brought up any significant red flags. All applications have been placed on public notice except for Boeing's second V-band application, the official said.

The FCC also doesn't anticipate many if any amendments to NGSO applications being triggered by NGSO rules adopted last fall, the person said. Since a OneWeb amendment was triggered by that rule change (see 1801050002), some have wondered whether more might be forthcoming (see 1801100044). The official said no other operators indicated plans to make amendments, and the only rule modification that would potentially lead to modifications is the changed milestone rules.

When the agency might undertake a C-band processing round isn't clear, in large part because the band is subject of a notice of inquiry (see 1708030052), the official said. There also is a question of whether there's much interest in the C-band, the official said. Some experts have speculated a C-band round might come after New Spectrum Satellite's application last year (see 1708080044).

The FCC could issue an earth stations in motion draft order in the first half of the year, the official said. The order likely wouldn't be very different from last year's NPRM (see 1705180042).

At some point, the agency will have to look at its geostationary orbit (GSO) satellite rules as they apply to V-band, the official said. Two-degree spacing rules for other bands, such as C-, Ku- and Ka- , don't apply to V-band, we were told. There aren't aren't quantified equivalent power-flux density limits for V-band to protect GSOs from NGSOs, though that potentially should be addressed at the ITU, the official said.