Amazon Satellite Plans Seen Ratcheting Up Orbital Debris Pressure on FCC
Amazon's plan now before the FCC for a 3,236-satellite non-geostationary orbit (NGSO) constellation is increasing the pressure on the agency to act on its orbital debris proceeding, especially since the e-tailer's resources make its constellation plan less speculative than others, satellite experts told us. Amazon's International Bureau application filed Thursday also could raise red flags from other satellite operators about its trying to bypass the processing round process, said satellite lawyer Steve Goodman of Butzel Long.
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Another satellite lawyer said the application puts more pressure on the FCC to act on its orbital debris proceeding, and could give Chairman Ajit Pai another argument for doing so. But the debris proceeding is also caught in the struggle between the FCC and Commerce Department over which agency has space debris authority, he said, and the Amazon proceeding likely won't be what resolves that turf struggle. Commerce urged the agency to pause its debris proceeding, which could duplicate other federal efforts on debris (see 1904080033). The FCC didn't comment Friday. The agency blamed Commerce for difficulty freeing up spectrum for 5G (see 1906120076). Goodman said the FCC already is under pressure to act, given the proliferation of NGSO plans, and Amazon incrementally adds to that.
Amazon's Kuiper Systems would orbit between 590 and 630 kilometers, providing broadband service in the Ka band, it said, saying its goal is "broadband communications services to tens of millions of unserved and underserved consumers and businesses in the United States and around the globe." It said it has at least part of the necessary global terrestrial networking infrastructure in the form of its intercontinental fiber links and global data centers.
Amazon anticipates a five-stage deployment of its satellites, with the first stage being 578 satellites, and that service could begin after those are in orbit and operational. It said its system is designed to provide continuous coverage between 56 degrees north and 56 degrees south latitudes, which would cover the continental U.S, Hawaii and U.S. territories, plus other parts of the world.
Citing 2017's NGSO fixed satellite service order (see 1709260035), where the agency said it would limit NGSO spectrum sharing initially to systems that were part of recent processing rounds but later applicants would be looked at on a case-by-case basis, Amazon said Kuiper is designed for spectrum sharing on par with other NGSO FSS systems. It said it would avoid in-line interference through coordination or dynamic spectrum sub-channelization. It said the Ka-band NGSO processing round is still in its pendency with some applications still pending at the FCC. The company said since other NGSO FSS systems are conditioned on spectrum sharing, it shouldn't disrupt the spectrum access regime.
Processing rounds aren't necessary any longer to ensure competitive entry given the NGSO FSS spectrum sharing framework, Amazon said, seeking a waiver of the requirement the Kuiper application trigger a processing round. It also asked for a waiver of agency geographic coverage rules since its system wouldn't cover most of Alaska. A satellite lawyer said it's inevitable Kuiper will get pushback from other constellation operators on the processing round issue. It puts a spotlight on an anomalous situation at the FCC -- it has rules about processing rounds, but it also allows spectrum sharing and has voiced a case-by-case approach, and there's tension between those positions.
The tech firm said Kuiper satellites would be actively de-orbited within a year of end of life. Their orbits are such that they would passively deorbit typically within five to seven years due to atmospheric drag, the expert said. It said its lowest orbit would be 40 kilometers away from any other orbit of a large NGSO system.