Before getting a full license from the FCC, any proposed supplemental coverage from space (SCS) system should conduct a demonstration letting interested parties monitor for harmful interference, said Lynk. Meeting with FCC Space Bureau Chief Julie Kearney and Wireless Bureau Chief Joel Taubenblatt, Lynk also urged that SCS providers be allowed to apply for a Part 25 license before having a lease agreement with a mobile network operator, though it would have to show an executed business agreement before it could start service pursuant to that license. In a docket 23-65 posting Tuesday, Lynk said it also advocated that proposed geographical limits to SCS service be eliminated, as technology and business relationships can address interference concerns for SCS deployment.
Tariff classification rulings
Opening the 12 GHz band to a high-power, two-way fixed service would "eviscerate [the] carefully crafted spectrum sharing regime" between direct broadcast satellite and multichannel video distribution and data service, DirecTV said. In a docket 20-443 filing posted Tuesday, it recapped a meeting with FCC Chairwoman Jessica Rosenworcel's office where it asserted advocates for the new terrestrial service haven't met the burden of showing it wouldn't harm incumbent DBS satellite subscribers and services. DirecTV reiterated its criticisms of a Dish Network-commissioned analysis by RKF Engineering (see 2312270045).
Iridium's maritime connectivity business is feeling competitive pressure from low-cost Starlink service, the company said Thursday as it announced Q4 financial results. Chief Financial Officer Tom Fitzpatrick said that SpaceX competition will likely drive average revenue per user down this year. However, Iridium should "get back to growth sometime in 2025" as the competition is primarily in the relatively few cases where Iridium is the primary connectivity service rather than a complementary one, he said. CEO Matt Desch said Iridium was invited to join the Mobile Satellite Services Association and is researching the direct-to-device service consortium unveiled this month (see 2402090013).
Ligado will oppose Iridium's request to intervene in its L-band litigation against the U.S., the company said in an email to us. Iridium and aviation interests filed an amicus brief with the U.S. Court of Federal Claims last week joining the U.S. in opposing the suit (see 2402120009). Ligado said Iridium is a competitor, and DOD -- also a defendant in Ligado's suit -- is one of its largest sources of revenue. "Iridium is using its proposed participation to support a primary customer, shield itself from discovery, and benefit from the government’s taking of our property," Ligado said. "Contrary to the amicus curiae parties’ assertions, the bipartisan FCC unanimously authorized Ligado to operate terrestrial 5G services within our licensed spectrum after a rigorous, multiyear process," it said. "That April 2020 decision is final."
Ligado's federal complaint about its planned L-band use is against the U.S., Commerce, DOD and NTIA (see 2402120009).
Ligado's federal complaint about its planned L-band use "rests in critical parts on a skewed, misleading narrative," satellite and aviation interests told the U.S. Court of Federal Claims Friday in an amicus brief (docket 1:23-cv-1797) backing the government's motion to dismiss Ligado's suit against the U.S., DOD, Commerce and NTIA (see 2401260003). Iridium, Aireon, the Air Line Pilots Association, Airlines for America and the International Air Transport Association said that their concerns about interference from Ligado's plans for a terrestrial L-band network "should inform the Court’s consideration." The concerns about "harmful interference arising from Ligado’s planned terrestrial operations are real and ongoing, not pretextual or resolved," they said. The brief said the U.S. argument that Ligado doesn't have a property interest in its L-band license, and thus the Constitution's takings clause isn't implicated, "is underscored by the fact that Ligado’s license remains subject to substantial contingencies," including ones stemming from multiple reconsideration petitions before the FCC and from the possibility of judicial review if the agency denies the petitions.
EchoStar's restructuring and refinancing efforts since the company's acquisition of Dish Network show that it's either "willing to ride roughshod over the interests of its creditors" or facing imminent bankruptcy, MoffettNathanson's Craig Moffett wrote Monday. Having last month dropped a debt swap offering for Dish senior notes (see 2401300003), EchoStar said Monday it was also terminating a swap offering for Dish convertible notes due in 2025 and 2026. New EchoStar "now appears to have exercised all available avenues to raise additional debt under existing covenants," Moffett said.
The in-space servicing, assembly and manufacturing NPRM on the FCC's February agenda (see 2401250068) gives the agency far too broad authority, SpaceX said Monday in docket 22-271. Recapping meetings held with all five commissioners' offices and the FCC Space Bureau, SpaceX said the draft NPRM provides no limiting principle for agency authority over orbital debris mitigation or the cost, reliability and safety of ISAM craft. The draft also proposes assessing planetary protection plans of all spacecraft, including non-ISAM vehicles, it said. "Such broad interpretations of the Commission’s statutory authority ... would needlessly test the bounds of the Commission’s jurisdiction," it said.
The FCC should urgently clarify the 2023 World Radiocommunication Conference's intention about updating rules for equivalent power flux density limits, SpaceX said Friday in docket 16-185. That clarification would eliminate delaying updates "critical to connecting more people as soon as possible," it said. In addition, it said SES/O3b is mischaracterizing the text of the WRC-23 minutes in saying the ITU conference decided no regulatory action on EPFD limits can occur at WRC-27 (see 2401300032). Administrations clearly have the ability at WRC-27 of supporting EPFD rule changes after receiving ITU Radiocommunication Sector results of studying possible EPFD limit changes, it said.
Viasat, Terrestar, Ligado, Omnispace and Al Yah Satellite Communications have formed the Mobile Satellite Services Association, focused on supplemental coverage from space and the direct-to-device ecosystem. MSSA said it wants "to develop a global ecosystem utilizing over 100 MHz of L- and S-band spectrum already allocated and licensed for mobile satellite services," saying that spectrum is well-suited for integration into mobile devices. The new group said it plans to align with 3rd Generation Partnership Project standards for extending terrestrial mobile coverage for both mobile network operator and over-the-top services.