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Diverging Views on Filings About Spectrum for ESIMs Talking to NGSOs

Satellite operators and others are at odds over where to allow communications between earth stations in motion (ESIM) and non-geostationary orbit satellites (NGSO) operating in fixed satellite service (FSS). There are schisms over the 12 GHz band and parts of…

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the Ka band, in docket 18-315 replies Wednesday and Thursday. Boeing backs ESIM operations with NGSO FSS systems in the NPRM-identified bands and in additional FSS allocations. It urged the agency reject co-equal status for ESIMs operating with NGSO FSS and GSO FSS systems in the 18.8-19.3 and 28.6-29.1 GHz bands because that would prejudice the rights of future NGSO FSS systems. OneWeb backs extending ESIM operations into other bands, including the V band and 12 GHz band. It said given its propagation characteristics, V "is well-positioned to become a critical component" of NGSO FSS services to mobile platforms. Telesat Canada said the 12.2-12.7 GHz band has no allocation to FSS and is outside the NPRM's scope. Intelsat supports NGSO ESIM operations in the 12 GHz and other bands on condition NGSOs don't interfere with or claim protection from GSO networks. ViaSat said allowing NGSO FSS ESIM access in spectrum where ESIM deployment is compatible with primary allocated services, such as in the 27.7-28.35 GHz band, would help increase sharing. But the MVDDS 5G Coalition said allowing ESIM/NGSO communications in the 12 GHz band "would ... imperil 5G services," and there are alternative bands for such communications. ESIM operations into 12 GHz "would introduce a number of problems," such as "upend[ing] the delicate balance" among the co-primary services authorized in the band -- multichannel video distribution and data service, NGSO FSS and direct broadcast satellite, echoed MDS Operations and RS Access. They said ESIM/NGSO links in 12 GHz would create coordination problems for incumbent licensees. Iridium said allowing opening the 19.4-19.6 GHz band and the 27.5-30 GHz bands to NGSO FSS systems is "ill-advised" and falls outside the rulemaking's scope. Backing NGSO ESIMs in 27.5-30 GHz, SES/O3b said more FSS frequencies available for NGSO ESIMs will increase mobile capacity. SES/O3b said the FCC should consider NGSO ESIM issues in any future proceeding coming up with service rules for V-band FSS, and that would be timely since the agency has authorized some NGSO operators to use the band. Hughes asked if the FCC allows ESIMs to communicate with geostationary operations in 18.8-19.3 and 28.6-29.1 GHz, clarify those GSO operations are secondary to NGSO operations in the U.S. and co-primary elsewhere.