ViaSat Reply to Spac

REPLY submitted by ViaSat, Inc.

ViaSat Consolidated Reply

2017-10-23

This document pretains to SAT-LOA-20170301-00027 for Application to Launch and Operate on a Satellite Space Stations filing.

IBFS_SATLOA2017030100027_1295038

                                             Before the
                 FEDERAL COMMUNICATIONS COMMISSION
                                     Washington, D.C. 20554

____________________________________
                                        )
In the Matter of                        )
                                        )
O3B LIMITED                             )              Call Sign: S2935
                                        )
Amendment to Application to Modify U.S. )              File No. SAT-AMD-20170301-00026
Market Access Grant for the O3b         )
Medium Earth Orbit Satellite System     )
____________________________________)


                   REPLY OF SPACE EXPLORATION HOLDINGS, LLC


       Space Exploration Holdings, LLC (“SpaceX”) hereby replies to the response filed by

O3b Limited (“O3b”) in the above referenced proceeding. 1 As SpaceX demonstrated in its

opening comments, O3b satellites will cause significant and unnecessary coordination challenges

by failing to provide beam-pointing information to prevent pervasive “phantom” in-line events. 2

O3b has also provided insufficient information to determine whether its uplink beams, like those

of several other MEO and HEO applicants, will cause significant and pervasive interference to

lower-orbit satellites. O3b provides little substantive response to these serious concerns and,

instead, maintains that these issues will somehow be resolved in the coordination process. But

SpaceX raises these issues precisely because they may distort and frustrate the coordination

process if not addressed in the licensing process. And in the case of real-time beam-pointing




1
    See Response of O3b Limited, SAT-AMD-20170301-00026 (Oct. 11, 2017) (“O3b Response”).
2
    Comments of Space Exploration Holdings, LLC, SAT-AMD-20170301-00026 (Sept. 25, 2017) (“SpaceX
    Comments”).


information, this data is a prerequisite to effective coordination, because it is necessary for other

operators to know when coordination or beam splitting is necessary to prevent interference.


    I.       O3b’s Large Spot Beams Will Cause Numerous Additional In-Line Events Unless
             O3b Shares Beam-Pointing Information.

             Each O3b satellite covers a footprint that could encompass most of both North and South

America. Although O3b’s individual beams are significantly narrower and may be steered

throughout this large footprint, these capabilities do little to ease coordination unless O3b

informs other operators where its beams are pointing and where they are not. Otherwise,

operators must assume that the satellites are in-line and that interference would occur without

band splitting or other measures whenever they are within the O3b footprint and aligned with an

O3b satellite. Figures 1 and 2 below illustrate the dramatic impact of O3b’s refusal to provide

necessary beam-pointing information.




                            Figure 1. In-Line Events Without Shared Information 3



3
         These simulations assume that a potential in-line event is defined as the conjunction of two satellites within ten
         degrees of one another from the perspective of an earth station.



                                                               2


                         Figure 2. In-Line Events with Shared Information


        As an initial matter, O3b claims that these ubiquitous in-line events are caused by the

large number of SpaceX satellites, and not its own footprint. It simultaneously, however, claims

that SpaceX can mitigate these in-line events through satellite diversity, which is possible due to

its significant number of satellites. 4 Only one of these assertions can be correct—the latter.

SpaceX’s system is designed to mitigate in-line interference through satellite diversity, and is

designed so that its ability to do so increases as the number of satellites in the system expands.

        However, SpaceX’s ability to mitigate in-line events does not relieve O3b of its own

responsibility to design and operate its system in an efficient manner. Requiring SpaceX to use

satellite diversity and SpaceX’s other advanced sharing capabilities to avoid phantom in-line

events is a grossly inefficient use of scarce spectral resources, especially when the remedy is as

simple as sharing the needed beam-pointing information.




4
    O3b Response at 2.



                                                  3


              The Commission should disregard O3b’s conclusory and unsupported assertion that this

information is not necessary for effective coordination. SpaceX has robustly demonstrated that it

is necessary, if this coordination process is to have any chance of yielding an efficient outcome.

And although O3b objects that this information is commercially sensitive, SpaceX has already

proposed an effective means of addressing this concern: beam-pointing data can be shared with

other operators by way of a third-party clearinghouse which will aggregate and ensure the

confidentiality of any proprietary beam-pointing data. 5


    II.       O3b Should Provide the Information Necessary to Confirm That Its Uplink Beams
              Will Not Cause Unacceptable Interference.

              SpaceX has offered detailed analyses that demonstrate the significant interference risk of

high-EIRP uplink beams of HEO and MEO systems to LEO operations. 6 But as SpaceX

highlighted in its comments on the O3b system, O3b has failed to provide the necessary

information to effectively determine whether these concerns apply to the O3b system. SpaceX is

heartened by O3b’s assertions that its system is sufficiently flexible to resolve any such

interference concerns, and that any potential issues can be addressed through the coordination

process. 7 The Commission should require O3b to submit the necessary information to access

these assertions—as many other operators have done—so the interference risk can be more

accurately assessed before the system is licensed. To the extent that O3b’s uplink beams are of

similar EIRP-levels to other operators, however, O3b should also be asked to explain how the

significant levels of interference that SpaceX has identified, at any angular separation, can



5
          See Letter from William Wiltshire, Counsel to SpaceX, to Marlene H. Dortch, Secretary, FCC, IB Docket No.
          16-408, Attachment at 09 (filed Sept. 15, 2017).
6
          See, e.g., SpaceX Comments at 2-5.
7
          O3b Response at 2-3.



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Document Created: 2017-10-23 19:10:35
Document Modified: 2017-10-23 19:10:35

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