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The FCC’s current method for evaluating NGSO FSS system modification applications follows the standard set in 1999 for granting Teledesic LLC approval for modifying its NGSO FSS system. Teledesic, which had been granted authority to launch 840 satellites in the Ka-band for internet services, modified its application after it selected The Boeing Company as its primary satellite provider, with the modification reflecting the parameters of Boeing’s products. In its decision, the FCC stated that since the changes did not cause interference with other satellite operators (primary geostationary operators) and that since it was deemed to be in the public interest, they were to be granted.
O3b, for instance, states that, “the 1999 Teledesic decision is too vague to adequately address today’s dynamic NGSO FSS industry and the accompanying spectrum sharing issues”, with Telesat accepting that the current standard is too “general”.
Finally, SpaceX also provides a three-tiered framework for countering speculative applications. This consists of setting deployment milestones enabling the measurement of specifications promised to specifications achieved against a set timeline, require non-U.S. applicants to pay a “fair share” of application fees for preventing speculative applications and establishing an interference standard to ensure that applications with specifications that cause interference are evaluated on spectral efficiency. SpaceX also requests the FCC to require non-U.S. applicants to also follow debris mitigation requirements which often require adjusting altitude and other satellite parameters.
