No, No, No! No Terrestrial Service In Ku-Band

The global satellite communications sector has opposed a proposal made at the U.S. Federal Communications Commission (FCC) to allow terrestrial fixed services to operate in the 14.0-14.5 GHz band. This is a move that would cause harmful interference to fixed and mobile satellite-based services currently being provided to millions of users throughout the nation.

Following successive meetings held recently with the FCC, the Global VSAT Forum (GVF) filed comments late last week jointly with the European Satellite Operators Association (ESOA), calling upon the U.S. regulatory agency to dismiss a Petition for Rulemaking submitted by the Utilities Telecom Council and Winchester Cator, LLC. The two non-profit associations called upon the FCC to determine that the petition to permit shared, secondary terrestrial fixed service (FS) use of the 14.0-14.5 GHz band is “ill-conceived, technically flawed, and glaringly unjustified.” As GVF and ESOA show in their opposition, the petitioners’ proposal would not protect present and future fixed-satellite service (FSS) operations from harmful interference, and indeed would likely result in harmful interference even at modest deployment levels. The proposed secondary FS would likely cause significant amounts of harmful interference whose source primary FSS licensees in the 14.0-14.5 GHz band would not be able to identify.

The non-profit industry associations further demonstrated that the petitioners wrongly claim that their proposed FS can avoid causing harmful interference, because their analysis is based on the misapplication of an interference metric and interference mitigation schemes that do not properly take into account all of the current and primary and secondary operations in the 14.0-14.5 GHz band. Moreover, the associations show that the petitioners fail to address protection of future FSS applications in the 14.0-14.5 GHz band as part of their plan seeking authorization of millions of new FS links.

In comments filed at the FCC, GVF and ESOA noted that the petitioners also fail to explain why it is necessary to use an FSS band for their proposed critical infrastructure industries and commercial FS service when unused or underused FS bands are available: “Currently, there is primary FS spectrum in other frequency bands, including 27 GHz, 38 GHz, and 71 GHz, that is available and/or not close to full capacity. Even C-band spectrum is available for wireless point-to-point applications. Since [the] petitioners offer no justification for their selection of the 14.0-14.5 GHz band over other apparent spectrum options, the Commission should not make a new FS allocation when existing frequency bands with available spectrum are already allocated for terrestrial wireless services.”

The petitioners proposal was also strongly opposed because the International Telecommunication Union (ITU) Radio Regulations and Table of Frequency Allocations will make it impossible for a secondary FS service to be offered in the U.S. in the 14.0-14.5 GHz band. Presently, there is no FS allocation in the band in ITU Region 2, which encompasses the U.S., and while revising the U.S. Table of Frequency Allocations is possible, doing so would cause serious problems with non-U.S. satellites operating over the Americas in the 14.0-14.5 GHz band — which satellites are entitled to the full protection of the ITU Radio Regulations from interference from U.S. fixed service stations with no ITU allocation status.

GVF and ESOA commented that the petitioners’ proposal to have their FS stations accept all interference from FSS networks is dubious, as “critical” services are not protected on a secondary basis. The petitioners incorrectly rely on frequency coordination and the use of spread spectrum techniques when these measures are inappropriate to avoid causing harmful interference to current and future users of the 14.0-14.5 GHz band. If the petitioners proposal is adopted it is inevitable that they will seek to further disrupt current primary and secondary services’ operations by seeking interference protection for their proposed FS systems from the Commission. The petitioners would have the Commission cede its responsibility to protect allocated services to a self-interested licensee. The Commission should reject this attempt to subvert the Commission’s procedures to ensure that already allocated spectrum users are protected from harmful interference—Washington, D.C.