Spectrum Policies

Satellites provide secure and essential communications, navigation, weather, imaging and a host of other services for U.S. customers and others around the world.  Governments, media, industry, first responders, and consumers rely on satellite networks to provide primary and backup communications for essential business transactions, operational missions and mass communications.  End users in the United States include:

• Federal agencies, including the Departments of Defense and Homeland Security;
• State and local law enforcement, public safety and administrative officials;
• International, national and local media;
• Businesses, including utilities, banks, retail outlets, transportation, restaurants, hotels, and oil and gas companies; and,
• Tens of millions of American and global consumers, who receive broadband, video, and audio in their homes and while on the move via satellites plus the billions of global smart phone users who unknowingly rely on GPS satellite timing to make and receive calls.

Satellites are the most efficient technology for providing communications coverage to large geographical and sparsely populated areas, including to end-users dispersed throughout entire countries, continents or large oceanic regions.  Every day, satellites provide backhaul connectivity for wireless communications and network redundancy to back up global submarine cable communications.  In a disaster, satellite-based communications are heavily relied upon by first responders in the first seconds, minutes, hours and days and beyond, when terrestrial communications are disrupted.  As these networks are restored, satellites augment local networks, add international connectivity, and allow ongoing media coverage throughout recovery phases from a disaster.

As such, SIA advocates for the following core principles and policies to protect satellite services from interference:

1. U.S. Domestic and U.S. International Spectrum Policies are Especially Important for Satellite Systems

• The satellite industry serves vital U.S. national interests and contributes to the U.S. economic growth, by providing services domestic, cross-border and global connectivity.  This connectivity is predicated upon reliable, predictable, and consistent US spectrum policies here and advocated for internationally.   International advocacy that adheres to these principles, and is also technologically neutral is also a critical underpinning to sound U.S. spectrum policy.
• To maintain and expand the range of innovative satellite service offerings, satellite operators must be able to rely on the U.S. having and advocating spectrum policies that provide protection from harmful interference and accommodate the constant evolution of the space ecosystem – whether satellites, ground systems, or end user equipment.
• Technology neutrality in spectrum policy is not the equivalent of applying the same rules to different technologies, but instead applying the same policy objective in a way that does not ignore technology differences in how that policy can be reasonably implemented. Regulators must avoid technology favoritism – implicit or explicit – that can result from imposing policy uniformity.
• Satellites operate in an inherently international environment, the only technology subject to multilateral treaty regulatory requirements for deployment. Furthermore, satellites have a service coverage capability that extends well beyond national borders. This international nature of satellite services requires complex spectrum coordination on multiple levels, often among competitors and foreign governments and/or state-owned operators.  It also requires globally harmonized spectrum and coordination between U.S. and foreign regulators. 

2. Satellite Systems Require National and International Policies that Protect Against Harmful Radio Interference.

• A spectrum environment where operations are protected from harmful interference is essential for satellite services to continue providing the important services they offer today, for realizing the full potential of the capital investment in those capabilities, and for innovation in the space sector.
• In some instance spectrum sharing between satellite and terrestrial services may be difficult and may result in harmful interference. To mitigate such harmful interference, it is important that sound technical rules are adopted. It is also important to recognize that premature exportation of experimental sharing scenarios, well before they have been proved beyond concept, such as the Citizens Broadband Radio Service band rules,[1] simply add to the interference risks facing satellite operators. Furthermore, only the U.S. and a handful of other regulatory environments have the staff and capabilities to try to address satellite interference –but even they can at times lack significant procedural remedies and mechanisms to address, in a timely manner, terrestrial interference sources, e.g., the 2002 case of harmful interference from radar detectors to VSATs.[2]
• Despite the adoption of rules to prevent harmful interference to satellite services, some harmful interference may nonetheless occur. Mechanisms to resolve harmful interference must be swift, comprehensive, and effective.  Service providers should have an affirmative responsibility to report any interference, with a mechanism for an expedited complaint resolution process where regulatory intervention is required.

3. Satellite Spectrum Efficiency Should Be Considered During The Creation of New Spectrum Policies

• Satellite systems have large up-front infrastructure costs.  The business of purchasing, launching, operating and insuring even a single geostationary satellite is highly capital intensive.  Satellite operators have powerful economic incentives to quickly maximize spectrum efficiency so as to recover their upfront investment. 
• The FCC imposes licensing milestones and a bond regime,[3] both of which are designed to prevent warehousing.
• Continued advances in satellite technology have resulted in greater overall system capacity and higher levels of frequency reuse.
• The newest satellites are able to reuse frequencies up to 75 times across the country, and increased processing power allows for real-time communications with less lag time and less spectrum use.

4. Spectrum Policies That Recognize Long-Term Investments Are Essential.

• The time required to design, launch, and operate the space and ground segments of satellite networks represents a relatively longer development time—and relatively higher up-front and fixed-financial investment—than most terrestrial systems.  This holds true for upgrades as well, which must be planned for and financed far in advance and must last for many years for the business to be viable.  
• The on-orbit lifespan of a satellite can be upward of fifteen years and new innovations are providing ways to extend this lifespan even further.  Once launched there is currently no way to modify the design of the satellite.  As such, long term spectrum availability is necessary to maximize the use of on-orbit satellites and encourage investment in new satellites.
• Regulatory frameworks for satellite systems need to be predictable.  They also need to produce timely decisions so as to support the continued significant, up-front infrastructure investments required to deploy these networks.  Furthermore, regulatory approvals must be predictable throughout the system design and development phase.

• A spectrum environment that affords protection from harmful interference, is essential for satellite operators to continue to provide their unique and important services as well as new innovative services in the future.

[1] See Amendment of the Commission’s Rules with Regard to Commercial Operations in the 3550-3650 MHz Band, Report and Order and Second Notice of Proposed Rulemaking, Docket No. 12-354 (rel: April 21, 2015)

[2] See Amendment of Parts 2 and 15 of the Commission’s Rules to Deregulate the Equipment Authorization Requirements for Digital Devices, Second Report and Order and Memorandum Opinion and Order, 18 FCC Rcd 14741 (21), 2003

[3] See 47 C.F.R. §§ 25.164, 25.165.