The FCC could permit land and marine ESIMs (earth stations in motion) in the 29.25–29.3 gigahertz band “at this time, but defer consideration of aeronautical ESIMs to a further stage of the proceeding,” representatives of Iridium Communications, Inc., told Rachel Bender, a legal adviser to FCC Chairman Ajit Pai, during a Sept. 19 ex parte meeting regarding the IB docket 17-95 proceeding on facilitating the use of ESIMs in fixed satellite service frequency bands.
The FCC is scheduled to consider a report and order and further notice of proposed rulemaking in the proceeding at its Sept. 26 meeting.
“[A]eronautical ESIMs can be situated directly in-line with the Iridium feeder-link main beam, and thus produce even greater levels of interference into Iridium satellites,” the company’s representatives said during the meeting, according to an ex parte notice filed yesterday.
“Alternatively, to facilitate coordination, the Commission could permit all types of ESIMs in the 29.25-29.3 GHz band, but require ESIMs to comply with the ‘mechanisms’ for protecting ‘Iridium feeder link reception’ described in paragraph 56 of the Draft Order,” they added. “While the Draft Order, as written, would not make these mechanisms mandatory, they are the only mechanisms identified in the item for operating ESIMs compatibly with Iridium feeder links. Should the industry develop additional mechanisms for sharing spectrum in the future, the Commission could relax these requirements at that time.”
Iridium also objected to provisions in the draft order “suggest[ing] that the Commission’s policies require Iridium to coordinate its feeder links with ESIMs because GSO FSS systems and NGSO MSS feeder links are co-primary in the 29.25-29.3 GHz band. But, as noted above, the Draft Order’s logic only holds true if ESIMs are to be recognized as an application of the FSS in the band — and determining whether they should be is the fundamental purpose of this proceeding.”
And it objected to the draft order’s reference to “a ‘refusal to engage in coordination’ by Iridium. There is no basis in the record for this assertion. Iridium has completed more than forty coordinations with other satellite operators to ensure intensive shared use of the spectrum at issue, and has never refused to engage in coordination with any operator over the deployment of permitted services in this spectrum.” —Lynn Stanton, firstname.lastname@example.org