HUGHES URGES FCC TO ADOPT HOMOGENOUS CONSTELLATION FOR KA-BAND
Hughes urged FCC in filing to adopt Homogenous Constellations (HC) for proposed Ka-band nongeostationary orbit fixed satellite service (NGSO-FSS) systems. Commission is considering 4 spectrum-sharing plans, but Hughes said HC option would be best for operators. Hughes filing is direct response to plan proposed by Teledesic, only NGSO-FSS system authorized to provide Ka-band service as result of first round. Second round licenses are pending, but Commission is considering several spectrum-sharing options to facilitate service. Hughes said HC was spectrum-sharing technique in which all systems used similar power levels and had access to all 500 MHz of Ka-band spectrum, reducing inline interference events.
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With 5 of 6 proposed systems medium-earth-orbit (MEO) systems, various applicants already are significantly advanced toward sharing solution based on homogenous MEO constellation, Hughes said. Physical system coordination would allow systems to operate across entire Ka-band “without ongoing, complex and burdensome coordination,” it said.
Flexible band segmentation and dynamic band segmentation don’t provide sufficient operating spectrum to support Ka- band NGSO FSS system technically and economically, Hughes said. Biggest disadvantages of flexible system are limitations on capacity and number of users because of limited bandwidth, it said. Licensee may have access to only part of NGSO-FSS band that it needs to support necessary investment in system. However, additional bandwidth could become available if other NGSO-FSS applicants failed to launch or fully deploy systems as planned. Necessity for numerous guard bands also reduces amount of spectrum that can be used for provision of service, weakening commercial viability of any related investment, Hughes said.
Dynamic band segmentation results in more difficult frequency (and resource) planning and creates regulatory risk because when new systems become operational, existing systems will experience series of reductions in bandwidth and capacity, Hughes said, and avoidance of inline interference events might allow systems to operate but would require continuing and complex coordination, and raised far greater interference and coordination issues than HC option. Hughes also said Teledesic system was flexible enough to provide coordination with other applicants and as result shouldn’t receive priority. Teledesic proposal for modification may present major system modification, which would require application to be placed in 3rd processing round, it said.
Commission shouldn’t add “commitment of funds” requirement to current financial qualifications standard, filing said. Proposal would limit use of funds to pending satellite project licensed by FCC. “This unnecessary and unrealistic requirement has twice been considered and rejected” by FCC “for reasons that are still valid today,” Hughes said. Proposed rule is “inconsistent with policy and would impose unnecessary burdens” on Commission and applicants. Hughes proposed modified version of financial requirement standard that would require applicants to demonstrate ability to fund substantial portion construction, launch and first year operation of satellites. Hughes said those regulations combined with milestone requirements would “ensure timely system completion and more closely reflect the current financial realities” of financing global broadband satellite systems.
Hughes also supported proposal to eliminate mandatory reporting of unscheduled satellite outages. Proposal by @contact to require quarterly status reports is “unnecessary and burdensome step backward,” since Commission recently eliminated requirement to file semiannual system status reports, Hughes said. There also no need for Commission to adopt new rules for milestone certification because general milestone requirement already applies to Ka-band NGSO FSS.