Joint Comments on Satellite Spectrum Abundance

New America’s Open Technology Institute (OTI) and Public Knowledge (PK) submitted comments in response to the Further Notice of Proposed Rulemaking (FNPRM) and Notice of Proposed Rulemaking (NPRM) in several Federal Communications Commission's proceedings. We agree that expanding the use of the 12.7 GHz band for satellite communications is likely to “encourage a more efficient and intensive use of the band than previous proposals to repurpose this band for mobile broadband or other expanded uses.” We also support the authorization of FSS earth station gateways in the 42-42.5 GHz band as part of a light-licensing and automated database coordination process that is similar to the proven 70/80/90 GHz framework. That includes the coordination of at least fixed wireless terrestrial users as well. We further agree that this same light-licensing coordination framework should likewise be considered to accommodate NGSO uplink operations (earth-to-space) in the 51.4-52.4 GHz.