1. Satellite Harmful Interference: A U.S. Telecom Perspective
Justin (Gus) Hurwitz
University of Nebraska College of Law
June 6, 2014

2. A US Telecom Perspective
Satellite issues are relatively “uninteresting” in US
E.g., satellite issues are handled by International Bureau
Non-specialists at FCC often not familiar w/ satellite issues
A key question is what is “harmful” interference
I’m going to talk about something different
When do changed uses of spectrum interfere with existing uses
Four case studies of problems resulting from efforts to repurpose satellite spectrum for non-satellite use
LightSquared; Dish/Echostar; Globalstar; Iridium vs. Globalstar
June 6, 2014
Harmful Interference – A US Perspective

3. A US Telecom Perspective
Satellite issues are relatively “uninteresting” in US
E.g., satellite issues are handled by International Bureau
Non-specialists at FCC often not familiar w/ satellite issues
A key question is what is “harmful” interference
I’m going to talk about something different
When do changed uses of spectrum interfere with existing uses
Four case studies of problems resulting from efforts to repurpose satellite spectrum for non-satellite use
LightSquared; Dish/Echostar; Globalstar; Iridium vs. Globalstar
But first … why aren’t satellite issues “interesting”?
June 6, 2014
Harmful Interference – A US Perspective

4. Harmful Interference – A US Perspective
Federalism
The good
The bad
The ugly
June 6, 2014
Harmful Interference – A US Perspective

5. Harmful Interference – A US Perspective
Federalism
The good
Rules can be tuned to local conditions
Experimentation
The bad
Externalities & spillovers
Coordination problems
No economies of scale
The ugly
Competing jurisdictions (“race to the bottom”)
June 6, 2014
Harmful Interference – A US Perspective

6. Spectrum Liberalization & ATC
Spectrum liberalization – transferable & flexible use
Trend started in US in 1980s in response to CMRS challenges
Is increasingly the default & preferred treatment
2003 ATC Order (cf. Complementary Ground Component)
Two key requirements
“Substantial Satellite Service”
“Integrated Service Offering” (integrated receivers)
Purpose: gap-filling
Other Background: Nat’l Broadband Plan (2010)
300 MHz spectrum for CMRS by 2015 (incl 90MHz from MSS)
500 MHz spectrum for CMRS by 2020
June 6, 2014
Harmful Interference – A US Perspective

7. Case Study 1: LightSquared
LightSquared wanted to repurpose spectrum adjacent to GPS for nationwide LTE network
Spent $4 on two satellites and to buy & repack spectrum
1.6265– & 1.525–1.559 GHz
Est. consumer value $14–$120 billion
Worked with FCC & industry to design network
Started in 2001; conditional approval in 2011; denied in 2012
June 6, 2014
Harmful Interference – A US Perspective

8. Case Study 1: LightSquared
LightSquared wanted to repurpose spectrum adjacent to GPS for nationwide LTE network
Spent $4 on two satellites and to buy & repack spectrum
1.6265– & 1.525–1.559 GHz
Est. consumer value $14–$120 billion
Worked with FCC & industry to design network
Started in 2001; conditional approval in 2011; denied in 2012
June 6, 2014
Harmful Interference – A US Perspective

9. Case Study 1: LightSquared
LightSquared wanted to repurpose spectrum adjacent to GPS for nationwide LTE network
Spent $4 on two satellites and to buy & repack spectrum
1.6265– & 1.525–1.559 GHz
Est. consumer value $14–$120 billion
Worked with FCC & industry to design network
Started in 2001; conditional approval in 2011; denied in 2012
Huh???
GPS uses adjacent spectrum (1.559–1.610 GHz)
$millions of GPS receivers designed w/ insufficient filters
June 6, 2014
Harmful Interference – A US Perspective

10. Case Study 1: LightSquared
LightSquared wanted to repurpose spectrum adjacent to GPS for nationwide LTE network
Spent $4 on two satellites and to buy & repack spectrum
1.6265– & 1.525–1.559 GHz
Est. consumer value $14–$120 billion
Worked with FCC & industry to design network
Started in 2001; conditional approval in 2011; denied in 2012
Huh???
GPS uses adjacent spectrum (1.559–1.610 GHz)
$millions of GPS receivers designed w/ insufficient filters
June 6, 2014
Harmful Interference – A US Perspective

11. Case Study 2: DISH (a success story!)
June 6, 2014
Harmful Interference – A US Perspective

12. Case Study 2: DISH (a success story!)
June 6, 2014
Harmful Interference – A US Perspective

13. Case Study 2: DISH (a success story!)
DISH sought to repurpose MSS spectrum for LTE
2012: acquired other two 2 GHz MSS providers
2.000–2.020/2.180–2.200 GHz
Became only holder of “2 GHz” MSS spectrum
FCC reclassified 2 GHz band from Part 25 (MSS, w/ ATC possible) to Part 27 (AWS, flexible terrestrial)
2 GHz band had seen little MSS and no ATC
June 6, 2014
Harmful Interference – A US Perspective

14. Case Study 3: Globalstar
Repurposing satellite spectrum for terrestrial use
June 6, 2014
Harmful Interference – A US Perspective

15. Case Study 3: Globalstar
Repurposing satellite spectrum for terrestrial use
2.4835–2.495 GHz (exclusive sat. downlink license)
Globalstar seeks to offer terrestrial Wifi service on ch. 14
(unlicensed) –2.495 (exclusive) = 2.473–2.495 GHz = IEEE Ch.14
Key point: Wifi is a low power service
Seeking waiver of ATC rules
Need to demonstrate primary satellite service (minor)
That devices must support both MSS & terrestrial (major)
FCC NPRM is currently pending
June 6, 2014
Harmful Interference – A US Perspective

16. Case Study 3: Globalstar
Repurposing satellite spectrum for terrestrial use
2.4835–2.495 GHz (exclusive sat. downlink license)
Globalstar seeks to offer terrestrial Wifi service on ch. 14
(unlicensed) –2.495 (exclusive) = 2.473–2.495 GHz = IEEE Ch.14
Key point: Wifi is a low power service
Seeking waiver of ATC rules
Need to demonstrate primary satellite service (minor)
That devices must support both MSS & terrestrial (major)
FCC NPRM is currently pending
June 6, 2014
Harmful Interference – A US Perspective

17. Case Study 4: Iridium vs. Globalstar
Globalstar also wants to use its 1.6 GHz spectrum to deploy terrestrial LTE (high power!) service
June 6, 2014
Harmful Interference – A US Perspective

18. Case Study 4: Iridium vs. Globalstar
Globalstar also wants to use its 1.6 GHz spectrum to deploy terrestrial LTE (high power!) service
Iridium is petitioning FCC to prohibit this
– GHz (excl. Globalstar MSS spectrum) – GHz (shared b/w Iridium & Globalstar) – GHz (excl. Iridium MSS spectrum)
Iridium is a pure-MSS play, wants shared spectrum reclassified for MSS-only use, promises immediate use of spectrum
FCC is slated to address this after 2.4GHz petition
Would Globalstar’s LTE ATC interfere with Iridium’s MSS
Globalstar’s higher-value use vs. Iridium’s immed. deployment
June 6, 2014
Harmful Interference – A US Perspective

19. Harmful Interference – A US Perspective
Conclusions & Issues
High vs. Low value uses
Regulatory vs. Market control
ATC Rules & how (whether?) to allow flexible uses
Part 25 vs. Part 27 classification
High vs. Low power uses
Receiver design
Defining & Measuring Interference (not satellite specific)
Interference temperature
Harm-claim thresholds
June 6, 2014
Harmful Interference – A US Perspective