2015年にアメリカ合衆国FCC連邦通信委員会（Federal Communications Commission）から承認を得た、グローバルブロードバンドインターネット衛星サービス構築継続（FCCはユニバーサルサービス/Universal Service、ナショナルブロードバンドプランNational Broadband Planと呼んでいたりします。）
1990年代にはすでにアメリカ合衆国議会で議論されていたこの計画をスペースX（SpaceX）がFCC連邦通信委員会（Federal Communications Commission）から承認を受け、構築を継続。世界中のどこからでも宇宙にある人工衛星を利用して、で低コストで高速なブロードバンドインターネットサービスの提供構築を目指す。スペースX（SpaceX）スターリンクインターネットサテライト（Starlink Internet satellites）のテスト衛星は、2018年2月に打ち上げられたという情報でしたが。
Before the Federal Communications Commission Washington, D.C. 20554
In the Matter of
Use of Spectrum Bands Above 24 GHz For Mobile Radio Services
Amendment of the Commission’s Rules Regarding the 37.0-38.6 GHz and 38.6-40.0 GHz Bands
Implementation of Section 309(j) of the Communications Act – Competitive Bidding, 37.0-38.6 GHz and 38.6-40.0 GHz Bands
Petition for Rulemaking of the Fixed Wireless Communications Coalition to Create Service Rules for the 42-43.5 GHz Band
) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) )
GN Docket No. 14-177
ET Docket No. 95-183 (Terminated)
PP Docket No. 93-253 (Terminated)
To the Commission:
REPLY COMMENTS OF SPACEX
Space Exploration Technologies Corp. (“SpaceX”), by its counsel, hereby submits its
Reply Comments regarding the Federal Communications Commission’s (“FCC” or
“Commission”) Notice of Inquiry1 (“NOI”) in the above-referenced proceedings.
SpaceX, the world’s fastest growing launch services company, was founded in 2002 with
the specific mission to revolutionize space technology – with particular regard to reliability,
safety, and affordability. Over the past decade, SpaceX has gained worldwide attention with a
series of historic milestones in space transportation and related space technologies, including its
Dragon spacecraft (a highly advanced capsule capable of carry significant upmass and downmass
1 Use of Spectrum Bands Above 24 GHz for Mobile Radio Services, GN Docket No. 14-177, et. al., Notice of Inquiry, FCC 14-154 (rel. Oct. 17, 2014) (“NOI”).
to and from the International Space Station (ISS)). Among its many significant commercial
space initiatives, SpaceX is under a $1.6 billion contract to NASA to fly 12 cargo supply
missions to the International Space Station (ISS) (the company already has performed six
consecutive successful missions to the ISS), as well as a separate contract with NASA to restore
America’s capability to carry astronauts to and from the ISS. SpaceX has grown to more than
4,000 employees and is headquartered in Hawthorne, California, with launch and satellite
processing facilities at Cape Canaveral Air Force Station, Florida and Vandenberg Air Force
Base, California, and a rocket development facility in McGregor, Texas.
SpaceX recently announced plans to extend its commitment to innovation in commercial
space technologies by implementing a global network of non-geostationary orbit (“NGSO”)
communications satellites, which it will manufacture, launch, and operate.2 In this instance,
SpaceX will be a new entrant, as it was in the launch industry, seeking to provide low-cost, high
speed broadband Internet service worldwide. Operating in higher frequency bands, including the
Ka-band spectrum at issue in this proceeding, this network will provide high-quality Internet
access and other broadband services (including to end users in the United States). The
development, construction and launch of this network will employ a large number of highly
skilled workers at a new satellite manufacturing center in the Seattle, Washington area.
The NOI initiates a Commission proceeding to examine and develop technical and
service rules for the deployment of “Fifth Generation” (“5G”) mobile radio services in bands
above 24 GHz. The Commission is seeking public comments regarding the policy, licensing,
sharing and technical issues associated with the development and introduction of 5G services in
these higher bands. SpaceX has a direct interest in this proceeding, particularly as it pertains to
2 “SpaceX To Build 4,000 Broadband Satellites in Seattle.” Space News. January 19, 2015 (accessible at: http://spacenews.com/spacex-opening-seattle-plant-to-build-4000-broadbandsatellites/#sthash.Xsqm3Vdd.dpuf).
access to Ka-band spectrum by NGSO satellite network operators.
II. BANDS ABOVE 24 GHZ WILL BE USED MORE AND MORE EXTENSIVELY BY SATELLITE OPERATORS
Although the Commission initially considered operational and licensing rules for satellite
services in higher bands some time ago, significant deployment in Ka-band has occurred only
relatively recently. In the past several years, the United States has seen widespread consumer
acceptance of satellite broadband provided by Ka-band GSO FSS systems, and commercial Ka
band NGSO FSS operations have begun. Recent advances in satellite and user terminal designs
promise to hasten satellite deployment in higher spectrum bands.
A. Existing and Planned Satellite Operations
The record in this proceeding firmly establishes that satellite operators – domestic and
international – have launched or are developing satellite systems to operate in Ka-band
frequencies above 24 GHz.3 For example, Inmarsat indicates that it has invested extensively in
its I-4 satellite geostationary satellite orbit (“GSO”) network, which provides mobile broadband
in the United States and internationally, and will operate Ka-band satellites as part of its “Global
Xpress” high-speed broadband offering.4 O3b operates a network of 12 NGSO satellites with
uplinks in the Ka-band and seeks to offer expanded satellite broadband connectivity in the
United States.5 ViaSat offers the “Exede” satellite broadband service that competes in the
3 See Comments of O3b Limited, GN Docket No. 14-177 (Jan. 15, 2015) (“O3b Comments”); Comments of Inmarsat PLC, GN Docket No. 14-177 (Jan. 15, 2015) (“Inmarsat Comments”); Comments of ViaSat, Inc., GN Docket No. 14-177 (Jan. 15, 2015) (“ViaSat Comments”); Comments of EchoStar Satellite Operating Corporation, Hughes Network Systems, LLC, and Alta Wireless, Inc., GN Docket No. 14-177 (Jan. 15, 2015) (“EchoStar Comments”). 4 Inmarsat Comments at 4.
5 O3b Comments at 2. See Application of O3b Limited for Blanket License Permitting Operation of Up to One Thousand 1.2 Meter, One Thousand 1.8 Meter, and One Thousand 2.4 Meter Fixed Earth Stations to Communicate with its Non-Geostationary Satellite System, Call Sign E140101, File No. SES-LIC-20141001-00781 (filed Oct. 1, 2014).
United States with terrestrial alternatives.6 Hughes operates two GSO Ka-band satellites serving
over one million users in the United States and Canada, and plans to launch an advanced Ka
band satellite in 2016 to provide 150 Gbps throughput with more than 120 spot beams.7
For its part, SpaceX will join the ranks of Ka-band satellite operators in the near term as
it begins to test and deploy its planned NGSO satellite network. When fully deployed, this
network will comprise some 4,000 small low-Earth orbit (“LEO”) satellites providing low
latency, broadband connectivity for Internet access and other services throughout the United
States and the entire world. The SpaceX and the other Ka-band operator offerings are just a few
of the innovative and competitive satellite applications already deployed or soon to be
operational in higher frequency bands.
B. The Commission Should Ensure Adequate Spectrum for Existing and Future Satellite Requirements
As the record in this proceeding demonstrates, existing and future satellite networks share
bands above 24 GHz with other satellite systems and select terrestrial services capable of
effective co-frequency sharing. In the Ka-band, for example, the Commission determined that
Local Multipoint Distribution System (“LMDS”) networks can operate co-frequency with certain
satellite feeder links and the satellite operations can be conducted on a secondary basis in
primary LMDS spectrum. While accepting appropriate sharing, satellite interests ask that the
Commission ensure adequate spectrum for existing and future satellite requirements as it
considers possible 5G services in these higher bands.
6 ViaSat Comments at 3.
7 EchoStar Comments at 3-4.
ViaSat’s Exede broadband service, for example, is “based on reliable access to a core
segment of Ka-band spectrum” and also relies on “opportunistic” access to other portions of the
Ka-band originally designated for other technologies.8 In this proceeding, ViaSat urges the
Commission “to consider a regulatory framework that would facilitate” these types of spectrum
sharing between satellite networks and with terrestrial operations.9
EchoStar states that the “future of satellite broadband is bright,” and that the Commission
should “ensure that the Ka-band continues to remain available for the growing needs of the
satellite community and their users.”10 O3b writes that “incumbent satellite services above 24
GHz are on a strong growth trajectory.”11 Accordingly, the instant proceeding for possible 5G
services, or any other proceeding, needs to assess the compatibility of any 5G services with the
“continued growth and expansion” of incumbent satellite services in these bands.12 Similarly,
the Satellite Industry Association (“SIA”) asks that the Commission “carefully consider” the
potential impact on incumbent satellite services in bands above 24 GHz from possible sharing
with new 5G services, noting the direct impact that shared use can have on both current and
SpaceX echoes these observations; however, the language of the NOI also speaks in
terms of considering the spectrum needs of existing services in these higher bands. Specifically,
8 ViaSat Comments at 3.
9 EchoStar Comments at 12. 10 Id. at 17, 18. 11 O3b Comments at 4.
12 Id. at 10.
13 Comments of Satellite Industry Association, GN Docket No. 14-177 (Jan. 15, 2015) (“SIA Comments”), at 9.
the Commission notes that it must carefully consider the characteristics of any technology that
“might coexist without impact on incumbent services that occupy the relevant frequency
bands.”14 Moreover, as emphasized by the Commission, any adopted 5G policies should
“accommodate the widest possible range of technologies and uses, including compatibility with
SpaceX fully agrees with these commenters that the Commission must ensure that any
new allocation and service designation decisions enable existing and planned services to flourish
and expand in a shared-spectrum environment. SpaceX notes that even in satellite uplink bands
there are potential challenges to sharing between intensive, high-power terrestrial operations and
satellite services. Not only do satellite earth station uplink operations have the potential to cause
interference into terrestrial receive antennas, but aggregate interference from terrestrial
operations could adversely impact satellite receive operations. These effects are particularly
important to consider in the context of NGSO operations, where steerable earth station transmit
antennas would have a wider geographic impact and significantly lower satellite altitudes
magnify the impact of aggregate interference from terrestrial transmissions. While spectrum
sharing between some terrestrial and satellite operations remains possible in appropriate
circumstances, the Commission should remain cognizant of technical and operational differences
between services that may effectively limit sharing opportunities.
III. FCC SHOULD PRESERVE THE ABILITY OF NEW SATELLITE ENTRANTS TO UTILIZE KA-BAND SPECTRUM
SpaceX urges the Commission to preserve the ability of new satellite entrants to use
higher frequency bands, including Ka-band spectrum. As the comments from the satellite
14 NOI at ¶ 17.
operators have shown, the Ka-band is a critical resource for FSS operations in the United States
and throughout the world. New satellite network operators, such as SpaceX, will also rely on
Ka-band spectrum to bring added competition, innovation and new services to users.
Accordingly, SpaceX urges the Commission to consider new satellite entrants in the Ka-band
and avoid taking steps in the instant proceeding that might otherwise create barriers to entry into
A. Enhancing Competition and Innovation Should Drive FCC Policy Considerations for Ka-band
Enhancing competition and innovation are two fundamental policy goals long-held by the
Commission because they result in lower costs and new service applications for consumers.
Nowhere is this more true than in the Ka-band. As described above, the existing satellite
network operators commenting in this proceeding explain how they are continuing to expand
satellite infrastructure with new capabilities to provide more and better services to the public.
These commenters are careful to point out that the Commission’s proceeding regarding 5G
services should consider the potential impact on current and future services by existing satellite
network operators in the Ka-band.
New satellite entrants in the Ka-band will similarly enhance competition and innovation,
and thereby bring better and more efficient services to users at lower cost. In short, new satellite
entrants should have equal access to spectrum in the Ka-band as existing operators. New
satellite operators, such as SpaceX, must have meaningful opportunities to access Ka-band
frequencies and should be fully considered in any 5G sharing proposals along with existing
B. The Commission’s Policies Should Continue To Facilitate Entry of New Kaband Satellite Service Providers
As noted previously, SpaceX has announced plans to deploy a large NGSO satellite
network operating in multiple satellite frequency bands, including the Ka-band, to provide
broadband Internet access to fixed and mobile users in the United States and abroad. Extensive
Ka-band GSO operations have been conducted in the United States for years, and limited Ka
band NGSO operations have been permitted in the United States pursuant to waivers based on
findings that these operations can accommodate future entrants.16
While technical and regulatory approaches exist to facilitate sharing between GSO and
NGSO Ka-band operations, as well as other incumbent services, the Commission should remain
mindful of the impact that changes to the current operational circumstances and sharing
proposals may have on future entrants. For example, protection of incumbent satellite operators
in the Ka-band from interference by possible 5G services is important, but should not undermine
new satellite entrants in the Ka-band. In addition, further expansion of limited Ka-band NGSO
operations via waiver should not be afforded priority over or be allowed to limit or preclude new
entrants. SpaceX therefore urges the Commission to fully analyze and consider new Ka-band
satellite entrants and ensure that intra-service and inter-service sharing mechanisms, as well as
processing of further Ka-band satellite market access requests, accommodate new service
16 See Application of O3b Limited for Authority to Operate Earth stations Aboard Maritime Vessels to Communicate with its Non-Geostationary Satellite System, Call Sign E1300198, File No.SES-LIC-20130528-00455. See also Application of O3b Limited for O3b Limited for Authority to Operate a Gateway Earth Station in Haleiwa, Hawaii with its Non-Geostationary Ka-Band Satellite System, Call Sign E100088, File No. SES-LIC-20100723-00952 (granted Sept. 25, 2012) and Application of O3b Limited for O3b Limited for Authority to Operate a Gateway Earth Station in Vernon, Texas with its Non-Geostationary Ka-Band Satellite System, Call Sign E130021, File No. SES-LIC-20130124-00089 (granted June 20, 2013).
Comments in this proceeding evidence the extensive and growing use of frequency bands
above 24 GHz by satellite operators, particularly in the Ka-band. However, in any consideration
of introducing 5G services into these bands, the Commission is urged to take into account new
satellite entrants and not just incumbent satellite operators and their existing or planned
operations. SpaceX is committed to introducing a new NGSO network in the Ka-band, further
enhancing competition and innovation for satellite services. Any adopted 5G policies should
contemplate the continued march of innovation and new entrant business models so as to
enhance competition and expand consumer choices in the Ka-band.
SPACE EXPLORATION TECHNOLOGIES CORP.
TimothyR. Hughes Monica S. Desai Senior Vice President & General Counsel Carlos M. Nalda SPACE EXPLORATION SQUIRE PATTON BOGGS (US) LLP TECHNOLOGIES CORP. 2550 M Street, NW 1030 15th Street, NW #400E Washington, DC 20037 Washington, DC 20005
Counsel for Space Exploration Technologies Corp.
FCC Authorizes SpaceX to Provide Broadband Satellite Services
Full Title: Space Exploration Holdings, LLC, Application for Approval for Orbital Deployment and Operating Authority for the SpaceX NGSO Satellite System
Document Type(s): MOO&A
Authorize Space Exploration Holdings, LLC to construct, deploy, and operate a proposed non-geostationary orbit (NGSO) satellite system comprising 4,425 satellites for the provision of fixed-satellite service (FSS) around the world
DA/FCC #: FCC-18-38
File #: SAT-LOA-20161115-00118
FCC Record Citation: 33 FCC Rcd 3391 (4)
FCC Record: FCC-18-38A2_Rcd.pdf
Preparing to return human spaceflight capabilities to the United States, Crew Dragon and Falcon 9 went vertical at historic Launch Complex 39A in Florida. pic.twitter.com/igggZdCU9k
— SpaceX (@SpaceX) 2019年1月5日