The Satellite Industry Association (“SIA”) submitted the following comments in response to the Notice of Inquiry in the above-captioned proceeding.¹ The Commission seeks input on “the factors that encourage innovation and investment in wireless” and “concrete steps the Commission can take to support and encourage further innovation and investment in this area.”² While the Notice of Inquiry appears largely focused on terrestrial-based services, any meaningful evaluation of the “wireless ecosystem” must also account for the dynamic innovation and investment occurring in satellite operations, services, and technologies.

SIA is a U.S.-based trade association providing worldwide representation of the leading satellite operators, service providers, manufacturers, launch service providers, remote sensing operators, and ground equipment suppliers.³ SIA is the unified voice of the U.S. satellite industry on policy, regulatory, and legislative issues affecting the satellite business.

Discussion
As an initial matter, SIA encourages the Commission to consider, in the context of its inquiry here, the record developed as part of its proceeding in preparation for the next annual report to Congress on satellite competition. The record in that proceeding recounts the significant innovation and investment occurring in the U.S. satellite market.⁴ SIA submits these comments to highlight a handful of examples of such innovation and respond to some of the spectrum-related issues raised in the Innovation NOI.

Innovations in Satellite Operations
Just last year, the Commission observed that “consumers of communications satellite services continue to realize significant benefits in terms of service choice, innovations fostered by technological change and improvements in both space and ground segment, and improvements in service quality.”⁵ In particular, the Commission cited the “[r]ecent technological advances [that] have enabled more efficient reuse of spectrum,” including advancements in satellite antenna technology, satellite beam forming technology, and on-board processing payload systems.⁶ These are but a few of the innovations taking place in the satellite industry. As shown below, many others abound

For instance, the Ka-band spacecraft that Hughes Network Systems (“Hughes”) has deployed (SPACEWAY-3), which was placed into commercial service in 2008, achieves capacity of approximately 10 Gbit/s on a single satellite — a significant increase over older satellite designs — through use of phased-array antennas, on-board signal processing, mesh connectivity among terminals, and spot beams that enable spectrum to be reused many times over.

The newest generation of Ka-band spacecraft being designed and built, including the ViaSat-1 spacecraft (scheduled for launch in early 2011) and Hughes’ new Ka-band satellites, will be able to achieve 100 Gbit/s throughput. These results are enabled by leveraging a number of different innovative technologies, including innovative propulsion systems, which permit less satellite mass to be assigned for fuel; bigger satellite buses that have more prime power for hardware; heavy duty launchers that allow a larger mass to be delivered into orbit; more powerful and efficient RF components; and more efficient coding methods.

Innovation in satellite spot beam technology is also enabling more efficient spectrum usage than in previous generation satellites.


For example, next-generation mobile satellite service (“MSS”) satellites built for DBSD, SkyTerra, and TerreStar have phased-array antennas which, in conjunction with innovative ground based beam forming systems, give these systems flexibility to generate a virtually infinite number of beam configurations over their service areas. TerreStar-1 and DBSD G1 are capable of producing hundreds of simultaneous spot beams over the United States and Canada. Similarly, in the case of Inmarsat, its I-4 fleet has been designed to provide spot beam coverage globally via three satellites that support IP-based communications, including BGAN service.

Innovation is occurring on the ground segment side as well. Ever more complex chip designs, new modulation and coding schemes, and antenna performance improvements, have all facilitated the design and commercial availability of smaller, more powerful and less expensive Ku-band Earth stations. Where it cost tens of thousands of dollars in the 1980s for a terminal with a 2.4 meter antenna providing speeds of only 9.6 kbit/s, today, 5 Mbit/s terminals are commercially available for $400, requiring an antenna only two-thirds of a meter wide.

As the Commission’s recent proceedings in the ESV, AMSS and VMES contexts recognize, innovation in the development of Earth terminals now allows Fixed Satellite Service (“FSS”) satellite operators to provide the same types of mobile satellite-based services that once were the domain of MSS operators, and without increasing the chance of harmful interference.

Inmarsat’s BGAN service offering uses highly portable and easily deployed “notebook sized” antennas that are one-third the size, weight, and price of traditional Inmarsat terminals, and provide voice and broadband service at speeds of almost half a megabit per second worldwide.⁷ These technological advances, coupled with the regulatory flexibility that the Commission has provided, lead to more choices for consumers and enhance competition.

Satellite operators also are driving innovation in new chipsets that will radically redefine the capabilities of end-user handsets. TerreStar has developed a multimode smartphone operable on both satellite and terrestrial networks that will support 3G-level data speeds.⁸ SkyTerra, TerreStar, and Infineon announced an agreement earlier this year to develop multi-standard mobile platform chips that would allow a handset to access both terrestrial and satellite networks. In addition, ICO (now DBSD North America), SkyTerra, TerreStar and Qualcomm announced an additional agreement to develop chipsets allowing satellite interoperability with GSM and CDMA networks. These agreements are important steps towards deploying devices that will drive significant economies of scale in satellite communications, and provide an anywhere, anytime functionality for wireless users across the country.

Additionally, Ancillary Terrestrial Component (“ATC”) is a significant innovation that allows MSS operators to re-use their assigned L-band, Big LEO, and 2 GHz spectrum bands in order to integrate terrestrial and satellite operations on the same spectrum. Since the Commission adopted the ATC policy in 2003, hundreds of millions of dollars have been invested to further develop the necessary technology, and to develop the next-generation satellites capable of best providing a robust suite of services to consumers.

With the launch of next generation satellites this year and next, the industry is on the threshold of deploying ATC networks that will make even more efficient use of MSS spectrum and expand the consumer market for satellite services, increasing economies of scale and lowering prices.

In addition to communications services, satellites use the radio spectrum to deliver a broad variety of other innovative services and applications. Almost every day, it seems, the global marketplace develops new applications for precision navigation, timing and geospatial references provided by satellite systems in the radio navigation-satellite service (e.g., GPS and its augmentations) and the Earth exploration-satellite service. In fact, many of the newest and most innovative location-based features of consumer wireless products come from satellite derived information, delivered via satellite radio spectrum.⁹

Advances in the emerging field of environmental monitoring are driven by satellite sensors that use unique properties of portions of the radio spectrum to detect changes in atmosphere, pollutants and other features in order to supply real-time weather information and monitor long-term climate changes.

Service to Key Constituencies
Satellite providers offer voice, broadband data, and video services in areas where terrestrial wireless providers have no, or limited coverage, providing significant benefit to consumers, government, and industry alike.¹⁰

In particular, by virtue of their ubiquitous coverage and limited dependence on terrestrial facilities, both fixed satellite and mobile satellite services offer invaluable connectivity to “solve problems” with respect to public safety/homeland security, health care and disaster relief, and the energy and education sectors.¹¹

In 2007, for example, working with the Department of Justice and the FBI, SkyTerra developed Satellite Mutual Aid Radio Talkgroups (“SMART”). SMART rides over SkyTerra’s existing push-to-talk (PTT) voice network and allows a public safety agency to communicate with a defined user group that not only includes its own first responders but any first responder also using SkyTerra PTT. The SMART offering was recently recognized by Maryland emergency management for allowing seamlessly interoperable communications among Allegany County Emergency Management, 911, the County Emergency Operations Center, and the State Highway Administration when a tornado destroyed terrestrial communications capability in western Maryland in July 2009. Notably, SkyTerra can establish additional talkgroups within hours to address specific crises. This kind of flexible and always-available interoperability is exactly the kind of solution public safety needs, and which has been made possible only because of innovation in mobile satellite communications.

In the security arena, Inmarsat service was used to repel pirates who tried to attack a bulk carrier in the Indian Ocean by allowing the ship to alert naval units in the vicinity, as well as to provide piracy warnings to alert ships to incidents in the area.¹²

In the disaster relief context, small fixed terminals have provided broadband accessibility at rescue command posts; enabled banks and stores to authorize credit cards and bank cards so customers have access to cash and goods; and allowed disconnected terrestrial mobile service base stations to reconnect to the PSTN. For the health care sector, small satellite terminals allow two-way video conferencing, permitting medical consultations with patients in rural villages by specialists located far away.

Of course, as the Commission itself recognizes, satellite service is a viable and cost-effective means of providing high quality wireless broadband and other communications services in rural, remote and sparsely populated areas,¹³ making affordable connectivity available to those who would not otherwise be connected. Developments in services and equipment also are expanding the availability of satellite-based broadband services on mobile platforms such as planes, trains, ships and buses, thus allowing consumers to remain connected while in transit.

Harmonization In Spectrum Allocations
One area identified in the Innovation NOI and of significant interest to the satellite industry is the spectrum allocation process and various licensing and use policies.¹⁴ Satellite operators face unique technology and deployment challenges in light of the global or regional scale of their networks, making international spectrum harmonization critical to investment and innovation in satellite operations.

First, satellite systems have extremely high up-front infrastructure costs which must be financed many years before any revenues flow, unlike terrestrial systems that can be built incrementally and generate revenues as soon as deployed. Capital investments, therefore, must be planned far in advance of satellite launch and service initiation, and the assets must last for many years in order for the business to remain viable. For example, the foresight that the Commission had to open the Ka-band for satellite licensing, and subsequently to authorize blanket licensing in the band, has provided the certainty that is needed to enable the billions of dollars that ViaSat, Hughes and others in the satellite industry have invested and will invest in Ka-band broadband infrastructure.

Second, in order to build a viable international satellite system (and thereby use spectrum efficiently), operators must secure spectrum allocations, assignments and landing rights in many countries rather than obtaining just one license in one country. This too can result in a long, drawn-out process.

International harmonization of spectrum bands, and maintenance of regulatory stability in spectrum bands already allocated, are therefore critical to the long-term success of the satellite industry. Access to harmonized spectrum that can predictably be available to support a long-term capital investment is essential to satellite operators, and provides them with powerful economic incentives to maximize spectrum efficiency and fully exploit their assigned spectrum so as to recover their upfront investment.

Spectrum Management
The Commission also seeks comment on a number of spectrum management issues, such as efficient and flexible spectrum use, band sharing, and interference protection.¹⁵

In this regard, the Commission’s technical rules already provide for the efficient use of satellite spectrum. For example, the Commission’s two-degree spacing policy and full frequency reuse requirements enable limited spectrum to be re-used many times at multiple orbital locations across the geostationary arc through a combination of orbital separation, spatial separation of satellite beams and/or dual polarization. These rules provide an excellent starting point for intra-service coordination and operation among satellite operators for the use of limited spectrum resources. The Commission’s rules also allow satellite spectrum to be flexibly deployed for virtually any kind of service offering or application.

In the MSS context (L- and S-band), the Commission’s MSS/ATC policy is an important example of how flexible spectrum use, where proven after extensive study to be technically feasible, can foster innovation. MSS satellite operators have also found that operator-operator sharing arrangements, such as the cooperation agreement entered into by Inmarsat and SkyTerra, offer the prospect of improved spectrum efficiency and flexible spectrum use, and should be encouraged by the Commission (and accommodated via rule waiver, as appropriate).

The combination of detailed technical regulations that are designed to maximize spectrum utilization and efficiency within the satellite services and reliance on operator-to-operator sharing arrangements between satellite licensees has proven effective for C-, Ka-, and L-band licensees. The Commission should recognize the success of these techniques as useful means of improving spectrum efficiency, flexible spectrum use, and spectrum re-use throughout the vast geographic areas served by geostationary satellites.

In recent years, satellite operators have developed innovative technologies, such as improved frequency reuse (e.g., multi-color spot beam reuse and paired carrier multiple access, whereby two Earth stations can operate co-frequency and co-time), multiple access protocols (which allow dynamic re-assignment of capacity), digital modulation, high performance FEC codes, and video compression standards. These new technologies provide a number of significant public interest benefits, such as higher throughputs, more intensive use of spectrum, better quality service, and lower cost to end-users.

These advanced techniques allow satellite service providers to achieve significantly increased efficiency over earlier generation technologies, but, as a consequence, they provide little, if any, margin for new sources of interference. As a result, inter-service sharing, i.e., spectrum sharing between separately operated satellite and terrestrial services, can be problematic for satellite operators, particularly in the satellite downlink bands where an Earth terminal is designed to receive signals from a satellite located as far away as geostationary orbit, 22,300 miles above the Equator. For this reason, while the process of coordinating satellite earth stations has proven manageable in certain circumstances to date, this problem would be much more vexing in the case of sharing with new classes of ubiquitously-deployed or unlicensed terrestrial wireless services.

SIA, therefore, urges the Commission to exercise extreme caution before considering the allocation of new fixed and mobile terrestrial services — licensed or unlicensed — in frequency bands allocated on a primary basis to fixed satellite and mobile satellite services.

Conclusion
Satellite operators and technologies are a critical component of the wireless ecosystem the Commission is examining in the Innovation NOI. In order to continue to fostering innovation in the satellite industry, the Commission must ensure that its policies continue to account for the satellite industry’s unique geographic scope, far-reaching contributions to the public interest and national security, and technology characteristics.

Respectfully submitted,

SATELLITE INDUSTRY ASSOCIATION
/s/
Patricia Cooper, President
1730 M Street, NW
Suite 600
Washington, DC 20036