Joint Comments on a Spectrum Sharing Framework for NGSO Systems

New America’s Open Technology Institute, Public Knowledge, the Center for Rural Strategies, Next Century Cities, the Benton Institute for Broadband & Society, Oregon Fiber Partnership, and Access Humboldt submitted comments in response to the Federal Communications Commission's Notice of Proposed Rulemaking seeking comment on rules governing burgeoning uses of non-geostationary satellite orbit, fixed-satellite service (NGSO FSS) systems. This group urges the Commission to adopt and enforce a good faith coordination framework that facilitates intensive spectrum sharing, market entry, and competition among NGSO operators. If the Commission prioritizes earlier-licensed systems, it should require the information necessary to coordinate and, in any case, adopt the degradation of service metric to determine harmful interference.