Joint Comments on Modernizing the Spectrum Sharing Framework For GSO and NGSO Systems

Public Knowledge (PK) and New America’s Open Technology Institute (OTI) filed comments in support of the Commission’s Notice of Proposed Rulemaking on modernizing the spectrum sharing framework for geostationary (GSO) and non-geostationary (NGSO) fixed-satellite service (FSS) systems operating in the 10.7-12.7, 17.3-18.6, and 19.7-20.2 GHz bands. The existing framework, using outdated Equivalent Power Flux Density (EPFD) limits, does not properly accommodate spectrum sharing between GSO and NGSO systems and instead favors GSO incumbents over a practical framework that can more fairly balance spectrum sharing between GSO and NGSO FSS systems. As NGSO systems continue to develop, now is the proper time for the Commission to replace the EPFD-limit protection framework with an industry and world-leading framework that requires operators to coordinate on a good faith basis and includes default objective interference thresholds. These thresholds are based on what was adopted last year in the NGSO/NGSO sharing framework for long- and short-term interference to adequately protect GSO systems from harmful interference if good faith coordination fails. Such a framework will increase satellite broadband network availability, improve service quality, promote competition, and ultimately make satellite broadband more affordable—all objectives PK and OTI urge the Commission to aim to achieve through this rulemaking.