Comments of Space No

COMMENT submitted by Space Norway AS

Comments of Space Norway AS

2017-06-26

This document pretains to SAT-PDR-20161115-00112 for Petition for Declaratory Ruling on a Satellite Space Stations filing.

IBFS_SATPDR2016111500112_1241687

                                        Before the
                            Federal Communications Commission
                                   Washington, DC 20554


                                                 )
In the Matter of                                 )
                                                 )
LeoSat MA, Inc.                                  )   File No. SAT-PDR-20161115-00112
                                                 )
Petition for Declaratory Ruling to Permit U.S.   )
Market Access for the LeoSat Ka-band Low-        )
Earth Orbit Satellite System                     )
                                                 )




                          COMMENTS OF SPACE NORWAY AS




                                                       Jostein Rønneberg
                                                       Director and Chief Executive Officer
                                                       SPACE NORWAY AS




OF COUNSEL:
   Phillip L. Spector
   Lafayette Greenfield
   Milbank, Tweed, Hadley & McCloy LLP
   1850 K Street NW, Suite 1100
   Washington, DC 20006
   (202) 835-7540


June 26, 2017


                                               TABLE OF CONTENTS

                                                                                                                                 Page

I.     INTRODUCTION .............................................................................................................. 1
II.    DISCUSSION ..................................................................................................................... 2
III.   CONCLUSION ................................................................................................................... 5




                                                                  i


                                         Before the
                             Federal Communications Commission
                                    Washington, DC 20554


                                                     )
In the Matter of                                     )
                                                     )
LeoSat MA, Inc.                                      )     File No. SAT-PDR-20161115-00112
                                                     )
Petition for Declaratory Ruling to Permit U.S.       )
Market Access for the LeoSat Ka-band Low-            )
Earth Orbit Satellite System                         )
                                                     )


                           COMMENTS OF SPACE NORWAY AS


I.     INTRODUCTION

       Space Norway AS (“Space Norway”) respectfully submits these comments with regard to

the petition (the “Petition”) of LeoSat MA, Inc. (the “Petitioner”) to provide services to the

United States via its proposed satellite system.1 The proposed system involves the use of

satellites in non-geostationary orbit (“NGSO”), and specifically in low Earth orbit (“LEO”).

       On May 26, 2017, the Federal Communications Commission (“FCC” or the

“Commission”) issued Public Notice DA 17-4252 (the “FCC Notice”), announcing that the

Commission had accepted the Petition for filing. In this regard, the Commission asked interested

parties to submit comments or petitions to deny no later than June 26, 2017.




1
       LeoSat MA, Inc., Petition for Declaratory Ruling to Permit U.S. Market Access for the
       LeoSat Ka-band Low-Earth Orbit Satellite System, IBFS File No. SAT-PDR-20161115-
       00112 (filed Nov. 15, 2016).
2
       See Public Notice DA 17-524, Report No. SPB-271 at 2 (May 26, 2017).



                                                 1


       Space Norway does not oppose the FCC’s granting the Petition, so long as the Petitioner

is required to comply with the interference-avoidance approach that Space Norway proposed in

its comments in a related rulemaking proceeding.3 For reasons explained in those comments and

summarized below, the Commission should require LEO NGSO systems to implement

mechanisms to avoid in-line interference with highly elliptical orbit (“HEO”) NGSO systems

with only one active satellite.

II.    DISCUSSION

       NGSO systems using space stations in HEO, particularly those like Space Norway’s

Arctic Satellite Broadband Mission (“ASBM”) which have high angle of inclination (63.4),

high eccentricity (0.55), and only one active satellite, are easily distinguishable from other types

of NGSO systems, such as LEO systems comparable to the Petitioner’s system and medium

Earth orbit (“MEO”) systems. The ASBM would be more similar to a geostationary orbit

(“GSO”) system than to other NGSO constellations because of various factors. Specifically, the

ASBM: (i) would have a single active satellite that is quasi-stationary in its active phase (dwells

around its apogee for eight hours); (ii) would be similar to a GSO satellite from a LEO/MEO

interference perspective; (iii) would have a wide coverage area comparable to a GSO satellite;

(iv) is inherently compatible with GSO networks through its orbital inclination and coverage

area; (v) would be compatible with GSO user terminals; and (vi) would require the same type

and level of protection as afforded to GSO user terminals. In addition, the ASBM would provide

“quasi-GSO” coverage at northern latitudes, including providing vital communications services

for unserved and underserved remote areas of the Arctic (including those in Alaska).



3
       See Comments of Space Norway AS, IB Docket 16-408, at 9-12 (filed Feb. 27, 2017).



                                                  2


          Because the beams of the ASBM’s satellite would be wide and would have a

considerable footprint in the Arctic region, the ASBM’s operations would be affected by lower

altitude NGSO satellites, such as the Petitioner’s satellites. As a result of the distance between

the Earth and the ASBM’s satellites, particularly during ASBM’s active phase around apogee,

multiple simultaneous in-line interference events would almost certainly occur – in the absence

of techniques to avoid interference – between the ASBM system’s beams and the beams of a

LEO/MEO system that has numerous satellites in multiple planes. Thus, if no mechanism for

avoidance of in-line interference between HEO and LEO/MEO systems were adopted, both

Space Norway and Petitioner would be forced to limit their operations to their respective selected

“home base” spectrum,4 which would unavoidably and unnecessarily constrain the amount of

spectrum available to both systems to provide their proposed communications services to the

public.

          A HEO system such as the ASBM, with only one operational satellite (except during a

brief hand-over), cannot implement the commonly proposed techniques to avoid in-line

interference, such as satellite diversity and progressive pitch. By contrast, it is relatively easy for

LEO/MEO systems, such as the Petitioner’s system, to apply in-line interference avoidance

techniques used both to protect GSO networks (NGSO systems are required to implement such

techniques pursuant to Article 22 of the Radio Regulations of the International

Telecommunication Union (the “RR”) to protect GSO operations)5 and to co-exist with other


4
          See 47 CFR § 25.157.
5
          The ASBM system would also protect GSO systems from interference. See Space
          Norway AS, Petition for a Declaratory Ruling Granting Access to the U.S. Market for the
          Arctic Satellite Broadband Mission, IBFS File No. SAT-PDR-20161115-00111 at 5 (filed
          Nov. 15, 2016).



                                                  3


NGSO systems in order to avoid in-line interference events, such as those that would otherwise

occur between the ASBM system and the Petitioner’s.

        Spectrum sharing between ASBM and LEO/MEO systems would require the same

protection levels and mechanisms as GSO networks are afforded through the equivalent power

flux density limits (“EPFD Limits”) in RR Article 22. Specifically, ASBM would require that

the EPFD Limits defined for a 1.2 meter antenna in Table 22-1A of the RR be applied for a

single continuous 250 MHz band segment in Ku-band and that the EPFD Limits defined for a 90

centimeter antenna in Table 22-1C be applied for a single continuous 500 MHz band segment in

Ka-band.

        Thus, Space Norway believes that it is in the public interest for the responsibility for in-

line interference avoidance between the Petitioner’s system and the ASBM system to be placed

on the Petitioner, to be implemented through application of EPFD Limits to limited band

segments in Ku- (250 MHz) and Ka-band (500 MHz). The Petitioner will need to implement

mechanisms for the avoidance of NGSO in-line interference and GSO interference in any event,

and it is in the Petitioner’s interest not to restrict its operations to a relatively small amount of

“home base” spectrum. The proposed approach would be the most beneficial for both

LEO/MEO and HEO systems, and would ensure the efficient use of space spectrum resources.

Under this approach, both the ASBM system and the Petitioner’s system would be able to use all

of the spectrum requested by each system, and the operations of each system would not be

restricted by band segmentation.




                                                   4


III.   CONCLUSION

       For the foregoing reasons, Space Norway respectfully requests that the Commission

include in any grant of the Petition a condition requiring the Petitioner to implement mechanisms

to avoid in-line interference with HEO NGSO systems, such as the ASBM system.



                                     Respectfully submitted,

                                     SPACE NORWAY AS


                                                /s/ Jostein Rønneberg
                                     By: ___________________________
                                         Jostein Rønneberg
                                         Director and Chief Executive Officer
                                         SPACE NORWAY AS


June 26, 2017


OF COUNSEL:
   Phillip L. Spector
   Lafayette Greenfield
   Milbank, Tweed, Hadley & McCloy LLP
   1850 K Street NW, Suite 1100
   Washington, DC 20006
   (202) 835-7540




                                                5


                                CERTIFICATE OF SERVICE


       I, Jostein Rønneberg, hereby certify that on this 26th day of June, 2017, I caused to be

served a true copy of the foregoing “Comments of Space Norway AS,” by electronic mail upon

the following:


       Phil Marchesiello
       Wilkinson Barker Knauer, LLP
       Email: pmarchesiello@wbklaw.com


                                                  /s/ Jostein Rønneberg
                                          ______________________________
                                          Jostein Rønneberg
                                          Director and Chief Executive Officer
                                          SPACE NORWAY AS




                                                6



Document Created: 2017-06-26 11:12:51
Document Modified: 2017-06-26 11:12:51

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